ML20049J370

Transcript of 820310 Public Meeting in Washington,Dc for Briefing & Possible Vote on Draft Final Rule Requiring Documentation of Deviations from Revised Srp.Pp 1-26

ML20049J370
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Issue date:	03/10/1982
From:	NRC COMMISSION (OCM)
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REF-10CFR9.7 NUDOCS 8203180010
Download: ML20049J370 (40)

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1 r' 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 4 BRIEFING AND POSSIBLE VOTE ON DBAFT FINAL RULE REQUIRING DOCUMENTATION OF DEVIATIONS FROM 5 THE REVISED STANDARD REVIEW PLAN 6 PUBLIC MEETING 7 Nuclear Regulatory Commission Room 1130 8 1717 H Street, N.W. Washington, D.C. 9 Wednesday, March 10, 1982 10 The Commission met, pursuant to notice, at 11 9:10 a.m. 12 BEFOREa 13 NUNZIO P ALLADINO, Commission Chairman 14 JOHN AHEARNE, Commissioner PETER BRADFORD, Commissioner 15 VICTOR GILINSKY, Commissioner THOMAS ROBERTS, Commissioner 16 _ STAFF AND PRESENTERS SEATED AT COMMISSION TABLE: 17 WILLIAM DIRCKS, EDO 18 FORREST REMICK, OPE SAMUEL CHILK, Secretary 19 MARTIN MALSCH, OGC 20 21 22 23 24 25 ALDERSON REPORTING COMPANY,INC, _, _ _@ VIR?INDA AS SW WC90CIN@T@N,0.@. f@f]4 (858 954 2345._ _ _ y

s y . ~. / DISCLAIMER This is an unofficial transcript af a. meeting of the United States Nuclear Regulatory Comission held on March *10, 1982 in the Cocmission's offices at 1717 H Street, N. W., Wasnington, D. C. The meeting was open to public attendance and observation. This transcript - has not been reviewed, corrected, or edited, and it may contain inaccuracies _ The transcript is intended. solely for general infonnational purooses. As provided by 10 CFR 9.103, it is not part of the forinal or informal record of decision of the matters discussed. E.xpressions of opinion in -.this. transcript do not necessarily reflect final detenninations or

p ; beliefs.

No pleading-or other paper may be filed. with the-Commission in any proceeding as the result of or addressed to any statement or argument e contained herein, except as. the Comission may auth'orize. 9' M O*'

2 1 EEECEEEI1EE 2 CHAIRMAN PALLADIN04 Good morning, ladies and 3 gentlemen. 4 The meeting vill please come to order. 5 Ihe Commission meets this morning to discuss 6 and.possibly vote on the final rule requiring the d 17 documentation of deviations from the revised Standard 8 Review Plan. This meeting is a continuation of the 9 m ee ting held on this subject last Thursday. 10 I hope all of the Commissioners got the 11 suggested changes that I have proposed. They were based 12 on two sets of concerns that I expressed the last time. 13 One, that in the process of justifying, I was concerned 14 about the number of questions that might follow up, and l l 15 it seems to me that guidelines should be developed and 16 any that are developed should go out for comment. 17 The other concern I had was that we were 18 elevating some of the NUREGs and bulletins that were 19 referred to in the Standard Review Plan to the point of l 20 requirements. While there was a paragraph in the 21 statement of consideration on this point, I was 22 concerned that when the rule finally gets published 23 several years from now, without that statement of l l 24 consideration, that this concept might be lost. I 25 suggest that it also be included in the rule. \\_ ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W.. WASHINGTON D.C. 20024 (202) 554-2345

e 3 ('T 1 These are the bases on which I sent out these 2 two suggested revisions. j 3 COMMISSIONER AHEARNE: Is anyone from NRR 4 coming? 5 HR. DIRCKS: No, but I have talked to.the 6 people today. Ed Case, he is in the branch, and I asked 7 him about the preparation of the guidance documents, and 8 he said that they are working on such documents. 9 COMMISSIONES AHEARNE: What if I have a 10 question? I will ask my question, good luck in 11 answering it. 12 (Laughter.) 13 CHAIRMAN PALLADIN0s Why don't you go ahead / ~ k 14 with your question. 15 COMMISSIONER AHEARNEa The Chairman has 16 suggested an addition which is going to talk about the 17 use of criteria and he is proposing the use of criteria 18 different from those set forth. It says, "The SRP was 19 used to establish criteria tha t the staff intends to 20 meet, and the SRP acceptance criteria provide one way." 21 If I take a look at the Standard Review Plan 22 2.2.1 to 2.2.2, an acceptance criteria where potentially 23 hazardous materials may be processed, stored, used, or 24 transported, sufficient sta tistical data are provided. 25 Is that an acceptance criteria? ALDERSoN REPORTING COMPANY,INC,

e 4 / 1 CHAIRMAN PALLADINO: Say that again, John. 2 COMMIS1'IONER AHEARNEa' It says, you want 3 potentially hazardous materials, in this'particular case 4 it talks about hazardous materials, one acceptance 5 criterion that is listed is sufficient statistical data 6 are provided. 7 I am not sure how that translates into a 8 criterion that is sufficiently specific that it is a 9 true acceptance criterion. Just going through some of 10 the documents, it appears to me the Standard Review Plan 11 has a number of section which are guidance documents to 12 the staff saying, "Here is approximately the way you 13 should start." ( 14 Strict acceptance criteria seem to be those 15 that are imbedded in the Reg Guides. It wasn't clear to 16 se now, when the Chairman is proposing the use of 17 alternative criteria, that sounds as though there must l l 18 be in the Standard Review Plan very specific criteria to l Ig which you can then propose alternatives. l l 20 Hy impression is that some of the Standard I ( 21 Review Plan is very qualita tive as opposed to 22 quantitative. 23 CHAIRMAN PALLADIN04 Did I speak of criteria? 24 Have I spoken of any guidelines that the.y could follow? 25 COMMISSIONER AHEARNE: I am talking about what ALDERSON REPORTING COMPANY,INC, I (fG MfeVC'W3 MIL EE?MSt61A RR lWFQ#1EFRffLf%$

