ML20137S154
| ML20137S154 | |
| Person / Time | |
|---|---|
| Issue date: | 11/26/1985 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8512060175 | |
| Download: ML20137S154 (80) | |
Text
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m ORIGINA!.
UNITED STATES OF AMERICA
('
NUCLEAR REGULATORY COMMISSION In the matter of:
COMMISSION MEETING Discussion of 1986 Policy and Planning Guidance (Public Meeting)
Docket No.
i
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1 Location: Washington,_D. C.
Date: Tuesday, November 26, 1985 Pages:
1 - 76 8512060175 851126 PDR 10CRR PT9.7 PCR i
ANN RILEY & ASSOCIATES Court Reporters 1625 I St., N.W.
Suica 921 Washington, D.C.
20006 (202) 293-3950
V 3
1 D i SC LA I M ER 2
3 4
5 6
This is an unofficial transcript of a meeting of the 7
United States Nuclear, Regulatory Ccemission held on 3
11/26/85 In the Commission's office at 1717 H Street, 9
N.W.,
tJas h i ng t on,
D.C.
The meeting was open to public 10 attendance and observation.
This transcript has not been 11 reviewed, corrected, or edited, and it may contain 12 inaccuracies.
18 The transcript is intended solely for general 14 informational purposes.
As provided by 10 CFR 9.108, it is 15 not part of the formal or informal record of decision of the 16 matters discussed.
Expressions of cpinion in.this transcript 17 do not necessarily reflect final determination or beliefs.
No 18 pleading or other paper may be filed with the Commission in 19 any proceeding as the result of or addressed to any statement 20 or argument contained herein, except as the Commission may 21 authorire.
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1 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
4 DISCUSSION OF 1986 POLICY AND PLANNING GUIDANCE 3
6 PUBLIC MEETING 7
8 Nuclear Regulatory Commission 9
Room 1130 I C.
1717 "H"
- Street, N.W.
11 Washington, D.C.
12 13 Tuesday, November 26, 1985 14 15 The Commission met in open session, pursuant to 16 notice, at 2:05 o'clook p.m.,
NUNZIO J.
PALLADINO, Chairman of 17 the Commission, presiding.
18 19 COMMISSIONERS PRESENT:
20 NUNZIO J.
PALLADINO, Chairman of the Commission 21 THOMAS M.
ROBERTS, Member of the Commission 22 JAMES K.
ASSELSTINE, Member of the Commission 23 FREDERICK M.
BERNTHAL, Menber of the Commission i
24 LANDO W.
- ZECH, JR.,
Member of the Commission 25
a 2
1 STAFF AND PRESENTERS SEATED AT COMMISSION TABLE:
2 H.
PLAINE 3
W.
DIRCKS 4
J.
ROE 5
D.
HATHBUN 6
G.
EYSYMONTT
?
R.
SCHOGGINS 8
P.
BOLLWERA 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
9 e
3 1
P ROC EED I NG S 2
CHAIRMAN PALLADINO:
Good afternoon ladies and 3
gentlemen.
The Commission is meeting today so discuss the 4
Draft 1986 Policy and Planning Guidance document that I 5
circulated to the Comuission on November 20.
6 I believe the PPG is one of the agency *s most 7
important annual documents in that it sets forth NRC's 8
regulatory philosophy, strategic goals and policies and it 9
provides overall agency management direction.
I 10 It is intended to focus NRC ettorts on implementing i
11 the regulatory process that is effective and efficient in 10 protecting the public health and safety, the common defense 13 and security and the environment.
14 The PPG for 1986 has been restructured from versions 15 in previous years.
The policies and planning guidance section 16 is organized along the lines of 12 general mission areas that
~
17 are being considered for use in formulating NRC*s Five Year J
18 Plan.
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19 It is the intent today to obtain the Commission's 20 views on the PPG and to give direction to OPE regarding any 21 needed changes so that we can finalise the PPG in a timely 22 manner.
23 Unless there are other Commissioner comments at this 24 point, I will have George Eysymontt from OPE lead us through 25 the drait 1986 PPG.
I should note that we also have Dennis
e 4
1 Rathbun here from OPE, the EDO Deputy and Controller.
2 Any additional comments?
3 COMMISSIONER BERNTHAL:
I have one minor comment on 4
your memo, Joe.
It was not my understanding that the fact 5
that we were going to try and do a Five Year Plan here 6
necessarily has anything to do with the annual Policy and
?
Planning Guidance.
8 The comment here that we are in a transition period 9
to a five year planning process, well, we are going to do a 10 live year planning process but we also will do a PPG, I should 11 think, on it.
12 CHAIRMAN PALLADINO:
Every year, yes.
13 COMMISSIONER BERNTHAL; It seems to me that obviously 14 they have to fit together but we do both.
That is all I want 15 to say.
16 CHAIRMAN PALLADINO:
The intent is to develop a Five 17 Year Plan.
At least it is my understanding of the Commission's 18 intent is to develop a Five Year Plan and then each year 19 supplement it with a PPG for the activities for that year.
20 COLMISSIONER BERNTHAL:
A l '. right.
Just so we are 21 clear.
22 CHAIRMAN PALLADINO:
My only point in mentioning the 23 Pive Year Plan in this discussion is the fact that the PPG was 24 developed around the 12 what we call mission areas that are 25 being considered for use in the Five Year Plan.
v
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-ww
5 4
1 COMMISSIONER ASSELSTINE:
Let me ask, is that the 2
understanding both of the stati and OPE as how they are going 3
about the Five Year Plan?
I have sort of had the sense that 4
the Five Year Plan was going to evolve so that perhaps we 5
would not have two separate documents.
In succeeding years we 6
would have a Five Year Plan that might highlight what needed 7
to be done in the first year but that we wouldn't go through 8
this exercise twice.
It seems like an imminently reasonable j
9 idea to me.
10 MR. RATHBUN:
Let me speak to that just for a 11 minute.
