ML20054F869
| ML20054F869 | |
| Person / Time | |
|---|---|
| Issue date: | 06/14/1982 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8206180048 | |
| Download: ML20054F869 (85) | |
Text
.
fg NUCLEAR REGULATORY COMMISSION l'
(
POD"TlI{#
wJ\\L1.,$frL6 COMMISSION MEbTING
{-
l In the Matter ef:
PUBLIC MEETING DISCUSSION AND POSSIBLE VOTE ON SECY-82-111 REQUIREMENTS FOR EMERGENCY RESPONSE CAPABILITY c
~
DATE:'
June 14, lh82
? AGES:
1 - 83 AT:
Washington, D.
C.
I ALDERSOX ' *t REPORT 1.TG C
400 virginia Ave., 5.W. Washing =n, D. C.
20024
(,
Telechene : (202) 554-2245 8206180048 820615 PDR 10CFR PT9.7 PDR
1
/
1 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
,7 4
DISCUSSION AND POSSIBLE VOTE ON SECY-82-111 5
REQUIREMENTS FOR EMERGENCY RESPONSE CAPABILITY 6
7 PUBLIC HEETING 8
9 Nuclear Regulatory Commission Room 1130 10 1717 H Street, N. W.
Washington, D. C.
11 Honday, June 14, 1982 12 The Commission met, pursuant to notice, at 13 10:33 a.m.
(
14 BEFORE:
15-NUNZIO PALLADINO, Chairman of the Commission VICTOR GILINSKY, Commissioner 1.6 JOHN AHEARNE, Commissioner THOMAS ROBERTS, Commissioner 17 JANES ASSELSTINE, Commissioner 18 STAFF AND PRESENTERS SEATED AT COHNISSION TABLES 19 S.
CHILK L. BICKWIT 20 F. REMICK Y. STELLO 21 D. DeYOUNG E. CASE 22 AUDIENCE SPEAKERS 23 R. HATTSON
(
24 H. THOMPSON B. GRIMES 25 J. SCINTO ALDERSON REPORTING COMPANY,INC, dQ0 VEY61MV3 QWL ELPJM/M00lKMT@N, @.C. >TRiR4 M5P3 523613-3
~~
o em
('
t DISCLAIMER This is an unofficial' transcript of a meeting of the United States Nuclear Regulatory Commission held on ame i4. 1992 in the Cocanission'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 informational 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.jteliefs.
No pleading or-other paper may be filed with the Commission in any proceeding as the result of or addressed to any'orize.
statement or argument contained herein, except as the Cournission may auth 4 e a
md
o 2
? E'9 G E E D 1 2 G E 2
CHAIRMAN PALLADINO:
The meeting will please 3
come to order.
4 We are meeting this morning to discuss with 5
the staff its proposed recommendations concerning 6
emergen cy response facilities.
The Commissioners have 7
previously been briefed on this matter on April 15th.
8 The purpose of this morning's meeting is to 9
allow further discussion of the issues that any of the to Commissioners may still ha ve.
11 So unless the Commissioners have some other 12 opening remarks, I suggest turning the meeting over to 13 Br. Dircks.
14 BR. DIRCKSa We have got.no prepared remarks.
15 We are here basically to answer questions.82-111 is 18 the approach we suggested and the offices are here, the 17 affected offices, and I want to stress again they are 18 fully supportive of this approach.
19 CHAIRMAN PALLADINO Who wants to start with 20 questions?
21 COMNISSIONER GILINSKYa I will start.
22 CHAIRMAN PALLADINO:
Well, let me ask a
(
23 question about the backing away from control room l
l 24 redesign.
There is an indication in some of the 25 correspondence that this is what the staff seems to be ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554-2345
3 1
doing.
Do we have any assurance that we are not backing 2
away from control room redesign?
3 HR. STELL0s Well, let me answer it.
With 4
respect to the emphasis that we have placed on this when 5
ve covered this the last time, it is our view that we 6
are not backing away from emphasizing human factors 7
elements.
We are going to get involved in control room 8
design reviews.
9 The perception that we are backing away, I 10 don 't know how you deal with it.
I think the only to 11 demonstrate that that is not the case is to'get on with 12 it and show by our action that we are in fact as 13 sensitive and aware of the need to take into account 14 human factors in the process.
I don't think that until 15 ve do that that question of perception vill be with us.
16 CHAIRHAN PALLADINO:
What I was looking for 17 was some action or plan that you have in process that 18 would give us assurance that you are not backing away
/
19 from it.
20 HR. DIRCKS:
I think we could pull 21 something 22 HR. CASE:
There is a plan described in 82-111, 23 COMMISSIONER AHEARNE:
Well,82-111 does not 24 really do much in the var of describing the plan we are 25 going to follow.
I found that Hugh's presentation to ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON. D.C. 20024 (202) 554-2345
4 1
the ACBS was much more explicit on the plan we were 2
going to follow.
At least my recommendation would be 3
that the elements of the presentation that Hugh Thompson 4
gave to the ACRS should be included in the document 5
since that apparently is what the NRC does intend to 6
follow in the way of doing the review of the control 7
room design reviews.
8 HR. THOMPSON That is correct.
That is the 9
plan we intend to follow and we have no problem from my 10 veivpoint of incorporating those steps.
We though t th a t 11 they were called for, maybe not explicitly, in 82-111.
12 COMMISSIONER AHEARNEa As OPE pointed out in 13 their memorandum, the evaluation critsria for the 14 detailed control room design review are specified in 15 NUREG 0801.
The extent of staff review of licensees' 16 design reviews appears to have been changed by the staff 17 proposal.
0801 indicates the staff will evaluate each 18 licensee's program plan.
The staff proposal is silent l
19 on this aspect.
20 I realize the approach now is not to do that 21 equivalent evaluation of every program plan certainly in 22 the detail that was originally proposed, but 23 nevertheless as I read through what you had listed to 24 the ACRS, at least from my point of view, I found a lot 25 more substance available by just reading that than I ALDERSON REPORTING COMPANY,INC, 4@@ VIR@iNI A AVL @.W, WC@HIN@T@N. D.C. 85@84 (858 @@3-8DO@
5 1
would have gotten out of the 82-111.
2 CHAIRHAN PALLADINO:
Are you suggesting that 3
some of that be put in here?
4 COMMISSIONER AHEARNE:
Yes.
I am suggesting 5
the list of steps that NRR had presented tc ;he ACRS, 6
which I think was part of the reason that the ACBS then 7
came back with a very f avorable letter saying that.ther 8
had no problems with this approach.
9 I think that they had had a pretty good 10 description presented to them of what NRR actually. vas 11 going to do and I think that that ought to be then 12 incorporated into the 82-111 document.
13 COHEISSIONER GILINSKYa Can. you get more 14 specific?
15 COMMISSIONER AHEARNEs Well, page 4 of my 16 meno and page 5.
17 (Laughter.)
18 COMMISSIONER GILINSKY:
That wasn't the 19 question.
1 20
. ( Laug h t e r. )
21 CHAIRHAN PALLADIN0s Hay I just ask you what 22 it is that we are putting out?
Is this a policy 23 sta t tment?
What is the document because it might 24 influtence how much detail we want to get into.
l 25 HR. STELLO:
The intent of the document was to ALDERSON REPORTING COMPANY,INC, l
400 VIAGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554 2345
6 1
put fo rth the requirements that would be imposed on the 2
licensees and it did not go into any detail on how the 3
NRC would go through its procedures in following the 4
implementation of those requirements.
I an using the 5
word " requirements" now because there is another comment 6
and I recognize what we are intending to do is to follow 7
the implementation scheme to make the requirements.
8 CHAIRMAN PALLADIN0s But what is it we issue, 9
the Commissioners, or don't we issue anything?
10 MR. STELL0s If the Commission approved this 11 piece of paper, the next step in the process would be 12 NRR vould issue letters that would tell the licensees to 13 develop the schedules to implement these requirements r
14 and they would come forward. with the schedules.
~
15 Following that process would be one of a variety of ways 16 in which to then make these into requirements by license 17 amendment, confirmatory order or some other vehicle.
18 It was not intended to go through the details, 19 but I don't have any problem in adding the presentation 20 th at you made to the ACRS that describes how we are 21 going to do our part of it.
22 CHAIRHAN PALLADINO:
Or a summary thereof.
23 HR. STELLO:
Or a summary.
I don't see any 24 difficulty in adding it and to the extent it provides 25
. helpful information it certainly is worth it.
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
)
L<
i
^
7l ll r
1 COMMISSIONER AHEARNE:
Vic or Bill, had you 2
intended to publish this?
This is the enclos're to u
3 82-111 en ti tled "NRC Staf f Recommendations On i
4 Requirements For Emergency Response Capability.".
5 HR. DIRCKS4 I don't think we v'ere coing to 8
publish that.
I think this served'only as the basis ~for 7
initia ting those 50.54 F letters.
8 COMMISSIO!!2R AHEARNE:
I guess my 9
recommedation would be that you do publish it as a 10 NUREG, and the reason is quite simply.
People who are 11 out in the field doing these kinds of reviews or 12 discussing doing them or thinking about doing 'them have 13 been using this document as this represents now the new I
14 direction on the encapsulation of the direction the NRC 15 is taking.
I think it would be useful to put it into a 18 document.
I think that would serve a couple'of
~
17 purposes.
18 Now, one, it would at least make sure 19 everybody has the same set of information, and, second, 20 the procedures are a puzzle right.at the moLent as to 21 what is this.
Is it a set of requirements or is it a 22 description the direction the'NRC has to go?
23 Your presentation I believe calls it the 24 latter, because to make it a set of requirements, there 25 are other steps that are necessary.
If you publish it
{
l i
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
8 1
1 as a NUREG, that also would be clarified.
4 2
HR. DIRCKS:
Of course, you know NUREGs have 3
given us problems in the past in that people look at 4
these things and interpret the in various ways.
j 5
COREISSIONER AHEARNE:
Well, but I was also 8
going to recommend that you incorporate the paragraph 7
OGC had recommended incorporating into the beginning of 8
that that I think clarifies it.
9 HR. DIRCKS Sure, NUREG is one wa y.
The real to action enforcing mechanism was these 50.54 F letters 11 that say here it is and now come back to us with a 12 schedule and an approach.
NUREGs have tendencies of 13 being videly distributed and being interpreted
(
14 differently by various sectors.
If we could issue it as s
15 some sect of a management directive to the directors of 16 the two offices, maybe that is one approach.
17 CHAIRMAN PALLADINO:
What other ways do you 18
.have of publishing information?
19 HR. DIRCKS4 That was my hang-up here.
I.vas 20 fishing for a tern like management guidance as something 21 to be used and holding it within the agency and letting 22 the offices then move within ---
23 COM3ISSIONER AHEARNE:
But, Bill, you have to 24 realize this is not held within the agency.
It has been 25 distributed.
't ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W.. WASHINGTON, D.C. 20024 (202) 554-2345
f 9
~
n 1
CHAIRMAN PALLADINO:
Is your problem calling 2
it a NUREG?
3 HR. STELLO:
Let me tell you about a problem 4
that I see.82-111 is a distillation of a whole variety 5
of NUREGs where we extracted -f rom those those things 6
which we felt were the important issues to be made into 7
"re quire me n ts. "
8 COMHISSIONER AHEARNE:
Correct.
9 MR. STELL0s To now publish it as a NUREG it to becomes some super-NUREG, which is a distillation of a 11 lot of other NUREGs and it just proliferates the use of 12 NUBEGs in a way which I think is inappropriate.
Given 13 enough time with the issues, the proper time to have 14 done this would have been to formulate a regulation and 15 issue it as a Commission regulation.
16 Now the intermediate position that we can tak e 17 is to issue the 50.54 F letters, attach this as here is 16 what the Commission proposes to move forward with and 19 then get the responses and cause them to become l
l 20 requirements.
l 21 Now I recogni:2 it would be nice to have l
22 another number put on it either as Reg. Guide or as 23 NUREG, but I think we are in a transition period of 24 trying to decide how to m'ove forward with the Commission 25 stating its policy and its guidance.
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON. D.C. 20024 (202) 554-2345
10
(
1 COMMISSIONER AHEARNE:
I don't take exception 2
to anything you said, Yic.
I would just expand a little 3
on it.
OGC was concernad about this question of how 4
this would be interpreted and that is why they in an 5
exchange of menos ended up with a paragraph which I 6
believe they felt would satisfy that particular problem 7
of how to interpret this.
8 Unf ortu na tely, at the moment what you have, 9
though, is you have a very uncertain situation as to 10 what direction is the Commission going.
The only thing 11 the Commission.has seen is this.