5 ~ e' 1 rou are adding to the body of the rule. 2 CHAIRMAN PALLADINO: I see. 3 HR. DIROKS: Not only that, but.the Standard 4 Review Plan, in many places, just refers the reviewer to 5 another document. For example, it refers to ASME 6 Such-and-Such, or it refers to a NUREG document, or 7 research report on these issues. So it is not a neat 8 yardstick by which you can measure whether you meet the 9 standard or not. 10 I admit it is a collection of methodologies by 11 which someone could, meet a requirement. 12 COMMISSIONER AHEARNEa I guess I am raising 13 the question, if we are talking about other criteria, f substitute criteria, how is the staff going to interpret 14 15 that or apply that? '16 HR. DIRCKSa You mean the statement that the ~ 17 Chairman sent around? 18 COHNISSIONER AHEARNE: Yes. tg MR. DIRCKS: I believe that was already in the 20 statement of consideration. 21 CHAIRHAN PALLADINO: That sentence comes out 22 of the statement of consideration. 23 COHNISSIONER AHEARNE: No, not quite. 24 CHAIRHAN PALLADINO: The SRP acceptance 25 criteria provide one way, but'not necessarily the only ALDER $oN REPORTING COMPANY. INC. 400 VIRGINIA AVE., S.W WASHINGTON D.C. 20024 (202) 554-2345

6 I 1 vay of complying with the Commission's regulations. 2 COMMISSIONER AHEARNEa No, you have introduced 3 different criteria. 4 CHAIRMAN PALLADIN0s "Use of criteria 5 different from those set forth will be - I see, the 6 word " criteria." 7 CONHISSIONER AHEARNE: Yes. The way the 8 wording in the rule was, if they are proposing 9 11ternative approaches. 10 CHAIRHAN PALLADIN04 It is a good point. 11 COMMISSIONER AHEARNE: I was not clear. 12 CHAIRHAN PALLADIN0a The use of alternative 13 approaches different from those set forth. ( 14 COEHISSIONER AHEARNEa The next question, 15 still on this criteria list. The rule is going to 16 require a documentation of differences from the 17 criteria. Is there an underlying assumption that the 18 only place where those differences will come is where 19 there are very explicit criteria? 20 Where the criteria are based upon such. vord as 21 " sufficient," I would expect that what you would have in 22 mind is just the licensee saying that they are 23 sufficient. 24 MR. DISCKS: No, I think it will be more than 25 that. ( _ ALDERSoN REPORTING COMPANY,INC,

7 (~ 1 I ga ther that if it is a methodology for 2 computing whether you meet a certain requirement and the 3 methodology is outlined in a particular guidance e 4 document in the standard review plan, then if you don't 5 follow that methodology, you.have to justify why you 6 have not followed it. 7 CONHISSIONER AHEARNE: Right. 8 NR. DIRCKSa What you have in front of you, 9 and why your methodology is just as good. 10 CONHISSIONER AHEARNE Right. But there are, 11 as it says in the introduction to the Standard Review 12 Plan, acceptance criteria that the Standard Review Plan 13 has are NRC regulatory guides, general design criteria, (. 14 codes and standards, branch technical positions, and 15 other criteria. Under that term "other criteria" comes 16 such words in the Standard Review Plan itself as 17 " sufficient data shall be provided." 18 That is relatively intangible, and I am 19 asking, is it the staff's belief that in addressing 20 those rather intangible areas, it is difficult to prove 21 or disprove sufficiency, that is judgmental, so would 22 You expect the licensee to merely say, with respect to 23 Standard Review Plan III, Criteria No. 3, y es, 24 sufficient data has been supplied. 25 MR. DIRCKS: I think it is more than that, and l ALDERSON REPORTING COMPANY,INC,

[ 8 X 1 I think that is why the guidance on how to comply with 2 this requistion is so essential and why it should come 3 down to the Commission for review, and it should go out l 4 for comment. l 5 The Standard Review Plan was written for the 6 reviewers in NRR, to guide them on how to review an 7 application. It was not issued to guide an applicant on L 8 how to fill it out, or how to comply with our 9 regulations. 10 CHAIRMAN PALLADINO: In the statement of 11 consideration, it says: "The purpose of this rule is to 12 require applicants to identify differences from SRP 13 acceptance criteria and to evaluate how proposed ( 14 alternatives to the SRP criteria provide an acceptable 15 method of complying with the regulations." 16 COMMISSIONER AHEARNEa If you v sid just take 17 that sentence straight and put it in, and say "The 18 Applicant should identify," or something like, "If the 19 applicants propose alternatives, the applicant shall 20 identify differences and evaluate how the proposed 21 alternative," etc. 22 CHAIRMAN PALLADINO: "The use of alternative 23 approaches different from those set forth will be 24 accepted if they provide a basis for the determining the 25 regulatory requirements have been met." ALDERSON REPoRnNG COMPANY,INC, 6 /XiL M W/N9A% DA FFR3 GM Wi3-fE09

9 ( ~ 1 CONNISSIONER AHEARNE: Okay. Now, who does 2 the determination? The way the statement of 3 consideration reais, the applicant identifies the 4 difference ~s. I at least have read the statement of 5 consideration as it was up to the applicant to 6 demonstrate that this is an acceptable method. Is that 7 the intention? 8 CHAIRMAN PALLADINO: They should demonstrate, 9 but the approval, of course, is NRC's. 10 COMMISSIONER AHEARNEa Sure, but the way I 11 read the rule, it was not clear to. ne whether-the 12 applicant had to demonstrate something or the NRC staff 13 was going to have to. That is what the statement of 14 consideration says, but your point is that years later 15 it is the rule that ends up being read, and the rule 16 began to be a little confusing as to whether the 17 applicant had to demonstrate. 18 CHAIRMAN PALLADIN0s Is the rule itself not 19 clear? ~ 20 COMMISSIONER AHEARNE: Your paragraph that you 21 are putting in. 22 CHAIRMAN PALLADINO: I thought that last 23 paragraph was just a paraphrase from what was said here, 24 "The SRP was issued to establish criteria that the NRC 25 staff intends to use in evaluating whether an ALDERSoN REPORTING COMPANY,INC, MS WBG'IQ A%% &% QCOE38TM @.@. $M4 (S!$ 933-8000

