ML20126M103

Transcript of 810527 Public Meeting in Washington,Dc Re Discussion of Secy 80-20D, Policy on Proceeding W/Pending CP & Mfg License Applications. Pp 1-37

ML20126M103
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Issue date:	05/27/1981
From:	NRC COMMISSION (OCM)
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ML19240C082	List: ML19240C081 ML20126M103
References
FRN-45FR18045, REF-10CFR9.7, RULE-PR-50 SECY-81-20D, NUDOCS 8106110417
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{{#Wiki_filter:- a i g .1 9. NUCLEAR REGULATORY COMMISSION c. / (. In tie maw" of: PUBLIC MEETING DISCUSSION OF SECY 80-20D - POLICY ON PROCEEDING WITH PENDING CP AND ML APPLICATIONS ( gag. May 27, 1981 pgggg 1 em 37 g.. Washington, D.C. l l 1 .LLDERSON ' REPORT 1XG C ~ 1 4o0 vi.:r_ ia Ave., s.w. wae.ingsen, c. C. 20024 l Talachene : (200) 554-2245 8106 110917 r, THIS DOCUMENT CONTAlf4S POUR QUAUTY PAGES A

l I RILEYl' [ UNITED STATES OF AMERICA 1 NUCLEAR REGULATORY COMMISSION 2 3. 7.. s PUBLIC MEETING 4 = 5 'd 8 6 = l DISCUSSION OF SECY 80'-20D - POLICY ON PROCEEDING 7 WITH PENDING CP AND ML APPLICATIONS n j 8 ~d ci 9 Y 10 Z Room 1130, jj 1717 H Street Northwest, a d 12 Washington, D.C. 3 Wednesday, May 27, 1981 13 5 l l 14 l 2 15 The Commissioners met at 2:50 p.m., pursuant to E. 16 notice, Joseph Hendrie, Chairman of the Commission, presiding. 3 ai g 17 PRESENT: 18 : JOSEPH HENDRIE, Ch airman. = JOHN ABEARNE, Commissioner. PETER BRADFORD, Commissioner. 19 _ l VICTOR GILINSKY, Commissioner. 20 PRESENT FOR THE OFFICE OF GENERAL COUNSEL: 21 LEONARD BICKWIT, Esq. 22 MARTIN MALSCH, Esq. 1 PRESENT FOR THE OFFICE OF THE SECRETARIAT: 23, 74 l SAMUEL CHILK, Secretary. l i 25 i i ALDERSON REPORTING COMPANY, INC. ]

2 1 PRESENT FOR THE NRC STAFF: g 2 R. PURPLE H. DENTON 3 E. SHAPAR D. EISENHUT 4 W. DIRCKS R. BERNERO g 5 R. MATTSON R C. THOMAS 3 6 a w ) 8 dd 9 Y 10 i' j 11 a y 12 g 13 ( -g-x l 14 m 2 15 g' 16 w 6 17 u !B 18 19 R 20 21 22 ,C 23 j 24, t 25! 1 ALDERSON REPORTING COMPANY,INC.

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3 1 PgQg((QlEgg 2 CHAIRMAN HENDRIE: Why don't we go ahead and get started 3 The Commission mets this afternoon to be briefed by pI 4 the Staff on comments on a proposed rule for construction permits o. 5 and manufacturing license applications. h . ] 6 We have had the proposed rule out for comment, I think R 7 it. went out for, what, 30 days? A ) 8 MR. SHAPAR: 20 days. d q 9 CHAIRMAN HENDRIE: And this is the first opportunity 10 to hear a Staff summary of the comments, and also any changes i g 11 that the Staff might recommend in the rule, a chance for 3 g 12 Commissioners to ask some questions about the proposition. Sg 13 I will warn those who came all prepared for'a final s mj 14 action, so that if they wish, they may leave and go immediately 2 15 to their swimming pools -- g 16 (. Laugh ter. ) as 6 17 -- that I will not be asking the Commission for a E E 18 vote on this rule this afternoon. E 19 Having thus disappointed some, delighted others, M 20 and generally antagonized the rest -- i l 21 (Laughter. ) i 22 -- I will ask Mr. Dircks to start the discussion on 23 the 3taff side, i 24 } COMMISSIONER AHEARNE: I half expected Bill to get 25l up and say, "Well, if that's the case, I'm going to the pool." l l l ALDERSON REPORTING COMPANY,INC.

4 I 1 (Laughter. ) 2 MR. DIRCKS: Well, we'll press on. I have a very ) 3' short discussion. Bob Purple will review the' comments that o 4 have come in, and also outline where the suggestions have been e-5 made for adding or-subtracting from the rule discussed severa'. 5 i [' 6 weeks ago. .g 7 (Commissioner Bradford entered the room at 2:52 p.m.) l 8 MR. PURPLE: All right. Put on the first viewgraph, {

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~k 10-(Slide.) ax3 -{'11 You should have had a handout of these very brief 5- [ 12 slides, and this will be a representation covering three copics ~. S 13 as shown: y a l 14 One, the question of whether or not to include the g 15 E application. I'll review the comments that were received on x j 16 that point. i d I ti 17 Then the bulk of all the other comments and responses,

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$5 18 how we handled those, and then to apprise you of some late I comments that we received after we closed the document thatowe 19 20 sent down to SECY, 80-20D. 21 Next slide, please, 22 (Slide. ) p. w 23 Of the 33 comments that we did receive in time to 4 put in 80-20D, 20 of those 33 have something to say about the E 24 25 application. I ALDERSON REPORTING COMP ANY, INC. _i

5 I l i ) of the three late comments that I'll talk about in a 2 little while, two of those three had something to sef. So.of the 3 3 22 that had something to say about the ML application, 18 were l l 4 in favor of its inclusion in this rule without qualification; l 5 three were in favor of inclusion, but not at the expense of = k l 6 ' delaying the CP rule; one was opposed, Mr. Marvin Lewis. R l 6 7 As explained briefly in the Staff paper, SECY 80-20D, i ] 8 the Staff has found no compelling technical basis that would d j 9 justify excluding the ML. l b l 10 All of those comments are in Enclosure 2 to the i E I 11 Staff paper that came up. j 12 Next slide, please. 5 13 (. slide. ) g = l l 14 Now the bulk of the comments and responses are ( g 15 found in about, I guess, 36 pages worth of Enclosure 3 of the l ) g 16 SECY paper, and for convenience we have included them in l d 6 17 to this package which is a tabular presentation l 18 of those changes that were more or less just purely editorial or h 19 typographical. We call them more significant changes. And of 20 that set, the three that are probably the most significant -- 21 and I want to mention on this. slide -- were the three that were 22 deleted as either a direct result of Staff consideration or 23 comments with which we agreed, and those three are listed on the 24 slide. l 25 The II.." .44 item is one for which we agreed that ALDERSON REPORTING COMPANY, INC. i