Previously it had seen-12 a lot of the documents that this supersedes, and I think 13 it is fair to say that this really supersedes and 14 modifies the direction or suggested direction of several 15 of the other documents.
After all, that is the purpose 16 of it.
I 17 CHAIRMAN PALLADIN04 That is correct.
18 C05MISSIONER AHEARNE:
The Commission has 19 spent a fair amount of time reviewing this particular 20 document, and if we approve the direction you propose it 21 is this document that we are using as that basis.
All 22 of that leads me to believe that it is fairly important 23 to p'ut this document out in some fashion other than it s
i 24 is enclosure one to a SECY paper.
25 COMMISSIONER GILINSKY:
As a requiement?
l l
l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
11 1
COMMISSIONER AHEARNE:
No.
That is why we 2
call it a NUBEG.
That would be called a NUREG and that 3
would put in this paragraph that OGC came up which would 4
make it clear it is not a requirement.
It is a 5
description of the direction that the NRC is going in 6
pulling together this areas, but requirements are going 7
to have to flow from some other actions.
8 COMMISSIONER GILINSKY What is the objection 9
to. tha t?
10 MB. STELLO:
Well, I stated that the' document 11 82-111 pulls from a variety of NUREGs those things which 12 are felt and believed to be significant important issues 13 for which it is intended, consistent with the way in 14 which it is described in the OGC paragraph, to cause 15 those to become requirements.
If we use a NUREG with 16 special significance, then I suppose there is nothing 17 vrong with it.
18 CONNISSIONER GILINSKY But isn't it?
I mean, 19 you have pulled things out of various NUREGs that you 20 think are important.
So it does have special 21 significan ce.
22 MB. DIBCKS:
I think we are just expressing 23 some problems that we have had in the past with NUREGs, 24 and, true, we can put this special disclaimer on it.
I 25 think we were very pleased with ourselves recently when ALDERSON REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
12 l 1
ve said that no more NUREGs that would contain anything
'ure, we can 2
that would be interpreted as requirements.
S 3
issue this and say it is not a requirement and look at 4
the OGC disclaimer, but NUREGs have had a tendency to.
5 take on a life of their own and people vill start waving 6
NUREG, whatever this may be, and say you do it because 7
NUREG srch and such says so.
8 CHAIRMAN PALLADINO:
If there a way for tne 9
Commission to issue something like a policy guidance 10 document to get away f rom a NUREG?
11 COMMISSIONER GILINSKYs That has even more 12 force ---
13 COMMISSIONER AHEARNE:
That is right.
t 14
( La ugh te r. )
15 COMMISSIONER AHEARNE:
A NUREG is not a 16 regulatory g.11d eline.
It is a lesser category 17 CHAiEMAN PALLADINO:
I appreciate that.
I was 18 looking to see if there is a way the Commission ---
19 ER. DIRCKSr That is what I was fishing for, 20 too.
21 COMMISSIONER GILINSKY:
Nov vithout something 22 like this aren 't we just at sea?
What are people 23 supposed to be guided by?
24 MR. DIRCKS4 Well, they shouldn't be guided by 25 anything but the 50.54 F letters that will issue forch-
~
~
ALDERSON REPORTING COMPANY,INC, 400 V1RGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
13 1
from this decision.
2 COMMISSIONER GILINSKY:
And these are going to 3
come from the 70 project managers or 100 project c
4 managers?
5 MB. DIRCKS:
No.
I would hope they would come 6
from the Office of Nuclear Reactor Regulation.
7 COMMISSIONER GILINSKYs Well, each'one is a
coing to be different though.
9 MR. DIRCKS:
Yes, but subject to management 10 review.
I would hope that we could have the NRC 11 management look at the guidance that is being issued and 12 then give that guidance to the various project managers.
13 COMMISSIONER GILINSKY:
What is the problem 14 tha t we are solving with the document that you want to 15 put out?
We had, for example, in the occasion of 16 emergency reponse f acilities a more detailed guidance 17 document and a lot of people went off and started 18 building and acting on the basis of this NUREG.
19 What is the problem that we have run into that 20 causes you to want to go in the direction that you have 21 recommended?
22 MR. STELL0s There are two parts to the answer.
23 The first one is there are a number of issues 24 that are not yet decided on in terms of whether or not 25 licensees are required to have such as the SPDS.
It has ALDERSON REPORTING COMPANY,INC, 400 VIRGINTA AVE., S.W WASHINGTON 0.C. 20024 (202) 554-2345
14 I
1 not yet been made or either the industry been told that 2
they are to in fact put in something like an SPDS.
The 3
same is true for the control room design review, and I 4
believe the implementation of the emergency operating 5
procedures, the plans.
6 COMMISSIONER GILINSKYs These are additions, 7
so to speak?
8 HB. STELLO:
Yes.
They are additions to the 9
documen ts that you were referring to.
10 The second part of the answer is.to try to go 11 through those documents, which are guidance documents, 12 and distill.from them what are really the requirements 13 in those documents.
What is it that the utility ought l'
14 to understand he is required to do.81-111 deals with 15 the answer to both parts of the question.
16 COMMISSIONER GILINSKY Well, let's take 17 something like an emergency operations facility.
- This, 18 I gather, has fairly detailed guidance on something like 19 this.
20 HR. STELLO:
That is correct.
21 COMMISSIONER GILINSKYs Your document is very, 22 very general statement.
Now how is someone who is 23 building a facility going to know what to do?
In fact, 1
l 24 I was just at a plant where they were a bit chagrined.
25 They had gone and built something or they more or less l
l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
15 j 1
fixed on a design of this sort and now discovering that 2
ve are backing off.
You know, what is it that we are 3
doing they asked, and I didn't know.
4 HR. STEL10s Well, that document that you have 5
is not a document which sets for the requirements.
It 6
is guidance.
7 CONHISSIONER GILINSKYa Yes.
8 HR. STELL0s Nov which parts of that document 9
ought to be taken out and made a requirement?
That is 10 what 82-111 tries to deal with.
11 COMMISSIONER GILINSKY:
But you come down to 12 very little and, from what I gather and correct me if I 13 am wrong, we are going to inspect the facilities after 14 they.have built them.
15 HR. STELL04 Partially that is true.
There is 16 some review and evaluation before and some af ter.
17 CONNISSIONER GILINSKYs. But I have to say I 18 get the impression we are letting this thing go.
Ther 19 can build practically anything and we are going to go 20 look at it afterward and we are not going to make then 21 rebuild something af ter they have built it.
22 Now if this guidance wasn't quite right, there l
23 ought to be some different guidance.
But to leave.the 24 thing in a very general state, and now maybe I don't 25 understand it.
Is it that the project manager is going i
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
16 1
to sit down with these people and lay out the specific 2
guidance which is comparable to this guidance for that 3
facility?
4 HR. CASES The project manager is going to 5
deal with the schedular aspect of these things.
That is 6
his function is to work out a schedule that is generally 7
consistent with what is in 82-111 and is consistent with 8
the licensee's ability to do the schedule working in 9
conjunction with all the other things that he has to do.
10 COMMISSIONER GILINSKYa Let's just take that 11 one.
What is it that a licensee has to do for an EOF?
12 I have done here on page 22 their recommended 13 requirements.
14 ER. STELLO:
Part of the problem, whether ther 15 call then recommended or anything else, deals with the 16 issue of making them requirements as part of this 17 process that I described.
I 18 The requirements, or what we are suggesting in l
19 82-111 be the requirements, are the items that are set 20 forth on page 22 that you described.
It tells where 21 this is located.
22 CHAIRMAN PALLADINO:
If we approve this, then 23 would these be included in the 50.54 letter?
24 MR. STELL0s Yes, they would be.
25 CHAIRMAN PA1LADINO:
Would the 50.54 letter be ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554 2345
I 17 1
almost as long as your enclosure two?
2 HR. STELL0s It would be an attachment.
This 3
document is an attachment to the 50.54 letter.
4 CHAIRHAN PALLADINO:
Where it says the 5
recommended requirements you would say they are nov 6
requirements?
7 HR. STELL0s After the licensee responds he 8
would set forth the schedule of when he would do these 9
things consistent with these requirements and then that 10 would be made a legal binding requirement of the 11 licensee through one of a variety of mechanisms.
12 CHAIRHAN PALLADIN0s But what I was getting at 13 is I presume the word " recommended". here means to the 14 Commissioners; is that right?
15 HR. STELLO:
Well, it is recommended to the 16 Commissioners and it is recommended ---
17 CHAIRHAN PALLADINO Once we approve it, then 18 do these become requirements?
19
- COMMISSIONER AHEARNE No.
20 HR. STELL0s Not legally binding requirements 21 until af ter the itera tion is gone through with the 22 project managers, and at that time when they would be 23 made legally binding on the licensee.
24 COHHISSIONER GILINSKY But when does this 25 happen?
When does the project manager cut his deal with ALDERSON REPORTING COMPANY. INC.
400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
18 1
the utilities ?
2 HR. STELLO:
Well, as soon as we get approval 3
form the Commmission and send the letters out.
4 COMMISSIONER GILINSKY So he would set a 5
bunch of requirements based on these?
8 HR. STELLO:
No.
He would send specifically 7
this attachment.82-111, the attachment thereto, would 8
be sent to the licensees in total.
9 COHHISSIONER GILINSKYa Yes, and then what?
10 E R.
STELL0s The licensees would be, pursuant 11 to 50.54 F, required to respond to these.
Given those 12 responses, schedules would be developed for doing these 13 things and then through one of a variety of mechanisms 14 they would become the legally binding requirement on'the 15 licensee, such as through a license amendment or 16 confirmatory order or an order if necessary.
17 HR. CASE:
In his response the licensee admits 18 to whether he is going to ---
19 COMMISSIONER GILINSKYa Suppose he does half 20 of these things or a third of these things?
I mean, 21 what are the project manager's instruction?
22 HR. STELLO:
The project manager's 23 instructions are for him to implement all of these 24 requirements.
If there is a particular problem with any 25 of these requirements, the paper suggests that that is ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345 '
19 1
to be escalated f or the specific approval by the 2
director of the office and it sets forth under what 3
conditions in the paper.
4 COMMISSIONER GILINSKY:
Now what was wrong 5
with the requirements in here, or the guidance in here, 6
let me put it that way?
7 MR. STELLO:
To what extent must he do any of 8
those?
The answer is he is not required to do any of 9
them.
On page 22 it sets forth what he must do.
He to must structurally build it in accordance with the 11 Uniform Building Code.
He must locate it 12 COMMISSIONER GILINSKYa Well, let me ask you, 13 now many utilties are left that have not gone forward on 14 the basis of this sort of a document, and I assume this 15 applies to the other parts of the emergency plan?
16 MR. STELL0s I don't know the answer.
17 COMMISSIONER GILINSKYs Who is it who isn't 18 meeting their schedule or who hasn't gone forward?
It 19 seems to be another case where if you hang back and you 20 vant long enough then we don't stick with the guidance 21 that we gave in the first place.,
22 COMMISSIONER AHEARNE:
I don't think the EOF 23 is really the problem at this stage.
I don't the EOF is 24 really ---
25 MR. STELLO.
There are some utilities which ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W, WASPINGTON, D.C. 20024 (202) 554 2345
20 I
have not yet begun an EOF.
2 COMMISSIONER AHEARNEa But the larger 3
issues ---
4 MR. STELL0s The larger issues are the ones 5
for which there are not yet any decisions made, such as 6
the SPDS.
With respect to the SPDS some have started to 7
look at various designs an,d have made commitments, but 8
there is no unform decision as to what on that they 9
should do.
10 COMMISSIONER AHEARNE:
At least as far as 11 actual changes that have occurred, we have been going i
12 down a path which utilities I think were interpreting as 13 they were going to have to do a major review of their e
14 control rooms.
At the moment a lot of utilities have 15 put that effort on-hold because they aren't sure whether 16 we are going to require that.
17 MR.STELLba And what is required.
18 CHAIRMAN PALLADINO:
Is there anything in here 19 that is a variance.
If anybody had followed the EOF 20 document, would they now be out of compliance with this?
21 MR. STELL0a If they had followed what is in 22 there ---
23 CHAIBMAN PALLADINO:
They are not 24 inconsistent; is that right?
25 MR. STELL0s I have to always add to the best ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W., WASHINGiON, D.C. 20024 (202) 554-2345
21 1
of my knowledge I guess.
2 (Laughter.)
3 MR. STELLO:
I am fairly certainly that if 4
they were following the guidance in those documents that 5
they will meet everything that is in here.
6 CHAIRMAN PALLADINO:
Not everything, but ther 7
vill have met those things that are related to that 8
issue.
