ML20054F868
| ML20054F868 | |
| Person / Time | |
|---|---|
| Issue date: | 06/11/1982 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8206180044 | |
| Download: ML20054F868 (58) | |
Text
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COMMISSION MEETING In ::he Mar::er ef:
PUBLIC MEETING DISCUSSION OF STATUS OF SHIFT MANNING REQUIREMENTS
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DAW:
June 11, 1982 PAGES:
1 - 56 l
l Ar.
Washington, D. C.
l 1
- f. (REPORT 1XG ALDERSOX b
400 Viryisia Ave., S.W. Washing==,
D.
C.
20024 Telechene: (202) 554-2245 8206180044 820611 1
1 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
c 4
DISCUSSION OF S?ATUS OF SHIFT MANNING REQUIREMENTS 5
6 PUBLIC MEETING 7
8 Nuclear Regulatory Commission Room 1130 9
1717 H Street, N. W.
Washington, D.
C.
10 Friday, June 11, 1982 11 The Commission convened at 11:00 a.m.
12 BEFORE:
13 NUNZIO P ALLADINO, Chairman of the Commission 14 VICTOR GILINSKY, Commissioner JOHN AHEARNE, Commissioner 15
- THOMAS ROBERTS,. Commissioner JAMES ASSELSTINE, Commissioner 16 STAFF AMD PRESENTERS SEATED AT COMMISSION TABLE:
17 J. H0YLE 18 L. BICKWIT J. MURRAY 19 E. CASE H. THOMPSON 20 J.
PERSENSKY F. REMICK 21 R. LEVI 22 AUDIENCE SPEAKERS:
23 C. GOODMAN L. CROCKER 24 B. ROSS S. SCHWARTZ 25 ALDERSON REPORTING COMPANY,INC, 4@s) VIR$1NIA A_V@., @ W., W@HIN@T@N, @.@. 8BEFd4 (858_QSD0Q_ _ _
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DISCLAIMER This is arr unofficial transcript of a meeting of the United States Nuclear Regul,atory Cornission held on June il lon?
in the Commission's offices at.1717 H Street, N. W.,
Kasnington, D. C.
The meeting was open to public attendance and observation.
in1s transcript
- has not been reviewed, corrected, or edited,. and it may contain inaccuracies.
The transcript is intended solely for general infomational purooses.
As provided by 10 CFR 9.103, it is not part of the forinal or informal record of decision of the matters discussed.
Expressions of opinion in
.this. transcript do not necessarily reflect final determinations or
- p ) beliefs.
ilo pleading-or other paper may be filed with the Commission in any proceeding as the result of or addressed to any s.tatement or argument contained, herein, except as the Commission may auth'orize.
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2 l 1
EE2CEERIEGE 2
CHAIR?AN PALLADINO.
The meeting will please
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3 come to order.
4 We are meeting this morning to hear fromlthe 5
staff on issues concerning nuclear power plants' shift 6
manning requirements.
7 It is my understanding that the staff vill 8
provide the Commissioners with the status of the 9
utilities' capability to provide additional senior 10 reactor opera tors on shif t by July 1st, 1982, as st'ated 11 in NUREG-0737.
12 Also, I understand that we vill hear a 13 discussion of the options available for the
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14 implementation of this requirement.
15 Also, if during the discussion there is a need 16 to close the meeting, I would like to the General 17 Counsel ---
18 (Laughter -- General Counsel's chair is l
19 vacant.)
20 CHAIRMAN PALLADINO:
We need a General Counsel l
l 21 he re.
22 (Mr. Levi assumes the General Counsel's chair I
23 at the Commissioners' table.)
24 CHAIRMAN PALLADINO:
All right.
If during the 25 meeting there is a need to close the discussion, I would ALDERSON REPORTING COMPANY,INC.
4 3
1 like the General Counsel to advise us.
2 COMMISSIONER GILINSKYa Why would we need to 3
close the discussion?
4 CHAIRMAN PALLADIN0s I just say if there is a 5
need I would like the General Councel to advise us.
6 COMMISSIONER GILINSKYa He always tells us 7
that we can close if we want to or leave it open, 8
whatever.
9 (Laughter.)
10 CHAIRMAN PALLADINO But it is nice to be 11 alerted to let us have that option.
12 (Laughter.)
13 CHAIRMAN PALLADIN0s Unloss my f ellow
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14 Commissioners have any opening.remsrks I suggest turning 15 the meeting over to Mr. Thompson.
16 (Slide presentation.)
17 MR. THOMPSON:
Thank you, Mr. Chairman and i
18 Commissioners.
19 As you stated, this is a briefing of the 20 Commission on the status of the utilities' ability to 21 meet the increased staff manning called for in 22 NUREG-0737, Item 1.A.1.3.
23 The Commission in their approval of NUREG-0737 l
24 as requirements for operating. plants as well as for 25 operating licenses stated that the action plan approved i
ALDERSON REPORTING COMPANY,INC, M0 Mf;1Wt1A AML RNL met 00(YeMcL1 f@ft FFJfd M8L@0-M
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1 by the Commission presents a sequence of actions that 2
would result in a gradually increasing improvement in
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3 safety as individual actions are completed and the 4
immediate actions are replaced or supplemented by 5
longer-term improvements.
6 COMMISSIONER AHEARNE:
Hugh, one of the issues 7
obviously that will be addressed this morning is 8
" requirement."
Now you just said the Commission 9
requires.
Could you just as you walk through this 10' refesh my memory on what kind of a requirement we made 11 need.
For example, now we have a bunch of operating 12 plants.
How did we make 0737 a requirement on those 13 operating plants?
14 MR. THOMPSONs 0737 was made a requirement for 15 implementation on operating plants in the Commission's 16 approval on October 28th, 1980.
The Commission's 17 approval of NUREG-0737 was then transmitted to the 18 licensees, bo th the operating plants and the applicants 19 for operating licensees, for their response and their 20 re view.
In their approval, that was an implementation 21 on a case-by-case basis with a schedule to be determined 22 with the individual a pplicants.
23 COMMISSIONER AHEARNE:
By so far from what you 24 have described you have not said that we issued an order 25 or make a ruling.
ALDERSON REPORTING COMPANY,INC,
1 MR. THOMPSON:
We have not issued an order or 2
made a ' ruling.
In fact, the Commission has specifically 3
considered whether or not 0737 was to be applied as a 4
regulation to operating plants.
The Commission's 5
guidance to the staff was that it was not to be made a 6
regulation in order that flexibility would be 7
maintained.
That was in SECY-81-422.
8 MR.. CASE:
I just want to make sure.
For 9
operating applications, we have a proposed rule out on 10 that.
i 11 COMMISSIONER AHEARNE:
No, I understood that.
12 That is why I said operating plants.'
13 COMMISSIONER GILINSKYa It is a staff position
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14 with a certain amount of ---
15 MR. THOMPSON:
It is a Commission blessed 16 requirement.
17 COMMISSIONER GILINSKY:
Well, it is a 18 Commission blessed staff position.
19 HR. CASE:
Pight.
20 CHAIRMAN PALLADINO:
I think Commissioner 21 Ahearne is trying to make a point.
22 COMMISSIONER AHEARNE:
Th,e point I am trying 23 to make is as far as I can tell you have not said that 24 there is a legally binding requirement; is that correct?
25 MR. THOMPSON That is correct.
There is no ALDERSON REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (2023 554-23_4_5
6 1
legally binding requirement on those utilities which 2
have not modified their technical specifications at this 3
time.
4 CHAIRMA!; PALLADINO:
So there is no legally 5
binding requirement on that July 1st, 1982 date.
6 MR. THOMPSON:
That is correct.
The July 1st, 7
1982 date is a date that was targeted in NUREG-0737.
8 COMMISSIONER AHEARNE And then referenced 9
several times.
10 HR. TH0HPSON:
Referenced many times.
11 COMMISSIONER AHEARNE:
Now you mention except 12 for those plants that have changed their technical 13 specifications.
How many of those are there?
Will you t'
14 get to that?
15 ER. THOMPSON:
I will get to tha t.
There are 16 approxima tely 28.
17 Go to slide 3.
18 This is an area which the Commission has been 19 following very closely and really has no lack of i
l 20 dialogue between the utilities and the Commission.
The l
l 21 area was discussed in NUREG-OSSS, NUREG-0660 22 COMMISSIONER GILINSKYa And the dates of those 23 are?
I 24 HR. THOMPSON 4 The dates of ---
25 COMMISSIONER GILINSKYs
'79.
ALDERSON REPORTING COMPANY,INC, l
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MR. THOMPSON:
That is correct,
'79.
In fact, 2
NUREG-0660 had the initial date of July 1st, '82 for the 3
increase 1 staff level.
4 We had dialogues then with the utilities on 5
th eir ability to meet the July 1st, '82 da te.
Initially 6
when it was perceived as two years away it didn't look 7
like such a difficult requirement to meet.