Quite frankly, I don *t think that is fully shaken 12 down.
13 COMMISSIONER ASSELSTINE:
All right.
14 MR. RATHBUN:
At least the thought of some'of us was 15 that the first year of the Five Year Plan in effect would 16 contain --
17 COMMISSIONER BERNTHAL:
PPG.
18 MR. RATHBUN:
That*s right, the PPG type guidance to 19 the statt.
20 COMMISSIONER BERNTHAL:
that is all right with me.
21 COMMISSIONER ASSELSTINE:
Yes.
22 COMMI.SSIONER BERNTHAL:
I-guess that settles that.
23 COMMISSIONER ASSELSTINE:
Al right.
24 CHAIRMAN P A L L A,D I N O :
I don't know that it settles 25' it.
It just says that we are-flexible.
We haven't really k
1 l
1 decided.
1 2
MR. RATHBUN:
At least the thought track that I and 3
the others that have been working on the Five Year Plan have 4
been on is that sort of thing, that in effect the first year 5
of that would contain the Policy and Planning Guidance.
6 So in that sense I think the Chairman's statement at 7
the beginning and also in his cover note is correct that this B
is a transitional type document.
9 COMMISSIONER ZECH:
On the other hand, when you get 10 the Five Year Plan in being the preamble to it or the 11 introduction to it or the first part of it should indeed be 12 some PPG type guidance and should lead into the Five Year Plan 13 with that kind of introductory part.
Whether we call it a PPG 14 cr a budget I don't think is too important.
15 COMMISSIONER ASSELSTINE:
Hight.
16 COMMISSIONER ZECH:
But it should lead into it in 17 some way, I agree.
18 Mr. Chairman, I have a comment I would like to make 19 too before we get going.
20 CHAIRMAN PALLADINO:
All right.
21 COMMISSIONER ZECH:
First of all, it would have been 22 very helpful for me to have a line-in/line-out. type version 23 because I am trying to figure out what we said last year and 24-that doesn't mean with my people we can't figure that out 25 ourself and all the other Commissioners can do the same thing, E
7 1
but it would have been very helpful for what I call completed 2
statt work, it would have been very easy and certainly make it 3
a l'o t easier to approach this if you had given us what are the 4
differences between last year.
5 I would still like to get that from you as we get 6
into this.
In any kind of a doonment like this, it is my 7
suggestion that you consider at least a line-in/line-out thing 8
to see whether it is easier to work with.
9 In other words, I don *t know what changes yet 10 although I have read through this rather quickly and my people 11 are looking at it, too, but I am not sure if you have made any 12 significant changes or not.
13 I read a lot of the same words and it sounds kind of 14 familiar but it would have been very helpful to have that.
15 I would like you to get that to all of us as soon as 16 you can.
17 CHAIRMAN PALLADINO:
Incidentally, I had three 2
18 questions and one of them is how does this ditter than the 19 planning guidance that we gave last year?
Is there any policy 20 or planning guidance that has changed significantly from last l
21 year and it so, identity?
22 Although I do think it may be ditticult to do 23 line-in/line-out because the whole format has changed but I 24 still think we need to know what is different from last year.
25 MR. R A T H B U N.-
Mr. Chairman, let me speak to that
g e
8 1
just for a second if I may and make a proposal and see it it 2
is satisfactory to the Commission.
3 We found in doing a line-in/line-out change on the 4
Advanced Reactor Policy Statement where a lot of material was 5
moved in a significant sort of way that it became very 6
ditticult for the Commissioners to follow and find out what
?
was truly new and what wasn*t.
8 As the Chairman points out there have been I would 9
say very, very major changes in the organizational format this 10 year in the PPG, What might be most helpful rather than do 11 the traditional dashing out and underlining for the new 1
12 material is just to indicate in the margin material which 13 essentially has come from last year *s PPG.
)
14 I say " essentially" in the sense that it we changed 15 some articles or adjectives or something, we wouldn*t indicate 16 that necessarily, but we would indicate then at least what was 17 old, what came from last year's PPG rather than the dash-out 18 kind of thing.
i 19 COMMISSIONER 2ECH:
I think that would be fine.
I 20 am not rigid on the format.
It is just that I would really 21 like to know what is new and what is not new and what has 22 changed.
23 MR. RATHBUN:
I think we can do that.
24 CHA!aMAtt PALLADINO:
That is a fair question and I 25 think we all have that in the back of our minds.
Q 9
1 COMMISSIONER BERNTHAL:
Same comment irom me.
2 Fortunately my staff here gave me finally or I should say at 3
the last minute, we had to do exactly the same thing that your 4
iolks are trying to do, too, so we could have saved us al1 a 5
lot of time the way it looks it somebody had done it for us.
6 CHAIRMAN PALLADINO:
Any other comments?
7 COMMISSIONER BERNTHAL:
Doing it five times over.
8 COMMISSIONER ZECH.
No.
That is all I have at this 9
time.
I have some comments later.
10 COMMISSIONER ROBERTS:
Yes, I have some specifics.
11 COMMISSIONER ZECH:
Perhaps we should hear from them 12 tirst.
13 CHAIRMAN PALLADINO:
All right.
14 MR. EYSYMONTT:
I am a little afraid to speak, 15 Mr Chairman, after all that discussion.
16 (Laughter.)
17 MR. EY S Y MON'k'T :
What I was proposing to do is just 18 to run you through basically the changes in organization that 19 have been made in the document and to try to indicate some of 20 the areas where we have reflected the fact that the staff has 21 completed some of its efforts and reflect the changes in 22 direction the Commission may have ordered through the past 23 year and then try to indicate what our current thinking on the 24 relationship between this document and the Five Year Plan 25 which you of course have all discussed a few minutes ago.
1 10 1
But I will give you my views since I am one of the 2
people involved in writing that document, also, so if I may 3
for a minute longer.
4 The basic organization of the document is it has 5
tour sections now, an introduction, a section on philosophy of 6
regulation, a section on strategic goals and a section on 7
policies and planning guidance.