9 MR. STELL0s Everything that is in here 10 exceedingly.
11 COMMISSIONER AHEARNE4 Th at I think is Vic's 12 point, that if they had followed the previous documents 13 they may well have exceeded what we are now coming out i
14 with.
15 MR. STELL0s They may have.
16 COMMISSIONER GILINSKY:
Probably likely would 17 have.
18 CHAIRMAN PALLADINO:
I think we ought to get 19 set forth as soon as we can what we really mean, because 20 that is not a requirement and this presumably will 21 become a requirement.
22 COMMISSIONER AHEARNE:
Eventually.
23 MR. STELLO:
That is correct.
24 COMMISSIONER GILINSKY:
Well, specific 25 variations of that would become 70 or 100 different ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON. D.C. 20024 (202) 554 2345
22 1
requirements.
]
2 COMMISSIONER ASSELSTINE:
Are the variations 3
only in terms of schedule?
4 MB. STELLO4 That is the real problem is the 5
recognition that the schedules for licensees will have 6
to vary.
I don't expect to see any significant 7
variations over and above those that have already been 8'
approved by the Commission as a result of this.
The 9
Commission has already approved variations.
10 COMMISSIONER ASSELSTINE:
Is the scheduling 11 problem the principal reason why it is not advisable to 12 put this out as a proposed regulation?
13 HB. STELL0s That is the principal reason.
14 COMMISSIONER AHEARNE:
If you publish this as 15 a NUREG, that isn 't going. to affect the scheduling 16 problem.
17 HR. STELL0s No, it would not.
18 COMMISSIONER GILINSKY:
I guess I don't 19 understand why the scheduling knocks us of f ---
20 HR. CASE:
Commissioner Asselstine was going 21 in a different direction.
The approach is we hope to 22 make a reglation as to technical requirements and handle 23 the schedule outside the regulations.
24 COMMISSIONER GILINSKIs I certainly better 25 prefer that.
ALDERSON REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
23 l I
1 HR. STELLO:
I agree with you, I would have j
2 preferred that as well.
1 3
COMMISSIONER GILINSKY Let me ask you, is the 4
5 HR. STELL0s No.
6 COMMISSIONER GILINSKY:
Where does the SPDS 7
have to go ?
8 COMMISSIONER ASSELSTINE:
The control room.
9 COMMISSIONER GILINSKYa That is it?
10 HR. STELLO:
No.
Tha t is' where the 11 requirement is.
The requirement is it must be in the 12 control room.
13 COMMISSIONER GILINSKY:
What about the 14 technical support center?
15 HR. STELL0s They mar.
Some of them have l
16 incorporated it.
The kind of information that is'in the 17 technical support. center and the EOF is also set forth i
18 in here, which can include the SPDS in addition to other I
19 variables that would have to be presented.
20 CHAIRHAN PALLADINO:
Is the SPDE an operator 21 aid or is a supervisor aid ?
By that I mean is the 22 operator going to look at the SPDS and take his actions 1
23 based on that, or is going to be the supervisor using 24 the SPDS to perhaps determine what guidance or direction 25 he wants to give to the staff?
- ~ ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE S.W., WASHINGTON, D.C. 20024 (202) 554 2345
24 1
MR. STELL0s Well, let me give the first 2
answer and then I guess I will ask Hugh to add to it.
3 The SPDS is principally dealing with one of 4
the major lessons learned fron.THI, and that is 5
providing the information necessary to. try to help the 6
staff avoid making conflicts of errors.
That was a 7
major problem at THI.
To that extent it is f or those 8
people in the control room who are deciding on the 9
overall course of action to follow in the plant which is 10 generally a senior reactor operator or shift supervisor.
11 The meeting that we had with the Commission I 12 guess last week dealt with senior reactor operator 13 always being present in the control room and he would be 14 the principal user.
Others would not be free to 15 implement this.
It is in making this cognitive process 16 work better which is aimed more at the senior reactor 17 operators and other levels of management in the plant.
18 MR. THOMPSON:
That is correct.
19 CHAIRMAN PALLADINO:
Let me go just a little 20 bit farther to understand.
Based on your answer I would 21 envision that the reactor operator would not be looking 22 at the SPDS particularly during an incident.
He would 23 be manipulating from the information that is on the 24 control room board unless the supervisor says, oh, we 25 had better close the PORY or open it or do whatever, or ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
o 25 1
stop the pumps or start them.
2 HR. STELLO:
The reactor operator would 3
generally be following the instructions from whoever is 4
in charge and would be told to either start and put in a 5
piece of equipment into the plant that vts not or 6
monitor and surveil particular pieces of equipment or to 7
follow a particular emergency procedure.
He would be an 8
implementer of the policy that was being developed by 9
someone other than the reactor operator himself.
10 CHAIRMAN PALLADIN0s I ask the question 11 because on a recent trip I saw this, and I guess it is 12 the equivalent of the SPDS, and it wasn't in a position 13 or a location, if I recall correctly, where the reactor i
'~
14 operator could make use of it.
It was off on a table to 15 the side and if I were the reactor operator I would have 16 a tough time looking at it.
17 HR. STELL0s That is correct.
18 CHAIRHAN PALLADINO:
So you say it is more of 19 a supervisor aid than it is an operator aid.
20 BR. STELLO:
Yes.
21 COMMISSIONER AHEARNEa Your description also, 22 Vic, seems to be that you do not expect the operators to 23 be making many independent decisions during that time, 24 but rather to be f ollowing prescribed procedures or else 25 implementing decisions made by a supervisory operator.
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. O.C. 20024 (202) 554 2345
c 26 1
MR. STELL0s That is the notion.
That is 2
correct.
3 COMMISSIONER GILINSKY:
But we are not 4
designating who ought to be monitoring the SPDS?
5 MR. STELL0s No.
6 COMMISSIONER GILINSKYa It is up to them to 7
sort that out.
I am not sure it would be a bad idea if 8
we did, but in any case we aren't.
9 MR. STELLO:
I would recommend against 10 proh'ibiting others from looking at an SPDS.
11 COMMISSIONER GILINSKY:
No, no, no.
It is not 12 a question of prohibiting people from looking at it.
It 13 is not X-rated or anything.
14 (Laughter.)
15 COMMISSIONER GILINSKY:
In one plant I was at 16 they were going to designa te a specific senior person as 17 the man who monitors the SPDS so there will definitely 18 be one person who is always ---
19 MR. STELL0s And I would expect that normally 20 to be the senior reactor operator or higher level of 21 management.
22 COMMISSIONER GILINSKY Let me ask you.
Why 23 do you not think an SPDS should be required in an TSC or 24 EOF 7 25 MR. STELLO4 I think that the TSC and the EOF ALDERSON REPORTING COMPANY,INC, 400 VIRGIN'A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
27 1
that is being developed in the plant ought to be j
l 2
developed consistent with the philosophy and the 3
management principles that are being formulated for a 4
particular. facility.
To the extent that an SPDS fits in 5
with that management system or philsophy then it ought 6
to be incorporated.
Then if there is a particular 7
philosophy where there.is much more information, which 8
there vill be in a number of cases, other.information to 9
be put in the TSC and EOF, and what they expect to get 10 out of the TSC and the EOF in the control room are 11 harmonized.
If the SPDS fits in vith.that scheme, 12 fine.
If they want to do it another way, I think that 13 flexibility ought to be there so that they get the best 14 possible arrangement.
15 COMMISSIONER GILINSKYi But the other way is 16 their version of an SPDS or it is something completely 17 different or nothing at all?
18 MR. STELLO:
There are schemes where in the 19 TSC they have the capability to get almost a complete 20 hook-up with the computer.
21 COMMISSIONER GILINSKY But suppose they do a 22 lot less than is available in the SPDS?
23 MR. STELLO:
Tha t is not likely if they follow 24 the requirements that are in here in terms of the 25 informa tion that is going to be needed.
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
28 1
COMMISSIONER GILINSKY I see for the EOF it 2
says provide reliable voice and data communications.
3 ER. STELLO:
No. 6 says capable of reliable 4
collection, storage and analysis display and 5
communication or information on containa'ent conditions, 6
radiological releases ---
7 CONHISSIONER GILINSKYs I mean, don't we want 8
to be sure that the people in these three places are 9
dealing with the same facts?
10 HR. STELLO4 That is precisely the point, in a 11 harmonious var.
12 COMMISSIONER GILINSKY:
Yes, but do you want 13 to do that in a hundred different ways?
I wouldn't 14 think so.
15 CHAIRHAN PALLADIN0s What do you mean in a 16 hundred different ways?
17 COMMISSIONER GILINSKY Well, I mean on th e 18 reactors out there.
19 HR. STELL0s Not in a hundred ways, but in 20 enough vars to allow flexibility for the utilities to do 21 it best for them.
l 22 COMMISSIONER AHEARNE:
We already are getting, 23 according to OPE, there are something like 30 to 40 l
l 24 different designs in SPDS already.
i 25 HR. STELLO4 You have got to recall that the l
l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTCN. D.C. 20024 (202) 554-2345
~
29 1
plants that are out there now ate of different designs 2
over a period of time and have different arrangements, 3
different management principles and different management 4
capabilities.
I think you need to allow the flexibility 5
for those to be used as effectively and efficiently as 6
you can.
In an overprescription of simply just coming 7
up and saying thou shalt have this SPDS here doesn 't 8
seem to me to be warranted.
We don't preclude it.
9 The guidance document suggested, 3.1though it to is one part of the guidance document that I do have a 11 problem with, it suggested it ought to be a slave SPDS.
12 So that in the TSC and the EOF you can only see what you 13 must be in control of and I think that is very relevant.
1 14 CHAIRMAN PALLADIN04 Let's see, I think the 15 plant we visited there had one of the TSCs, the is technical support center.
17 MB. STELLO.
Yes, there are plants that do.
18 CHAIBMAN PALLADIN04 But I didn't that the one l
19
. was a slave to the other.
l
' 20 COMMISSIONER GILINSKYa I didn 't think so 21 either.
But is it possible under this guidance to end 22 up with different data in one place than another?
23 MB. STELLO:
Oh, most certainly and I expect 24 it will be different.
25 COMMISSIONER GILINSKY No, but I mean ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
30
~
/
1 different data for the same parameters.
2 CHAIRMAN PALLADINOs Within a plant.
3 HR. STELL0s I don't understand your 4
question.
5 CHAIRMAN PALLADINO Clarif y it.
Are you 6
saying in a given plant if there are several SPDS's ---
7 CONHISSIONER GILINSKYa Different time delays, 8
different -- (Simultaneous conversations -- Inaudible).
9 CHAIRMAN PALLADINO:
When you ask for data 10 vill you get the same data on each one of these even 11 though one is not a slave to the other?
12 HR. STELLO:
If they are all SPDS's you will 13 he getting consistent data.
14 COMMISSIONER GILINSKY But under this 15 guidance, or whatever you call it?
16 ER. STELL0s This does not require an SPDS in 17 the TSC or the EOF.
18 COMNISSIONER GILINSKf Well, let me ask you 19 this, what does it require?
20 CHAIRMAN PALLADINO:
He doesn't want to be 21 getting part from EOF and part from TSC.
He wants it 22 all to come from one source.
23 COMMISSIONER GILINSKY:
Capable of reliable --
24 (Simultaneous conversations -- Inaudible) -- you just 25 read this.
Now how do you go from this to what it is ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
31 1
you are going to build in your plant?
2 HR. CASE He describes what he is going to 3
build ---
4 COMMISSIONER GILINSKY:
And he sits down with 5
the ---
6 HR. CASE:
Then the project manager, just like 7
this project manag'er says, fine, if you have a question 8
and he refers it to the ---
9 COMMISSIONER GILINSKY:
Just like what?
10 HR. CASE:
To the extent that it meets the 11 specific requirements, that is fine.
If there are 12 issues involved in the specific requirements he will go 13 to the technical group involved, like if it is energency t
14 planning, Brian's group, get some recommendations and 15' these would be reviewed.
He doesn 't make decisions all 16 by himself.
He follows the usual pattern of the project 17 manager.
18 COMMISSIONER GILINSKY:
It is one thing to say 19 th a t, you know, you can't have it in the control room 20 and you can't do a lot of things, and saying you have 21 got to make accommodations and they are all different 22 plants and run by different utilities and so on, but I 23 thought the idea here when we were talking about it a 24 couple of years ago, or whatever, was that there should 25 he a certain minimim set and that ought to be the same.
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554 2345
32
/
1 Everybody ought to have at least that.
Now, I don't see 2
that spelled out anywhere.
3 MR. STELL0s Hell, if you look at page 22, 4
item No. 6, Reg. Guide 197, in Tables 1 and 2 are listed 5
alaost a hundred parameters on which there are tech.