6 I we would get no new data from any of the BWRs that are applicants 2 for cps now.- We have generic studies in hand and are reviewing it i 3- .and it would serve no useful purpose to require these cps to .4 .'re-do that'same study. =- 5 Item-II.E.5.2, B&W sensitivity to transients. This l 6 is a study undertaken which resulted in the issuance of NUREG R 7 0667, which itself had a long string of recommendations in it X l 8 that as we now reach the wire and realized as we were putting d- ,d 9" this into the regulation, we don't really have all the subtasks z l ' h -10 of. that NUREG well defined, and decided on in terms of how -E. m 11 soon things need to be done, or whether they are already covered l is 7 f;12 under other items on the action plan. [ 9 5 13 It appeared out of all the items that were recommenda-I a 14 tions'in the NUREG 0667, probably are in fact already covered $l 15 by the items in the action plan. -The rest are of low priority, m g.16 and we haven't exactly.. decided yet how soon they need to be ai 6 17 applied. y: Ni 18 The most prudent thing, we thought, in this case, was 0 19 to pull that item out. It would have been hard to meet as it 20 was stated. 21 II.K.2.11, this is the one that's been in the m

ion 22

~ plan all along. It's the one where a very specific component 23 was identified as having f ailed' the test, and the action plan 24 < item will say, "If you have this particular PORV, justify its t 25 . use.'. ALDERSON REPORTING COMPANY, INC.

l 7 1 There have been a lot of complaints that that was 2 way too specific and too pointed a thing to put into the 3 regulations, and considering the f act that if anyone used such a 4 valve, the PORV test program would cover it, and either demonstrate e 5 that the valve was all right or not, so we didn't see a need h ^ ] 6 to keep that item in. 7 The remainder of the type of changes that we talked ,f8 about in Enclosure 5 are really mostly clarifications, making d things more in line with what was in the action plan, making it c 9 10 more clear and direct response to public comments. 3_ ll Next slide, please. 3 Y, 12 (Slide.l S 13 I hope you received yesterday -- if not yesterday, 5a l 14 early this morning -- a four-page summary of these late 13 comments from these three commentors. A more complete descriptiom si 10 is found in that handout. as N 17 Department of Interior is concerned that we didn' t U { 18 seem to speak in this rule about the new siting policy. They E have words that talk about the siting regulation, the public 19 l g n 20 laws, and so forth, which we think would respond to that comment. The Department of Energy, generally speaking -- it 21 was a long letter, but I think we captured it on there with the 22 23 five bullets. We ogght to defer things to the pending rule-making; we are much too prescrip.ive in this rule; we shouldn't 24 such as the CRBR. 25 apply this to advanced reactors, l .ALDERSON REPORTING COMPANY,INC. h

8 t i 1 Incidentally, that's one that we did respond to in 2 time to have it in this paper. 3 ' You will notice that in the statement of applicability ~ 4 in this rule, instead of just saying pending cps, we now have 3 '5-defined who the'pending cps are by listing the six cps and'the = (6 E,. and that provides c ery thick set which excludes the CRBR, R 7 and the final DOE substance of comments was that the E and CP X 4] 8-requirements should be the same. d,

1 9

Seminole Electric Cooperative, as'shown, their only z h 10 comment was include the E application in the rule. z= 11 The only final comment I would make is I don't think is ( 12 we mentioned it in the commission paper, but it is in the 5 ll3 13 supplementary information of the rule. You may recall we issued a l 14 a NUREG document 0718 which set the foundation for this require-i j 15 ment that led to this rule. Now that we have revised the rule N g[ 16 in a number of places and deleted some items, it makes sense to d l 17 go back.and bring 0718 administrative 1y up to date to conform Ej 18 with whatever the final rule looks like. And we have that i h 19 a underway as an administrative conformance type of thing. l 20 Any further changes to the rule, we would have to 21 revise those, so they would both go out at the same time. 22 That's under the concept the NUREG document sort of takes the i ,y 23 . place of a reg guide in the sense of providing further 24' clarification to the items that are in the rules here. So that 25 is underway and would be a necessary, we think, thing to do, if i ALDERSON REPORTING COMPANY, JNC. 1

9 1 and when the rule is issued. 2-MR. DENTON: I'd like to add just one comment. At 3 the last meeting it was suggested that some Applicants may wish 4 to submit amendments to their application, assuming the proposed e 5 rule was about right. Two Applicants have done that. We h'] 6 have essentially completed our review of one application against R 7 the. proposed. rule and are a third to a half of the way along Xl 8 -on the second application. d ci 9 COMMISSIONER GILINSKY: Which are those? z 10 M".. PURPLE: Pilgrim 2 is the one that's essentially = II' through, and Allens Creek is about a third or half the way j 12 through. '5 - (j-_ g 13' CHAIRMAN HENDRIE: As a matter of fact, you're h 14 conforming 0718 to what we currently think the rule ought to be, g 15 so I can regard those as sort of alternate versions of the same a g 16 guiding propositions for cps and MLs. as f I7 I see no reason if you find it useful and timely to u h 18 do so, I see no reason why the Staff could not go ahead on the l k 19 g basis that you think is what cps and MLs ought to do about n 20 Three Mile Island, and go ahead with the reviews, and in fact, l 21 go on into hearing with a position. 22 MR. PURPLE: We had planned to issue the revision ( 23 whether or not there's a vote on the rule, because it does - 24 represent our best technical position of what the requirements 25 and it's the best document available with all the

are, ALDERSON REPORTING COMPANY. INC.