Eut as we 8
have had additional discussions with thea and new plants 9
coming on line there have been some difficulties and we 10 have continued to be in touch with them and that is part 11 of the reason we are here today.
12 The next slide.
13 COMMISSIONER GILINSKYs Well, wait a minute.
(
14 Let's go back to this slide.
Our July 31 letter 15 requested a response from the utilities.
16 MR. THOMPSON:
That is correct.
17 COMMISSIONER GILINSKY:
And it was supposed to 18 be in f airly soon af ter that letter.
19 MR. THOMPSONs Correct.
20 COMMISSIONER GILINSKYa What was the response 21 of the utilities?
22 MR. THOMPSON 4 Well, the response varied.
I 23 have not gone back and reviewed those in detail at this 24 time.
Some utilities felt that the requirement was not 25 called for, but in general the utilities did not ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
a 1
indicate that this was one of their major problems.
2 COMMISSIONER GILINSKYs After those responses 3
did we expect that this condition would be met by July 4
'827 5
MR. THO PSON:
In nost caser that is correct.
6 I do not of specific individual problems that were 7
identified.
8 COMMISSIONER GILINSKYa What I am trying to 9
get at is did we know at that time that we were going to 10 run into this situa tion you are saying we didn't?
11 MR. THOMPSON:
We did not know at that time.
12 MR. CASES Not to this extent.
13 MR. THOMPSON:
Not to the extent that we have
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14 today.
15 COMMISSIONER AHEAPVEs The particular letter 16 does request the licensees to notify NRR within 90 days 17 of this July letter of the date by which their staffing 18 could be in compliance with the criteria.
19 MR. CASE:
Right.
j 20 COMMISSIONER GILINSKYa Now were they supposed 1
21 to present a plan in that letter?
22 MR. THOMPSON No, sir.
23 COMMISSICNER AHEARNE:
But did they respond?
24 COMMISSIONER GILINSKY:
You seem to be saying l
25 that most of them I
ALDERSCN REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON. O.C. 20024 (202) 554 2349
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1 COMMISSICNER AHEARNE:
Wait.
I think they 2
were asked for a plan because it said:
"In yo u r 3
response you are requested to discuss your planned 4
schedules and commitment.c."
5 MR. THOMPSONs Well, mostly those were plans 6
to meet it and a commitment as to we can meet the date.
7 CHAIRMAN PALLADIN0s In SECY-82-219 it says 8
that the NUREG-0739 requirements superseded the July 1,
9 1980 letter from Darrell Eisenhut.
10 MR. THOMPSON:
That is correct.
11 CHAIRMAN PALLADIN0s So does that mean that a 12 reponse to this was no longer required ?
13 MR. THOMPSON:
That is correct.
0737 was 14 issued on October 31st because of some of the 15 difficulties with all of the TMI Action Plan at that 16 time.
17 COMMISSIONER AHEARNE:
Actully if they had met 18 this letter they would have ---
19 COMMISSIONER GILINSKYa But I thought this 20 requiremen t has been the same throughout all of these ---
21 COMMISSIONER AHEARNEs This particular request.
22 MR. TH05PSGN:
Vith respect to the additional 23 senior reactor operator, that is correct.
24 COMMISSIONER GILINSKY:
So what is there to 25 talk about?
They were on notice that this is what we ALDERSON REPORTING COMPANY,INC, 400 VIRGINf A AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
10 1
wa nted to happen ---
2 MR. THOMPSONs Correct.
3 COMMISSIONER GILINSKYs
--- and they made 4
commitments, or at least most of them from what you are 5
telling me, made commitments in response to the July 6
1980 le tte r.
7 MR. THOMPSON:
These commitments were not 8
enforceable type commitments.
That is, they were not 9
CHAIRMAN PALLADINO:
Did all the utilities 10 make commitments in their responses to this July 31st, 11 1980 letter?
12 MR. THOEPSONs I cannot answer that specific 13 detailed a question.
Let me see if Bill Ross can.
14 COMMISSIONER GILINSKYa How did we deal with 15 those who said they weren't going to comply, if there 16 were any 17 CHAIRMAN PALLADIN0s Or were not able to.
18 COMMISSIONER GILINSKYs Or were not able to.
19 MS. GOODMAN:
(Inaudible) 20 MR. THOMPSON:
Clare, would you want to come 21 to the microphone and identify yourself and give us the 22 specific results.
j 23 MS. GOODMAN:
Clare Good man, NRC staff.
The 24 original responses varied.
Generally there were more 25 commitments to the date than there are presently.
But ALDERSON REPORTING COMPANY,INC, l
Gi@ VIRGINIA AML @.W, WQ@HIN@T@N, @.@. 88@84 (85Q 023-fEKS
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11 1
at that time there were some problems indicated.
As 2
time passed more and more problems came to light.
3 COMMISSIONER GILINSKYa Do you know how we 4
responded to these submittals?
5 MS. GOODMANs No, we did not respond.
We just 6
compiled.
7 COMMISSIONER AHEARNEa Is there such a 8
compilation, a list?
9 MS. GOODMANs Yes, but that list has changed to as time passed.
The problems increased as time went on 11 and we have kept track of those problems as time went 12 on.
They have had additional problems that they did not 13 know about at that time.
They have had a heavier f
14 attrition rate than they originally expected.
They have 15 had other problems that Hugh will address in a couple of 16 minutes and those problems have been larger than they 17 had originally projected them to be.
18 CHAIRMAN PALLADIN0s You are going to cover 19 the current status of problems?
20 MR. THOMPSON Yes, sir.
21 MS. GOODMAN:
He will cover the current status 22 that is different from the status in the SECY paper that 23 you have in front of you nce.
24 COMMISSIONER ASSELSTINEa When you say there s
25 were commitments, did those letters in essence say we ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. O.C. 20024 (202) 554-2345
12 1
will meet this particular item by the July date?
2 MS. GOODMAN:
Yes, in most cases that is true.
3 MR. MURRAY:
They probably were couched in 4
terms that we plan to meet it by that date.
5 MS. GOODMAN Yes, and several of them said if 8
other additional problems do not come about we plan to 7
meet them.
We at this moment don't foresee problems.
8 They left it open.
9 COMMISSIONER AHEARNE They were smart ---
10 (Laughter.)
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11 CHAIRMAN PALLADINO:
Okay.
Thank you.
12 HR. THOMPSON:
We continued corresponding with 13 the utilities on this same increased staffing level when 14 we promulgated NUREG-0737 as well as the amendment to 15 NUREG-0737 by NRC generic letter 8110 on February of 16
'81.
The NUREG letter 8110 was the emergency facilities 17 staffing level and those staffing levels for the 18 emergencies as well as normal operations with respect to 19 licensed operators are consistent.
So there has been no 20 change with respect to the ---
21 COMMISSIONER GILINSKYa Well this a t least is 22 one item where we have been consistent.
l 23 MR. THOMPSON We have been consistent with i
24 the increased level as well as being consistent with the 25 deadline da te.
ALDERSoN REPORTING COMPANY,INC, 400 VIAG!NIA AVE S.W., WASHINGTON. O C. 20024 (202) 554-2345
13 1
COMMISSIONER AFEARNE:
Did 8110 explicitly 2
give the deadline date?
3 M2. IHOMPSON:
8110 ref erenced the NUREG-0737 f
4 and amended NUREG-0737, the table.
So the da tes stayed 5
the came.
6 CHAIRMAN PALLADINO:
But did the criteria stay 7
the same?
8 MR. THOMPSON:
The criteria for licensed 9
reactor operators stayed the same.
10 COMMISSIONER AHEARNE:
The table really 11 doesn't give a date, does it?
12 MR. THOMPSON:
The. table itself does not.
All
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it did was amended an existing table in NUREG-0737 which 13 14 established the date.
I did note on this chart the one 15 related document where the Commission elected not to
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16 make this specific 0737 a formal regulation for the 17 utilities.
18 CHAIRMAN PALLADINO:
Well, what I don't 19 understand is if there was no change, what is the 20 meaning of the statement that NUR EG -0737 requirements l
21 superseded the July 1,
1980 letter from Darrell Eisenhut?
22 MR. THOMPSON:
There were come of the shift 23 staffing requiremen ts that were changed.
It was not v.
24 with respect to the additional SRO.
25 CHAIRMAN PALLADINO:
I see some signals from ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202? @54 8343_
14 1
the staff.
2 MR. CROCKER:
Larry Crocker with the staff, 3
sir.
I think the words in that paper should have said 4
incorporated.
That July 31st letter was incorporated 5
in tact in 0737.
6 CHAIRMAN PALLADINO:
I see.
So there really 7
were no changes?
8 MR. CROCKER:
No, there were no changes to the 9
letter as such.
10 CHAIRMAN PALLADINO:
Thank you.
11 MR. THOMPSON:
The next slide does indicate 12 the minimum staffing level called for in NUREG-0737.
13 The asterisks indicate the increase in staffing that is 14 called for since THI.
We note that.it is the shift 15 technical adviser who has been on shift since July 1st 16 of 1981 and the increase in the SRO which is the point 17 of this discussion today.