6 specs. established that will deal v'ith containment 7
condicions and the ccnditions of the reactor plant.
8 Then there are meteorological conditions which are 9
identified in Part D.
Now to go beyond that and say 10 what more do you need to get the list of the specific 11 pa ra me te rs that ought to be included ---
12 COMMISSIONER GILINSKYs Now how is that 13 different from an SPDS when you say you are not
(
14 requiring an SPDS?
15 MR. STELL0s Hell, the SPDS will be extracted 16 from this same list.
In my judgment, it would not 17 necessarily have to have all of these parameters in the 18 SPDS to deal with the issue we were talking about, the 19 question of what is happening to the reactor, and I 20 think that that has to be worked out on a plant-by-plant 21 basis.
I don 't know how one can specify all of the 22 parameters that have to be displayed in every plant.
23 That will have to be worked out case-by-case.
24 COMMISSIONER GILINSKY I guess you lost me.
25 I mean, we are saying that variables from the i
1 i
l l
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
33 1
appropriate Table 1 or 2 of Regulatory Guide 1 97.
Nov 1
2 where do you get the list for an SPDS?
3 BR. STELLO:
Well, that is page ---
4 COHNISSIONER GILINSKYa Is that different?
5 COHHISSIONER ASSELSTINEs Page 7.
6 COMMISSIONER GILINSKY What is it that these 7
people don't have to do?
8 HR. STELLO:
They.'.cn't have to do anything 9
that is not listed here as a requirement.
Here is what to they must do, and these are the things that are 11 required.
Outside of this they are not required to 12 do ---
13 COHNISSIONER GILINSKY Let me ask you, do
(
14 those tables, and I am not familiar with them, cover 15 reactivity ccatrol, reactor core cooling 16 HR. STELLO4
.Yes.
17 COMMISSIONER GILINSKT Let's see, 18 radioactivity, control containment conditions ---
19 HR. STELLO:
To a degree, yes.
l 20 CHAIRMAN PALLADINO:
Well, let's see if I can 21 help, Vic, both in clarifying the question and in 22 responding.
We are not in a position to design these 23 systems and I think we have to set forth what we want 24 them to accomplish and tha t is usually our pattern for 25 going after the requirements.
ALDERSON REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
34 t O
1 However, I think there is hidden, or there is 2
included in Commissioner Gilinsky's series of questions 3
some questions about the adequacy of our specification.
4 For example, even though we may not require an SPDS in 5
the technical support center, among the suggestions that 6
would arise from his questions is but if you are going 7
to have one in the technical support center, then it 8
ought to be drawing on the same information base and the 9
same data base as the one in the control room so that 10 you are not getting two sets of information.
I use that 11 only as an example of his questioning as to whether or 12 not we specified all the things we really want.
13 MR. STELLO:
If you did put an SPDS in it, it 14 would be hard wired and the same information would be 15 available.
However, in the TSC and the EOF it is 16 expected that at least for some SPDS designs that might 17 not be as comprehensive additional information.
18 COMMISSIONER AHEARNE:
You have described the l
l 19 information contained in the SPDS and in the EOF l
20 somewha t differently.
On the SPDS you give that short 21 list and it says " Minimum information shall be 22 sufficient to provide information to plant operators 23 about.
" and that is on page 8 and there are five 24 items and this is what information must be provided.
l 25 Then it just goes on to say "The specific parameters I
ALDERSON REPORTING COMPANY. INC.
'~~
400 VIAGINIA AVE., S.W WASHINGTON. D.C. 20024 (202) 554-2345
/
35 i
1 shall be determined by the licensee."
In talking about 2
the information to the EOF you refer back to 1 97.
3 What would'yoa expect to be the overlap?
4 HR. STELL0s The SPDS parameters would,also be 5
extracted from the Reg. Guide 1.97, Item No.I.
That is 3
6 where we would expect them to extract from that list.
7 COMMISSIONER AHEARNE:
It'has been,a long time 8
since I looked at those lists and I can't even recall 9
how they are defined.
What would you expect the SPDS to 10 have?
If the licensee looks at what information you are 11 requiring to put in SPDS and the information you are 12 requiring to put in the EOF, would you expect the 13 licensee to be most likely to come out with 14 significant1.y greater information in one than the other?
15 El'. STELL0s Well, the control room would be 16 the place whore the largest volume of information. exists.
17 COMMISSIONER AHEARNE:
But the SPDS by its 18 very nature is a distillation.
19 Ma. STELL0s And it can be, depending on the i
20 control room, a small distillation or by choice a much' 21 larger collection of information.
Now how the utility 22 then plans, given whatever he has with that kind of an 23 SPDS, as to wha t he is going to put in the TSC and the i
24 EOF, I think ought to be left as a variable rather than 25 a prescription.
I ALDERSON REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W., WASHINGTON. O.C. 20024 (202) 554-2345
36
^1 COHHISSIONER AHEARNE:
So I guess what you are
- f
~
2 saying is that as far as you can see from the guidance
~
3 the utility could have the same information on the SPDS 4
and in the EOF, he could have more information on the t
5 SPDS than is presented in the EOF and he could have less 0
information on the SPDS than is in the EOF, and any of 7
those three options would be consistent 8
HR. STELLO:
Yes, and there are SPDS's that 9
are being designed that cover all of those.
There are 10 some that are very, very sophisticated that also include 11 the capability to help the plant, if you will, during 12 normal operation and small departures from normal 13 operation, and that is a fairly large, comprehensive 14 SPDS, and I think we ought to allow for that.
15 ER. DIRCKS4 I think if we need more 16 information we have Roger Mattson here who could maybe 17 add a little more detail.
18 CHAIRHAN PALLADINO:
But, Vic, can I make an 19 ob serva tion.
On page 22 under Recommended Requirements, 20 Item No. 6, you are calling for a lot more data to be 21 available at the EOF than would be available at through 22 the SPDS system.
23 HR. STELL0s If he has a minimum SPDS, then 24 there would be a lot more in the EOF relative to that 25 type of SPDS.
But there are other kinds of SPDS's that i
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
37 a
1 are being developed which are ve ry sophisticated and 2
have a great deal of information, and there it becomes 3
difficult to try to describe more or less.
4 CHAIRMAN'PALLADINO:
Fell, here you are 5
talking about including radiological releases and 6
meterology characteristics that I would not expect 7
HR. STELLO:
In the EOF.
8 CHAIRHAN PALLADINO:
Yes, in the EOF, that I 9-would not expect to be in the EPDS.
10 MR. STELLO:
That is correct.
11 CHAIRRAN PALLADINO:
The point is the EOF does 12 need a lot more information than you get by merely by 13 looking at the SPDS.
i 14 HR..STELLO:
Yes, of different types.
15 COMMISSIONER GILINSKY It seems to me we are 16 encouraging diversity here, which I think is unfortunate.
17 CHAIRMAN PALLADINO:
We've got it.
18 COHNISSIONER GILINSKY:
Oh, I know we have 19 it.
But, you know, we have talked a great deal about l
20 future plans and the value standardization f or safety, l
21 et cete r, et ce te ra.
Here is an opportunity to backfit i
22 a certain degree of standardization for at least certain 23 minimum readings on safety variables, and I don't get 24 the impression we are doing that.
25 CHAIRMAN PALLADINO:
I think part of the ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
38 1
problem is we have not yet developed a device to a point 2
where we know what we want to standardize.
3 COMMISSIONER GILINSKY:
Well, maybe we got 4
ahead of ourselves.
5 CHAIRMAN PALLADINO:
That may be.
6 COMMISSIONER GILINSKYs But I am not sure that 7
what we are doing here is. helping.
I get the impression 8
that rather than giving more guidance we are giving less 9
quidance, and since we are going to check after the to fact, we are going to end up with many, many situations 11 that we vill just have to swallow hard and live with.
12 But Roge'r I guess is the father of SPDS and 13 maybe we cught to hear from him.
14 (Laughter.)
15 CHAIRMAN PALLADIN0s Roger, would you like to 16 make some comments?
17 HR. MATTSON:
I have been sitting here tryinq 18 to think of a way to help this.
Maybe using some 19 numbers would help and give us something more concrete 20 to talk about.
21 We wrestled with this problem back in the l
l 22 summer of 1980 when 0696 was first being developed.
We 23 tried to simplify the information requirements for these 24 various facilities by free =ing to Reg. Guide-1.97 has 25 having the minimum list of parameters necessary to ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE. S.W, WASHINGTON, D C. 20024 (202) 554 2345
39 1
follow the course of an accident.
You could make all 2
the decisions you needed to make if you just have the 3
Beg. Guide 1.97 parameters.
4 That has proven to be a more complex qustion 5
than that simple answer will serve.
Reg. Guide 1.97 has 6
about a hundred parameters, a good round number, and it 7
varies a little bit depending on whether it is a PWR or 8
a BWR or what vintage, but it is a good number to talk 9
to, a hundred parameters in Reg. Guide 1.97.
10 A good SPDS, a sophisticated SPDS may have a 11 thousand pa rameters on 'it, but the thousand parameters 12 are things that go well beyond the minimum requirements 13 for the SPDS.
I don't know if I was it father, but its 14 original idea was to provide an integrating service to 15 the strategists in the control room, the people who 16 stood back and asked the question do we really knov 17 where we are going and are we taking the right stragegy 18 in dealing with this accident.
19 That integrating fuction can be served by a 20 relatively few parameters, maybe 25.
The six things 21 listed at page 8 don't take a thousand parameters.
They 22 don't even take a hundred parameters but just a few, say 23 25.
24 But the sophisticated SPDS puts those 25 25 parameters up on page one and then has a console down ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
40 1
below the view screen that says that if you want to knov 2
more details punch in the following numbers and we vill 3
give you succeeding pages of the SPDS that tell you hov 4
the subsystems and the components are working.
That is 5
where you get into the thousand parameters of the SPDS.
6 Vic in his review of the guidance that had 7
cone out on these various functionc that had to be 8
performed said, look, the information can vary depending 9
upon the facility you are talking about, because each of to the facilitis, the control the TSC and the EOF, have a 11 different function.
So you ought to tailor the 12 information required and the display for that 13 information to the function being provided.
That is why 14 the EOF concentrates on radiological information and the 15 control room concentrates on safety functions and the 16 TSC is sort of in between, mostly engineering l
17 information where managers and plant engineers could 18 ad vise the control room.
19 It then says what is the requirement that has 20 to be met in each of those and what is the minimum you 21 have to assure?
Well, the integrating function has to l
22 be available in the control room.
Hence, the page one 23 of the SPDS is required for the control room.
But that 24 integrating faction is done auch differently in the TSC 25 by different people on a different time scale.
If they l
ALDERSON REPORTING COMPANY. INC.
400 VIRGINIA AVE S.W., WASHINGTON. D.C. 20024 (202) 554-2345
41 1
choose to use an SPDS, then they might slave the SPDS in 2
the control room.
3 Vic has said, and I agree with him, that that 4
might be a stupid thing to do because then the 5
information available to the TSC is only that that the 6
control room senior operator chooses to call to his 7
display.
The engineers, on the other hand, in the TSC 8
may want to go back in time or forward in time and try 9
to trend what is going on to give better advice to the to control room.
11 So you tailor the individual displays and the 12 content of inf ormation to the function that ther, i,
13 provide.
Vic has said that you have to tailor it to the 14 management and how they are organized and what shots are 15 called'in which facility.
That is true.
You also have 16 to tailor it to what equipment is already there.
17 For example, the control room has an ability 18 to call up on visual displays all kinds of subsystems.
19 We were just up at Susquehanna.
That is a plant that 20 already had that built into the control room and 21 designed it that way since 1972.
Their SPDS probably 22 doesn't have these call-up functions as some of the 23 other SPDS's will have.
They can get the subsidiary 24 information fron.the existing control room.
They don't 25 need that call-up f unction on the SPDS.
ALDERSON REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W., WASHINGTON. O.C. 20024 (202) 554-2345
s 42 1
So this way of stating the criteria, the 2
minimum criteria for these informations systems is 3
flexible enough to allow that and still fix the plants 4
like D. C. Cook or elsewhere where they have a very poor 5
visual display of this information.
6 I don't know if I have helped the situation or 7
not, but there are variances. that you have to account 8
for in setting these criteria.
9 COMMISSIONER GILINSKYs Good enough.
But it 10 seems me that it would be helpful if these three centers 11 could get on the phone and all have page one to look 12 at.
Now it may be that every one of then will have a 13 lot,of other pages that they look at, but there ought to
(
14 be some basic set of parameters that they can ---
15 CHAIRMAN PALLADIN0s I would hate to constrain 16 them by ---
17 MR. MATTSONs That is how we have ended up 18 using 1.97.
They have to be able to show that they have 19 got the 1.97 stuff, and even though they may display it l
20 differently in the three different facilities, it is all 21 going to be drawn from the same source.