9 8
The introduction section basically talks about the 9
purpose of PPG and states the general relationship of the 10 document to the Five Year Plan.
11 As you were discussing earlier we vie'w this document 12 as a departure point for the Five Year Plan which the 13 Commission will be getting a draft of in the middle of February 14 of next year according to our current schedule.
15 The structure of the Five Year Plan especially with 16 respect to strategic goals and policies and planning guidance 17 will look fairly similar to what we have in the Policy and 18 Planning Guidance, at least again according to our current 19 thinking.
20 One of the differences, of course, will be that 21 there will be tive year objectives in that document whereas 22 there are not five year kinds of objectives in this document.
23 The Five Year Plan will also include a section on the external 24 environment.
There will De a forecasting section c, n electrical 25 energy demand and the number of licenses we expect to get over
11 1
the next five years a r. d so forth.
2 Also the Five Year Plan will contain a section on 3
resources which will describe in detail how the strategic 4
objectives will be met.
5 I guess that is all I am really prepared to say 1
6 about the Five Year Plan at this point.
I think we should 7
wait obviously until February until you see the draft.
8 The Philosophy of Regulation section in the PPG now 9
is essentially unchanged from last year's document with the 10 exception of a section on special regulatory objectives which 11 were in there last year.
12 These objectives have now been,put into section 13 three entitled, " Strategic Goals."
14 There are five major goals together with a number of 15 supporting objectives.
16 The first one is to assure safe operation of licensed i
17 facilities and proper construction of facilities to be 18 licensed..,There are supporting objectives to meet this 19 broader goal of assuring safe operation ranging from applying 20 operational experience on the part of both the NRC and the 21 licensee to undertaking enforcement actions.
22 The second strateg.ic goal is to improve regulation 23' of the nuclear industry.
There are a number of supporting 24 objectives here which should be carried out to meet that goal 25 including the control of back11tting, encouraging L
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12 1
standardization and preparing to deal with requests by 2
licensees to reactivate deterred construction projects.
3 To assure adequate protection of nuclear naterials, 4
objectives in support of this goal range trom ensuring that 5
safeguards measures are commensurate with threats to reducing 6
over exposures of radiographers.-
7 The next goal is to assure rtdioactive waste is 8
managed safely.
The main supporting objective here is timely 9
review of DOE's repository program and assuring that TMI-2 is 10 expeditiously cleaned up.
11 The last goal is to manage the agency resources more 12 ettectively and in this section the Commission itself to 13 continue pressuring for consolidation in one location and to 14 continue to improve management accountability in all areas of 15 administration.
16 The Icet section of the document,is divided into 12 17 mission areas.
It is intended that the mission areas include 18 all of the activities of the NRC.
19 CHAIRMAN PALLADINO:
You say to include all of the 20 activities?
21 MR. EYSYMONTT:
Yes, that is correct.
22 The Commission does not give policy direction or 23 planning guidance for every activity within the Agency but for 24 accounting purposes the statt has suggested that the Commission-26 subdivide its activities into these areas.
13 1
Perhaps the most significant change in using this 2
scheme from last year *s approach is that there is no separate 3
section which addresses research.
Rather, research activities 4
are addressed within the mission areas and in the introductory 5
section preceding the material for each mission area.
6 Mission areas include overseeing reactor performance, 7
to adequately manage and support technical programs.
Each 8
program contains a policy part and a planning guidance part.
9 I have j tis t a few more words to say about areas 10 where we have done some updating and some additions from last 11 year *s document and then I think we would be prepared to go 12 through the document page by page or as you would like to go l
13 through it.
14 CHAIRMAN PALLADINO:
In your general comments, could 4
15 you comment on how the 12 mission areas relate to the five 16 strategic goals?
It is a little difficult to connect, at 17 least I found some difficulty in connecting the two.
18 MR. EYSYMONTT:
I think quite frankly, Mr. Chairman, 19 it has been very difficult for us to combine the two views 20 that we have of the Commission *s activities.
The staff is 21 very much concerned about being able to encompass all of the 22 resource areas, all the activities within the agency.
23 Whereas, the general policy directions that the 24 Commission gives does not necessarily encompass all those 25 areas and trying to marry the two if you will has been in
J 14 1
fact a very difficult problem.
2 COMMISSIONER ZECH:
Wait a minute now.
It wasn't my 3
intention and I an. n o t so sure that it was the intention of 4
any of the Commissioners to try to tell you in the guidance 5
that we had gi
.n you vvery specific thing.
Certainly I would 0
expect the stati would c o v e.r areas that perhaps we had not
?
even gotten to.
8 MR. EYSYMONTT:
On the policy side, that is quite 9
true, Commissioner.
The policy does not cover every activity 10 within the Agency.
11 However, the stati*s concern on the other side and 12 the resource side is that it does want to encompass all of the 13 activities.
14 COMMISSIONER ZECH:
Well, that*s fine.
Then you id ought to get together and give us those recommendations.
16 Don *t just tell us we didn't give you all the policy.
If you
- 7 think there is something that we should give you that we 18 didn't give you or the stati thinks there is something then 19 you should bring it to our attention.
20 MR. EYSYMONTT:
On the area of policy, I am not sure 21 that we are asking you to give us further guidance.
I thitk 22 we are talking more about the organization of the document and 23 two separate concerns.
24 Perhaps you would l'i k e to address your e ince rn in 25 the-resource area.
O 15 1
MR.
ROE:
I think the mission areas should encompass 2
all of our activities that it we were to address a Five Year 3
Plan with just strategic goals there would be parts of our 4
activities that are extremely important but we may not address 5
as a strategic goal 6
- 1. e t me give you an example.
We have as one of our 7
mission areas, inside one of the ml.tsien areas, to assure that 8
we license operators m'tificiently.
It may not be one of those 9
things ihat we address as a strategic goal.