10 1 applicant / licensee meets the Commission's regulations. {m 2 The SRP is not a substitute for the regulations, and 3 com pliance is not a requirement. The SRP acceptance (^ 4 criteria provide one way, but not necessarily the only 5 vay, of complying with the Commission's. regulations." 6 Now if we revise it to say, "The use of 7 alternative approaches different from those set forth 8 vill bc accepted if they provide a basis for ~ determining g the regulatory requirements have been met." to COHNISSIONER AHEARNE: Here is what our 11 difference is. Here it says, "The rule requires 12 applicants to identify and to evaluate -- 13 CHAIRMAN PALLADIN0's I am villing to put that ( 14 last sentence. 15 COMMISSIONER AHEARNE: All right, 16 The other question I had, the Chairman's 17 proposal, and you say you agree with it, is the 18 Commission vill publish for public comment any guidance tg documents that the staff intends to use to implement the 20 rule. l 21 The rule itself as proposed calls for this to 22 trigger within a given six months after publication, or 23 anything doctored after this, or six months after 24 publica tion. That, it seems to me, is inconsistent with 25 the Commission publishing for public comment any ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., ' ASHINGTON, D.C. 20024 (202) 554 2345 W

11 ~ 1 guidance document the staff intends to use. 2 MB. DIRCKS: I spoke to staff people in NRR 3 this morning, and they believe they can issue the [~ 4 guidance documents quite quickly. 5 COMMISSIONER AHEARNE: How soon? 6 HR. DIRCKS: It is like the Standard Review C 7 Plan. 8 COMMISSIONER AHEARNEs Yes, I remember that. 9 HR. DIRCKS: I will have to check this out, 10 but I would say that within six weeks we can get 11 something out. 12 CHAIRNAN PALLADINO Within six weeks. 13 HR. DIRCKS: Then if you want 30-day comment ( 14 CHAIREAN PALLADINO: Would that be 15 inconsistent with what we have here? 16 CONHISSIONER AHEARNE: I noticed this letter 17 that came in from Hooks, which indicated that the staff 18 already has under review the FSAR for WMP-1. Now, would 19 you tend to get this out soon enough? 20 I won't be around to push some more, but do 21 you believe that you can get the guidance documents out 22 for comment, review the comments, and have the guidance 23 documents then final in time to pick up 24 MR. DIRCKS: You mean within six months? 25 COMMISSIONER AHEARNE: Yes. ALDERSoN REPORTING COMPANY. INC, 400 VIRGINTA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345

12 / 1 HR. DIRCKS: I would say that it is possible. 2 I would say that we could do it if we put the urgency 3 behind it. Obviously the Commission vants us to. ( 4 COMMISSIONER BRADFORD: Is the point here that 5 without guidance documents, the rule would be 6 ineffective? As a practical matter, until th'e guidance 7 documents are approved, the rule vill not have any 8 force? 9 C0hMISSIONER AHEARNE: That is what I 10 suspect. 11 HR. DIRCKS: I did not author this product. 12 CONHISSIONER BRADFORDs I understand that. 13 HR. DIRCKS: You vill have to ask the author. ( 14' CHAIRMAN PALLADINO I think we can get the 15 guidance documents out, and still meet the intent of the 16 rule, and get them out for comment. Four weeks for 17 comment, and six weeks for preparation, that is 10 18 weeks. 19 ER. DIRCKS: I talked to Ed Case, he did not 20 believe there was an extensive amount of writing. He 21 said that he would get on it right away. I said, "If 22 the Commission goes this way, when would'he start on 23 it?." He said, "I start on it this morning." 24 (General laughter.) 2.r, COMNISSIONER BRADFORD: My point is, I don't ALDERSoN REPORTING COMPANY,INC,

13 t' 1 object in principle to getting comment on the guidance i 2 document, but I would not want that to work out in such 3 a way that the practical effect was a six month m 4 postponing of t'he effective date of the rule. That is, 5 such as the plants that came in within the next six 6 months would not be covered by the rule itself. 7 CHAIBHAN PALLADIN0s Where does it say about 8 the six months, John? 9 CONNISSIONER AHEARNE4 The section of the 10 rule, for example, on page 5. 11 CHAIRMAN PALLADIN0s Where? 12 COHNISSIONER AHEARNE: " Applications for light 13 vater cooled nuclear power plants. 14 CHAIRHAN PALLADINO: "or the SEP revision in 15 effect six months prior to the docket date of the 16 application," I don't think we are changing that. 17 COMMISSIONER AHEARNE: No. My concern really ~ 18 was, I had seen a few instances where publishing 19 something for public comment and then getting the 20 comments, and getting the document. turned around, has 21 taken a long time. That was my concern. 22 But with both Bill and your argument to the 23 parties there, we ought to be able to do it. So I would 24 be villing to accept it with this revision that I 25 mentioned. ALDERSoN REPORTING COMPANY. INC. 400 VIRGIN!A AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345

4 14 ( 1 CHAIRMAN PALLADINO: In the last sentence. 2 COHNISSIONER AHEARNE: Yes. 3 CH AIRM AN P ALLADINO All right. ( 4 Any other comments? 5 COHHISSIONER GILINSKYa Yes. On page.3 of the 6 statement of consideration, I guess, on the bottom, I c 7 vonld like to add something along the lines that the 8 identification of these differences will focus staff's 9 and licensee 's attention, or is intended to focus 10 staff's and licensee's attention on significant safety 11 issues, and improve the review process. 12 COHNISSIONER AHEARNEa This is with respect to 13 14 COHNISSIONER GILINSKYa Where it says, "The 15 purpose of this rule is to require the applicants to 16 identify differences," -- ~ ~ 17 COHHISSIONER AHEARNEa And to evaluate 18 alternatives provide acceptable method. 19 COHNISSIONER GILINSKYa The reason we want to 20 look at those differences is that we want to see whether 21 the important points need f urther attention. I think we 22 ought to say something about why we want to see the 23 differences. 24 COHHISSIONER AHEARNE: I would agree with 25 rou. But I think the reason why we want to see the ALDER $oN REPORTING COMPANY,INC,