So that l
22 although it is displayed differently, it is the same 23 in form ation.
So that you are not getting one 24 transmitter going to the control and a different 25 transmitter going to the TSC and they both think they i
ALCERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
43 1
are measuring cold leg temperature and it turns they are 2
different loops or something like that.
They have to be 3
the same information but they can be displayed 4
differently.
S COHHISSIONER AHEARNE:
Ale you saying, Roger, 6
that the 1.97 instrumentation, and I thought you said 7
approximately a hundred, that that information has to be 8
displayed in all of these centers?
9 HR. MATTSON:
Well, the way it has come out is 10 it has to be in both. the control room, and it may or may 11 not be on the SPDS in the control room, and it has to be 12 in the TSC.
If you will look at page 13.
13 CHAIRHAN PALLADINO:
Did you say we are 14 requiring thousands of parameters?
15 ER. NATTSON:
No, a hIndred.
16 COHHISSIONER AHEARNEa A hundred.
17 HR. STELLO:
1.97.
18 HR. MATTSON I understand the words at page 19 13 to say that you have.to have all of the Reg. Guide 20 1.97 parameters in the control room and you have to have 21 them in the TSC.
If you will turn to page 14, in the 22 EOF, it restricts it somewhat and only says you have to 23 have the containment conditions and the release of 24 radioactivity in the EOF.
25 COMMISSIONER AHEARNE:
But then back on page ALDERSON REPORTING COMPANY,INC, 400 VIRGINI A AVE, S.W., WASHINGTON, D.C. 20024 (202) 554-2345
44 I ~
l 1
22 in talking about the EOF, and I am not sure what 2
" appropriate table means," but it does say "The 3
following categories shall be available and variables 4
from the appropriate table."
5 CHAIRMAN PALLADINO:
Can you tell whether 6
Table 1 is appropriate or Table 2 is appropriate?
7 HR. STELLO:
One of the tables I think is a 8
PWR and the -- (Ina udible).
9 CONNISSIONER AHE ARNE :
The page 13 description to that Rogers referred us to has " Provide measurements and 11 indication of Type A, B, C, D and E variables listed in 12 Reg. Guide 1.97."
Now 'how does that correspond to the 13 variables from, say, Table 17
('
14 HR. HATTSON:
Be. careful.
Page 13 is the 15 tech.. support center and on page 22 rou are taking about 16 th e EOF.
17 COMMISSIONER AHEARNE:
I understand that.
18 HR. HATTSON:
My understanding of what we have 19 here on page 14 for the EOF ---
20 HR.,STELLO:
Roger, he is asking a simple 21 question.
You have type A, B, C, D, and E variables on 22 page 13 and on page 22 it is Table 1 and 2.
Please 23 explain Table 1 and 2 relative to A, B, C, D and E.
24 HR. HATTSON:
Okay.
A, B, C, D and E are a 25
'whole series of types of"information that are in both ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTCN D.C. 20024 (202) 554-2345
45 1
Tables 1 and 2.
But for the EOF you take out of Tables 2
1 and 2 only that information needed for monitoring 3
containment conditions and releases of radioactivity per 4
the guidance on page 14 for information for an EOF.
5 COMNISSIONER AHEARNE:
What you are saying is 6
the information to be provided to the EOF is not found 7
under the recommended requirements for EOF, but rather 8
is found on page 14 under the emergency response 9
facility general statement.
10 HR. NATTSON:
Yes.
In the sense that they 11 seem to conflict with one another, it might say that you 12 ought to repeat-them in both places, but that is how it 13 is st ructured.
14 COMMISSIONER AHEARNE:
But you read then page 15 14 as restricting the information required in the EOF?
16 HR. NATTSON:
Yes, because that was something 17 specifically discussed, debated and decided upon with l
18 CRGR.
I 19 COMMISSIONER AHEARNEs Yes, I understand.
I 20 am just trying trying to make it clear.
The previous 21 section in which the reference was to look at the Tables 22' 1 and 2 of 1.97, that does provide a whole list of ---
23 MR. NATTSON:
Of A, B, C, D and E variables.
24 COMMISSIONER AHEARNE:
But then which ones are 25 required f o r ---
ALDERSON REPORTING COMPANY,INC, 4M VIRGINIA AV@., @.W., WC@HINGTON, D.@. 85384 (8EQ @j!3-@0Q
_~4.~
46 1
HR. MATTSON:
Only those for containment and 2
radioactivity release.
0696 said all the variables had 3
to be in the EOF ---
4 COMMISSIONER AHEARNE4 All righ t.
So that 5
would then say that the EOF could meet the guidance in 6
the EOF with substantially less information than would 7
be on the SPDS.
e 8
HR. MATTSON:
Yes.
9 HR. STELL0s That is a requirement.
10 CHAIRMAN PALLADINO:
Do you have any more 11 comments?
12 COMMISSIONER AHEARNE:
No, I made my comments 13 in writing.
14 COMMISSIONER GILINSKYs I have some questions 15 to ask John later.
16 (Laughter).
17 COHNISSIONER AHEARNE:
With reference to this 18 document?
19 COMMISSIONER GILINSKY:
Yes.
20 (Laughter.)
21 COMMISSIONER GILINSKY:
This is on page 23 22 where it talked about previous reviews of EOF's and 23 so..
You say "NRC does not intend to approve each l
24 design prior to implementation, but rather has provided 25 in this document those recommended requirements which l
(
ALDERSoN REPORTING COMPANY,INC, M 1%B3Xi6 lam RR 32iFMTMt%Y%%Tct _., _ _ _ _ _ _ _ __ -_
. ~ _ _
47 1
should be satisfied."
2 I don't know how that squares with what we 3
were saying earlier.
4 (Pause.)
5 COMMISSIONER GILINSKYa Is that a 6
comprehensible question?
7
. MR. STELLO If you will forgive me, no.
8 (Laughter.)
9 COMMISSIONER GILINSKY That is all right.
I 10 von't repeat it.
11 I gather we are not going to review the 12 emergency response facility design presumably including 13 the information system and so on prior to 14 implementation.
Does implementation mean building or 15 does implementation mean carrying out?
Well, what does 16 implementa tion mean?
17 HR. STELLO:
Well, the conceptual designs, as 18 I recall for all of them, have already been submitted 19 and pieces of paper for then have been generated which 20 indicate there are a number of problems and made 21 available, but we are not asking them to now take that 22 and turn it into a final design and then come get our 23 approval before we have to go back and start 24 CHAIHEAN PALLADIN0s But that presumably 25 includes their information systems in these facilities.
- - ALDERSON REPORTING COMPANY,INC,
48 1
They may go and set up a data collection system or 2
information system.
3 HR. STELL0s This only applies to the EOF.
4 For SPDS, for example, we have been asked now, Roger has 5
had quite a few requests that before people go forward 6
and purchase an SPDS that they would like to have Roger 7
look at it and agree with that SPDS design before ther 8
go forward, and Roger, if you recall, at the last 9
meeting outlined how we are going to do that.
10 COHNISSIONER GILINSKYa Well, it comes back to 11 that the licensee has this list to look at and it goes 12 off and does the best he can and then we will look at it 13 when he is finished.
Is that inaccurate?
(
14 CHAIRHAN PALLADINO:
For the EOF 7 15 COHNISSIONER GILINSKY For the EOF.
16 HR. STELL0s (Inaudible) 17 COMMISSIONER AHEARNE:
But isn't it also true 18 for the SPDS?
That is, you mentioned several licensees 19 have come in and asked, and whether it is Roger or Hugh 20 who ends up looking at it, but.that is at the licensee's 21 initia tive.
As I read this the licensee is authorized 22 to go off and put the SPDS in without approval.
23 HR. STELLO:
That is correct, without out 24 prior approval.
25 COHNISSIONER GILINSKY:
Now isn 't that also ALDERSON REPCRTING COMPANY,INC.
400 vtRGINIA AVE S.W., WAShlNGTON. D.C. 20024 (202) 554-2345
49 1
Is the OSC a requirement?
2 MR. STELLO:
The answer I think to all the 3
questions is yes.
4 COMMISSIONER GILINSKY:
Are you implying it is 5
vrong to go that way?
6 COMMISSIONER AHEARNE:
I would imply it is 7
vrong on the SPDS.
8 CHAIRMAN PALLADINO:
On the SPDS, but on the 9
others 10 COMMISSIONER GILINSKY Well, there may not be 11 an SPDS in those places.
So we j us t don ' t k now ---
12 COHHISSIONER AHEARNE:
It is only the,SPDS 13 that I am concerned with.
I 14 COHHISSIONER GILINSKYs Let me ask you about 15 phone communications with NRC.
It says reliable phone 16 communications.
Does that mean dedicated phone 3
17 communication or just' a phone or what?
I gather earlier 18 ve were thinking in terms of dedicated phone 19 communications.
20 HR. STELL0s They have the capability and l
21 Brian maybe can help us.
I believe in the TSC and in 22 the EOF they are making arrangements to connect th e 23 dedicated phone system in most plants, and I am 24 hesitating to say all.
25 CONHISSIONER GILINSKY:
But we are not ALDERSON REPORTING COMPANY,INC,
&@ WEE 0fM3 MitJdL M
50 l
i 1
requiring it I gather.
2 MR. GRIMES:
Are you asking a question on what 3
the document requires or what they capable of?
4 HR. STELL0s What are they doing?
5 MR. GRIMES:
The people are using dedicated 6
phones by and large.
7 COMMISSIONER AHEARNE:
What does the document 8
require?
9 COMMISSIONER GILINSKYs Well, it says 10 re'11able.
What does reliable mean?
I am wondering.
I 11 am not trying to be cute about it.
But there are phones 12 and there are dedicsted systems and I don't know.
When 13 you say reliable do you mean something more than a phone?
14 HR. GRIMES:
If you are asking me how would we 15 review a specific case ---
16 COMMISSIONER GILINSKYs Just what do you mean 17 when you put that down?
What is it intended for them to 18 do?
19 MR. GRIMES:
What we would fall back on in all 20 of these areas is the guidance in 696 as an acceptable 21 way of performing the function.
These very broad 22 requirements we do not regard as superseding, as 23 Commissioner Aherne mentioned, the previous guidance, 24 but rather it being a distillation of an easily 25 enforceable item which if the licensees don't do that is ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
51 1
clearly an unacceptable situation.
2 But it is going to be up to the individual 3
viewers to use the guidance similar to a reg. guide 4
situation and determine in each case whether there is 5
adequate assurance that the system will'vork.
That may 6
involved not only a comparison against the existing 7
guidance but an observation of the system in an 8
ex ercis e, for example, an identification of a specific 9
deficiency.
10 CORMISSIONER GILINSKYs Is this still the 11 recommended guidance then, the 6967 12 HR. STELLO:
The 82-111 says somewhere up 13 front that those documents were revert back to being 14 documents to be used for guidance.
15 COHEISSIONER GILINSKY:. But is this our 16 recommended guidance?
In other words, is this the l
17 equivalent of a reg. guide?
I am just trying to 18 understand.
19 HR. STELLO:
Well, the answer to that question 20 depends on the reviewer.
Some reviewers use guidance 21 and say the requirements, other reviewers negotiate and 22 other reviewers do other thing.
To the extent that it 23 is guidance, it is guidance that is to be used by the 24 reviewer.
These are not hard and fast requirements.
25 COMMISSIONER GILINSKY:
I realize we are faced I
ALDERSON REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W., WASHINGTON. 0.C. 20024 (202) 554 2345
52 1
with a complicated situation and there is a variation of 2
plants and we are in midstream and there are all these 3
complications.
4 MR. STELL0s No, I as talking about any 5
document which is issued for guidance, which is in the 6
status of guidance.
It is used by the reviewer and by 7
the licensee.
It is generally interpreted that the 8
licensee knows that if he does whatever that says that 9
they reviewer vill say, okay.
If he chooses to do 10 something different, then there is going to be argument 11 and discussion and ---
12 COMMISSIONER ASSELSTINE:
In other words, it 13 is one acceptable way of satisfying the requirement.
\\
~Yes.
14 MR. STELLO:
15 COMMISSIONER GILINSKYa Well, this isn't 16 listed as a. reg. guide and I guess it hasn 't gone 4
17 through the reg. guide process.
18 HR. STELLO:
That is. true, but you asked me 19 what it means and I as telling you that that is 20 generally the way they are used.
21 HR. CASES What he is saying I think is that 22 this is no different guidance than a reg. guide guidance.
23 MR. STELL0s That is generally the var they 24 are used.
25 HR. GRIMES:
And it is specifically our intent ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
53
\\
1 to put NUREG 696 into the reg. guide process as 654 has 2
been.