However, it is 10 very important for us to do and I think it is important for us 11 to realize the ettort it takes both in the human resources in 12 the statt and also financial resources.
13 We see that it is important for us to know what the 14 strategic goals that the Commission wants to set out and find 15 that they can stand somewhat alone.
But it is important to 16 the statt to have a comprehensive look at all of our activities 17 so that the Commission can understand where we are putting 18 forth the full range of our activities.
19 COMMISSIONER ZECH:
It seems to me though that the 20 strategic goals should in some way and maybe not in a very 21 specific way but i.n s on.e encompassing way should cover the-22 major mission areas.
l 23 MR. ROE:
They should and I think we will see --
i 24 COMMISSIONER ZECH:
If they don't, we ought to put 25 them together.
16 1
MR. ROE:
We will track 2
COMMISSIONER ZECH:
It is just a logic thing.
3 MR HOE:
I think we can track everyone of these 4
strategic goals back into the mission areas.
5 CHAIRMAN PALLADINO:
I was thinking the other way 6
around.
You set some strategic goals and then your mission 7
areas should relate at least to one or more of the strategic 8
goals.
9 COMMISSIONER ZECH:
Yes, that's right.
So 1.1 we 10 don't have the strategic goals covered properly then perhaps 11 we should but by the same token you should not be performing a 12 lot of missions that perhaps are not expected to perform.
13 It is a logic sequence.
We are trying to flow 14 through it and it should start from the top and flow down in 15 this particular case in my view.
There is nothing difficult 16 about it.
l 17 MR. RATHBUN:
Start with the strategic goals and 18 then the mission areas conform to meet the goals *f 19 COMMISSIONER ZECH:
Sure.
.The strategic goals 20 should be encompassing enough or 3 road enough to cover the 21 mission areas and it they are not, we ought to fix them.
22 MR. RATHBUN:
I think that is a key point, 23 Commissioner.
24 CHAIRMAN PALLADINO:
One way this might be approached 25 is in each of the mission areas give some statement with regard
=
17 1
to its relationship to the strategic goal.
Then that would 2
begin to tie them together.
3 COMMISSIONER 2ECH:
Sure.
It is just a matter of 4
putting them together in a logical sequence but tt should flow 5
and it should be clear to anybody why we are doing these 6
things in the mission area.
?
We are not doing just because the statt wants t3 do 8
them.
We are doing it because it is a strategic goal.
9 CHAIRMAN PALLADINO:
It helps fulfill a strategic 10 goal.
11 COMMISSIONER ZECH:
Yes.
It is to fulfill 12 essentially our basic primary mission. to our country.
13 CHAIRMAN PALLADINO:
When you do that you may find 14 some strategic goal that emerges that we haven t identified.
15 CCMMISSIONER ZECH:
Yes, that*s right.
16 CHAIRMAN PALLADINO:
Why don *t you go ahead.
17 MR. EYSYMONTT:
- Yes, I was just going to mention a 18 tow of the items that we have changed in the document just to 19 give you some examples and then propose that we start going 20 through the document.
21 This year the Commission issued a Severe Accident 22 Policy Statement so that now we have changed tne document to 23 reflect that and basically say that we will now begin to 24 implement the policy.
25 We have taken into account the fact that the
18 1
Commission has a Backiit Rule in place.
There is a section in 2
the document that deals with the Commission's concern about 3
preventive, corrective and other areas of maintenance.
The 4
Planning Guidance says for example that the staff should 5
monitor the effectiveness of the accreditation program.
6 The statt has urged to continue to seek to understand 7
the effects of aging and irradiation on materials and 8
components in reactor c on t a i nme r.t s.
9 The Planning Guidance says to conduct research to 10 identify measures which can be taken to correct deficiencies 11 att.ributable to aging.
The Commission also indicates an 12 intention to provide prompt and effective investigation of 13 major incidents.
The Planning Guidance says to implement the 14 program recently approved by the Commission.
15 The document also suggests that we take some 16 regulatory efforts to improve radiographer safety and that 17 steps should be taken to expeditiously convert non-power 18 reactors to low-enriched uranium.
19 Those are some of t %.
- examples of changes in the 20 document.
21 CHAIRMAN PALLADINO:
In light with Commissioner 4-22 Zech's comment would either an accompanying letter or an 23 insert or a section that is differ?nt or changes from last 24 year or major highlights of this year as compared to previous 25 years where you could summarize some of tbase, I think that
19 1
would be very helpful, 2
MR.
EYSYMONTT:
Yes, certainly we could do that.
I 3
think the line-in/line-out one would be a big problem but 4
indicating it in the body of the document would be fine and we 5
could do it very rapidly.
6 COMMISSIONER ZECH:
Then also if you do it that way,
?
you have to also not only indicate in the margin whether it B
was in last year or is something new or not, you have to tell 9-us in a separate document or something what is eliminated, you 10 know, if you left things out.
11 MR. EYSYMONTT:
-Very little is, but yes, certainly.
12 COMMISSIONER ZECH:
If you do, just tell us that 13 just so that we will all Know.
We have to know what is 14 eliminated and what is added.
What are the changes and any 15 way you figure out to do it is fine with me as long as it is 16 easy to read.
17 CHAIRMAN PALLADINO:
I think there is some merit in 18 giving a summary of the major changes in addition to 19 identitying individual changes in the report.
20 MR. EYSYMONTT:
I will be happy to provide that.
21 That is the end of my presentation, Mr. Chairman.
If you 22 would like, we can begin going through the document or whatever 23 format you preter.
24 COMMISSIONER ZECH:
Let's not do that.
25 (Laughter.)
20 1
COMMISSIONER ZECH:
I think we all I have questions, 2
I, know I do.
3 CHAIRMAN PALLADINO:
Yes.
I had three questions for 4
4 you and I had three questions I would the Commissioners to 5
either address or consider in their comments.
6 My first one was how do the 12 mission areas relate 7
to the five strategic goals and do the mission areas cover the B
entire agency *s activities and I think you have covered that.