18 The next slide indicates ---
19 CHAIRMAN PALLADINO:
I have got a question.
20 This lists "Three Units - Two Control Room s," and it 21 lists a number of options.
I was curious, are there any
?2 three units with three control rooms?
23 MR. THOMPSON:
Not presently.
There had been 24 some previously planned but they have been cancelled or 25 deferred st this time.
~~
ALCERSON REPORTING COMPANY,INC, 4MD VIA@lNIA AVL @.M_ CA@HIN@T@R). @D.@. P@M3 d%R Peti-2YR
15 1
I would note at the bottom of the page another 2
of the TMI Action Plan itams tha t a re currently in clud ed 3
in this phase of implementation by the NBC staff for 4
ope ra ting plants ---
5 CHAIRMAN PALLADINO:
I am sorry.
I should 6
hsve been listening and I was talking.
Co uld you repeat 7
th*i santance?
8 HR. THOMPSON:
I would note at the bottom of i'
9 the page we identify some increased shif t manning called 10 for in NUREG-0737 relat6d to the emergency preparedness 11 facility response capabilities for the utility.
These 12 are identified also as part of SECY-82-111 as what the 13 staff requirements are under emergency response i
14 facilities.
That is not directly part of today's 15 briefing, though that particular item will be in essence 16 covered and treated in a similar f ashion with respect to 17 its implementation as is 1813.
18 The next slide basically addresses the intent 19 of the additional SRO that is called for in 1813.
20 COMMISSIONER AHEARNE:
While they are 21 straightening the slide, can I ask you on the previous 22 one, and you don't have to put it back, one of these 23 additional cla rification letters, namely I guess, the 24 February 18th one, introduced the term " shift foreman."
25 Is that a term that you are now using regularly?
I ALDERSoN REPORTING COMPANY,INC, 400 VIRGINTA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
16 1
noticed tha t doesn' t seem to show up on other charts.
2 MR. THOMPSON:
Shift foreman is used r
3 interchangeably with shif t supervisor at times and there 4
are utilities that have both shift supervisors and shift 5
foremen.
6 COMMISSIONER ASEARNE:
The chart though that 7
was sent out on February 18th had both shift supervisor 8
and shift foreman.
It was just an informational 9
question.
10 MR. CROCKER:
Larry Crocker again.
The shift 11 foreman is a term tha t many of the utilities use for the 12 senior reactor operator who is stationed in the control 13 room.
These terms vary drastically from utility to
(
14 utility and it is sort of hard to keep up on them.
15 COMMISSIONER AHEARNE:
But by our sending it 16 out in our staffing requirements, was there anything in 17 addition other than just a label?
18 ER-CROCKER:
I.think it was just a label, sir.
19 MR. THOMPSON:
As stated in the lessons 20 learned in NUREG-0737, the intent of having the 21 additional SRO on shif t was to assure the availability 22 of a qualified SRO in the control room at all times 23 while the pla nt is operating to allow the shift 24 supervisor to move about the plant and about the site.
25 The resl purpose there is to prevent accidents ALDERSON REPORTING COMPANY,INC.
40@ V! A$fMOR AV@., @M, WA@M190$T@G0, @.@, M@8dM 96tl-RitM
17 1
and to prevent the plant f rom getting into an emergency 2
situation.
'4ith respect to the emergency situations, 3
COMMISSIONER GILINSKY This grew'out of the 5
experience at TMI.
6 MR. IHC3PSON:
That is correct.
7 CGMMISSIONER GILINSKY:
At one point there was 8
not a senior reactor operator in the control room.
i 9
HR. THOMPSON:
That is correct.
In many 10 utilities there is not that capability.
Either the 11 shif t supervisor or the senior reactor operator has to 12 stay in the control room and can't go out and observe 13 i,
items, work maintenance or the condition of the plant 14 during the shif t.
He has to stay in the control room 15 and there is no individual of that kind of management 16 capability available to do tha t.
4 17 CHAIRMAN PALLADINO:
Is 0737 clear on the 18 question of whether or not this SRO can be the STA or 19 vice versa?
20 MR. THOMPSON:
0737 has the STA as a separate 21 individual with the acknowledgement that we may in the 22 future change our requirements in that area.
23 CHAIRMAN PALLADINO:
I notice some of the 24 alternative suggestions made by some of the utilities is 25 that the SRA and the STA be the same person.
ALDERSON REPORTING COMPANY. INC.
400 VIRGINIA AVE., S.W. WQ@HINGTON, D.C. 20024 (898) 554-2349
18 1
MB. THOMPSON:
That is correct.
That is one 2
of the categories where people are responding to and we 3
will discuss that and our approach to that in just a 4
moment.
5 CHAIRMAN PALLADINO Okay.
Thank you.
6 MR. THOMPSCN:
71th respect to the emergency 7
response facilities and their staffing level, the 8
numbers that they have ide ntified in 0654 were to assure 9
that sufficient staff and appropriate skills are 10 available during an emergency.
The important point 11 there is that they wanted to have people with the 12 ca pability to respond to an emergency as opposed to 13 preventing it, which is the 1813.
(
14 Again, I indicated this was an a rea in which 15 there has been considerable correspondence and this is 16 kind of an outline of what had happened.
We had really 17 some concerns that by this January the utilities were 18 no t going to be able to meet the increased staffing 19 level as called for by 1813.
We transmitted a letter 20 asking them to formally respond, and the next chart 21 indicates the ---
22 COMMISSIONER AHEARNE:
Let me just interrupt 23 f o r a min u te.
In trying to hunt through and prepare, 24 that was the one letter that I couldn't find.
What date 25 was that?
l l
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
10 l
1 MR. THOMPSON:
I am sorry?
j 2
COMMISSIONER AHEARNE:
What date was that 3
January letter.
I was unable to find it.
4 MR. ROSS:
It was a letter sent out to every 5
individual plant.
It was not a generic letter.
6 MR. CASE:
What was the date?
7 HR. ROSS.
It was in the middle of January.
8 COMMISSIONER AHEARNE In other words each 9
specific plant got a letter?
10 MR. ROSS Yes.
11 COMMISSIONER AHEARNE:
Was it only focused on 12 those plants that you thought were likely to be a 13 problem or was it to every operating plant ?
(
14 MR. ROSSs Every operating plant.
15 COMMISSIONER GILINSKY Let's see,.in January 16
'82?
a 17 MR. THOMPSON:
Yes, January.
18 COMMISSIONER GILINSKY4 You began I think that 19 they weren't going to make it by July.
Now why didn't i
20 you think that, and I don' t mean you personally, in 1980 i
21 or early '81?
After all, in 1980, from what I gather, l
22 more plants indicated they would comply than are 23 presently indicating, but still a fair number suggested 24 they might not, and then things went downhill f rom 25 then.
So why wouldn't we have ever though t that they I
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
20
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would comply?
2 MR. THOMPSON:
I agree, Commissioner, that 3
that was an area that we could have focused more 4
attention on.
My only response at this time would be 5
that the large number of other TMI Action Plan items 6
that were being focued on with due dates earlier were 7
the ones where we indicated and put our attention.
8 COMMISSIONER AHEARNE:
Of course, I find that 9
as of April of '82 the TMI Action Plan tracking system 10 supposedly says that this particular item is on 11 schedule.
It is a green status ---
12 MR. THOMPSON:
There are two items in there.
(,
13 One is the overtime policy, which the Commission has-14 acted on with respect to the implementation of that.
15 The second is the requirement being established through 16 the staff's process of requesting through 50.54 F 17 letters.
18 COMMISSIONER AHEARNE:
Well, all I am pointing 19 out is that what this is saying, current status, 1
20 submittals on shif t manning not due until July
'82.
21 That is what this says, and it is just listed as green.
22 MR. THOMPSON:
That was not carefully 23 scrutinized by myself.
I did make a significant effort 24 to change a number of the greens to yellows and some of 25 the reds to yellows, and hopefully we could change some s
ALDERSON REPORT 1NG COMPANY,INC, 0@ VIRGINTA A% @.W., WA@H:N@T@N, @.@. 8@@84 (2@@ @@34@4@
21 1
the other way.
Ihat cne should have reflected the 2
cu rren t difficulty that we were having in this area.
3 CHAIRMAN PALLADINO:
What was the nature of 4
the January '82 letter?
Is this a request for 5
information?
6 MR. THOMPSON:
This was a request for the 7
utilities to reaffirm their ability to meet this 8
increased staff level.
9 MR. CASE:
This, among other things.
Weren't to there a number of items d ue a t that July '82 date and we 11 asked their response to all of them?
12 COMMISSIONER AHEARNE:
There is a head shaking
(,
13 no.
14 MR. ROSS:
No.
This was a letter sent out 15 specifically to get an uriate status on this single item.
i to MR. CASE:
We wrote a request on the other l
17 items, too, didn't we?