10 1 references for guidance. ) m 2 COMMISSIONER GILINSKY: Are they otherwise on hold? 3 CHAIRMAN RENDRIE: Well, I thought I would start t 4 that line of discussion just so that we either decide whether = 5 they're on hold. Ej. 6 My impression is that they are not on hold, but in Rg 7 case there was an impression that they were, why, good, let us Xl 8 be clear that the Staff is not'on hold. If they want to go ahead d~ d 9 like this, my own view is it's a reasonable thing to do. After ~z h 10 all,'the Commission might very well have decided a couple of El 11 months ago to go for construction permit applications the same 3 g 12 direction that we started out going for operating license 5 13 applications, (' g. a 14 That is, to publish a policy statement which said, W 2 15 "Look, here is Staff digest of requirements," in that case 0737, _. E 16 in this case it would be 0718, "which the Staff thinks adequately g .m 6 17 meet the nee.ds revealed by Three Mile Island. The Commission L l 18 in general agrees, and we urge people to go forward." They L r

1. ' 19 might very well have done a construction permit policy statement X

i 20 of a very similar framework to the one for operating license 21 matters, simply referencing a report on 718 as appropriate, 22 and I haven' t sensed any position among the Commissioners that 23 they disagree with the fundamentals of the technical positions l 24 involved. 25 We do clearly have some differences of opinion: I ALDERSON REPORTING COMPANY. INC.

,a 11 'l' (a) whether this proposition should 'be a rule, or should be ( 2 handled as the OLs were, by policy statements; and we say, " Good,

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- Staff has a position, we think it's a reasonable one, go. forward," p \\ 4 whether we. should have a rule -for that. j i 4 5 There are also some differences -- there-may be some l l l' ] 6' - differences between us on whether we include the MLs in or r 7 don't include them in and maybe even there could be a couple of Xl 8' other items. But basically I think we are not in any fundamental .d ci '9 disagreement.on the technical safety provisions. It seems to me 2 h 10'l we've had a long and fruitful discussion, in fact, on those E lI ' matters. ~ m . 5/ > 12 Commissioners, please tell me if I' don't read the x+ ( -- :15-13 situation correctly. i m' l 14 COMMISSIONER BRADFORD: Well, I think that's right. { 15 - I-have a query or two, but it doesn't certainly rise to the level-a / 16 of taking issue with the technical safety judgments. i . ad h 17 CHAIRMAN HEN'DRIE: Okay. With that understanding, a 18-then, why don't -- John has some questions he wants to ask. You're E 19 leaning forward to your mike. Why don't you go ahead, Peter? 20 COMMISSIONER BRADFORD: On page 63, in the item 21 labeled 1, it indicates that the application has to describe a 22 set of studies and the way they are to be conducted, and then 23 there's a list of ' items underneath it. 24 Do you construe that as requiring that the studies I ' 25 .be done? ALDERSON REPORTING COMPANY, INC. pg+ -se s y 7 --'-I --9 y 'g=e'W*w'**T* '1 wr y e v 10 -e +*-Hv+ .-~F' e

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12 MR. PURPLE: It was certainly our intent. I think j 2 our legal advice told us that was the case. COMMISSIONER GILINSKY: Starting when? 3-4 _ COMMISSIONER BRADFORD: That was the next question. = 5 MR. PURPLE : It was done on an agreed-to submittal 3-j 6-date.- In other words -- e 7 COMMISSIONER AHEARNE: From the way that you have 8 it written up in ' the supplementary, and some of the : comments, I d d 9 gather you do not' intend to require that be done prior to the CP? li h 10 'MR. PURPLE: That's correct. If they're in this iE I section. 11 r4 12 COMMISSIONER GILINSKY: I thought the whole point of Z_ it was to have some influence'on the design of the plant, so 13 5 E 14 it's got to come -- 5 15 MR. PURPLE: Which is why we want to ,i 3R.DENTON: I didn't see it quite that way. 16 is m CHAIRMAN HENDRIE: It's got to come before the OL. [ 17 l. l;; 18 COMMISSIONER GILINSKY: But it was hhrds to put some b 19 boundaries on it. R 20 MR. DENTON: The key was that it be used to guide I 21 the design and not be an af ter-the-fact reliability assessment t 22 of what we originally proposed, but to be a tool in the design; 23 if there are unique features, that these be looked at as a guide ' n design. i i 24 25 So we saw it being a phase process, and that's why we l-ALDERSON REPORTING COMPANY, INC. L

13 I were going to get, before issuance of the CP, a description of 2 the program in sufficient detail to be sure that it would mesh 3 chronologically, to provide that sort of assurance. 4 COMMISSIONER GILINSKY: Whether you require it or not, 5 I think you'd be encouraging them to get going on it as rapidly 6 as we can. R b 7 MR. DENTON: Yes. N j 8 COMMISSIONER BRADFORD: But what is it that requires d c; 9 the study actually'be done? Maybe I am splitting hairs here, z 10 but what the language requires is a description of the study. = Il CHAIRMAN HENDRIE: A study to be done, is 9$ I2 COMMISSIONER BRADFORD: Yeah, but where does it say E ( 5 13 that? m l 14 MR. PURPLE: It's in the opening phrase. It says g 15 "to satisfy the following requirements," and then each requirement-m ij 16 is listed for study and so forth, as h h II COMMISSIONER AHEARNE: I guess the distinction would x h 18 be on -- on page 66, you have other requirements which say the i:: } 19 required actions must be completed by the OL stage. Couldn't n 20 you pick up something in some similar phrase to say that af ter 21 l you have finished this -- 22 MR. SHAPAR: If you look at the statements on page 61, 23 you will find -- 24 MR. DENTON: I think, knowing what your concern is, 25 I that OELD can make it clear. I ALDERSON REPORTING COMPANY, INC, o

14 I CEAIRMAN HENDRIE: Sufficient information to 2 describe the nature of the studies and then just add "to be 3 done" or to be done -- m 4 COMMISSIONER AHEARNE: To be completed prior to g 5 operating license. 8 6 MR. PURPLE: It's our intent, and I thought it was 7 in the package -- I'm having trouble finding it now -- that M j 8 in fact these requirements would be listed with dates, d C 9 COMMISSIONER AHEARNE: Yes, back up in the supple-Y 10 mentary, I think Peter and I were just addressing what the E 11 rule says. There is another, later on, explicit statement B I 12 that something will be required to be done by a given date. ~c 13 COMMISSIONER BRADFORD: There is a problem here, I Jg m l 14 guess, in the way you phrased it, it doesn't require it to be 15 done by a given date. That is with the OL you can either say g 16 it's got to be done by OL issuance. Here what they are after w d 17 is to be sure it's done by a date such that the results of E a 18 the studies are f actored into the -- ~ i: l9 MR. EISENHUT: It was our intention in the discus-g n 20 sions when we discussed this all along of when can you have 2I these requirements -- first, make it clear they are requirements 22 and then have the results submitted, and we think on the order 23 of two years after the CP. You want to be sure the studies get done in time to influence that piece of the design of the 24 You don't want to wait 25 plant that they are really evaluating. ALDERSON REPORTING COMPANY,INC.