9 We discussed is there any policy or planning guidance 10 that has changed significantly from last year and identify it.
11 Now could you review the schedule that we have for 12 the PPG and what the plan of action is so that I get a better 13 feel for the time table on which we are trying to work.
14 MR. EYSYMONTT:
I think the original schedule, 15 Mr. Chairman, was that as soon as we get comments from the 16 Commissioners on how they would like to see the document 17 modified within five working days we would be able to turn the 18 document around and provide you with another copy, 19 I don't know whether you would like to have another 20 meeting on it or not or whether it would be sufficient 21 subsequent to that to just circulate the document and have the 22 Commissioners approve or disapprove the final version.
23 Of course, we could do it on a line-in/line-out i
24 basis so that you would be able to see the changes that have 25 been made.
4
, ~ - - -
--4 u--
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a 21 1
CHAIRMAN PALLADINO:
It depends on how extensive the 2
changes are.
3 MR. EYSYMONTT:
Yes, that is correct.
4 CHAIRMAN PALLADINO:
I would say that it we could 5
give you our guidance this atternoon plus any supplemental 6
information we want to give by the end of the month, could
?
you be ready by about the 6th of December with something you 8
circulate?
9' MR. EYSYMONTT:
Yes.
That is the end of next week, 10 yes.
11 CHAIRMAN PALLADINO:
The object would be to try to 12 have this ready for implementation by January 1st.
13 MR. EYSYMONTT:
That*s right.
The normal course of 14 action is to issue the document as early as possible in 15 January and we would work toward that.
16 CHAIRMAN PALLADINO:
I think we have been pretty 17 successful in getting it done pretty much by January 1st.
r 18 MR. EYSYMONTT:
Yes, that is correct.
19 CHAIRMAN PALLADINO:
Well, why don't we come back to 20 that.
21 COMMISSIONER ZECH:
That is important because I 22 think we have more work to do.
It seems to me that we all are 23 perhaps going to have some comments for you but first what we 24 need to see is your revised version to us and fit it out as 25 you see tit so we can look at the changes a little bit better.
22 1
COMMISSIONER ASSELSTINE:
That is going to slow the 2
whole process down a lot though it we have to wait before we 3
give them comments until we see it.
4 CHAIRMAN PALLADINO:
I thought we were going to give 5
such comments as we could at today's meeting.
6 COMMISSIONER ASSELSTINE:
Yes, I am ready today.
7 CHAIRMAN PALLADINO:
Then if you have anything more 8
to say, try to get it out by the end of the month.
9 COMMISSIONER ZECM; I have some general comments to 10 give you today and I can give you a lot of specific ones, 11 too.
I am not so sure that they would be as meaningful as 11 12 I had from you what I have asked you for as far as the changes 13 are concerned.
14 MR. EYSYMONTT:
Let me attempt to have a document to 15 you by Wednesday of next week.
I don't think that is 16 unreasonable.
17 CHAIRMAN PALLADINO:
I think we ought to give you 18 our comments and then tne comments such as you made I think 19 are very valuable and then we see it with all the comments in 20 there.
21 COMMISSIONER ZECH:
That*s fine except it is very 22 likely after we see their document we may have other comments.
23 CHAIRMAN PALLADINO:
Oh, true.
4 24 COMMISSICNER ZECH:
We can do it parallel I have 25 no problem with that.
It just makes it perhaps not quite as l
l l
23 1
neat a way to do it.
2 CHAIRMAN PALLADINO:
The major comments we have had 3
so far relate to making sure that we identity the changes from 4
previous years.
There may be other specific comments but it 5
you could provide them to OPE, they can go ahead and put 6
together another draft and it our comments are consistent, it
?
ought to be a converging process.
B MR. RATHBUN:
Just to establith a baseline here, 9
suppose we take this document as the document to which we 10 respond to Commissioner Zech*s proposal and yours also, 11 Mr. Chairman, and that is to show as simply as possible the 12 major changes from the PPG of last, year.
13 CHAIRMAN PALLADINO:
All right.
14 COMMISSIONER ZECH:
Sure.
I don't think it would be 15 that ditticult.
16 MR. RATHBUN:
By next Wednesday.
17 COMMISSIONER ZECH:
That*s what I say.
I don't 18 think it would be that ditticult, 19 MR. RATHBUN:
Then in addition, taking this document 20 as the baseline document to incorporate such changes as we 21 receive at the table here today and within the next few days 22 begin to build in the changes that the Commission wishes.
23 CHAIRMAN PALLADINO:
So the proposal is 24 COMMISSIONER ASSELSTINE:
We we would have two 25 documents to work from.
)
24 i
1 MR. RATHBUN:
You will have a document which shows l
2 the changes from last year and then you are going to have, e
3 that's right.
You will have another.
4 COMMISSIONER ASSELSTINE:
But it won't reflect any 5
changes we discuss today.
6 CHAIRMAN PALLADINO:
That is what bothers me.
7 MR. RATHBUN:
That's true.
You are right.
8 CHAIRMAN PALLADINO:
Why don't we go ahead and 9
discuss the changes and then we will come back.
10 COMMISSIONER ASSELSTINE:
I guess I agree a little 11 bit with Fred's point.
It some people feel that they really 12 need to see a line-in/line-out of the existing document before 13 they are prepared really to otter a lot of detailed comments I l
14 think it may ena up more confusing.
15 CHAIRMAN PALLADINO:
I don't think a line-in/line-out 16 is going to work on this one.
However, there could be marginal 17 notes on what would change in this document.
18 COMMISSIONER EERNTHAL:
All I can say is that 11 I 19 am going to sit here for an hour and a half offering comments 20 and then get another document that doesn*t reflect those 21 comments, I will come back next time and otter my comments.
22 COMMISSIONER ASSELSTINE:
That's right.
That makes 23 a lot of sense.
24 COMMISSIONER ZECH:
My rel comment was we shouldn't 25 be in here without a line-in/line-out paper.