3 COMMISSIONER GILINSKY:
I see.
Let me ask 4
you, you have changed the times for when these centers 5
have got to be operational.
Could you say something 6
about that?
7 MR. STELL0s We have not picked the time.
8 What we have said is we want the implementation 9
schedules to be developed according to this process that 10 I have mentioned several times that vill follow the 11 50.54 F letters.
12 COMMISSIONER GILINSKY:
No, I meant in terms 13 of 30 minutes or an hour or so many hours after the 14 centers need to be activated.
I gather that you have 15 slowed that down, in other words, where it was a half 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> to an hour or whatever.
a 17 MR. STELLO:
Yes.
t 18 COMMISSIONER GILINSKYa What is the thinking 19 behind that?
20 MR. STELL0s The difficulty in being able to 21 meet the shorter times.
It is only used as guidance and 22 a number of the facilities have an extremely difficult 23 time and cannot meet them and there many, many 24 exceptions to the guidance.
In trying to come up with 25 the table the new numbers were used, and that is one I
ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
54 1
particular area I understand that there in some 2
discussion as to whether that ought to be embodied as a 3
requirement and whether additional flexibility ought to 4
be left with that specific reg. guide and making it 5
guidance and that micht be a' vise idea.
6 Is it Table B-17 7
(No response.)
8 COMMISSIONER GILINSKY Who has the 9
responsibility for reviewing all this?
Is it NBR or is 10 it IEE?
11 MR. STELLO:
Both.
12 COMMISSIONER GILINSKY:
And what is tho 13 division of responsibility?
What is Brian's group?
14 MR. STELLO:
Brian's group does the TSC, EOF, 15 off-site emergency preparedness working with FEM A, s
16 on-site emergency planning with the licensee, the 17 control room design reviews and the SPDS.
The 18 instruments and equipment and rest of that type of stuff 19 is NRR.
Have I said that correctly?
20 MR. THOMPSON:
That is correct, with the 21 exception tha t we vill both jointly review the TSC from 22 the human f actors viewpoint as well.
COMMISSIONER GILINSKY:
And they are both 23 24 comfortable with the way this has come out?
25 HR. STELLO:
Yes.
ALDERSON REPORTING COMPANY. INC.
400 VIRGINIA AVE., S.W WASHINGTCN D.C. 70024 (202) 554 2345
55
~.
1 COMMISSIONER GILINSKYs Let me ask John,:where 2
have you come out on this SPDS and what is safety
~
3 related and what is not safety related?
4 COMMISSIONER AHEARNEs Let me explore that 5
issue.
6 COMMISSIONER GILINSKY:
You seem to have done 7
some thinking about it.
8 COMMISSIONER AHEARNE:
As I read through the 9
description of the SPDS and in particular I also to listened to you discuss it last time, let me tell you 11 what my impression was and then you can.tell me whether 12 that is not the picture you intend to have of it.
13 The impression that I had is that the SPDS in 14 the staff's view is an essential element in the handling 15 of an accident in that it flows from, as you I think 16 earlier had mentiond, from the lessons learned from
.2 17 Three Mile Island.
It is therefore an integral part of 18 the NRC's posture as to how a licensee ought to prepare 19 himself to be able to handle something that goes beyond 20 the normal opeentions.
21 Now I grant that SPDS, some of these designs 22 clearly have expanded to the point where they will have 23 a value in normal operations, but that wasn't the 24 original driving. factor behind the NRC's interest.
25 It also seems that if we do place that auch ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE S.W WASH;NGTON D.C. 20024 (202) 554 2345
56 1
emphasis on it, and it is that important an element, 2
that the traning the utilities'go through will 3
concentrate on the use of the SPDS in handling an 4
accident.
5 Therefore, it seemed anomalous to me, if that 6
is a correct description of both the value we place on 7
it and the likely value the licensee vill end up placing 8
on it, it seemed anomalous to me that our position ought 9
to be that it need not then meet the qualifications of, 10 and since ve have debated on the tern I am a little 11 uncertain whether to call this safety related, safety 12 grade or important to safety, but the a key safety piece 13 of equipment.
14 Our concern is we don't make it meet those 15 requirements, and it seemed to me the answer was the 18 reason we didn't was that if it were to fail in,an 17 accident then the operators could fall back on the 18 regular equipment which was safety related or safety 19 grade.
But is anomalous because if we concentrate here 20 is this key piece of equipment to help them handle an 21 accident and ther train on using that, the time when you 22 least want them te question and least want. to then to 23 have to f all back on the other equipment is just in that 24 case of an accident.
25 CHAIRHAN PALLADINO:
John, this is also why I ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
57 1
raised my question is this an operator aid or is it a 2
supervisor aid.
3 COMMISSIONER AHEARNE:
Yes, but recall what 4
the answer was, it is that the operators are following 5
procedures and ditections.
They are implementing.
6 Someone is giving them guidance.
That someone is using 7
this piece of equipment to give them the guidance.
8 CHAIRHAN PALLADINO:
That is different from 9
the operator having to adjust from his normal operations.
10 COHNISSIONER AHEARNE:
No, it is even worse, 11 because the operator is following procedures o'r guidance 12 and you now are thrown into the situation that we are 13 trying to help then handle, namely, the cir<-r :.%nce I
14 that an accident is occurring, particularly one in which 15 they are not really sure of what is happening.
They 16 need the guidance and this is the time that the SPDS, 17 however, we say we don't require to be able to function.
18 That is at least a feeling I am getting and it 19 seems anomalous and I would appreciate any answer or 20 comments you have.
21 MR. STELL0s Let me start with a philosophical 22 description of what I see.
Following the accident we 23 decided that there were a large number of things that 24 needed to be done tha t would add and significantly 25 improve the ability to deal with accidents.
These ALDERSON REPORTING COMPANY. INC.
400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
58 1
covered a whole variety of things, no one of which do I 2
believe is a weak link.
They are all parallel circuits 3
which significantly improve the ability to deal with 4
accidents with clearly an emphasis on operator training 5
and transient and accident analysis to truly improve the 6
understanding of the plant to develop new procedures, 7
the symptom oriented procedures of more training of the 8
operators on the simulator and advanced qualificaton of 9
the operators.
What we are talking about is an SPDS to control room design review to improve and upgrade the 11 control room.
12 No one of these, again, do I believe is a link 13 which if broken that everything comes to a screeching 14 halt.
The SPDS is an aid to significantly improv'e, and 15 yes, it has a potential for being unavailable during an 16 accident, but an accident has a small likelihood of 17 occurrence and I do not wish to argue numbers.
Given 18 that the accident occurs, it is small in terms of times l
19 in which an S?DS would be unavailable.
l 20 The requirements vill be that. the plant is 21 capable of dealing with an accident, even if an SPDS is 22 unavailable.
There would be a lot of people who would 23 now be looking at the accident and will be looking at 24 the accident through the control room, the TSC and EOF, 25 and there are many, many strengths and parallel paths to ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
59 1
help to get there.
Ihis is an aid to the operator, but 2
it is not the only thing that we have done.
I think it 3
needs to have the flexibility.
4 You raise a point, which you didn't raise this 5
morning, but you raised in your comments, the notion of 6
how abou'c single failure in Class 1E1.
There are some 7
designs that go that way.
To the extent that you can 8
place a great deal more reliance on the SPDS, perhaps 9
some of these other paths can change in terms of changes 10 you might make in the control room or elsewhere.
11 I think that there is a give and take in a 12 relationship with one and the other.
What we have tried 13 to set is a minimum set of standards for the SPDS which i
14 ought to be there as an aid, not as the one and the only 15 vay in which to deal with accidents, and clearly that is 16 not the case.
We have many plants that are nov 17 operating in excess of three years since the accident 18 and we felt that could be done safely because of many of 19 these other things that we have done.
20 I think as an aid the SPDS can help the 21 problem significantly, but I don't think we need to 22 design it so that it is always there.
That clearly is 23 not possible anyway.
If you make it what it is now, a 24 single channel system, it might be.95 or.99 and we if 25 ve make it a multi-channel system you are not going to ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON. O.C. 20024 (202) 554-2345
60 1
get significantly a greater improvement over its 2
availability anyway.
So even if you added these other 3
requirements, I don't think you would change that.
4 It is the total of what we have done which I 5
think is the strength in terms of safety and not any one 6
of which becomes so critical.
So I don't really feel 7
that this SPDS, if it weren't there, was a critical 8
veakness in the process, and I think it has the 9
potential for significant ---
10 COMMISSIONER AHEARNEa Let me ask a couple of 11 questions with respect to that.
12 Would you expect the licensee to then get into 13 a training program to. train for transients both with and
(
14 without the SPDS present?
15 HR. STELL0s Yes.
16 COHHISSIONER AHEARNEa So you would require 17 the training program then to have those two ---
18 HR. STELL0s And the procedures.
19 CHAIRMAN PALLADINO:
Is that clear in here?
I l
20 don't recall.
21 ER. STELLO:
I hope so.
22 COMMISSIONER AHEARNEa The second question.
I 23 Is the' primary reason that you have not gone to placing 24 the safety related requirement on it the low probability i
25 of its use, the higher costs that that would lead to or s
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
61 1
the longer time that it would take to develop it, or all 2
three together?
3 MR. STELLO4 I think it is more all three.
4 CHAIRMAN PALLADINO:
More what?
5 HR. STELL0s All three of the reasons.
~
6 COMMISSIONER AHEARNE:
Now, as you say, some 7
people I guess have already decided to try to 8
incorporate the safety related criteria; is that correct?
9 MR. STELLO:
That is correct.
10 COMMISSIONER AHEARNEa So at least the 11 schedule and the costs for some people has not been an 12 insurmountable obstacle.
13 MR. STELLO:
A lot of the reasons I have heard
(
14 for that is what they feel is the benefit they can get 15 from some of these designs for even normal operation in 16 terms of avoiding problems.
The systems you are talking 17 about are fairly sophisticated as well and have the 18 potential for adding other benefits, other than those 19 which are of interest -- (Inaudible).
20 COMMISSIONER AHEARNE:
The last question on 21 that line of discussion.
The ACHS, while accepting your 22 position, did however go on to say that they believed 23 that you ought to try to develop, perhaps working with 24 industry, some reliability criteria.
25 MR. STELLO:
I have no problem with that.
ALDERSON REPORTING COMPANY,INC, 400 VIRGINTA AVE., S.W., WASHINGTON. D C. 20024 (202) 554-2345
62 1
COMMISSIONER AHEARNE Has there been any 2
effort in that direction by the staff, do you know?
3 HR. STELL0s We have not yet, to the best of 4
sy knowledge, met.with INPO to explore that.
I know the 5
industry was gathering a group together to look,at doing 6
what the ACRS has suggested, and I think you suggested 7
in your comments, of trying to get together to look at a 8
common design.
9 Roger, I don't know if you have had any 10 discussion on tha t.
11 MR. NATTSON 0696 had a reliability number in 12 it.
The genesis of that number was an industry 13 suggestion.
About the time that the original drafting
[ ',
14 was going en there was a group.of industry people, and I
-15 believe the chairman was from Duke Power Company, that 16 had been looking into ---
17 COMHISSIONER AHEARNEa It usually is.
18 NR. MATTSON:
--- what can you buy off the 19 shelf and found lov and behold that there were 20 microprocessors and all that. good equipment with good 21 reliability and others that were kind of not so reliable 22 and that we ought to have some fairly good reliability 23 number specified.
It is in 0696 and it didn't make the 24 cut of the things that were essential in this boiled 25 down list in 82-111.
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
63 1
It would be our intent to go for that kind of 2
number in what people are inst alling and urge people to 3
go for the kinds of numbers that are in there.
4 COMMISSIONER AHEARNF.:
Roger, Vic had 5
mentioned that some people are coming in to ask you I 6
guess you opinion or informal approval of their SPDS 7
system.
8 MR. MATTSON:
Yes.
9 COMMISSIONER AHEARNE:
In those kinds of 10 discussions do you give them any guidance or suggestion 11 as to reliability?
12 HR. MATTSON:
Yes, the 0696 kind of 13 suggestion.
I just saw one recently.
The Westinghouse
(
14 people have been in with their system that we have seen 15 several times and the internal documents show a f airly 16 advanced stage of accepance by th e staf f.
A lot of the 17 details that are excluded from 82-111 yet are down in 18 the guidance documents and it is a fairly accepted 19 practice in some sections of industry to design to meet 20 that guidance.
21 Some of these things that you are hotly 22 debating here in practice aren't that big a debate.
l
'.3 Good designers know how to solve them and they want to 24 sell reputable products.