15 I necessarily until the FSAR is submitted. So we tried to break 2 - the middle ground, and we looked at something like a couple of 3 years in the process. 4 COMMISSIONER AHEARNE: You intend to put them in is 5 the tech specs or license conditions? hj 6' MR. EISENHUT: In'the license conditions. We would R b 7 specifically put in all these things as CP license conditions Xl 8 which is, of course, a new way of putting it. d 9 COMMISSIONER BRADFORD: Let's see. That, of course, 2 h 10 would cover it as long as you get some -- why would you not 11 just say here "to be done within two years of the date"? E I I2 MR. EISENHUT: I think we certainly could. Sg 13 MR. PURPLE: But you have different planess.id final m l 14 design of the set of plans we are considering, some are well g 15 along, some daat are -- some we may want it sooner, based on a g' 16 what they tell us, so it's hard to pick one date that will fit e f 17 everybody. = 18 . COMMISSIONER GILINSKY: What sort of an effort do you c 19 envision that a study like this would involve? 20 MR. DENTON: I think it would involve a similar effort 21 to the Limerick type study which is drawing event trees, fault 22 trees, and determin@ng which system failure as compared to the 23 rest, and then some reiteration process, to try to lower those 24 that we found to be outlined. 25 MR. EISENHUT: You recall, of course, that the Indian ALDERSON REPORTING COMPANY, INC.

16 1 Point-Zion studies are being done, the Limerick studies. They 2 are turning out to be multi-million dollar studies, and dealing 3 with multi-manyears of effort, tens of manyears of effort, so 4 that they are quite major studies. They are not the kind of e 5 thing -- and they take a long period of time drawing up the 3 6 event trees, the fault trees. They are not the kinds of things R 7 that can be turned around overnight. M] 8 You remember, we issued some requirements on dd 9 Limerick and asked them to do it in a short period of time, i h 10 something on the order, I believe, of six months, and they 3l 11 came back and just said it couldn't be done in that short a 3 y 12 period of time. 5 13 We have been having progress meetings with them. l 14 Similarly, Indian Point and Zion, we are doing 2 15 probabilistic studies. It's a major program. g 16 MR. DENTON: It's a system-by-system analysis. e d 17 Does that answer the -- 18 COMMISSIONER GILINSKY: Yes. k 19 MR. DENTON: It's sort of comparable to WASH 1400 in g M 20 scope. 21 MR. BERUERO: I'd like to volunteer an opinion. 22 This is a point of some controversy as to how much is really ~../ 23 necessary. If you go at the major risk assessment studies 24 being done right now in industry, like Zion and Indian Point, 25 you are dealing with something in the range of 30 or 40 or 50 ALDERSON REPORTING COMPANY, INC.

17 1 manyears, quite expensive. In the IREP, UREP, we are trying to s 1 keep it down below 10 manyears and still have an effective reliability study. 4 I consciously used the word " reliability" as e 5 g against " risk," because you put the emphasis on system analysis, 6 system failure modes, the things that can be factored into a n R 7 design, that can change the design and improve it, rather N j 8 than the thanatology of drawing risk curves. d 9 g So I think, you know, in an ideal world where we h 10 g get some experience with and some judgment on procedures, and 5 11 j quality assurance on what'we are doing here, I think something d 12 E in the realm of 10 manyears or even less can cover the plant. 9 13 j COMMISSIONER BRADFORD: Was that word " thanatology," E 14 g study of death? 2 15 g (Laughter.) ~ 16 MR. BE RNERO : Yes. d 17 w MR. MATTSON: Can the other half of the mutter talk = 18 a minute? We were arguing. 0 19 l (Laughter.) 20 l These are cps and these plants are still on paper, 21 NREP and IREP are plants that are built predominantly, and maybe ~ 22 _j it won't be 50 manyears like Zion and Indian Point, but I doubt l 23 it will be as efficient as NREP and IREP for plants that are 24 already built. These are paper plants. We do intend the study 25 to be before the final design is frozen, while there still are ALDERSON REPORTING COMPANY,INC.

l 18 I options to do things. We thought that's what was intended, to 2 take advantage of some flexibility for these cps as a condition 3 of giving them cps. . (3 ' 4 COMMISSIONER GILINSKY: So in some sense there may be 5 some advantage in a less ambitious study that comes to some ] 6 conclusions earlier? f t b 7 MR. MATTSON: We are balancing the two. Ml 8 CHAIRMAN HENDRIE: Peter, are you thumbing your pages d 5 9 I o r -- z 10 COMMISSIONER BRADFORD: No, I'm exhausted. l k Il CHAIRMAN HENDRIE: John? is f I2 COMMISSIONER AHEARNE: First I'd like to start C 13 the question by asking Bob Bernero a question. l 14 This relates to the provision you have in the rule, g 15 I think it's on page 73, or we have in the proposed rule, on the-m j 16 three-foot diameter opening, and I guess the question is, Bob, as I7 with respect to as far as to the extent that we or contractors x IO have looked at filtered vented containment, my understanding was k 8 that its potential as a real advantage, if there is a potential n 20 for real advantage, is for small containments, rather than the 2I large containments. (~, Is that not correct? Or is that incorrect? 23 MR. BERNERO : In a comparative sense, yes. It is a 24 device to enhance the containment capability, and therefore 25 the less resilient or the less capable the containment, the more ALDERSON REPORTING COMPANY, INC.