18 MR. ROSS:
Yes, that 19 COMMISSIONER GILINSKY:
The politic answer is 20 yes.
21
( Lau g h t e r. )
22 CHAIRMAN PALLACINO:
Was this a request for 23 information primarily?
24 MR. ROSS:
It was a request to let us know if 25 there was any problem in meeting the 6/30 deadline tha t l
ALDERSON REPORTING COMPANY, INC, 400 VIRG:NIA 8.VE.. S W., WASHINGTON D.@. 20024 (202D 993 8349__ _
22 1
ve did not know about.
2 CHAIRMAN PALLADINO:
Did that imply that if 3
they had let you know they didn't have to respond?
4 MR. ROSS:
In fact, that is what happened.
5 (Lauchter.)
6 MR. ROSS:
All of those who were absolutely 7
sure they would meet it did not respond by letter but 8
they responded by telephone.
Those that had problems 9
sent us letters.
10 CHAIRMAN PALLADINO:
Okay.
Thank you.
11 Go ahead, Hugh.
12 HR. TH05PSON:
The next slide indicates our
(.
13 general understanding of the utilities' ca pabilities to 14 meet the 1813 staffing levels based on that information 15 and subsequent phone calls.
It indicated that about 40 16 units would and th t about 34 would probably not with 9
17 some exceptions.
18 COMMISSIONER GILINSKY There are some 19 utilities complying, are they not, or are some of these
~
20 utilities complying in part?
21 ER. IHOMPSON:
Yes, some utilities in fact 22 have some plants that are able to comply with it and 23 some that are not able to comply with it.
The most
\\
24 current information indicates that there are 77 plants 25 now, 40 which will probably conform and 37 which will ALDERSON REPORTING COMPANY,INC, M-
23
/
1 probably not conf orm.
2 COMMISSIONER GILINSKY Do you have a lis't of 3
those 377 4
MR. THOMPSON:
Yes, I do, or I have a list of 5
all of them.
6 COMMISSIONER GILINSKY:
Could yo u give a slide 7
on that?
8 MR. THOMPSON:
I don 't have a slide on that.
9 CHAIRMAN PALLAD!NO:
Can I break down the list 10 a little bit.
Some of these I think had requested 11 extensions.
12 MR. THOMPSON:
Some of these in the response to the January letter did request an extension of time.
13
('
14 CHAIRMAN PALLADINO:
You say 40 will probably 15 make it.
This summary table enclosure to SECY-82-219 16 said we currently have technical specs which are in 17 compliance with the requirements or compliance by July 18 1982 is probable.
There are 28.
l 19 MR. THOMPSON:
There are 28 ---
20 COMMISSIONER AHEARNE:
Licensees versus units.
21 CHAIRMA3 PALLADINO:
Oh, this is licensees and 22 this is units.
Okay.
Thank you.
23 HR. THOMPSON:
'Je wanted it to add up to the 24 number of operating units.
So we had changed the l
25 statement to talk about units.
?
l l
l ALDERSON REPORTING COMPANY,INC, 400 VIRGINTA AVE., S.W., WASHINGTON D.C. 20024 (202) 554 2345
24 1
There were a number of reasons stated by the 2
utilities f or having an inability to meet the increased 3
staffing level.
One of them was the lengthy time 4
required to train new senior reactor operators.
5 COMMISSIONER GILINSKTa Hadn't they taken 6
steps to assure the adequate number of operators some 7
time ago, or have they just ignored this?
8 MR. THOMPSON:
I believe it falls in both 9
categories.
Some had and some hadn't.
For instance, 10 Browns Ferry, which is one which falls into a fairly 11 difficult ability to meet this staffing requirement, has 12 one of the most extensive training programs around.
13 They have trained operators.
They have dedicated 14 simulators and dedicated training programs and what ther 15 found out they were doing was training operators for 16 every other BWR around the country and that their 17 auxiliary operators who would have been the replacement 18 for the reactor operators who would then have been able 19 to become the senior reactor operators were offered 20 opportunities at other utilities.
21 So there are those who took that approach and 22 then those who also had idicated to us that, well, this 23 is not a requirement and therefore we are not moving 24 forward at this time.
Those people in the latter 25 category have now changed.
There is nobody who now is ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE.. S.W., WASHINGTON. D.C. 20024 (202) 554-2345
25 l
1 not actively naking efforts to comply with the incressed 2
staffing le tter, with two who are going to request 3
exemptions.
4 CHAIRMAN PALLADINO:
On those that requested 5
extensions, has sny response been given?
6 MR. THOMPS0" Not at this time.
We have 7
actually on May 5th sent out the 50.54 ? letter which 8
vill set in place the formal process by which we will 9
grant extensions, exemptions ---
10 MR. CASE:
It is the first formal process 11 under which we would make this'a legally binding 12 requirement.
13 MR. THOMPSON:
And therefore need an extension
(
14 or exemption, as the case might be.
15 CHAIRMAN PALLADINO:
You mean if somebody 16 writes in and asks for an extension you don't respond to 17 them?
18 MR. THOMPSONs Well, there was no formal 19 requirement to exempt or extend from.
20 CHAIRMAN PALLADINO:
Well, now wait.
You were 21 making quite a point that some of them have met it and 22 some have not.
So if somebody requested that they 23 wanted an extension, I would assume that would deserve
\\
24 some attention.
25 MR. THOMPSON:
We have given it some ALDERSoN REPORTING COMPANY,INC, 400 VIRG NI A AVE., S.W WASHINGTON, D.C. 20024 (202) 554 2345
26 1
censideration.
'J e have not acted on those yet.
2 HR. CASE:
In other words, the date for 3
everybody responding to this latest letter has not yet 4
expired.
Isn't that true, Hugh?
5 MR. THOMPSON:
It is about expiring.
6 CHAIRMAN PALLADINO:
.This letter, the May 5th 7
letter?
8 MR. THOMPSON:
The May 5th, correct.
9 MR. CASE:
So we are just collecting the 10 inforoation and we are going to presen t it to you and we 11 are going to discuss what we plan to do about it, 12 including what ';e plan to do about the extension 13 requests.
14 CHAIRMAN PALLADINO:
How about those who 15 request exemptions, you haven't responded to those yet?
16 MR. THOMPSON:
That is correct, sir.
17 CHAIRMAN PALLADINO:
Now what must they do to 18 request an exemption?
19 MR. THOMPSON:
Well, they must file with us 20 the basis for their exception or exemption from this.
21 This is not the only one of the TMI Action Plan items 22 which they are doing that.
23 CHAIRMAN PALLADINO:
I was just trying to 24 learn how we would react.
Have they sent formal 25 exem p tion requests?
ALCERSON REPORTING COMPANY,INC, 400 VIRGIN! A AV@
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27 1
MR. CASE:
I have to say no because there is 2
no formal requirement.
3 MR. THOMPSON:
It turns out that they have 4
su bmitted to us formal exemption requests based en the 5
January ---
6
( La uch te r. )
7 COMMISSIONER AHEARNE:
I think the right way 8
to say it is that they have submitted letters which 9
could be viewed as a formal request.
But Zd is correct, 10 there is no formal requirement from which ---
11 MR. THOMPSON:
To need to request an exemption 12 from.
13 CHAIRMAN PALLADINO:
But then why a re we
(,
14 here?
I am seriously having problems.
If a utility in 15 good faith says, look, we are so special tha t we ought 16 to be exempted and they write a letter.
Does that just 17 sit?
Doesn 't it ever get answered?
18 COMMISSIONER GILINSKY:
We are just talking 19 about two utilities.
20 CHAIRMAN PALLADINO:
I appreciate that, but 21 there are other things that ---
22 COMMISSIONER GILINSKY:
They are snall cases.
23 CHAIRMAN PALLADINO:
No, but I am trying to 24 understand because there are other items.
25 MR. CASE:
No, they don 't sit, but we have to ALDERSON REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W., WASH 1*tGTON, D.C. 20C24 (202) 554 2345
28 1
get enough of them together to understand the general 2
status, and since this is a " Commission re qui re men t, " we 3
have to come back to you and tell you what we plan to do i
4 about it to get your approval or lack thereof.
5 COMMISSIONER AHEARNE:
That is correct.
6 CHAIRMAN PALLADINO:
Is that the way we would 7
do it on all these 0737 requirements?
8 MR. THOMPSON:
That is correct.
The phased 9
implementation of 0737 for operating plants though is 10 the short-term lessons learned which we im plemented with 11 the show-cause orders.
There was a July show-cause 12 order for Phase II.
Phase III will be coming down 13 probably by the end of this month with those TMI action 14 items that were due the past year.
Then this will be in 15 Phase IV which will come down and present the utilities' 16 response to each of these items and what the staff's 17 recommendation to the Commission would be, whether to 18 grant that extension of time, whether to modify it ---
19 CHAIRMAN PALLADINO:
I was thinking 20 specifically of exemptions now for the moment.
On 21 exemptions you wait until you see the whole pattern 22 before you recommend to the Commission tha t something 23 ought to be done on the request.