.. ~ 15 1 differences is that the staff has concluded that the SRP (m 2 forms an acceptable way of meeting the regulations.- You 3 vant to see the differences because that means that the [ 4 licensee has proposed to meet the regulations a 5 different way. 6 CHAIRMAN PALLADIN0s I just wonder :if by 7 focusing it, you don't introduce another uncertainty as 8 to whether or not they are to identify all the 9 differences or only those which in their mind focus on 10 safety issues. 11 COMMISSIONER AHEARNE: I guess the one 12 hesitance I have, at ieast my initial reaction to the 13 var you phrased it, is that it seems to imply that where '(. _ 14 the licensee says they are meeting the regulation in a 15 var different than the SRP, that might be a safety 16 problem. Whereas, if they say they meet it using the ^ 17 seans of the SRP, it isn't. 18 We have had, I think, a number of cases QA, 19 f or e xam ple, where the licensee would say they meet it l 20 by meeting the requirements of the SRP, and it turns out 21 that they didn't. So just because they say that they do 22 seet it using the SRP, it doesn 't mean that, therefore, l it is not potentially where the safety issue ought to 23 l 24 be. 3 25 I think the staff has to focus its efforts on l i Al.DERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345

16 r 1 those elenants which they conclude are most important, 2 or most critical with respect to an individual client. (. 3 I agree that the purpose of this is to make sure that 4 the differences are identified and they can make sure 5 they examine those. C COMMISSIONER GILINSKYa They why would ther 7 vant to see the differences; because this will be a more 8 efficient way of conducting the review? 9 COMMISSIONER AHEARNE: Yes, I think so. 10 COMMISSIONER GILINSKY: Then let's say that. 11 COMMISSIONER AHEARNEa Fine. 12 CHAIRMAN PALLADINO: Do you have some thought, 13 or what would you like to put in there? ( COMMISSIONER GILINSKY Well, we could put in 14 15 there that this will lead to more efficient review. 16 That is certainly all right with me. 17 CHAIRMAN PALLADINO: Any other comments? 18 COMMISSIONER BRADFORD: How is that different 19 from the last sentence of the summary on page 1. 20 CHAIRMAN PALLADIN04 Do you want to repeat it 21 there? I COMMISSIONER GILINSKYs Maybe it does not have 22 23 to be. This is merely a summary, so it ought to -- COMMISSIONER AHEARNE: -- show up somewhere 24 25 else, so that it is stamarized. ALDERSON REPORTING COMPANY. INC. I 400 VIRGINIA AVE., S.W WASHINGTON. D.C. 20024 (202) 554 2345

17 ( ~ 1 COMMISSIONER GILINSKYa Yes. 2 COMMISSIONER AHEARNE: It is a good 3 principle. 4 CHAIRMAN PALLADINO: I will come back and we 5 vill go over these proposals, so that we are' clear on 6 what we ara finally voting on. 7 Are there any others? 8 MR. MALSCHs I have a question, and that is 9 whether the Commission intends by the added language in to (f)(3) to establish a formal Commission position that 11 compliance with the SRP is compliance with the 12 Commission's regulations. 13 CHAIRMAN PALLADINOs Say that again. ( 14 MR. MALSCH Whether the Commission intends by 15 the language that says, "The SRP acceptance criteria 16 provide one way of complying with the Commission ~ ~ 17 regulations," to actually preclude argument in 18 individual cases as to whether compliance with the SRP 19 is equal to cour '. lance with the regula tions. 20 I coul, read this as saying that. I am not l 21 sure that was eithin the original proposal the l 22 Commission published, and I will have to check that. 23 But I think it is a new concept. 24 COMMISSIONER GILINSKYa Isn't it the same as a 25 Reg Guide. A Reg Guide is a staff position, if it is an ALDERSOr. REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W WASHINGTON, D.C. 20024 (202) 554-2345

18 { 1 adequate solution to a problem. 2 NR. MALSCH That is true, except that this is 3 the Consission speaking. For example, you could say, O~ i 4 "The SRP acceptance criteria are intended by NRC staff 5 to provide one way." As written, it says, " provide one 6 vay," and it is the Commission speaking. 7 COMEISSIONER GILINSKY: I guess I think it 8 ought to have the status of a Reg Guide. This is a very 9 big Reg Guide. 10 HR. HALSCH4 It is the biggest, incorporating 11 numerous other Reg Guides. 12 COMNISSIONER GILINS U4 I must say I haven

• t 13 raised a thought about it, but it is a staff doc '2 ment.

(3 1 L' 14 It is merely. a compendium of Reg Guides. 15 MR. DIRCKS: Yes, plus many other things. 16 COMMISSIONER GILINSKYa Yes, but it has that ~ 17 kind of status, it seems to me. It is what the staff is 18 using to review the application, and we are approving 19 its use. But when the Reg Guide goes out, it will say 20 that the Commission regards this as a way of meeting the 21 regulation. 22 COMMISSIONER BRADFORD: As a practical matter, 23 Marty, I take it the Commission really'can't say that (, 24 the SRP acceptance criteria complies with the 25 regulations in a manner that couldn't be argued in C ALDERSON REPORTING COMPANY,INC, , _ _ - _ _, _ _ _ 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2346

19 ( 1 individual cases, unless it put the SRP itself out for 2 comment. 3 MR. MALSCH: That is right, and that is why I 4 said that I would have to see whether, when this was 5 published, it was arguably within the scope -- 6 COMMISSIONER GILINSKYa It would then become a 7 regulation. 8 MB. MALSCHs It would become a regulation. 9 COMMISSIONER GILINSKYs Yes. 10 MR. MALSCH4 You would also have to 11 incorporate by reference, which you haven't done here. 12 COMMISSIONER GILINSKY: We would basically be 13 taking all the regulations and inserting them into one b . 14 super-regulation. 15 MR. DIRCKS: That was one of the problems in 16 outlining the approach you take. 1/~ COMMISSIONER BRADFORD: It is not a problem in l l 18 the approach, it is a problem in this one sentence. 19 HR. DIRCKS: First of all, I don't know what l 20 was said, but I guess we can look it up. 21 MR. MALSCH: Language similar to this was was 22 in the preamble to the earlier draft, except the 23 difference is that you are not taking from the preamble 24 which is not part of the rule itself. You are putting 25 it into the rule itself. ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554-2345