I 19 j thefdevices work. It's sort of a diminishing return as you go 0 2 to the large dry containment. And some three months ago, or if 3 whatever it was, we took a short term look at the information 4 available to date, and we just looked at the tiark III containment l and the ice condenser. We didn't look at the large dry, really. 5 e 5 6 And we identified something like a three-foot hole that could be 7 a genuinely effective thing. t 8 That doesn't mean it's not effective in the large l d

i 9

dry. It just is found to be less effective, all else being j. 2? h 10 what it is. } E I 11 COMMISSIONER AHEARNE: Right. Now given that it may I ci 12 be less effective, and I switch over to Harold or Darrel or Bob, E ) in a large prestressed concrete configuration, putting in a

5. 13 three-foot hole is a nontrivial -- plugging up a three-foot hole,I E

14 w b N 15 if you decide you don't need it, is substantially more non- _l g' 16 trivial, and I just wondered, have you thought about not having ai g 17 that requirement for the large containment? -o 18 MR. PURPLE : Ziay I answer a different question? = b 19 CO!2iISSIONER AHEARNE: Sure. R 20 MR. PURPLE: First of all, we don't require a 21 three-foot diameter hole or some equivalent. It could be a 22 number of smaller holes, like three at one feet or something. 23 We do -- 24 CHAIRI1AN HEUDRIE: I'm not sure the area scaling 25 goes -- ALDERSON REPORTING COMPANY,INC.

y 1 (Laughter. ) 2' -- or whatever. 3 (Laughter.) 4 COMMISSIONER AHEARNE: Yes, I'm going to -- you're e 5 not going to introduce any other engineering _ calculations, are hl 6 you? R { 7 MR. PURPLE:'No. Nl 8 CHAIRMAN HENDRIE: It's a pity to go away from this d ci 9 when it's the first one we've had in a long time that the 10 Commission is fully competent to deal with. E j 11 COMMISSIONER BRADFORD: That went right by me. in y 12 (Laughter.) 1 g 13 CHAIRMAN HENDRIE: I take back my remark. Go ahead. m 14 MR. DENTON: Bob, let me answer first. The origin of g 15 this was we didn' t warit to foreclose that this might turn out m if 16 to be the greatest way of improving risk that had been identified d l l t[ 17 It was recommended by the ACRS at one time that we require N 18 design studies of such plants be done. So we sort of thought c t. 19 we were going halfway there by providing capability for it, g 20 and then when the question did arise in the course about 21 the penalty for putting this in, Bob does have some statistics 22 on the present size of holes in large containment, and there l 23, are quite a few of much larger size. Maybe you can cite some l l 24 of those. ~ 25l MR. PURPLE: We took a look at the design j 1 i ALDERSON REPORTING COMPANY, INC. i

21 1 containment which is prestressed concrete, looking for how 1 .. s 2 many penetrations there were above 12 inches, or 12 inches and 3 above..The total number was on the order of 200 such penetra-4 tions exist in that plant. = 5 The numbers run between 12 and 16 inches, 114; h I ]~6 penetrations between 16 and 24, 52; between 24 and 48 inches, R 7 23;' and there are six that are 48 inches and above. So one 'W l l 8 Lmore didn't seem like it was a major change to the design. O m; 9 CHAIRMAN HENDRIE: Is that design typical? z h 10 MR. PURPLE: As best I can tell, yes, it's typical 3= 11 of the prestressed concrete. 'd. l 2 CHAIRMAN HENDRIE: John, I don't think it's a trivial 5 13 cost.because you've got'to -- for this purpose you've got to get (s _ _g m l :14 yourself a big f abrication made, steel f abrication, you know, 15 with a flange cover and the whole thing and work it into the 7 16 3 wall, and run the rebar and stuff out, but three feet isn't I N 17 that bad. l 18. I'd love to have, for instance, for personal use h 19 g the dollars it will cost, but as an engineering matter and on n 20 the scale of these plants, why, I don't think it's an excessive 21 sort of burden. 22 COMMISSIONER AHEARNE: Going back to the DOE comment u.- 23, on the CRBR, I realize that in the statement for consideration, i I ' 2<4 that you have said here are the six. However, the rule itself 25 says that each applicant for a construction permit whose i i ALDERSON REPORTING COMPANY, INC.

1 I' 22 l ? I application was pending as of the effective date of the rule a 2 shall meet the requirements. 3 MR. DENTON: We ll, let's first discuss whether you ~ 4 think it should or shouldn't apply. We thought that we should e-5 apply. hj 6-COMMISSIONER AHEARNE: It seemed to me that the way R 7 the rule itself was written, independent of the fact you have X j l 8 listed six some place else, the way the rule was written, my d C; 9 understanding is there still has been application pending. 2 h 10 MR. DENTON: We meant to exclude it because the i j 11 requirements are really for light water reactor designs. 3 j 12 COMMISSIONER AHEARNE: I understand that. Sg 13 MR. DENTON : And so if it's not clear, we attempted m l 14 to make it clear in the change. g 15 MR. SHAPAR: We can make it clearer. i d 16 COMMISSIONER AHEARNE: Well, I would have thought M g 17-that would have been in the rule. 18 (Laughter.) l E 19 g I should have a list somewhere of things that you n 20 would agree to. 21 (Laughter.) 22 Let's see, could you just briefly remind, because I 23 have forgotten, on page 67, in the rule, in the limits to 24 radiation exposures to individuals taking the samples we use i 25 l of 5 rem whole body or 75 rem to the extremities, and I have i ? i l ALDERSON REPORTING COMPANY, INC. l c

1 i 23 I forgotten where. those numbers came from. I would appreciate it s 2 if you would just remind me. 3 MR. DENTON:- I believe they are out of the annual 4 exposure' limits, Part 20. f f 5 MR. THOMAS: GDC 19, I think, specifies it for the h 0 control room. Cecil Thomas, Division of Systems Integration. Rb7 I believe GDC 19 addresses these limits, either directly or by X k8 reference to Part 1. They are consistent with the regulations, d SotheyarePart20regulationsf d 9 COMMISSIOITER AHEAR!iE: z j 10 you say. E l h Il MR. THOMAS: Definitely GDC 19, and I believe Part is f 12 20, also. ^ 3 13 COMMISSIONER AHEARNE: Could you check that, and g 2 I4 if it isn't, would you give me a call? Otherwise. l r 15 On page 39, there is a discussion of control room ~ ij 16 design, and you pick up some comments made by commentors, and so e h I7 you have changed basically two words. One, previously where x IO applying, and now they reflect the state of the art. 19 8 And, second, instead of giving it to us for approval, n l it is now for Commission review. I didn' t really follow the 20 21 argument that you made in the comments as to why those changes 22 were made. 23 MR. DENTON: I think what we had in mind is that 24' we' haven't developed yet a standard review plan for control 25 rooms, and therefore approval meant that it might have to be ALDERSON REPORTING COMPANY, INC.