(
24 MR. CASE:
Well, it is very hard to 25 generalize.
Some exemptions we grant ourselves without ALDERSCN REPCRTING COMPANY,INC.
400 VIRGINIA AVE S.W WASHINGTON, D.C. 20024 (202) 554-2345
29 1
coming back to the Commission.
2 COMMISSIONER CILINSKYa In any case, this 3
problem is not domina ted by the exemption request.
4 CHAIRMAN PALLADINO I appreciate that.
I am 5
just looking at exemptions for the moment.
6 MB. THOMPSON Typically we don' t receive 7
exemptions from non-requirements.
8 (Laughter.)
9 MR. THOMPSON:
So this kind of fell into a 10 rather unique category.
You know, normally we would not 11 le t one sit.
We would act on it promptly.
12 CHAIRMAN PALLADINO:
We are sitting here 13 asking a lot of questions implying that these utilities
(
14 weren' t being diligent.
We can't say it is a 15 non-requirement and then treat it as though it were a 16 requirement.
That is what is bothering me in the 17 discussion.
18 COMMISSIONER GILINSKYs Well, it is a 19 Commission approved staff position.
This is something 20 that we wanted to see ---
21 CHAIRMAN PALLADINO:
But then you can't say it 22 is not a requirement.
I don't understand this.
23 COMMISSIONER GILINSKY:
It doesn't have the 24 legal force that 25 CHAIRMAN PALLADINO:
But which way are we ALDERSON REPORTING COMPANY. INC.
400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554 2345
30 1
going to treat it, a legs 1 ---
2 COEMISSIONER GILINSKY:
Well, let =e just 3
pursue this.
Hai ve know which way things were going, I 4
don't have any doubt but that the Commission would have 5
made this a requirement.
6 CHAIRMAN PALLADINO:
I can't possibly ---
7 COMMISSIONER AHEARNE:
I think Vic is 8
correct.
Similar types of discussions have been held 9
and the issue was here is where after all this review to and all this THI Action Plan, et cetera, a conclusion 11 was finally reached that these are things that ought to 12 be done.
We had a lot of debate on would we put things 13 into rules or would we put them into ordersa The
(
14 general conclusion again was that we would try to 15 concentrate on a rule for the NTOL plants, and there was 16 a little bit more time in order to try to get that done.
17 As far as the operating plants, the approach 18 that was taken, correct me, Ed, if I am wrono, was to 19 lay it out as clearly as possible in 0737 and follow-on 20 letters, and then in those cases where it looked like 21 there was going to be great difficulty in getting 22 something done to then come back and say w ell, we will 23 issue a show-cause order to put that into effect.
24 But we did explicitly address should we put 25 all of this into a rule f or operatino plants and we s
ALDERSON REPORTING COMPANY,INC, 400 VIRGINI A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
31 1
concluded no, we wouldn't put it all into a rule for 2
operating plants but that we would treat it on a 3
case-by-case basis.
4 I think Vic is right that if the issue had 5
come up that there were a lot of utilities that did not 6
want to, or if there was not good substantial reason, if 7
it was just they don't want to go to two SB0s. I have nc 8
doubt that the Commission would have then gone to the 9
order.
10 CHAIRMAN PALLADIN0s Now wait.
Did anybody 11 say they wouldn't go except these two that asked for 12 exemptions?
13 MR. THOMPSON:
There was one at one time
(
14 taking that position, but the initial reponse we have 15 not to the 50.54 F letter, which has more force to it, 16 they are now not taking that position any longer.
17 CHAIRMAN PALLADINO:
I am trying to understand 18 it from the point of view of the utility.
Here is a 19 target and they try to meet it.
If in good faith they 20 come and ask for an extension and we don!t act on it and 21 are waiting for more feedback, I don't think we can come 22 back then and clobber them and say you didn't do right.
23 MR. THOMPSON:
No, sir, and we would not 24 in tend to d o th a t.
25 CHAIRMAN PALLADINO:
But some of the ALDERSON REPORTING COMPANY,INC,
32 1
discussion implies th a t we should, and tha t is what 2
bothered me.
3 MR. THOMPSON:
I am sorry.
I didn't mean to 4
imply that at all.
5 COMMISSIONER GILIHSKY:
(Inaudible) 6 CHAIRMAN PALLADIN0s I didn't say we ought to 7
clobber them.
g 8
COMMISSIONER GILINSKY:
( In au dible )
9 (Laughter.)
10 COMMISSIONER ASSELSTINE:
I must say I agree 11 with the Chairman.
If you follow this kind of an 12 informal approach, it seems to me that we really do 13 leave ourselves open to just this kind of a situation.
\\
14 In essenca it seems to me what the Commission did is the 15 Commission said if would be very nice if the utilities 16 would go ahead and add this extra staff and we think it 17 would be a good idea if it was added by a certain date.
18 Then I gather the response that we got back was well, in 19 ome cases we will try to do that or we think we may be 20 able to do it or we will plan to do it.
21 Now we are in a situation where they haven't 22 and there isn 't a whole lot we can do about it in t erms 23 of ---
24 MR. CASE:
But there is another point that 25 hasn't gotten through.
ALDERSON REPORTING COMPANY,INC, 400 vtRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
33 1
COMMISSIONER GILINSKY First of all, it is a 2
lot more than sayinc it would be nice.
You now, it is 3
true that it is not legally enforceable, but the 4
Commission took a much stronger pcsition than it would 5
be nice.
6 Now I think it is unfortunate that we were not 7
alerted to the situation some time ago so we could tak-8 more formal actio'n ---
9 MR. CASE:
But, Vic, I agree with you.
10 COMMISSIONER GILINSKY I don 't mean punishing 11 anybody, but I think we can get more forceful about it.
12 MR. CASES But when we initially wrote the 13 letter in 1980 ve said the Commission feels you ought to i
14
.t o this by July 19 9 2.
Now it is pretty hard, even from 15 th61r standpoint and ours, to predict two years in 16 advance how likely they are to meet such a requirement.
17 It is only when it comes upon you that can you get a 18 detailed breakdown of how many will and how many won 't l
19 and whit are the reasons for not, and that is where we i
20 are today.
21 COMMISSIONER GILINSKY:
You know, this is one 22 of the more important things that came out of our l
23 experience, and it is not a terribly complicated one.
24 CHAIBMAN PALLADINO:
I gather the training 25 though is.
(
ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE S.W., WASHINGTON. D.C. 20024 (202) 554 2345
i 1
34 1
COMMISSIONER GILINSKY:
Well, I can understand 2
situations where a utility has put a lot of people into 3
a pipeline and for one reason or another things haven't 4
worked out or they all got hired away and you have to E
deal with these cases and make some accommodation.
Put 6
it is quite another thing if the utility just paid no 7
attention to this whole 8
CHAIRMAN PALLADINO:
Are you going to go 9
into ---
10 MR. THOMPSON:
I would address how we intend 11 to come back to the Commission and address the various 12 areas that utilities tend to find themselves in.
13 We did issue on May 5th a 50.54 F letter which
(
14 covered this and about nine other TMI Action Plan items 16 requesting that they respond formally to their ability, 16 plans and schedules to meet these items.
17 COMMISSIONER GILINSKY:
Remind me what a 50.54 18 F letter is, in o ther words, legally.
19 MB. THOMPSON:
A 50.54 F legally, and I will 20 ask the practicing attorneys ---
21 MR. CASE:
It requires information.
22 MP. THOMPSON:
It requires them to submit 23 information.
I 24 MR. MURRAY:
What it says is we need the 25 following information to tell whether your license ALDERSON REPORTING COMPANY. INC, 48B VIR@lN! A AV8.. @ W., WA@HINGT@N. @.@, 8?@84 (Rdf@ @@S-M42
s 35 1
should be suspended or revoked or in some way amended, 2
and we need it by such and such a date and if we don't 3
have it the implication is that we are going to take 4
some further action.
It gets people's attention.
5 CHAIRMAN PALLADINO:
Is this the one of May 6
Sth?
7 MR. CASE:
Yes.
8 CHAIRMAN PALLADINO:
It says this letter 9
requests your commitment to implement on a timely basis 10 the remainder of the NUREG-0737 items.
11 MR. THOMPSON:
Correct.
12 CHAIRMAN PALLADINO:
Then it goes on to 13 discuss this issue.
i 14 MR. THOMPSON:
About ten, in fact, of the 15 items came due during this time frame, which is 16 consistent with the phased implementation of the 17 case-by-case effort.
This is not the only item in fact 18 that the utilities find tha t they are having difficulty 19 meeting the dates set out previously in the 0737.
20 Anyway, we find that the utilities will fall 21 basically in four conformanca categories.
That is, th e y 22 vill be in conformance or expect to have the increased 23 staffing level, which is the a0 units that we 24 identified.
Some will be able to meet the requirement 25 if the combination of the shif t techncial adviser and ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
36 I
the second SFO or in some cases the shift technical 2
adviser would be the shift supervisor also.