Now it you want r
w wm*
25 1
to put marginal things rather the line-in/line-out, that is a
2 fine but you gave us a document that we can't work with very 1
3 well and you can see how ditticult and how we re wrestling 4
with trying to help you out but it is your statt work we are 5
talking about, not very good.
6 CHAIRMAN PALLADINO:
Lando, no, no, don't, don't, I
7 disagree.
8 COMMISSIONER ZECH:
We11, that is my view.
9 CHAIRMAN PALLADINO:
Let me tell you why I disagree.
10 The OPE hd been trying to work such that the PPG would bear 11 some relationship to the torthcoming Five Year Plan so they 12 changed the structure.
13 Now whea you change the structu*e as extensively as 14 they did, the line-in/line-out doesn't work.
That doesn*t 15 mean they should not have told us what was different between 16 them because we all had the same question.
17 I am going to suggest it we can possibly live it 18 let's get the suggestions we have today and it we have 19 supplemental suggestions tr3 to get them in by the end of the 20 month and then have the revision come back with us and see it 21 that can't satisfy 22 COMMISSIONER ZECH:
The end of the month is kind at 23 like tomorrow, I think.
I would say that we shoot for the end 1
24 of next week, we get the whole damn thing done by then.
1 25 CHAIRMAN PALLADINO:
Ii we had all the comments in,
a 26 1
we could.
Let's go get the comments from today and then we 2
will come back to the scheduling.
3 COMMISSIONER BERNTHAL:
Am I going io get a document 4
it we go through this today the next time that reflects what 5
we say today?
6 CHAIRMAN PALLADINO:
That was my idea.
?
COMMISSIONER ASSELSTINE:
We get one document that 8
does but you will also get one that doesn't.
9 CHAIRMAN PALLADINO:
No.
My intent was to --
10 COMMISSIONER ASSELSTINE:
One document.
11 CHAIRMAN PALLADINO:
One document.
12 COMMISSIONER ASSELSTINE:
Which will indicate in the 13 margins how the document differs from last year.
14 CHAIRMAN PALLADINO:
From last year plus any comments 15 that they get within the next ten days, counting the fact that 16 some holidays are in there.
17 COMMISSIONER ZECH:
I think it is not that ditticult, 1B I really don't.
I recognize that it is a new undertaking but I
,i 19 really don't think it is that difficult to put together what at 20 least I have in mind and certainly you can take our comments 21 and tactor then into the new document 11 you want to and just 22 indicate the comments that you get.
23 We are just trying to make some progress without 24 wasting our time here today and it.seems to me that it is not 25 that difficult a task.
27 1
CHAIRMAN PALLADINO:
What I was proposing is they 2
come back with one document that reflects the request for what 3
is different and reticcts the other comments as well 4
COMMISSIONER ZELH:
There is no reator they can't do 5
that as far as I am concerned.
6 CHAIRMAN PALLADINO:
That is what I think we are 7
talking about doing.
8 COMMISSIONER ZECH:
Fine.
9 COMMISSIONER ASSELSTINE:
Al right.
10 CHAIRMAN PALLADINO:
I had as we go through -- those 11 were my questions for OPE.
For the Commissioners, I think we 12 need to know whether the Commission agrees with the structure 13 of the PPG and what about the substance of the Policy and 14 Planning Guidance statements, whether there are any other 15 specific near term or long term objectives that we should 16 emphasize or identity and are the mission areas the right 17
- ones, 18 Let~me start to see who would like to comment.
- Jim, 19 should we start with you?
20 COMMISSIONER ASSELSTINE:
- Yes, I for myself, I 21 guess my reaction would be that in terms of the Philosophy of 22 Regulation part, Joe, I have some of the same kinds of concerns 23 that I had last year and that we discussed last year.
I guess 24 I d ort t see a whole lot of purpose in going through that 25 discussion again.
I still disagree with it in many respects
28 l
1 and I would propose not to dwell much on the Philosophy of 2
Regulation part.
3 I have maybe just one or two comments on it but I 4
would reserve most of my comments for the Strategic Goals and t
5 the Policy and Planning Guidance for the coming year.
6 I have a number of detalled comments in both of 7
those two sectionc that I could provide.
In terms of the 8
basic structure, apart from my substantive objectives to the 1
9 Philosophy part, I don't have much of a problem with the 10 structure of it or with the organization or the approach.
11 That is fine as far as I am concerned.
12 But I have a lot of detailed comments that I would i
)
13 raise as we go through it.
I am prepared to go page-by-page 14 through the document.
15 CHAIRMAN PALLADINO:
Let me ask 11 the Commissioners 16 would like to go page-by-page and give their comments as they 17 go along, 18 COMMISSIONER ZECH:
I would prefer not to do that.
19 I would prefer to do it later on.
I have some specific 20 comments, some general comments that I could give and I 21 thought that would be sutticient as far as today is concerned, i~
22 I will do it anyway that everybody wants to but it just doesn't 23 seem to me that going through page-by-page is particularly l
24 useful at this particular time.
{
25 CHAIRMAN PALLADINO:
Well, we have done it both
~
29 1
ways, Lando, in the past, 2
I am sure some of the comments may be sort of 3
editorial and could be given separately.
4 COMMISSIONER ASSELSTINE:
That is probably true, d
yes.
That is.Aght.
6 CHAIRMAN PALLADINO:
Can you at least pick the ones 7
that you think are quite significant?
8 COMMISSiCNER ASSELSTINE:
I can mention a few 9
broader ones.
10 On thing in the Philosophy of Regulation part that I 11 thought was particularly useful and was in last year *s although 12 you have modified it a little bit, I am not sure I understand 13 quite why the modification was made, but the concept that
)
14 excellence is an objective not only for the industry but also 15 for the NRC and then you have several key elements that are 16 apart of achieving excellence in our own performance.