I i 24 approved prior to issuance of the CP. 2-What we want'ed to have required there is that some-j 3 time as this plant is under construction, or before ' they 4 actually mcke their mock-ups and commit to a design, that. they = 5 g submit for a. review, if they -- at that time we don't think it 6 1 reflects state-of-the-art requirements, we would deal with it a R 7 case by case, al 8 COMMISSIONER AHEARNE: But earlier in discussing 1 I d d 9~ these analyses, I think we all agreed that there are some things t o 10 z that don't have to be done by CP. =E 11 j MR. DENTON: Yes. c 12 Z COMMISSIONER AHEARNE: That isn't the issue.- The S R. 13 issue, I think, is that when they have gone through their / \\ E 14 g design and they send it to us, do we approve it or do we review 2-15 g it? And there is a subtlety here. We have changed from T 16 - ] approving it to reviewing it, and the argument seemed to be 6 17 made that says the approval has specific legal connotations wx 18 = in the engineering area. 19 l MR. PURPLE: Well, I didn' t see that we were restraines 20 I didn't think we were restrained. Then that would have to be 21 found acceptable to us. 22 L COMMISSIONER AHEARNE: It would have to be 1 23 acceptable to us. We would have to approve it. L 24 MR. PURPLE : I don' t believe we approve designs. 25 In that sense the concern here is that you approve it, what was l l ALDERSON REPORTING COMPANY, INC, ,. _. ~. _ i

~ i i 25 1 pointed out to us, you have bought certain legal responsibilities 2 for its behavior. 3 CHAIRMAN HENDRIE: Well, John, you're running into a 4' certain amount of trade practicein the language. Approval of 5 a design, in fact, is what I do when I get out my professional = b 6-engineer's stamp and emboss the drawing and initial the stamp. R T.2 d 7 Now in the commonplace of the language, we regulate X .] 8 or approve an application, or the Staff approves'it. I guess d ci 9 they are just trying to avoid the implications of the formal z h 10 engineering approval under state laws. = II COMMISSIONER AHEARNE: Do you mind if I get a second is j 12 opinion? 5 l-5 13 CHAIRMAN HENDRIE: I wasn't attempting to stop you i a t l 14 from getting a second opinion. { 15 MR. SHAPAR: I agree. i 16 (Laughter. ) a$ , ( 17 CDFMISSICNER MEAR1E:.! So when you say the connotations x 5 18 in the engineering area, that's what you mean? E g CHAIRMAN HENDRIE: We've got to stop having these l 19 n ~ 20 meetings where Harold has gone to lunch. q 2I (Laughter.) 22 COMMISSIONER AHEARNE: Howard, is that correct? 23 ! MR. SHAPAR: Yeah. l 24 (Laughter.) 25l COMMISSIONER AHEAaNE: So that if we were to put , ALDERSON REPORTING COMPANY, INC.

~. 26 1 " approve" in there, it would mean that the Staf f would have 2 to. officially agree? 3 MR. SHAPAR: Yes. 4 COMMISSIONER AHEARNE: And if we put " review," they e 5 g do not have to officially agree? 6 MR. SHAPAR: Correct. _n R 7 COMMISSIONER AHEARNE: So we have, by the change, e 8 decided that the Staff does not have to officially agree? d. ci 9 i MR. SHAPAR: Because the Staff has all the leverage o g 10 z during the review at the operating license stage. j 11 COMMISSIONER AHEARNE: I understand that.

g d

12 i z MR. SHAPAR: So I don't think that's the same thing - k.. 2 13 5 as a private matter. And I think clearly so. l 14 COMMISSIONER AHEARNE: All of that makes me a little l g ,2 15 g uneasy about why we are no longer approving it. T 16 l l What is the distinction between " reflecting" and ti 17 g " applying"? Ni 18 = MR. PURPLE : Well, the argument was that the use of 19 l the word " apply" meant that every single conceivable state-of-the-l 20 art human factors thing, even if they might be contradictory 21 somehow, had to be applied to this thing, and the argument of a l 22 l possible conflict or contradiction led us to back off and say i' 23, r okay, we reflect rather than apply. 24ll COMMISSIONER AHEARNE: I'm not much more comfortable l 25 with that than the other. l-ALDERSON REPORTING COMPANY. INC.

.~ L ) 27 1 All right. On page 33, if we get the rule out,.I 2 would give you three options: 3 Option A is-to keep the first sentence under '4 discussion.as it is, and I'll take a dissenting footnote. = 5 Option B coul'd be that the Commission Staff notes; h j 6 or Option C could be - the Commission notes that the methodology R R 7 may be available in several years. ) 8 CHAIRMAN HENDRIE: The clear solution of that is d ci 9-that the Commission, except for Mr. Ahearne. z . h 10 COMMISSIONER BRADFORD: Or the Commission notes that E h 11 - its staff. is y 12 (Laughter. ) 5 -( 5 13 COMMISSIONER AREARNE: I just don't think that g l 14 you' re going to get that methodology available in a year. Y -.,15 That's, I think, fairly optimistic. g 16 (Laughter. )

d b~

17.q CHAIRMAN HENDRIE: How about not inconceivable that E 18 it will be? 5 19-(Laughte r. ) 20 Could be. 21 COMMISSIONER;AHEARNE: Page 45. 22 COMMISSIONER BRADFORD: That depends on how you define s 23 l year. 24 (Laughter.1 25 COMMISSIONER AHEARNE: We could do as they do in ALDERSON REPORTING COMPANY, INC. .. ~. - _,

28 I the legislature, we can hold the calendar. 2 CHAIRMAN HENDRIE: Study may be available at some 3 time. t 4 COMMISSIONER GILINSKY: It's like graduate school, y 5 where the year isn't -- N 6 COMMISSIONER AREARNE: Right. R b 7 Okay, on page 45, this is more just for my information, X j 8 the way that you have now modified it -- and I'm probably not d d 9 ' interested in the way it was originally -- what do you intend h 10 with respect to the licensee in answer to do you expect them to = Il put in a device to directly measure the coolant level in the a f I2 reactor vessel? S 13 j MR. DENTON: I think when we first originated fI4 this requirement, we did intend level -- and level is a common h: y 15 measurement -- to in a sense have these other schemes imposed m E 10 which they incurred, unambiguous indication of core cooling, I h'17 and there are several schemes. I think one is being put in a x { 18 reactor and tested. So we left a bit of an out as to exactly how k I9 g do you show unambiguous core cooling, and I'll let Bob or Roger 20 amplify where that stands. It's gotten more complicated as more 2I people have come up with schemes. ( COMMISSIONER AHEARNE: Roger? Bob? MR. EISENHUT: I think in f act Roger -- while you' re 4 thinking, I'll return the favor. A lot of the level schemes 25 I that are being proposed are not a direct indication of level. ALDERSON REPORTING COMPANY,INC.