We are not having that much 25 resistance to getting good products in SPDS land.
ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
4 64 1
COMMISSIONER AHEABNE:
Hugh, I gather then 2
that the position of the NRC is that the presence of an 3
SPDS increases the requirement on training?
4 HR. THOMPSON:
It certainly expands the 5
training requirement for both o,perators for use of 6
procedures as well as.the crew function and how 7
integrate that in their response to facility transients.
8 COMMISSIONER AHEARNE:
Well, but you are going 9
to and has the industry yet gotten to the point where 10 they are changing their training to concentrate on a use 11 with and without it?
12 HR. THOMPSON:
They-have not gotten to that 13 point yet, although we are as we propose requiring an 14 integrated response where they will have in their 15 submittals how they plan to integrate both the 16 procedures of the SPDS and the control room.
Part of If that will be our evaluation of their capabilities of 18 their training programs to include use of the SPDS and 19 not using the SPDS and where they are with their 20 emergency operating procedures.
l j
21
. COMMISSIONER AHEARNEa Thank you.
Those are l
22 essentially the concerns I have been having.
l l
l 23 COHNISSIONER GILINSKYa So where do you come 24 out?
25 (Laughter.)
l l
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
65 1
CHAIRMAN PALLADIN0s I think you just brought 2
out an important point though on the requirement to be 3
trained both with and without the SPDS.
I
\\
COHNISSIONER GILINSKY In reading Forrest 5
Remick's March 26th memo here I find that the last time 6
around you said that it is our understanding that the 7
Division of Emergency Preparedness disagrees with 8
portions of the staff's proposal from techncial and 9
policy aspects.
Where does that stand?
l 10 BR. STELLO:
The same place it did.
We 11 explained at the Commission meeting that there was one 12 particular area for which we still had disagreement.
13 COHNISSIONER GILINSKYa Could we just run
(
14 through that again?
15 HR. STELLO:
Let's see if I can recall it.
16 COHNISSIONER GILINSKY:
Can we hear from them?
17 HR. STELLO:
I believe it was radiological 18 requirements for the TSC.
19 COMMISSIONER GILINSKYs Can we hear from them.
l 20 HR. STELLO:
By all means.
l 21 COMMISSIONER GILIF"112 Is it just that one 22 item?
23 HR. GRIMES:
4s viu mentioned, there were 24 discussions just before the last commission briefing and 25 Mr. Schwartz, my Deputy, and Mr. Stello reached ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W, WASHINGTON D.C. 20024 (202) 554 2345
66 4
1 agreement on all except this one item, and those I later 2
documented in a meno to Mr. Stello dated May 10th and it 3
involved some minor word changes that we suggested.
4 The one item that remains outstanding is the 5
question of habitability for the technical support 6
center where we believe that the guidance in NUREG 0696, 1
7 which states it should be essentially equivalent to that 8
in the control room except that the redundancy and 9
automatic features of the ventilation systems need to be 10 required, would be the referred position.
11 There is a different position in the current 12 SECY 82-111 which would indicate the need for specific 13 dose calculations to determine acceptability, and I i
14 understand Mr. Stello believes that the habitability 15 requirement should be substantially less than the 16 control room.
1 ~.'
COMMISSIONER GILINSKY And you think they 18 ought to be comparable to?
19 MR. GRIMES:
Yes.
20 COMMISSIONER GILINSKY Does tha t state the 21 difference in sum?
22 MR. STELLO4 Yes.
23 COMMISSIONER GILINSKY:
Can we just hear why 24 you think the difference is acceptable or reasonable?
25 MR. STELLO:
In my view the control room ought ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
67 1
to be the place for which the highest standards ought to 2
apply.
If there is ever a situation where you would 3
have to leave the TSC, there is a place to leave it to 4
and that is the control room-I think that is an 5
unlikely event, but neverthelass I don't believe that 6
the same stards ought to apply to the TSC as to th e 7
control room.
It ought to be the highest standard of S
the plant.
9 CHAIRMAN PALLADIN0s The control room.
10 MR. STELL0s Yes.
11 COMMISSIONER GILINSKYs Well, okay, if that 12 suas it up at least I an informed.
13 Let me ask you about another item here, 14 radiological monitoring, NUREG 0696, and I ask this just 15 to try to get an understandin7 of why you moved from one 16 to the other.
It says " Provide radiation monitoring 17 systems capable of installing monitors' or dedica ted 18 portable monitoring equipment with detectors able to 19 distinguish the presence of radioiodines at 20 concentrations as low as ten to the minus six t
l 21 microcuries per cc. "
22 Now wha t you have in the new document is 23
" appropriate radiological monitoring systems."
Now why l
24 th e shif t?
Now does that help a licensee or what is the l
l 25 purpose?
ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W. WASHINGTON, D.C. 20024 (202) 554-2345
68 1
ER. STELLO:
I believe that what we ought to 2
do in terms of the requirement is set the general 3
principles down and avoid trying to get into the 4
detailed specification in terms of a recitirement.
A 5
small departure from that detail that yta read clearly 6
could very well be acceptable and appropriate or it may 7
not be.
8 COMMISSIONER GILINSKY But where is the 9
reviewer, who I' suppose is going to be in ICE, go to 10 decide what is appropriate?
Does he go to 06967 11 HR. STELLO4 They probably vill do what I 12 said.
They will go to 0696 and if they do what that 13 sa ys, which is detailed in red, we vill say that if 14 fine.
If he wants to do something different which the 15 general requirement would permit, then they would have 16 to justify it and that would be acceptable.
17 COMMISSIONER GILINSKYs But how would that be 18 different if we had stuck with this?
19 ER. STELL0s That doesn't even require any t
20 instrument at all.
There is no requirement.
It is a 21 guidance document.
That is a requirement.
22 COMMISSIONER GILINSKY:
Well, it is not a I
23 requirement until you put some flesh on it, because 24 "a ppropriate" could be anything.
25 HR. STELL0s It is the same principal as the i
ALDERSON REPCRTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
69 1
general design criteria, should we replace them with all 2
of the reg. guides that implement them or keep the 3
general design criteria as they are with the general 4
philosophy of the agency implemented though its reg.
5 guide process which are not the actual requirements.
6 COMMISSIONER GILINSKY:
Well, you obviously 7
need both.
8 MR. STELL0s That is the same philosophy here.
9 COMMISSIONER GILINSKYs But I don't get the to feeling 11 COHNISSIONER AHEARNE:
Let me ask Vic's 12 question slightly differently.
Why could you not have 13 sent a 50.54 letter referencing 696 to accomplish the 14 same purpose?
15 COHNISSIONER GILINSKY:
And say justify all 16 departures.
17 COMMISSIONER AHEARNEs As we discussed 18 ea rlier, 8 2-111 isn 't a requirement either.
j 19 HR. STELL0s Well, it is going to be made a 20 requirement.
1 21 COMMISSIONER AHEARNEs Yes, but it going to be 22 made could have just as well been 696.
23 HR. STELL0s For part of it.
l 24 COHHISSIONER GILINSKYa The process in effect 25 encourages greater diversity.
It makes it easier to ALDERSON REPORTING COMPANY,INC, 1
l Q$Q VIMINia AYig., @M7., W@WK@T@4 @.@. 8!M93 (8)@ 593-8D;G _ _ _ _ _ _ _ _ _ _
70 1
depart and it is going to be harder for us to draw back, 2
and I must say I think that is unfortunate.
3 HR. STELLO:
I guess it could do that at the 4
same time it goes beyond.by setting forth requirements 5
which have not yet been implemented so it does both.
6 COMMISSIONER AHEARNE:
But isn't it tr ue tha t 7
you could have done a 50.54 letter off of 6967 8
HR. STELLO:
I don't know of any legal reason 9
why not.
10 COMMISSIONER AHEARNE:
And had you done that, 11 that wouldn 't be any different as far as the process as 12 doing it off of 82-1117 13 dE. STELLO:
No, I think there would be a big i
14 difference because 82-111 distills from the guidance and 15 says these are requirements, and for the requirements 16 they are obligated to meet these when they are now the 17 requ ir emen ts.
18 If you vent from NUREG 0696 you would be hard 19 pressed to decide which of the language in there is a 20
" requirement."
Is it every paragra ph, every sentence ---
21 CONHISSIONER GILINSKY:
But you are going to 22 sit down and negotiate with a rather low level in the 23 organization over precisely that.
24 HR. STELLO:
Well, these are very precise 25 elements that are described as the requirements.
ALDERSON REPORTING COMPANY. INC.
400 VIRGINIA AVE., S.W WASHINGTON. D.C. 20d24 (202) 554 2345
71 1
COMMISSIONER GILINSKY:
Well, except they are 2
go general at this point.
3 COMMISSIONER AHEARNE:
There are very general 4
terms in some cases.
t 5
HR. STELLO:
In some cases it is general and 6
in other cases it is not.
The judgement has been made 7
as to where to be. general and where not to be.
So that 8
first part of the process has been done.
9 COMMISSIONER GILINSKY:
It may be as you say 10 that in some strictly legal terms you may end up with 11 the same result or legally it is equivalent, but it 1
12 looks like you have sort of untied the shoe laces.
13 HR. DIRCKS:
The shoe laces were never tied.
14 They were never tied.
Are you going to say that we knov 15 enough about 0696 and all those requirements now to make 16 them a Commission regulation?
17 CONHISSIONER GILINSKYs Well, we have to 18 decide what it is we want to do, but the process you are 19 going down encourages diverse solutions for every single 20 plant.
21 HR. DIBCKS:
I think the option is we can 22 bring up 0696, 0700, 0799, 0801, 0814, 0818 or 0835 and 23 see if the Commission wants to adopt them as a 24 regulation and then there is no question, but I think at 25 this level you don't want to impose requirements in that
--ALDERSON REPORTING COMPANY,INC, 4M MRGiNIA f--L {W, WpSgNGTON. D.C. 2M24 (202) 55f_-23f5_ _ _
y - -- --
72 1
details.
2 COMMISSIONER GILINSKYa Well, but you are 3
going to impose requirements in that detail and you are 4
going to have each project manager doing it differently.
5 MR. DIRCKSt Well, because you have got a lot 6
of different plants out there and you have project 7
managers and people at that level have some familiarity 8
with those plants and those conditions.
9 COMMISSIONER GILINSKYa Yes, but we are also 10 going to be faced with a lot of accomplished facts thd 11 vay you are going down this road.
12 HR. DIRCKSs But these documents haven't been 13 blessed with any great insight when they were first 14 enacted and I think we have to admit that some of them 15 were pushed through rather quickly without a great deal 16 of review.
17 CHAIRMAN PALLADINO:
I have a feeling having 18 read some of these that we would get quite a hodge-podge 19 because I remember some of them being so specific that I 20 think it said the TSC had to be within a two-minute walk 21 cr some number like that which I think is overly 22 prescriptive to vagueness that is no less than this 23 document.
I don't find any problem with this, but I am i
24 not sure that we would do any better by referencing 25 those two regs. than we are by referencing this in our ALDERSON REPORTING COMPANY,INC,
@_VIRGl_NIA_A /E., S._W., WA_ SHIN _GTON D_.C._20024_ (202) 554-234_5_ ________________
4 73 1
50.54 letters.
2 MR. STELL0s Well, 0814 is a classical example 3
of extremely fine detail.
4 COMMISSIONER GILINSKY:
0814 is what now?
5 MR. DIRCKSs Methodology fcr evaluation of 6
emergency response facilities.
7 MR. STELL0s I think if that went out pursuant 8
to 50.54 F and you had responses and had to deal with 9
each of those and derive requirements from them, that 10 that would be an enormous and massive job, and I-think 11 it would be a very unwise use of the agency's and 12 industry's 7asources.
13 CHAIRMAN PALLADINO:
Well, let's see where we
(
14 stand.
We had three individuals as far as I know that 15 had voted and I think we had at least two sets of 16 comments.
17 John, your comments now have become more 18 specific and maybe you can set forth your suggestions 19 more specifically.
I think my were specific enough.
If 20 others have specific, suggestions ---
21 COMMISSIONER ASSELSTINE:
If I can just ask 22 one more question of Vic before we go to that.
23 CHAIRMAN PALLADINO:
Sure.
24 COMMISSIONER ASSELSTINEs Vic, you mentioned 25 earlier that you would have preferred originally to have ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTCN, D.C. 20024 (202) 554-2345
74 1
issued this document as a proposed regulation.
Why do 2
you now believe that that is not the preferred way to go?
3 HR. STELLO4 We are auch too far down the path 4
with the hodge-podge of ways in which we have gone about 5
trying to articulate what it is we wanted through a 6
large list of letters, NUREG's, NUREG's that have been 7
approved by the Commission as scheduled line items.