So they 3
have a little flexibility in the wa y they are prop'osing 4
the combination of the STA and the SRO positions.
5 C0hMISSIONER GILINSKY:
How many fall into 6
that category?
When you have listed 13 units here with 7
plans for alternative proposals for STA and STO, would 8
they in fact meet the requirement if one made that 9
accommodation?
10 MR. THOMFSON.
I believe that is correct.
I 11 am not precisely sure how Oconee fits.
Oconee I 12 indicated their response was dependent on the 13 Commission's decision on the shift control engineer.
t.
14 They were a little clever about their response.
So 15 until we really have an opportunity to go back and 18 discuss their proposals, I can't say.
17 COMMISSIONER GILINSKYa Is this the guy 18 who -- (Inaudible) 19 MR. THOMPSON:
No.
I am pretty sure their guy 20 would be the STA and the SB0 also, but I just can't 21 confirm it.
I do know Oconee originally was in ca tegory 22 one, that they intend to conform.
They lost seven SR0s 23 recently by participating in the job task analysis to 24 INPO.
25
( La ugh te r. )
t ALDERSON REPORTING COMPANY,INC. ~
400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
37 1
MR. THOMPSON:
The guy found out that tha t was 2
such a wonderful thing tha t a couple of them hired away, 3
and I mean it was just tha t type of 1 ---
4 CHAIRMAN PALLADINO:
We had better watch out.
5
-These task analyses are dangerous things.
6 (Laughter.)
7 COMMISSIONER GILINSKY Is it your impression 8
that with that possible exception the others complied 9
MR. THOMPSON:
That is correct.
10 HR. CASE:
But you have got this problem of 11 the extra hands that you have to ge't into.
12 MR. THOMPSON:
With respect to the 1.A.1.3 13 they would meet that requirement.
14 COMMISSIONER GILINSKY:
They would meet the 15 SRO requirement 16 MR. THOMPSON:
That is correct.
17 COMMISSIONER GILINSKY :
--- but they wouldn't 18 meet the STA requirement as it is phrased 19 HR. THOMPSON:
Right, as it is phrased.
20 MR. CASE:
But there is another requirement 21 coming from emergency preparedness that you have to have 22 so many hands.
l 23 COMMISSIONER GILINSKY:
Like a minimum of 24 ten 25 MR. THOMPSON:
Correct.
l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554-2345
38 1
MR. CASES Yes.
So they would have to supply 2
somebody else to, and correct me if I am wrong, to 3
satisfy the hands requirement, and we require come 4
competence in that hand.
So he would have to be an 5
operator, a licensed operator.
6 MR. THOMPSON:
That is correct.
We would 7
propose in our review for those categories that the 8
acceptable approach would be that the individual who is 9
filling the dual role would be fully trained as the 10 shift technical adviser as well as being fully qualified 11 as an SRO and that we would except that they would have 12 an additional RO on shift to meet the emergency response 13 facility requirements.
(
14 MR. CASE:
So it is more or less approval with 15 a condition, and the condition being they have an 16 additional RO.
17 COMMISSIONER GILINSKY At least on an interim 18 basis that is a sore satisfactory situation than the 19 ones that are not meeting it.
20 MR. CASE:
Oh, yes.
21 MR. THOMPSON:
That is correct.
22 MR. CASE:
It may even be a long-term 23 solution, too, but that is for later on.
24 MR. THOMPSON:
That is right.
Generally I 25 think that the STA who is an SRO on shift is a more
~
ALDERSON REPORTING COMPANY,INC, 05@ VIRGINI A AV1, S.W., WA@HINGTONe D C. 8M84 (2@8) 990-2E49
39 )
1 effective individual.
2 COMMISSIONER GILINSKYa I agree.
The only i
3 problem is the extra hand problem, and I think it is 4
good to have the STA in -- (In a udible. )
5 MR. THOMPSON:
I am not sure if the utility 6
industry knew that that was a acceptable alternative 7
that they might be more in that catetory.
8 COMMISSIONER GILINSKY Well, we ought to find 9
out how things stand in these categories three and four, 10 whether there are any'others that could make it on that 11 basis.
But it is'important to have that extra person 12 there, that extra SRO in the control room and have the 13 other SRO available to get around the plant.
14 i You know what is troubling, and we have been 15 through this over and over again, it is going to be, a t 16 least the way we are going, it is going to be five years l
17 after Three Mile Island and no SRO in the control room, 18 before we are going to get an SRO in every control room 19 at all times.
I just don 't think that is very good.
20 MR. CASE:
The last ones are harder to get 21 th an the first 67 percen t.
I grant you that.
Another 1
22 way of saying the same thing is that we do have a 23 substantial number who do have right now -- (Inadible) 24
-- and it all depends on whether you are calling the 25 glass half full or half empty.
1 ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
40 l 1
COMMISSIONER GILINSKY Well, we oucht to 2
concentrate on these categories and see how many in fact 3
could comply on the basis that we have discussed here.
4 I mean, I don't know what to do about it.
We ought to 5
narrcv it down so we know ---
6 COMMISSIONER AHEARNE How, Hugh, were you 7
approaching this?.
8 MR. THOMPSON:
The approach that we would take 9
is to review those who have that proposal and evaluate 10 on a case-by-c:ase their situation; tha t is, do they have 11 the people in training, can they meet it with a second 12 SRA with an STA and if you use that approach, how are 13 you going to meet the hands requirement.
14 I think we are' committed to looking at each of 15 these responses to the 50.54 F letter and encourage the 16 utilties to make efforts to do this and to meet the 17 increased s ta f fing level as best they can.
Fo r example, 18 if you can ' t meet it on all shift and you can meet it on 19 the swing and the graveyard shif t, you know, and not 20 meet it on the day shift, then you are in a better 21 position than you would be because of the staffing that 22 you have available during the normal work week.
23 CHAIRMAN PALLADINO:
Do some of these 24 partially meet the re quire men t?
- 25 HR. CASE:
I d'on't think we can tell with the l
l l
ALDERSON REPORTING COMPANY,INC, 4@9 VtR@lNIA AM., @.W., WA%HIG3@?@% @.G. $$$M R@B1@@3fpKG_ _
41 1
information we have yet.
2 COMMISSIONER OILINSKYs Well perhaps they 3
could meet it on some -- (Inaudible).
4 MR. THOMPSON:
On some shifts, and the shift 5
that we would ---
6 COMMISSIONER GILINSKY:
I will tell you, I 7
think we ought'to get more formal about this 8
requirement.
Control room manning ought to be a formal 9
requirement, part of the Commission ---
10 CHAIRMAN PALLADINO:
We keep saying we are 11 studying the whole situation.
That is one of the 12 feelings I got over the last several days.
We are 13 studing this situation and we have all sorts of tIask i
14 analyses and somewhere around 1985 ve are finally going 15 to say here is what a control room cadre ought to be, 16 and this seems like a long ways off.
Yet, the utilities 17 are pleading for don't do it piecemeal, but tell us and 18 then we will go ahead and do it.
19 BR. THOMPSONs. We certainly can bring th e 20 Commission a specific rule addressing the second SHO.
21
'85 or '84 is an effort to establish the shole concept 22 of what the issue should be.
23 MR. CASE:
I tend to agree with the Chairman 24 now.
We are looking for something in the next year or 25 two where we can put out a rule, but in the meantime.I ALDERSoN REPORTING COMPANY,INC, 400 VIRGINI A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
42 1
would continue with this approach and get as much as we 2
can, and where there is any flagrant problem we would 3
bring it to the Commission's attention and do something 4
about it.
But in general it is our feeling that given 5
the exception request that we could work out ---
6 COMMISSIONER GILINSKYs There are just two 7
exception requests and those are alterna tives.
8 HR. CASE With the alternative proposal, 9
which we think we can buy with the Commission ---
to COMMISSIONER GILINSKY:
I guess what I would 11 like to know ---
12 ER. CASE:
What we generally feel is up to a 13 year beyond July 1,
1982 is not unreasonable.
t' 14 NH. THOMPSON:
Particularly if they make good 15 efforts to get their training 16 HR. CASE:
It is caregory four that we think 17 has to be worked on.
18 COMMISSIONER AHEARNE:
But you would have to l
l 19 look at what is the reason they are giving for the 20 one-year extension.
I recall that the July 1982 date 21 was set two years ago, and the reason it was set two 22 years ahead, as all of these phases, there was a 23 recognition it would be difficult to get there.
You 24 couldn't just instantly switch on.
The argument was 8
25' that it-takes time to identif y people and it takes time ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
43 1
to train SRos.
2 MR. CASE:
But what neither one of us took 3
into account is the pirating in the meantime that also 4
goes on.
5 COMMISSIONER AHEARNE:
Well,' wait.
Some 6
pirating is done because they want experienced people 7-and some pirating is done because they didn't want to 8
train them.
9 MR. CASE:
That is right.
But it is a fact of 10 life that I don't think people really took into account-11 when they 12 CHAIRMAN PALLADINO:
.The pool isn't large 13 enough I think.