~. 20 I 1 If the Commission doesn't intend that, it is 2 an easy fir, and that is to add "that the criteria are 3 intended by NRC staff to provide one way," and that puts 4 them clearly in the status of Regulatory Guides. 5 CONNISSIONER,AHEARNEs Would it do, Marty, if 6 you just dropped the sentence, "The SRP acceptance i 7 cri te ria provide'one way." 8 HR. MALSCH: If we dropped the sentence. g COMMISSIONER AHEARNE4 You have said, "The SRP 10 is not a substitute for the regdlations and compliance 11 is not a requirement." -If we go on to add the sentence 12 the Chairman has suggested 13 CHAIRHAN PALLADIN0s The last sentence on page 14 3. 15 COMMISSIONER AHEARNE: Right. "The rule 16 requires applicants to ide'ntify differences," and so 17 forth, then that leaves moot this " acceptance criteria 18 provide a way of complying gg HR. DIBCKS: That would achieve the objective 20 also. 21 CHAIRHAN PALLADINO: Would you leave it in the 22 statement of consideration? CONNISSIONER AHEARNE: I would guess that you 23 i 24 would take it out of both places. 25 MR. MALSCH: It is probably better to take it ALDERSON REPORTING COMPANY,INC,

i 21 ' 1 out of both places, although it is probably harmless in ps 2 the statement of consideration because that is actualiy 3 not par t of the rule. p 4 COMMISSIONER AHEARNE: Then leave it in the 5 statement of consideration. 6 CHAIRHAN PALLADINO: Are there any other 7 pomments? 8 CONHISSIONER BRADFORDs I think my 9 recommendation would be to keep it consistent in both 10 places, just so that there is no potential of it 11 confusing the Licensing Board or things of that sort. I 12 don't object to leaving it the other var within the 13 statement of consideration, if there is a strong feeling 14 to do that. But I think it is more prudent to have it 15 the same var in both. 16 COMMISSIONER AHEARNE: Take it out. 17 CHAIRMAN PALLADINO: All right. 18 Are there any other comments? 19 (No response.) 20 CHAIRMAN PALLADINO: I wonder if we may e 21 proceed to see if we accept the proposed amendments. 22 The proposed amendments, the ones that I had indicated: 23 Add at the bottom of page 3 a new paragraph, 24 "The Commission vill publish for public comment any 25 guidance documents the staff intends to use to implement ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) !E$ C,5

/ y c ~ .f' 1 the rule." 2,' Add to the body of SF.3, "The SRP was issued '3 to establish criteria that the NRC staff intends to use (' 4 in evaluating whether an applicant / licensee meets the 5 Commission's regulation. The SRP is not a substitute 6 for the regulation, and compliance is not a 7 requirement._ The purpose of this rule is to require 8 applicants to identify differences from the SRP 9 acceptance criteria and to evaluate whether proposed 10 alternatives to the SRP' criteria provide an acceptable 11 method of complying with the Commission 's regulations." 12 'In other words, we cross out that sentence 13 that the parties raisad the question about, a'nd instead 14 of using the last sentence I had put on my letter to you 15 last night, I used the last sentence on page 3. 16 COMMISSIONER AHEARNEs Could I suggest that, ~ 17 since it is in the rulje now,, rather than saying, "The 18 purpose of this rule is," just say, " Applicant shall 19 identify differences from the SRP acceptance criteria 20 and evaluate - " 21 CHAIRMAN PALLADINO: We are restating what we 22 already said. 23 COENISSIONER AHEARNE My point is, this is t 24 now going into the body of the rule. So I would not 25 think that we vocid, in the rule itself, say, "The ( L ALDERSoN REPORTING COMPANY,INC, MMZilWYf2ITMif4nfk1MGEDXiliMsLR& KGD EB 921@32

9 23 1 purpose of this rule is." {- 2 CHAIRMAN PALLADIN0s This is why I was trying (, 3 to say something a little different in last sentence. 4 "The use of alternative approaches different from those 5 set forth will be accepted if they provide a basis for 6 determining that regulatory requirements have been 7 met." That was to keep it from repeating what had 8 already been said. i 9 COHNISSIONER AHEARNEs I guess I as not clear 10 why it would be wrong to repeat it. The rule is what 11 lasts, I thought that was your point. 12 CHAIRMAN PALLADINO Yes. What I was going to 13 say, suppose that instead of saying, "The purpose of 14 this rule is to require applicant," start by saying, 15 " Applicants are to identify differences." 16 COHNISSIONER AHEARNE: Fine. 17 CHAIRMAN PALLADINO: If we coulh get a vote on 18 these two. 19 All those in favor, aye. 20 (Chorus of ayes.) 21 CHAIRMAN PALLADIN0s Opposed. 22 (No response.) 23 CHAIRNAN PALLADIN0s Then we go to page 3, and i 24 in the bottom paragraph we would cross out the sentence 25 that says, "The SRP acceptance criteria provide one way, l._ - l ALDER $oN REPORTING COMPANY. INC. 400 VIRGINIA AVE., S.W WASHINGTON. D.C. 20024 (202) S54 2345

24 ( 1 but not necessarily the only way, of complying with the 2 Commission's regulations." 3 I agree we want to try to keep things 4 consistent, but I wonder if we are not losing an 5 important thought. I wouldn't mind fixing it up the way 6 Natty fixed it up, saying, "The SRP acceptance criteria 7 provide 8 How did you say it, Htsty? g NR. HALSCH: "-- are intended by staff to 10 p rovide one wa y -- 11 CHAIRHAN PALLADINO: "-- are intended by staff 12 to provide one way, but not necessarily the only way." 13 COHNISSIONER GILINSKYs Is that in both (. 14 pinces? 15 CHAIRHAN PALLADINO: I as willing to put it in to both places. 17 COMMISSIONER AHEARNE: I have no problem, but 18 I as not sure why you would put in the rule what the 1g staff intends to do. 20 CHAIRHAN PALLADINOa I would rather put it 1 21 only here, in the statement of consideration. I don't 22 think it confuses anything that is said in there. 23 "The SRP acceptance criteria are intended by 24 the staff - " Then we vould add a sentence that says, 25 "They will lead to a more efficient review." l l ALDERSON REPORTING COMPANY,INC,