17 I like that and I thought it would be very useful to 18 try and feed some of those ideas back into the Policy and 19 Planning Guidance part of the document for this next year, I
20 think without going through and identifying specific places, 21 some of those concepts, honest assessments, valid apalysis, 22 effective decision making, strong and vigilant management 23 could be used fairly productively in the back part of the 24 document as well to re-emphasize some of those concepts.
25 As I say, I don't have much beyond that broad I..
30 1
comment on the regulatory philosophy.
2 On the Strategic Goals we say in the Regulatory 3
Philosophy that we are going to set priorities and i noticed 4
or at least the sense I had was that there was not a set of 5
priorities in the strategic goals.
It struck me that is what 6
the philosophy said we were going to do.
?
It might be useful to try and do that, say what the 8
priorities are unless they all are of equal importance.
9 In terms of the Strategic Goals themselves, goal I
10 one, to assure safe operation, I didn*t have any problem with 11 the elements that you had in there.
I had a couple of others 12 that I thought might be useful as well, one being identify 13 root causes of accident risks and applying resources in 14 accordance with those risks.
15 That gets a bit perhaps at priorities in terms of 16 what gets emphasis but overall I still have the comment in 17 terms of the goals themselves.
18 There isn*t any attempt or ettert to set what our i
19 priorities are, what is most important to us.
20 In terms of goal number two I have a few editorial 21 comments I could make on those but maybe now is not the best 22 time.
23 CHAIRMAN PALLADINO:
The editorial comments maybe 24 could be submitted by submitting your marked up copy.
25 COMMISSIONER ASSELSTINE:
Yes.
Goal three, okay.
-~
a 31 1
Goal four, radioactive waste management.
I didn*t think that i
2 all of the necessary elements were captured in the ones that 3
we have there and I thought that some others could be added 4
in.
For example, identifying as soon as possible technical 5
issues that must be addressed as part of the Commission's 4
6 licensing process for the repository and attempting to reach a 7
scientifically defensible resolution of those issues.
8 You have the timeliness in there.
It seems to me 9
you ought to have the technical part as well.
10 I think it would be useful also in the waste 11 management area to emphasize encouraging State and Indian 12 tribe participation, conducting reviews and evaluations in an l
13 open manner which are things that we are doing, that we are 14 saying we are going to do.
15 I had a little question about whether we wanted to 16 continue to put clean-up of TMI-2 particularly 11 one of our 17 goals was to assure the expeditious clean-up of TMI-2, that is 18 not one I would particularly want to draw attention to I think 19 at this point in terms of our success in doing that.
20 CHAIRMAN PALLADINO:
I would like to keep TMI-2 in 21 there some way yet.
22 COMMISSIONER ASSELSTINE:
If you want to keep it in 23 the FPG part. in the back, I think maybe that 14 useful in some 24 way to continue to assure continuing progress or something 25 like that.
It might not be so bad.
l 1
=
32 1
Managing agency resources more effectively and i
2 efficiently, it struck me a couple of other areas that we 3
could add in to emphasize, one would be training of our 4
personnel and I remember the last. time we had I guess it was 5
one of the regional administrator's meetings somebody talked 6
about the difficulty in making sure that our own people stay 7
trained and aware of current developments and also I thought 8
it might be useful to mention as one of our goals there 9
assuring equal employment opportunity.
10 MR. DIRCKS:
Clean-up of TMI-2 should be rephrased 11 anyway.
12 COMMISSIONER ASSELSTINE:
Yes.
13 MR. DIRCKS:
We are not cleaning it up.
14 COMMISSIONER ROBERTS:
We are not cleaning it up.
15 COMMISSIONER ASSELSTINE:
I had lots of comments on 16 the PPG itself both I suppose comments and questions.
One 17 comment on the positive side I would say I like the emphasis i
1 18 on emphasizing performance monitoring and some of the new 19 ideas that are in there.
20 I think those are new ideas.
They are consistent 21 with some of the things Bill that you and Jim Taylor and 22 Harold have been emphasizing and I think that is a good i
23 positive step and I was glad to see those retlected in t,h e 24 document.
25 MR. DIRCKS:
I have one more contribution.
I don't
. -.. ~ _ -.,.
"~
33 1
know whether this is the right time to put it in there, l
2 CHAIRMAN PALLADINO:
Which?
3 COMMISSIONER ASSELSTINE:
Suro.
4 MR. DIRCKS:
Maybe this is something the Commission wants to debate about.
I think somewhere in here should be a 6
reduction of the number of challenges to safety protection 7
systems.
8 CHAIRMAN PALLADINO:
That is a good point.
9 COMMISSIONER ASSELSTINE:
I like it.
10 MR. DIRCKS:
Even though some of those challenges 11 may come from balance of plants.
12 MR. RATHBUN:
That should be a goal 13 COMMISSIONER ASSELSTINE:
Yes.
14 COMMISSIONER ZECH:
But not necessarily a goal five, 15 somewhere else, goal one or two.
16 COMMISSIONER ASSELSTINE:
It could be part of goal 17 one.
18
Goal one, yes.
19 COMMISSIONER ASSELSTINE:
Assure safe operation of 20 the facility but then follow it up with some elements in the 21 Policy and Planning Guidance as well.
That is a good idea.
22 COMMISSIONER ZECH:
I agree.
23 COMMISSIONER ASSELSTINE:
I have a lot of mark ups 24 or editorial suggestions and also some things to add in.
25 Again, I don *t know how much detail you would want to go into 1
a 34 1
on the PPG itself but there is a fair number of those.
I had 2
a couple of questions about what things meant, what the 3
message was that was trying to be conveyed.
I don't know how 4
you want to proceed, whether you want to go through every one 5
of those that each of us have.
6 I suspect all of us have those things.
?
COMMISSIONER ROBERTS:
I suspect we all do.
Don't 8
you think this thing will be interminable it we do that?
9 COMMISSIONER ASSELSTINE:
It can go two ditterent 10 ways.