14 COMMISSIONER AHEARNE:
Yes, but one of the 15 reasons the pool isn't large enough is that some 16 utilities just didn't go out and work hard at the 17 training.
l 18 MR. CASE:
They took the easy way out.
19 COMMISSIONER AHEARNE4 Now, unfortunately, 20 what this is going to end up doing is penalizing someone 21 like TVA who worked very hard to build a good training j
22 program and then is training them for the industry, as l
23 you say.
24 CHAIRMAN PALLADINO:
It is a little bit like l
l 25 - trying to run up a stairway that is moving downward.
ALDERSoN REPORTING COMPANY. INC.
400 VIRGINIA AVE., S.W WASHINGTON. D.C. 20024 (202) 554 2345
44 1
(Laughter.)
2 3R. CASE:
But when I said the one year, 3
Commissioner Gilinsky, I meant assuming that there have 4
been goed faith efforts and they have been trying and 5
th ey have run into unforeseen difficulties, th a t up to a 6
year beyond July 1,
'82 did not seen unreasonable to 7
us.
Given the other things then, we are left with this 8
category four which we think are the tough nuts to do 9
something about and we would try as best we can in 10 talking to them to move up their date.
If we got to a 11 position where they didn't want to do it, then I think 12 we have to consider orders.
13 COMMISSIONER GILINSKY:
Why not lay down a 14 requirement.
You know, you have this problem of being 15 informal -- (Inaudible).
16 HR. CASE:
I thin we are just looking at one 17 of the 100 or whatever the number is of TMI requirements.
18 COMMISSIONER GILINSKY:
But you are talking 19 about continuing to be informal ---
20 CHAIRMAN PALLADINO:
Is that right?
I thought 21 You were looking at the ---
22 COMMISSIONER GILINSKY:
It would assume they 23 met the requirements?
l 24 HR. CASES No.
We will confirm those who meet 25 the requirement by a confirmatory order and therefore ALDERSON REPORTING COMPANY. INC, 400 '/lRGiNIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
IS 1
put it in their tech. specs. that it is a commitment, a 2
legally binding commitment.
3 COMMISSIONER GILINSKY:
When would you do that?
4 MR. CASE:
As soon as we get through reviewing 5
all this pile of thinor and deciding where we are going 8
to ---
7 MR. THOMPSON:
We would anticipate to be in a 8
position to come down to the Commission with our 9
proposed orders for each individual plant covering this to and other of the items covered in the May 5th letter in 11 six to eigh t weeks.
12 COMMISSIONER ASSELSTINE:
In other words, for 13 those people that say that they will meet the
(
14 requirement voluntarily you will leave it voluntary?
15 COMMISSIONER 90BERTS:
No, that is not what he 16 is saying.
17 MR. CASE:
No.
18 MR. THOMPSON:
No, sir, it will be a binding 19 requirement.
20 COMMISSIONER ASSELSTINE:
For everyone.
21 COMMISSIONER AHEARNE:
It goes into their 22 tech. specs.
23 CHAIRMAN PALLADINO:
But if somebody says they k_
24 can do it in five months are you going to say now your 25 tech. specs. will say you will do it in five months?
ALDERSON REPORTING COMPANY,INC, 400 V: AGINA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
46 I
1 MR. TH3MPSON:
That is the present proposal.
2 CHAIRMAN PALLADINO:
Is somabody says they 3
will do it in a yea r, and you feel it is okay, their 4
tech. specs. will say a year?
5 MR. THOMPSON Yes.
6 CHAIRMAN PALLADINO:
If somebody says well, I 7
need 18 months, you may come back and say do it in a 8
year?
9 MR. THOMPSON:
We have may a show-cause to order ---
11 CONMISSIONER GILINSKY:
Isn't this precisely 12 the sort of situation that you have rules ---
13 MR. THOMPSON:
Correct, precisely the quoted
(-
14 situation.
That is correct.
15 COMMISSICNER GILINSKY:
Why don't we have a 16 rule?
17 MR. CASE:
As I said, we came down and 18 recommended that to the Commission and they said no, we 19 vant more fle xibility.
20 COMMISSIONER GILINSKYa Well, okay 21 (Inaudible).
22 (Simultaneous voicec -- (Inaudible).
23 CHAIRMAN PALLADINOs I think there is value in i_
24 flexibility.
I think this proves tha t we need some 25 flexibility because there are a number of these that I ALDERSON REPORTING COMPANY,INC, 48D VIA@lNI A AV@.. @.W., W A@HIN@T@N. @.@. Rg6R4 (rwa $13&42
9 47 1
believe have made good faith efforts.
Ne w th e re a re 2
some of them that 3
COMMISSIONER GILINSKY:
You can always make 4
exceptions to the requ_rements of a rule, but the rule 5
has a little extra umph to it.
6 CHAIRMAN PALLADINO:
Well, for the 0737 items 7
I think with operating plants ---
8 COMMISSIONER AHEARNE:
The fire protection 9
rule.
10 CHAIRMAN PALLADINO:
--- that case-by-case 11 attention is ---
12 MR. CASE:
(Inaudible) l l
13 MR. THOMPSONa Well, I propose it would be ---
i' 14 CHAIRMAN PALLADIN0s Do you have to come down 15 here and ask the Com.nission for approval in each 16 specific case?
17 MR. CASES No, we would bring the whole bunch 18 down.
19 MR. THOMPSON:
We would bring a whole package 20 of the responses for Phase IV implementation of 21 NUREG-0737 for operating plants.
22-MR. CASE:
I am not sure this has gotten 23 th ro ugh.
It will include this one, but all of the other 24 NUREG-0737 requirements that were supposed to be 25 implemented by July 1,
'82, what the licensee has said ALDERSON REPORTING COMPANY,INC, 400 VIRGINI A AVE.. S.W WASHINGTON. D.C. 20024_1202) 554-2345
4R 1
they are going. to do and what we intend to de about it.
2 COMMISSIONER ASSELSTINE:
So in essence there 3
will be a proposed binding requirement and enforceable 4
requirement for all of those items.
5 MB. CASES Yes.
6 3R. TH0dPSON:
That is correct.
7 COMMISSIONER ASSELSTINE:
And once we sign off 8
on that package, then you have got something 9
CHAIRMAN PALLADIN0s But what worries me is to you coing to send, and I don't know how many 11 requirements you are talking about 12 MR. CASE:
Ten.
13 CHAIRM AN P ALLADIN0s Ten, and then you are i
14 going to have a whole series of different dates for each 15 one.
I just wonder, do you have to wait until all of
~
16 them are ready before you settle one of them?
I could 17 just see a multitude of different dates kind of.
18 MR. THOMESON:
Well, one of the proposals we 19 could evaluate in detail is having kind of a fixed date 20 at the end where nobody exceeds that date.
21 MR. CASE:
I think it is probably easier for 22 the Commission rather than doing this ten times ---
23 COMMISSIONER ROBERTS Well, th e ten items 24 ha ve difficulties with compliance with the nine others.
25 MR. CASES I don 't know, but I would guess it ALDERSON REPORTING COMPANY,INC, 400 V!AGINIA AVE., S.W WASHINGTON, O C. 20024 (202) 554-2345
49 1
is about the same.
2 CO3MISSIONER GILINSKY:
Those are nine other 3
meetings.
4 (Laughter.)
5 (Simultaneous voices -- Inaudible).
6 (Laugher.)
7 COMMISSIONER GILINSKY:
I think a rule is 8
fairer to licensees, too.
We put out a rule, they get 9
to comment on the rule and then we act on it.
10 MR. MURRAY:
That is correct.
11 MR. BICKWIT:
I think to have a full 12 discussion of the alternatives here that it would be 13 better to close the meeting.
(
14 CHAIRMAN PALLADINO:
But Vic is having so much 15 fun.
16 (Laughter.)
17 MR. BICKWIT I think you can go all the way 18 to the question of how are we going to make these 19 binding in open session, but once you get into that, to 20 have a thorough discussion, I think you should close the 21 meeting.
22 CHAIRMAN PALLADINO:
Well, before we address 23 that, are we going to go any farther in this?
You say
(
24 you are coming back with a proposal.
25 MR. THOMPSON:
That is our present plan, to ALDERSON REPCRENG COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
50 1
come back with a proposal with respect to each of these 2
categories and each item by each utility in about six'to 3
eight weeks.
4 MR. CASES If the Commission really thinks 5
this one is more important and ought to be handled 6
se pa ra tely, we obviously can do that.
7 COMMISSIONER GILINSKY:
It seems to me it is a 8
lot simpler for you to deal with it on the basis of a 9
rule.
10 MR. CASES I am not talking about a r61e.
I 11 am talking about dealing with this one item separate 12 from the other ten that are due July 1,
'82.
13 COMMISSIONER GILINSKY I guess I haven't 14 gotten to the other nine, but I think this one is very 15 important.
16 HR. THOMPSON:
5e could ' also come down with a 17 rule fairly promptly.