25 r 1 We need to say, "This will lead to a more 2 efficient review." 3 COENISSIONER GILINSKY: A sentence which would 4 4 summarize f or the summary, and I will leave it to you. 5 COMNISSIONER AHEARNE: Why not take that 6 sentence out and put it in the summary. C 7 CHAIRMAN PALLADINO Yes, put it in there, or 8 if you want to state the whole purpose, we can say, 9 "This purpose of this rule is to improve -- 10 CONNISSIONER AHEARNE4 Fine. 11 CHAIRMAN PALLADINO: Then've can copy that 12 sentence. 13 Do we have a vote on accepting this. This 14 would be putting the middle sentence here, " Acceptance 15 criteria are intended by the staff to provide one way, 16 but not necessarily the only way, of complying with the 17 Commissi~on's requirements." l 18 We would add to the paragraph a sentence that 19 says, "The purpose of this rule is to improve the 20 ef ficienty and effectiveness of NBC safety reviews." 21 Could we have a vote on that? 22 (Chorus of ayes. The vote was unanimous.) 23 CHAIRHAN PALLADIN0s Now can we vote on the i 24 amended document? 25 COHNISSIONER GILINSKYs I find that we have l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345

s 26 (" 1 gotte'n very formal. 2 CHAIRMAN PALLADIN0s Sometimes I get called on 3 lack of formality, and sometimes -- (- ' 4 CONNISSIONER AHEARNEs I think it is a good 5 idea. 8 Can we have a vote on the final document? 7 (Chorus of ayes. Vote was unanimous.) 8 CHAIRMAN PALLADINOs Anything else to come 9 before us at this time. 10 (No response.) 11 CHAIRMAN PALLADINOs Thank you very much, and 12 ve stand adjourned. 13 (Whereupon, at 9440 a.m., the Commission (- 14 adjourned, to reconvene at 10:00 a.m., the same day.) 15 16 17 18 19 20 21 22 i 24 25 l l ALDERSON REPORTING COMPANY. INC, I I

t* N NUCIZAR REGULATORY COMMISSION This is to certify that the attached proceedings before the in the matter of: COMMISSION MEETING Date of Proceeding: 3-10-82 Docket tiumber: Place of Proceeding: Washington, D. C. were held as herein appears, and that this is the original transcript thereof for the file of the Coc:m,ission., Patricia A. Minson Official Reporter (Typed) o ~ G W L.[ - Q, /J A >,. 3 - official Reporter (Signature) 1 l l l l

v i ttivb w J*u qs')bA N i t i NUCLEAR REGULATORY COMMISSI.ON 10 CFR PART 50 j RULE TO REQUIRE-APPLICANTS TO EVALUATE i DIFFERENCES FROM THE STANDARD REVIEW PLAN AGENCY: Nuclear Regulatory Comission ACTION: Final Rule.

SUMMARY

The Nuclear Regulatory Comission (NRC) is issuing a. rule 'that will. require futu,re applicants for operating licenses, construction permits, manufacturing ' licenses, and preliminary or final design approvals for standard plants to identify and evaluate differences from the ac,ceptance criteria of the applicable. revision of the Standard: Review Plan (SRP') as part of the technical. inforination' to be submitted as'part of an application. The SRP was originally issued in 1975-as NUREG-75/087; it describes an acceptable basis and criteria for on'clusions

• i

~ presented in a staff Safety Evaluation Rcport.(SER) for an application. The'most. 'recent revision to the SItP was issued in ' September 1981. The purpose of this i rule is to ' improve the efficiency and effectiveness of HRC safety reyfews. EFFECTIVEbATE: (60 days from da'te of publication)* l ADDRESS: Copies of the rule and related background material are available for l inspection at the Commission's Public Doc 0 ment Rpom at 1717 H Street, N.W., Washington, D.C. Single copies may be obtained on request from the U.S. ~ I f$ clear. Regulatory Commission, Washington, D.C. 20555,' Attention: Document Control. j INFORMATION CONTACT: Robert L. Tedesco, Assistant Director for Licensing, , Division of Licensing, Office of Nuclear Reactor Reculation, U.S. Nuclear

• (ir. sert date 60 days from date of publication)

i- .L'., *

• 1;; ~

Regulatory Commission, Washington, D.C. 20555 (301) 492-7425. .j, SUPPLEMENTARY INFORMATION: On October 9,1980, the NRC publi.shed in the M., FEDERAL REGISTER'[45 FR 67099] a Notice of Proposed Rulemaking that would - g ".T.J. require all commercial nuclear power plant licensees and applicants to document and evaluate differences from the Standard Review Plan (SRP). Interested. persons were invited to submit written comments to the' Secretary of the Commission by November 24, 1980. Numerous comments were received. After consideration of the comments and other factors involved, the Commission has amended the requirements as published for publ.ic comment by. limiting their applicabi,lity to nuclear power plant applications docketed after the effective date of the

5..

rul e. The majority of the comments on the proposed rule (1) questioned the time permit-ted to comply with the requirements of the rule in consideration of the significant short-term impact on engineering resources, (2) questioned the applicability of l the requirements 'to operating reactors, and (3) questioned why pending applications for construction permits should be subject to significantly different documentation' i h E requirements that similarly situated pending appl.ications for operating licenses. To allow further consideratio'n of these comments,'th'e Commission has decide'd'to exc1'ude operating reactors and p.ending.appitcations for operating' l licenses from the requirements of the rule, at this time. The pending operating license applicants have proceeded far enough in the licensing process that the' . application of the rule at this time could delay licensing decisions. Further. l l l l

.i ' ex'cluding tlye operating reactors and pending operating license applicants will ~ significantly reduce the impact on available short-term engineering resources. In addition, the Commission has decided to exclude pending applications for construction permits and manufacturing licenses docketed prior to the effective date of the rule, since the evaluation required of these applications co"uld add

• significantly to the length of their licensing process while the evaluation could be performed later at the operating license review stage without this,

disadvantage. The Commission is also c1'arifying that the requirements of the rule are explicitly applicable to n2w applications for preliminary, and final design. approvals of standard plants and that applicants for these approvals must* evaluate thsir application against the SRP. In the proposed rule,'such requirements for >(' standard plant applications were implicit in that it was proposed to$ include all CP and OL applications (including those referencing standard plant approvals). ~ The Commission 'as decided that.the requirements. h within the scope of the rule. for standard plants should be explicit to avoid any misunderstanding'on this' point. In adopting this rule, th'e Commission wishes to make it clear t! hat it does not intend to elevate the status of the 'SRP to that of a regulation. The SRP is not,a regulat. ion and compliance with it is not required. The SRP acceptance criteria provide one way, but not nece'ssarily the only way, of. complying 'with the Commission's regulations. The purpose of this rule is to require applicants to identify ' differences from the SRP acceptance criteria and to evaluate how the proposed alternatives to the SRP criteria provide an acceptable method of complying with the Commission's regulations. s

T: .m W -4 PAPEBWORK REDUCTION ACT REVIEW: The rule will.be submitted to the Office of

]l Management and Budget for clearance of the application requirements as required k!,

by the Paperwork Reduction Act (P.O. 96:511). The SFF-83, " Request for Clearance,"

• V:c

..)