29 1 They are either by pressure sensors or whatever, and I think it 2 would be our intention that those kinds of approaches will be 3 acceptable, as opposed to a. direct indication in the reactor 4 vessel. = 5 COMMISSIONER AHEARNE: But that scheme is still a j 6 measurement of the level -- .g b 7 MR. EISENHUT: That's right. 3l 8 COMMISSIONER AHEARNE: --- although it may not be a d ci 9 direct measurement. 2 10 MR. EISENHUT: I was just following your direct sense. Il MR. MATTSON: I was working on your last question. is I 12 Do we mean them to have a level indicator? Yes, sir. E'13 5 COMMISSIONER AHEARNE: Okay. Thank you. /. ~ a h I4 CHAIRMAN HENDRIE: But it neednot be a sight glas' ? s $j 15 MR. MATTSON: ' That's right. a: E 10 (P ause. ). l h 17 CHAIRMAN HENDRIE: It could be hung up outside the I z { 18 containment. A" 19 g (Laughte r. ) n 20 COMMISSIONER AHEARNE : A dipstick. l 2I The last question I have, we are, as I'm sure you know, 22 going through some reviews of a recent rule, and there are some 23 questions that have been raised about the technical justification 24 that we have imbedded in that rule, and it seemed to me that 25! there are similar questions raised here. So just for my cwn i L ALDERSON REPORTING COMPANY. INC.

30 1 future.possible use, could you give me your short description of 2 our technical justification for 100 percent? 3 MR. DENTON: Let me start, and I'll ask Roger, who 4 was at the last meeting, to amplify. The 100 percent was to e 5 foreclose arguments for CP plants where you had the flexibility, b 6 you designed for a given number, over whether the right number R 7 was 90, 75, 60 or 50, and I thought back when we started the N 8 CP process that it was simpler to go to 100 and we didn't have d m; 9 the analytical results to justify any number lower than that at 10 the time; whereas in the interim rule, trying to zero in on more j 11 technical -- 3 j 12 COMMISSIONER AHEARNE: So it's a regulatory 9 5 13 conservatism? m l 14 MR. DENTON: Yes. 2 15 COMMISSIONER AHEARNE: In the absence of more 16 g detailed knowledge? d d 17 MR. DENTON: That's correct. 18 COMMISSIONER AHEARNE: All right. Thank you, gentlemen. A { 19 Yes, that 's for Roger. Go ahead. 20 CHAIRMAN I don't think it's in Part 20, 21 because Part 20 deals with normal operation, normal releases to n 22 people in unrestricted areas. 23 Vic, you had some questions of one kind or another. 24 Nhy don't you --- 25 COMMISSIONER GILINSKY: Well, actually, I'd like to l l ALDERSON REPORTING COMPANY, INC.

31 I study the comments more carefully before pursuing it further, 2 and I'll just deal directly with Harold and his people. 3 CHAIRMAN HENDRIE: Did you get a chance the other 4 day to excise the point of what a rule would mean in terms of 5 construction permit proceedings? e h j 6 COMMISSIONER GILINSKY: With the General Counsel, yes. R 7 CHAIRMAN HENDRIE: Is there any of that that -- 2l 8 COMMISSIONER GILINSKY: No, I don't think so. d d 9 CHAIRMAN HENDRIE: Other questions? 10 Peter, did you have any residual items that we could E II usefully -- a f I2 OOMMISSIONER AHEARNE: I have one minor question. S 5 13 CRAIRMAN HENDRIE: We'll see if Peter has any. i m b I4 COMMISSIONER BRADFORD: I don't, no. I j ust had diat a g 15 one. = E 10 COMMISSIONER AHEARNE: The one minor question really w h 17 is -- I'm not sure to whom it should be addressqd, probably Sam. m 18 (I.aughter. ) c8 I9 g I am, I guess, somewhat -- I found it interesting -- n 20 7.ve read all the comments, and I was a little pu:: led by how 21 we decide to which proposal a commentor is providing comments, 22 when they don't specifically reference the Federal Register 23 notice, because I would almost bet -- in fact, I would bet that 24 some of these commentors were commenting on something different 25 than this rule. I ALDERSON REPORTING COMPANY INC.

i 32 1 COMMISSIONER BRADFORD: That's a fair question. 2 COMMISSIONER AHEARNE: What do you say to that, Sam? l 3 (Laughter.) .~ 4 MR.'CHILK: I'd have to look at the comment. e 5 (Laughter. ) h j 6 COMMISSIONER AHEARNE: The only reason I raised it is R 7 that Sam -- it's a question of information. But it appeared to me 8 that at some point when -- we take notice of that in our analysis d C 9 .and the comments, we say that comments 1, et cetera, et cetera, ,z h 10 didn't really refer to this rule, so we don't pay a ttention to i 11 them. 3 y 12 Well, that means that there probably are some other E: 13 requests we had out to which they did refer. That would be l 14 nice if they could get folded in. 2 15 COMMISSIONER GILINSKY: Whatever reservation I have = g 16 concerned the provisions that deal with containment design. as 6 17 I don't have any further questions about the rest of the rule. E 18 And that's something I want to pursue a little further.

g COMMIHONER BRADFORD

Sorry, I wasn' t laughing at 19 gn 20 you. 21 CHAIRMAN HENDRIE: But not at the moment? 22 COMMISSIONER GILINSKY: Not at the moment, no. 23 COMMISSIONER BRADFORD: Comment No. 9 had just come 24 to my attention. 25l COMMISSIONER GILINSKY: I thought you were laughing at i i ALDERSON REPORTING COMPANY,INC.