18 MR. CASES I must say about a rule that the 19 time has passed.
We should have decided that two years 20 ago.
If you try to develop a rule now, it will take a 21 while to develop it and you have got to go out for 22 comment and you won't be in an enforreable position for 23 a year from now.
24 COMMISSIONER ASSELSTINE:
What dc you do?
Do 25 you take the lowest common denomina tor as the deadline ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
51 1
for compliance?
2 COMMISSIONER AHEARNE:
Good try, Len.
3 (Laughter.)
4 MR. BICKWIT:
I would like to make an argument 5
for deferring the program.
6 (Simultaneous voices - Laughter - Inaudible) 7 CHAIRMAN PALLADINO:
What is that?
8 MR. BICKWIT:
I would like to respond to that, 9
but I am Waiting until the Commission focuses on my to recommendation to close the meeting.
11 (Laughter.)
12 CHAIRMAN PALLADINO Well, I was wondering 13 whether we had to close it.
14 COMMISSIONER AHEARNE:
Well, I think if we are
~
15 going to continue on this track I would go with Len.
16 CHAIRMAN PALLADINO:
Well, I don 't know what 17 track.
18 COMMISSIONER AHEARNE We keep on asking more 19 questions ---
20 CHAIRM AN PALLADIN04 I though t we were a t the 21 point where we were being asked do we want to take this 22 up as a separate item.
23 MR. BICKWII:
To have a thorough discussion of k
24 that question I think we should close the meeting.
I 25 recognize though this is somewhat cryptic ---
ALDERSON REPORT NG COMPANY,INC, 400 VIRGINIA AVE., S W WASHINGTON, D.C. 20024 (202) 554 2345
52 1
(Laughter.)
2 MR. BICKWIT:
That is the problem with the 3
Government in the Sunshine Act.
4 CHAIRMAN PALLADINO:
Are there any other 5
aspects of this report that are in the open?
6 MR. THOMPSON:
The only other aspect I 7
th o ugh t, and I don 't know if we have gone though the 8
category two, I think I have dicussed it briefly, for 9
those who would propose to combine the second SRO and 10 the STA type positions, no one has yet suggested tha t 11 they would voluntarily put an additional pair on hands 12 on shift, but that would be one of our considerations in 13 evaluating that proposal.
14 COMMISSIONER AHEARNE:
Where would they see 15 the clear requirement or description criterion that they 16 need ten people on shift?
17 MR. THOMPSON:
I believe that is included in 18 NUREG 0654.
Shelly Schwartz of the ICE staff can 19 comment on that.
20 CHAIRMAN PALLADINC:
You say it is in that 21 NUREG, but is it a requirement?
22 5R. SWARTZ:
Shelly Schwartz with the IEE 23 staff.
In Darrell Eisenhut's 81.10 letter it amended l
i 24 0737 and Table B-1 was included in 0737 which says that 25 there are ten.
It calls for ten in 0737.
l l
l ALDERSON REPORTING COMPANY,INC, C@@ VIRGINIA AVE., S.W., WA@HIN@T@N @.C. f61 M4 (T&a Gb~t346Ji
)
53 1
MR. CASE:
(Inaudible) in terms of 2
competence.
So it is clear that it has to be an RO, f -
3 this extra pair of hands?
4 MR. SCHWARTZ Yes.
It says the SS, the shift 5
supervisor, and it says foreman, and I don't remember 6
precisely what that table says, but it runs down all the 7
items that were previously in the 0737 for the licensed 8
operators, including the STA, and also adds the 9
communicator, the HP tech. and the rad. chem. tech.
10 CHAIRMAN PALLADINO:
So if it is in 0737 11 presumably it has Commission blessing.
12 MR. SCHWARTZ:
That is correct, sir.
13 CHAIRMAN PALLADINO:
And it is clear.
(
14 HR. SCHWARTZ Yes, sir.
15 MR. THOMPSON:
And I believe that is one of 16 the items that is also included in the May 5th 50.54 F 17 letter.
18 COMMISSIONER ASSELSTINE:
But again it is not 19 a requirement.
20 MR. THOMPSON:
That is correct.
It is in the 21 same category th a t the 1813 item is.
22 CHAIRY.AN PALLADINO:
Are there other open 23 items?
24 MR. THOMPSON:
The final item would be that I 25 just want to identify some of the items that we would be ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 2'0024 (202) 554 2345 f
54 1
1 evaluating and making our recommendation if we were to 2
go on the case-by-case reviews and evaluating the 3
extension past the existing dates.
That is the firm 4
commitment that they have to have the second SRO on 5
shift, that they have identified a reasonable target 6
date, that they have an active recruitment program, that 7
they have recognized that the training program has to 8
have a sufficient number of people in there in order 9
achieve the success and that their training program is 10 adequate such that when the people come up to take the 11 examinations there is some expectation that the large 12 majority of the people will actually pass and be found 13 acceptable ---
14 CHAIRMAN PALLADINO:
Do you have some criteria 15 on what fraction they should assume would pass it?
16 MR. THOMPSON:
Well, we would be talking 17 somewhere around 30 percent failure rates right now, 18 recognizing that the attrition rate that the current 19 exams experience as well as recognizing the fact that
{
20 people do leave on their own when other opportunities 21 are made available to them.
So I think those are the l
l 22 ones we would be usine to evaluate it.
23 COMMISSICNER GILINSKY:
Let's see, if a 24 utility does not have a reasonable and sensible program 25 you would do what?
i l
ALDERSON REPORTING COMPANY. INC, 400 MAGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554 2345
55 1
MR. CASE:
Close the meeting.
2 (Laughter.)
3 CHAIRMAN PALLADINO.
We will come back to that 4
question.
5 All right, go ahead.
6 MR. THOMPSON:
That is essentially all of it.
7 I was going to indicate at one time that there were two 8
options, to do it by the order or by rulemaking, but I 9
think that 10 (Simultaneous voices -- Inaudible) 11 (Laughter.)
12 CHAIRMAN PhLLADINO:
No, options to formally 13 impose staffing level ---
14 MR. THOMPSON:
Item No. 1 was to include it in 15 the regulations, which is 10 CFR 54, or the other one 16 was to issue the orders, and in most cases it would be t
17 confirmatory orders a nd you may need show-cause orders 18 in certain cases.
19 CHAIRMAN PALLADINO:
Are there any further 20 questions that should be addressed in the open meeting?
21 (No response.)
22 CHAIRMAN PALLADINO:
Okay.
Then I guess we 23 vill recess while the room is cleared of vistors and go 24 into closed session.
25 Oh, I am sorry, do we have to get a vote?
l l
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554-2345 _ _
56 f
1 HR. BICKWIT:
Yes.
2 CHAIR 5AN PALLADINO:
Excuse me, I guess we 3
have to have a vote whether we are going to go into 4
closed session.
5 MR. BICKWIT:
You need a vote before ycu can 6
do it and you can do it after the recess.
7 CHAIRMAN PALLADINO:
Do you want to vote now?
8 (Discussion off the record. )
9 CHAIRMAN PALLADIFO Let's first vote to see to if we are going to go into closed session.
11 All those in favor of going into closed 12 session say Aye.
13 COMMISSIONER AHEARNE:
Aye.
/
14 CO3MISSIONER ROBERTS:
Aye.
15 COMMISSIONER GILINSKYs Aye.
16 COMMISSIONER ASSELSTINEa Aye.
17 CHAIRMAN PALLADINO:
I would also urge that we 18 try to do the closed session in 20 minutes or less.
19 We vill recess for five minutes while we clear 20 the room.
21 The meeting is adjourned.)
22 (Whereupon, at 11:58 p.m.,
the meetinc 23 adjourned.)
24 25 ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE. S.W., WASHINGTON, D.C. 20024 (202) 554 2345
m W'M 3EWimEt CCWJ5 3 This is to ca.mif7 that the attached pecceeding: 'cefers the s.
i' COMMISSION MEETING in the ::sttar cf:,
Public Meeting - Discussion of Status of Shift Manning Requirements U4U4 cf Frcceedisg:
June 11, 1982 Occket llul:Wer:
Flace cf Frcceedisg:
Washington, D. C.
aors held as hers1: appears, anc tha'c. this is the criginal t:-azscrs thersef fc:
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AND DESCRIBEPLANNEd STAFF ACTIONS 1
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BACKGROUND INFORMATION NUREG-0585 "TMI-2 LESSONS LEARNED" NUREG-0660 "NRC ACTION PLAN" 5
STATEMENT OF ON-SHIFT STAFFING LEVELS JULY 31; 1980 LETTER FROM D. EISENHUT
~
.NUREG-0737 ITEM I.A.l.3 (OCTOBER 31, 1980)
-NUREG-0737 AMENDED BY GENERIC LETTER 81-10 (FEBRUARY 18, 1981)
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~
o MORE STRINGENT EXAMS PROPOSED ALTERNATIVE STAFFING ARRANGEMENTS
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