• Supporting Statement, and related documentation submitted to OMB will be Nj.

available for public inspection and copying in the NRC Public Dcoument Room

h..,1,7 at 1717 H. Street, N.N., Wishington, D.C.

20555 by Pursuant to the Atomic Energy Action of 1954, as amended, the Energy Reorganization Act of 1974, as amended, the Section 552 and 553. Title 5 of the United States Code, the following rule'is published for codification. M.! {Li PART 50 - DOMESTIC LICENSING OF PRODUCTION ANO UTILIZATION FACILITIES '[ 1. The authority citation for Part 50 reads as follows: ~ AUTHORITY: Secs.103,104,161,182,183',189, 68 Stat. 936; 937, 948, 953, 954, 956; as amended' (42 U.S.C. 2133, 2134, 2201,' 2232, 2239); secs. 201, 202, 206; 88 Stat.1243,1244,1246; (42 U.S.C. 5841, 5842 4 5846), unless otherwise noted. Section 50.78 also issued under sec.122, 1:Q: [- 68 Stat, 939 (42 U.S.C. 2152). Sections' 50.78 - 50.81 also issued under sec.184, 68 Stat. 954, as amended (42 U.S.C. 2234). Section 50.100 - h 50.102 issued under sec.186; 68 Stat. 955 (42 U.S.C. 2236)..For the purposes of sec. 223, 68 Stat. 958, as amended (42 U.S.C. 2273),150.41(i) issised under sec. 1611, 68 Stat. 949 (42 U.S.C. 2201(i)); !!50.70, 50.71 and 50.78 issued under sec. 1610, 68 State. 950, as amended (42 U.S.C. 2201(o)) and the laws referred to in Appendices. 0

L.. 5 2. A new paragraph (f) is added to 150.34 to read as 'follows: '950.34 Contents of applications; technical information. 2 (f) Confomance with the St'andard ' Review Plan (SRP). ~ (1)(a) Applications for light water coole' nuclear power plant operating ', d licenses docketed after [ effective d' ate o'f this amen'dmentj ~ shall include an evaluation of the facility against the Standard j i Review Plan (SRP) in effect on [ effective date of this amendment'] - or the SRP revision in effect six months prior to-the. docket date of the application, whichsver is later. (1)(b) Applications for light water cooled nuclear ' power plant construction ,1 permits, manufacturing licenses, and preliminary or final design f approvals for st:1ndard plants. docketed after [ effective date of this, amendment] shall include an evaluation of the facility ^ against the SRP in effect on { effective date of the rule] or the SRP revision in effect.six months prior to the docket date, of the application, whichever is later. '(2) The evaluation requir~ed by this section shall include an identification and description of' all differences in design feature's, analytical. ~ techniques, and procedural measures proposed for a facility and those corresponding features, techniques, and measure's given in.- the SRP acceptance criteria. Where such a difference exists, the evaluation shall discuss how the alternative proposed provides an acceptable method of c6mplying with those rule's or regulations of - ~ 1 t

r ? _ g;. Commission, or portions thereof, that underlie the corresponding j SRP acceptanc'e criteria. ~ Dated'at Washington, D.C., this ' day of 1982. FOR,THE NUCLEAR REGULATORY COMMISSION [ Samuel J. Chilk Secretary of the Comission f 6 0 e 4 I e l' ,e e a S 4 k g e e S 9 O e

ut Itt-WL w J kn ' g wj6< p i .i a !l HilCLEAR REGULATORY COMMISSI.0N 1 10 CFR PART 50 1 RULE TO REQUIRE APPLICAtiTS TO EVALUATE DIFFERENCES FROM THE STANDARD REVIEW PLAN AGENCY: Nuclear Regulatory Commission ACTION: Final Rule.

SUMMARY

The Nuclear Regulatory Commission (NRC) is issuing a. rule 'that will. require future applicants for operating licenses, construction permits, manufacturing - licenses, and preliminary or final design approvals for standard plants to identify and evaluate differences from the~ ac,ceptance criteria of the applicable. revision of the, Standard: Review Plan (SRP') as part of the technical. inforination ' to be submitted as'part o-f an application. The SRP was originally issued in 1975- ~ as NUREG-75/087; it describes an acceptable basis and criteria for onclusions presented in a staff Safety Evaluation Report..(SER) for an appl.ication. The'most 'recent revision to the S'RP was issued in ' September 1981. The purpose of this 3 i, l - rule is to ' improve the efficiency and effectiveness of HRC safety reviews, ) EFFECTIVE DATE: (60 days from da%.e.of publication)* i ADDRESS: Copies of the rule and related background material are available, for l-inspection at the Commission's Public Doc 0 ment R,oom at 1717 H Street, N.W., l f Washington, D.C. Single copies may be obtained on request from the U.S. ~ ~ ' Nuclear. Regulatory Commission, Washington, D.C. 20555, Attention: Document Control. INFORMATION CONTACT: Robert L. Tedesco, Assistant Director for' Licensing, Division of Licensing, Office of Nuclear Reactor Regulation, U.S. Nuclear

• (insert date 60 days from date of publication) l l

Q^ W - y.