I I
8 think we are auch too far down the path that if we were 9
starting afresh that clearly that clearly that would be to the way to go.
11 COMMISSIONER GILINSKY:
This is certainly is a 12 hodge-podge of guidance.
I must say that the licensees 13 that I have run into don't even share the view or are 14 clear on what we think.the TSC ought to be doing and 15 what the EOF ought to be doing.
I am not sure that we 16 are clear on it ourselves, but we are more clesr than I 17 think a lot of people out there.
l 18 The thing that concerns me about this approach l
19 is I au not sure it helps people out there.
20 ER. STELLOa Well, make no mistake about 21 tha t.
The information I have had in the presentations 22 that were made to the ACRS, the industry, our comments 23 on it have indicated that they find it very helpful and 24 have recommended strongly to the ACRS to move forward 25 with it in the ACRS presentation.
At.DERSON REPORTING COMPANY,INC, 400 VIRGINTA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
75 1
COMMISSIONER GILINSKY Well, my own thinking 2
on that is because they see it as a relaxation of the 3
requirements and they will find it easier to come up 4
with ---
)
5 CHAIRMAN PALLADINO:
Is it a relaxation of the 6
requirements?
7 COMMISSIONER GILINSKY:
I think so, yes.
8 HR. DIRCKSa But there are no requirements yet.
9 COMBISSIONER GILINSKYa Well, you keep coming 10 back to that, you know.
The fact is it is a relaxation 11 of what it is we intend to have out there.
12 COMMISSIONER AHEARNE:
Right.
It is a 13 relaxation of what the NRC was describing.vas eventually 14 to become a requirement.
I 15 HR. DIRCKS:
I,think we come back to that 18 question though if you want to tighten it up.
17 COHNISSIONER AHEARNE:
I am not saying it is 18 inappropria te.
19 HR. DIRCKS:
I think what we are trying to do 20 is, relaxation or no relaxation, is to pin it down once 21 and for all and get on with the job.
22 CHAIRMAN PALLADINO:
I think tha t is the most 1
23 important part of this.
24 HR. STELL0a That was the industry observation
(
25 I had, is they now saw a complete package for the first l
l l
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
76 1
time that they could move forward with, and that was I 2
think more of the reason that you had support from the 3
industry is that they now saw the whole job in front of I
4 them and they could move with it.
5 CHAIRMAN PALLADINO:
I think General Counsel 6
had a point that he wanted to make.
7 BR. BICKWITs Yes, just one point before you 8
declare yourselves.
9 CHAIRMAN PALLADINO:
Before we want?
10 HR. BICKWITs Before yo u decla re yourselves.
11 CHAIRHAN PALLADIN04 Well, I wasn't going to 12 ask for a vo'te now.
I was going to suggest that the 13 individuals go back and try to get their-suggestions set 14 forth in a way that we can try to resolve them, and 15 those of the, Commissioners that haven't voted, I would 16 nrge them to_try to vote as soon as they can after this 17 meeting and then come back for an affirmation vote.
18 HR. BICKWITs Well, one point before you do 19 all that.
20 CHAIRHAN PALLADIN04 All righ t.
21 MR. BICKWIT:
It is a point that was made at 22 the last briefing on this, which is that with the 23 modification that we propose, which I gather is 24 acceptable, I think it becomes clear exactly where 25 everything stands with regard to existing facilities and ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
77 1
with regard to existing licensees.
2 But with regard to new applications for OLs 3
and to a lesser extent with regard to new applications 4
for cps, it is still not clear to me from the document 5
as written how these requirements, if you want to call 8
them that, will be applied.
7 let me give one example.
We have a policy 8
statement for the issuance of new licenses in which it 9
said that the Commission believes that the THI related to operating license requirements list as derived from the 11 process described above, and. the process that is 12 described above is the development of 0694 and the 13 development of 0737, should be the principal basis for 14 consideration of THI-: elated issues in the adju_dicatory 15 process.
18 The Boards will not know the extent to which 17 that is modified by this particular action of the' staff, 18 on the one hand, or on the Commission, if you go that 19 vay, without some additional clarifying language.
And I 20 think sonathing has to go in there to make clear to the 21 Boards where in the hierarchy of our various documents 22 this particular document is supposed to stand.
23 To a lesser extent that is true with regard to 24 construction permits.
There we have a rule out, but the 25 rule references a NUREG. document, and it is 0719 as I' ALDERSON REPORTING COMPANY. INC.
400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
78 I
remember, and 0719 again is given some kind of special 2
status before the Boards as to what will provide a 3
reasonable basis for complying with the Three Mile 4
Island accident-related concerns.
5 Again, I think it has to be clear whether thin 6
amends that, supersedes that or is on the same level as 7
the NUREGs that are getting special treatment before the 8
Boards.
9 CHAIRMAN PALLADINO:
Good point.
10 This is geared primarily to existing reactors 11 or operating reactors?
12 HR. BICKWIT:
There is one paragraph in there, 13 and it is the second paragraph of the introduction whera But nowhere in that 14 new applications are discussed.,
15 paragraph is the subject of new applications for 16 operating licenses discussed.
There is a reference to 17 new applications for construction permits and 18 manufacturing licenses, and there I would say the 19 guidance is hazy.
But there is absolutely no guidance 20 whatever when it comes to new applications for operating 21 licenses.
22 CHAIRMAN PALLADINO:
Do you have some thoughts 23 on that?
24 HR. STELL0s We specifically looked at, and 25 this is consistent with it, and I my understanding is ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554-2345
4 79,
1 that this letter that went out would go out to all of 2
the NTOLs and some who have filed a CP.
This would be 3
part of the package that they would get as well and that 4
was the intent.
5 HR. BICKWIT:
I am sure this is consistent 6
with everything we have.
The question is what are you 7
telling the Boards with regard to the status of this 8
particular document.
With respect to OLs it is 9
completely unclear at this point and with respect to 10 cps, I think I could get something out of it if I were a 11 Board member but I would be a little foggy on even th a t 12 questions.
13 HR. STELLO:
Well, Len, is there something 14 that the staff could do to help or is there something 15 the Commission could speak to?
16 HR. BICKWITa I think the first question is 17 the policy question, what do you want to tell the Boards 18 and w'here do you want to elevate this in the hierarchy 19 of documents to be considered by the Boards?
I guess 20 what you would decide is you would want it on the same 21 level of 0737 and 0719, and under those circumstances 22 the Commission is going to have to bless this to the 23 extent it blessed those other NUREGs.
Those were not 24 just NUREGs as far as the Board process is concerned.
25 Those were NUREGs that had a very special meaning to the ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
80 l
l 1
Boards because the Commission is a policy statement told 2
the Boards that they were to have a special meaning.
3 CHAIRMAN PALLADINO:
Does it take a similar 4
kind of action to elevant this?
5 HR. BICKWIT:
It will take some kind of 6
action.
Well, one way to get that kind of action would 7
be to say in this document that this document should be 8
viewed as an amendment to 0737 and 0719 so that to the 9
extent that those items are referenced in other 10 Commission policy statements and other Commission rules t
11 they get the same treatment by the Boards.
So it would 12 net take any additional action of the Commission if you 13 vent that route.
But the first question is to make the 14 policy judgment.
15 CHAIRHAN PALLADINO:
That is not in this paper.
16 HR. BICKWITs It is not.
17 CHAIRMAN PALLADIN0s So if we move it we 18 haven't yet approved that provision.
19 HR. BICKWIT That is right.
20 CHAIRMAN PALLADINO:
Now they do say here "It 21 is intended that these f undamental requirements would be 22 applicable to licenses of operating nuclear power plants 23 and holders of construction permits for nuclear power 24 plants."
That isn't enough?
25 HR. BICKWITs No, I don't think it is.
Where ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
81 1
are you reading?
2 CHAIRMAN PALLADINO:
I am reading from the 3
second paragraph in the introduction of the enclosure, 4
right in the middle of the paragraph.
5 MR. BICKWITs That sentence relates only to 6
the holders of OLs and cps.
That sentence does not say 7
anything about applications for new OLs or cps.
Then 8
you go on to the next sentence.
9 COMMISSIONER AHEARNE:
Anybody who is going to 10 apply for an OL already holds a CP.
11 CHAIRMAN PALLADINO:
Don't they?
That is the 12 var I had assumed that.
13 MR. BICKWITs Well, okay.
But with respect to 14 how it is treated in the OL process it is unclear.
Then 15 the next sentence talks about applications for a CP or 16 an OL.
17 CHAIRMAN PALLADINO:
Yes.
18 MR. BICKWITs And that gives you some 19 guidance, but I don't think' it is clear.
20 CHAIRMAN PALLADIN0s Well, what I was trying 21 to say is do we have to get the staff to write a 22 supplement so we can approve it?
23 MR. BICKWITs I think a sentence vill do it, 24 but the first issue is to decide where you want these 25 documents to be in the scale of things.
ALDERSON REPORTING COMPANY,INC, 400 VIRGINlA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
82 1
BR. STELLO If they were considered as an 2
addendum to 737 everything would be okay?
3 HR. BICKWIT I think you need to say tha t.
4 HR. STELLO:
The Commission would have to say 5
that, that they consider this to be an addendum to 737.
6 BR. CASE:
An amendment.
7 HR. BICKWIT:
Well, if you amend this document 8
and you say that is the intention of this document and 9
the Commission approves the document I think that does to it.
11 CHAIRMAN PALLADINO So what do we have to
(
12 do?
Is it enough to get a letter f rom then saying that 13 the document is ---
14 COHNISSIONER ASSELSTINE:
If that is what the 15 Commission vants to do, just incorporate it into the 16 introduction.
17 CHAIRMAN PALLADINO:
In our approval we have 18 to say it.
19 COMMISSIONER ASSELSTINE:
Right.
20 CHAIBHAN PALLADINO:
Can we get a common 21 sentence written so that all five of us don't try to 22 vrite the same sentence?
23 HR. BICKWIT:
Why don't we work something out.
24 CHAIRMAN PALLADINO:
Okay.
25 Joe?
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
8 83 1
MR. SCINTO:
Yes, we would be pleased to work 2
with you.
3 (Laughter.)
4 CHAIRHAN PALLADINO:
Well, then I would like 5
to encourage early voting on this and then when we are 6
all agreed we can confirm in an affirmation.
7 Is there anything more that we should discuss 8
on this point?
9 (Mo response.)
to CHAIRMAN PALLADINO Well, thank you very much 11 for responding to our questions.
12 We vill stand adjourned.
13 (Whereupon, at 12:22 p.m.,
the meeting i
14 ad jo urned. )
15 16 17 18 19 20 21 22 23 24 25 ALDERSON REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W WASHINGTON. D.C. 20024 (202) 554-2345
o e
,m UUCLZAR mA9E CSFJSICN D is la Oc certif7 chat the. attached proceec.1:gs *:efere the COMMISSION MEETING in the satter cf:.
Public Meeting - Discussion and Possible Vote on SECY-82-111 Requirements for Emergency Response Capability USU4 Cf FPCCtediOg:
June 14. 1982 UCckat flMher; 1
F12C4 Cf PPCCeedisg:
Washington, D.
C.
~4& t held as hertir appears, and cha't. thi.5 is the cri41:21 0;Ensed therscf for ;he CLLs ci che C2-* stica.
\\
Mary C. Simons Official Espartar C7;ed)
M ri M r
Officisi Repceter (Signature) a h
o
-A l
w
_/L(f
-l TPJNSMITTAL TO:
Document Control Desk, p
016 Phillips
,j p
PS ADVANCED COPY TO:
O The Public Document P,oom b!/
M 4
DATE:
cc: OPS File From: SECY OPS Branch
,)
. Attached-are. copies of a dommission meeting transcript /s/ and related meeting documen't/5/.
They b
are being forwarded for ent.m.f on the Daily Accession IE:)
List and placement in the Public Document Room.
No P
other dis'tribution is requested or required.
Existing documents wh rever known.~.
DOS identification numbers are listed on the indivi, dual
~
p Heeting
Title:
5G45 son M
$55 h @ h/}h O "
h Ql.$RGuf4015 uf SerkesvA -
' 6# 7 e
r h;r Sk W C1osed DOS C05IES:
. M :G DATE:
Copies (1 of each Checked) b TEM DES TION:
Advanced May p
1.
W
- Original be DuplicateCE s
To PDR:.
- Document Dup
- Cocy* $
/
1 g
9
.g 2.'
act b
3.
d
~
4.
~
~
.h 5.
E h
S
?
- Verify if in DCS, and h~
ch'ange to "PDR
~
(PDR is advanced one of cac'h document, two available."
of each SEcr paper.)
i l