33 ' i 1 me. 2 COMMISSIONER BRADFORD: No. Comment 9.- that's the 3 first time I noticed it. 4 CHAIRMAN RENDRIE: Okay, Len, are you ready? = 5 MR. BICKWIT: I just had two points: h 6 One, if the rule goes through, I recommend that R 7' some conforming changes be made to Appendix B, because it appears F j 8 to me that the appendix in its present form as revised is to d c; 9 some degree inconsistent with what's being done in this rule. z h 10 That appendix states, with respect to construction permits, that 11 the Commission may, on a case-to-case basis, supplement the I_ -12 requirements of the rules that are applicable to an application 'S 13 for a construction pernit, and that is not, as I understand it, g x l 14 what is contemplated by this rule. g 15 In essence, Appendix B, as it relates to construction - m j 16 permits, repeals the Maine Yankee decision or announces that e p 17 the Maine Yankee decision will not be followed in the future, 18 and what I understand the Commission is doing here is to provide 5 I9 that in effect it is-to be restored, with the new set of gn 20 requirements. 2l CRAIRMAN HENDRIE : What I would suggest -- and I guess for or 22 I would hope that for whatever views we may have among us, 23 against the rule in one form or another of the rule, I think we 24 could probably all agree, or at least have no objection, would 25 we not, asking the Counsel to go ahead and prepare appropriate ALDERSON REPORTING COMPANY. INC. ~.

' < y ;, 34 9.. I confoming '-- appropriate confirmation of Appendix B of Part 2 to 2 this rule, 'and then if this rule gains votes in one form or '3 another.in due time, why, that would be in hand; and if not, why, 4 . no harm will have be.en done. 5 ' k". Fair enough? j 6 Please do that. '7 MR. BICKWIT: I will. K . 0 The other point I wanted to make is one I made before, d' f. 9 and it relates to the siting policy problem.. The rationale that 10 j is given for rejecting-USDI's comments is a legal rationale, and El II it takes the position, as I read it, that we are precluded from f I2 applying these regulations -- the regulations on siting -- to S 13 ( .j these applications. 14-7,11 admit that is a possible reading of Section 108 w 15 of the Authorization Act, but I do not think it's the only ~' ij 16 reading and, in fact, I think it's the less preferred reading, as .h I7 and I. would urge that since what I think was moving the Staf f in m lii 18 opposing that comment was the policy position, I would urge the 19 .g Staff to see if it could remove the legal language which might 20 be read back to us at some stage. MR. SHAPAR: Or modify it. 22 MR. BICKWIT: Or modify it. CHAIRMAN.HENDRIE: Well, I think it seems to me that 24 if there are Commissioners' votes for a CP rule which will apply simply to those applications that have been on file with us for ALDERSON REPGRTING COMPANY, INC. ~. -.. -... - -. - - -

35 1 some time, that we probably also agree that it makes little 27 sense to talk.about applying the siting requirements. 3 MR. BICKWIT: That's right. I would simply say that m, 4 it makes little sense, rather than to say that the Commission is I e 5 legally precluded from doing this. 3l 6 MR. DENTON: As a matter of fact, we have provided R 8 7 the Commission. a detailed site description for each of these a j 8' applications. d c[ 9 CHAIRMAN HENDRIE: Okay. If perhaps ELD could z h 10 supplement the information in that section. Okay. The 11 Commission will take the matter under advisement. _ If when you have ( 12 prepared some alternate wording, or some additional wording on 5g 13 this siting matter, why, send it along, and you have prepared a l 14 some proposed conforming changes to Appendix B that would go 15 with this, why, send it along, duly marked so we can get it in g 16 the right folders, and so on, and there were some other clarifying w d 17 pieces, the Commission will think on the matter. E h 18 In the meantime, as we agreed at the beginning of E 19 g this meeting, it seems to me that the Staff has a perfectly n 20 reasonable position to take on these construction permit 21 applications, and if you find yourself in a position where it 22 seems usual to go ahead and put those forward in a hearing, why, 23l do so. If the rule follows, why, it will only supplement and i 24 I overtake your effort. 25 MR. SHAPAR: Well, the Staff can go forward with the l ALDERSON REPORTING COMPANY,INC.

i .36 1 Staff position, and whether or not the Commission eventually 2-buys that Staff position and reflects it in a rule remains to be 3-seen. 4 CHAIRMAN HENDRIE: Just so. Very good. m. 5 COMMISSIONER BRADFORD: Are those proceedings in fact b 6 proceeding? g. 7 MR. PURPLE: Some are, and some aren't. X j 8-COMMISSIONER BRADFORD: But it's not us that are holdinct d ci 9 up the ones that.aren't? z h 10 MR. EISENHUT: Some of the hearings are actually 11 waiting on this piece of the process. There are other hearings, it I.12 .however, that some of these plants are actively in hearings now 5 13 on other pieces of the CP. 3m h 14 MR. SHAPAR: But based on what we've heard today, we a would not refrain from going forward with a Staff position. I 15 y - 16 COMMISSIONER BRADFORD: Right. vi ![ 17 CHAIRMAN - HENDRIE : And in any case, the Applicants Ili 18 are scratching their heads and saying, well, you know, is.0718 E 19 the current version or whatever we should be working toward, or 20 not, and it seems to me that it is the Staf f position -- it 21 'seems perfectly reasonable to me for the Applicants to work in thaQ 22 direction. 23, I would think that even -- whatever rule we pass l 24 is not going to go in radically different directions, I think 25 that's quite clear. We haven' t dif fered substantially on the ALDERSON REPORTING COMPANY, INC.

i 3y +.., 1 I. technical issues. I \\ 2 okay. Very good. Thank you very much. 3 (.Whereupon, at 3:45 p.m., the meeting was 4 adjourned.1 e 5 5 6 a .w a j 8 d .ci 9

i h

10 i j 11 a y 12 g 13 5 s,f m l 14 m 2 15 16 g as y 17 $3 18 19 gn 20 21 22 -23 24 25 ALDERSON REPORTING COMPANY, INC. b-

s NUCLi:AR REGUZATORI COMMISSICN - fch L2 Oc certif7 that the attached proceedings befors. che '\\ 4 q is the natter of: DIsgussION OF SECY 80-20D - POLICY ON PROCEEDING WITH PENDING CP AND ML APPLICATIONS

• Dace cf Freceeding: May 27, 1981 Uccket Munber:

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