.s

'1 Regulatory Commission, Washington, D.C. 20555 (501) 492-7425. g '.' SUPPLEMENTARY INFORMATION: On October 9,1980, the NRC published in the 6 FEDERAL REGISTER T45 FR 67099] a Notice of Proposed Rulemaking that would y require all commercial nuclear power plant licensees and applicants to document [ and evaluate differences from the Standard Review Plan (SRP). Interested, persons .. t '7.] were invited to submit written comments to the Secretary of the Commission by November 24, 1980. Numerous comments were received. After consideration of the comments a.nd other factors involved, the Commission has amended the requirements as published for publ.ic comment tiy. limiting their applJcabi11ty /d. to nuclear power plant applications docketed after the effecthe date of the [. rule. ~ The majority of the comments on the proposed rule (1) questioned the time pemit-ted to comply with the requirements of the rule in consideration of the significant short-term impact on engineering resources, (2) questioned the applicability of the requirements 'to operating reactors, and (3) questioned why pending applications for construction permits should be' subject to significantly different documentation' 4 P requirements that similarly situated pending applications for operating licenses. To allow further consideration of these comments,'th~e Commission fias decided'to excl'ude operating reactors and p.endt.ng.appltcations.for operating: licenses from the requirements of the rule, at this time. The pending operating license applicants have proceeded far enough in the licensing process that the . application of the rule at this time could delay licensing decisions.

Further,

)

i (N ,y ' ex'cluding tl}e operating reactors and pending operating license applicants will significantly reduce the impact on available short-term engineering resources.,' 1 In addition, the Commission has decided to exclude pending applications for f construction permits and manufacturing licenses docketed prior to the effective date of the rule, since the evaluation required of these applications co'uld add - significantly to the length of their licensing process while the evaluation could be performed later at the operating license review stage without this. disadvantage. The Commission is also c1'arifying that the requirements of the rule are explicitly applicable to new applications for preliminary, and final design. approvals of standard plants and that applicants for these approvals must evaluate their application against the SRP. In the proposed rule,'such requirements for [ standard plant applications were implicit in that it was proposed toIinclude all CP and OL spplicati,ons (including those refer'encing standard plant approvals). within the scope of the rule. The Commission 'has decided that.the requirements. for standard plants should be explicit to avoid any misunderstanding ~on this point. In adopting this rule, th' Comission wishes to make it clear tihat it ~does not e intend to elevate the status of the 'SRP'to that of a regulation. The SRP is not, a regulation and compliance with it is not required. The SRP acceptance criteria provide one way, but not necessarily the only way, of. complying ~ ~ 'with t'ne Commission's regulations. The purpose of this rule is to require applicants to identify ' differences from the SRP acceptance i:riteria and to evaluate how the proposed alternatives to the SRP criteria provide an acceptable method of complying with the Commission's regulations. ~ e t i

i 2C ' F.' $~[ -4 PAPEBWORK REDUCTION ACT REVIEW: The rule will.be submitted to the Office of Management and Budget for clearance of the application requirements as required f.g. P,6, .by the Paperwork Reduction Act (P.O. 96:511). The SFE-83, " Request for Clearance," .#c N-Supporting Statement, and related documentation submitted to OMB will be (Nf available for public inspection and copying in the NRC Public Dcoument Room ~ at 1717 H. Street, N.W., Washington, D.C. 20555. w> 4 Pursuant to the Atomic Energy Action of 1954, as amended, the Energy Reorganization Act of 1974, as amended, the Section 552 and 553. Title 5 of the United States Code, the following rule'is published for codification. W.I ~ {.f1 PART 50 - DOMESTIC LICENSING OF PRODUCTION AND UTILIZATION FACILITIES b 5. ' 1. The authority citation for Part 50 reads as follows:

.:-1 :

~ AUTHORITY: Secs.103,104,161,182,183,189, 68 Stat. 936; 937, 948, 953, 954, 956; as amended' (42 U.S.C. 2133, 2134', 2201,' 2232, 2239); secs. 201, 202, 206; 88 Stat.1243,1244,1246; (42 U.S.C. 5841, 5842 4 5846), unless otherwise noted. Section 50.78 also issued under sec.122, . u:. ?- 68 Stat, 939 (42 U.S.C. 2152). Sections' 50.78 - 50.81 also issued under sec.184, 68 Stat. 954, as amended (42 U.S.C. 2234). Section 50.100 - ~ 50.102 issued under sec.186; 68 Stat. 955 (42 U.S.C. 2'!36)..For the purposes of sec. 223, 68 Stat. 958, as amended (42 U.S.C. 2273),150.41(i). issued under sec. 1611, 68 Stat. 949 '(42 U.S.C. 2201(i)); il50.70, 50.71 1 and 50.78 issued under sec,1610, 68 State. 950, as amended (42 U.S.C. 2201(o)) and the' laws referred to in Appendices.

.g 2. A new paragraph (f) is added to 150.34'to read as 'follows: '550.34 Contents of applications; technical information. Confonnance with the St' ndard ' eview Plan (SRP). (f) a R (1)(a) Applications for light water coole'd nuclear power plant operating ~ licenses dockt'.ed after [ effective date o'f this amen'dment] i shall include an evaluation of the facility against the Standard Review Plan (SRP) in effect on [ effective date of this amendment'] - I or the SRP revision in effect six months prior to-thadocket -{ date of the application, which6ver is later. (1)(b) Applications for light water cooled nuclear ' power plant construction permits, manufacturing licenses, and preliminary or final design approvals for standard plants -docketed after. [effecti've date of ~ this, amendment] shall include an evaluation of the facility against the SRP in effect on [ effective date of the rule] or ~ the SRP revision in effect.six months prior to the docket da.te. of the application, whichever is later. '(2) The evaluation required by this section shall include an identification ~ y and description of' all differe'nces in design features, analytical. l. techniques, and procedural measures proposed for a facility and those corresponding features, techniques, and measure's given in.- the SRP acceptance criteria. Where such a difference exists, the evaluation shall discuss how the alternative proposed provides an acceptable method of complying with those rule's or regulations of

- r y 6:- Commission, or portions thereof, that underlie' the corresponding SRP acceptanc'e criteria. s I ~ Dated'at Washington, D.C., this ' day of 1982. i FOR,THE NUCLEAR REGULATORY COMMISSION k ? [ Samuel J. Chilk Secretary of the Commission ~ f e e 6 e I p .. = O e e e e \\, l l e 6 4 9 %}}