11 CHAIRMAN PALLADINO:
I think there are some important 12 issues that you may want to raise that would benefit form 13 interacting one to another.
Could you pick out a few examples 14 of non-editorial type comments or questions?
15 COMMISSIONER ASSELSTINE:
Maybe this is a question.
16 On page 12 on the oversee operating reactor performance, the 17 tirst two policies.
I guess one of the questions I had was 18 what does the second policy mean, what is it intended to 19 convey and how it at all does it modify the first policy?
20 What message is it that the second policy is trying 21 to convey to the statt?
What is it trying to tell them to do?
22 MR. RATHBUN:
I have the impression that that is 23 really a replication from I r. s t year.
24 COMMISSIONER ASSELSTINE:
What did we try to convey 25-last year?
.. = _
~ ~ _ - _ -._-
,e i
l 35 l
1 MR. EYSYMONTT:
Obviously, the issue, perhaps not i
2 obviously, the issue has been what role the NRC takes in the i
3 safety of a plant and I think there has always been dichotomy 4
there between our regulating and going in and actually 4
5 operating, the idea of operating the plant in the event that J
J 6
there is an incident.
7 CHAIRMAN PALLADINO:
Why don't you accept it as a j
8 question tc be examined and to be claritied.
9 COMMISSIONER ASSELSTINE:
Sure.
10 MR. RATHBUN:
Let me just say that it is more than i
j 11 just last year.
f 12 MR. EYSYMONTT:
It has been a historical issue.
3 i
j 13 MR. RATHBUN:
Going all the way back to the 14 beginning.
t 15 MR. DIRCKS:
It may fall under the Philosophy of i
j 16 Regulation.
17 COMMISSIONER ASSELSTINE:
It the concept here is 18 that the NRC should not be making operational decisions for
{
19 plants in emergencies, okay, now I understand the point.
That 20 is clear enough.
But I think that could be revised to convey i
21 that particular point it that is the point that policy is 22 supposed to connect.
f I
23 COMMISSIONER BERNTHAL:
I think Bill has probably 24 hit it on the head in that it really is a philosophy.
25 COMMISSIONER ASSELSTINE:
Yes.
i i
e 36 1
CHAIRMAN PALLADINO:
Philosophy in policy sometimes 2
emerge.
3 COMMISSIONER ASSELSTINE:
Yes.
4 MR. D I R C r.S :
It may be a statement of the limits of 5
our ability to control events out there.
6 CHAIRMAN PALLADINO:
I think this could be clarified 7
to better reflect the point that is trying to be made and make 6
it into something that is more policy oriented than just a 9
statement of philosophy.
10 COMMISSIONER ASSELSTINE:
Let's see.
11 CHAIRMAN PALLADINO:
Do you want to pick another one 12 and then I 'will give somebody else a chance while you pick 13 some others?
14 COMMISSIONER ASSELSTINE:
Sure.
On the monitoring 15 of performance, I am not sure this is a major point.
16 CHAIRMAN PALLADINO:
What page?
17 COMMISSIONER ASSELSTINE:
Pages 13 to 14, again as I 18 say I thought that this was one of the positive improvements 19 in the document to put in the concept that we are going to 20 tocus more on plant performance and it seemed to me that you 21 could strengthen that by adding -- we talk about plant 22 performance indicators, monitorin: performance indicators, and 23 it seemed to me that one could be strengthened by putting in 24 an element that the statt will prepare a set of performance 25 indicators and a system for reporting plant performance
+
my
-, - +
r+
-y--A
e 4
37 1
information which will be used as the basis for evaluating 2
plant performance.
3 It seems to me that is implicit in what you have 4
there but we ought to make it explicit that that is what is i
5 going to be done.
6 MR. DIRCKG:
There is a statement of performance 7
indicators.
1 1
8 MR. ROE:
Page 15, number five, it says the staff l
9 should develop performance indicators to monitor operating 10 reactors.
11 COMMISSIONER ASSELSTINE:
It seems to me that it 12 ought to be in one and it also ought to include a system for f
13 reporting performance information so that and that system will 14 he the basis for these reviews.
15 MM. ROE:
I think it is implicit, yes.
16 COMMISSIONER ROBERTS:
I want to make sure you 17 understand.
Are you talking about operating criteria because 18 that is what it sounds like to me.
J 19 MR. DIRCKS:
I don *t know how you define it.
I 20 think Commissioner Zech had a memo on performance indicators.
2i COMMISSIONER ASSELSTINE:
That*s right.
It said we 22 ought to have them and I agree with that.
1 23 MR. DIRCKS:
I think you and I talked about it.
24 COMMISSIONER ZECH:
right.
25 MR. DIRCKS:
I think it as less than general
38 1
operating criteria and it is more in line with what maybe INFO 2
is going.
3 COMMISSIONER ASSELSTINE:
That is right.
4 4
MR. DIRCKS:
It is not a regulatory the way I 5
look at it and I may be wrong, it may not be a set of i
'6 regulatory criteria but it is a set of indicators that would 7
direct our attention to plants that may require 8
COMMISSIONER ZECH:
It is a record of their plant 9
performance that could be useful to us perhaps in looking 10 ahead to see a declining performance or a problem area, for 11 example, increasing of rad waste or chemistry problems in the i
12 plant, those kinds of things.
13 Those are performance indicators as I see them but I 14 think they are very useful for us in helping us to look into 15 the future and perhaps find the plant that is declining 16 performance and how we define them here, I guess it was my 17 terms performance indicators.
It sounded fairly clear to me.
18 MR. DIRCKS:
I think general operating criteria 19 connotes some sort of a regulatory requirement.
20 COMMISSIONER ROBERTS:
No question.
21 COMMISSIONER ASSELSTINE:
Yes.
22 MR. DIRCKS:
This is not.
23 COMMISSIONER ROBERTS:
All right.
It just.seemed i
24 that you are driving toward that.
25 MR. DIRCKS:
That was not our intention.
J 39 1
COMMISSIONER ASSELSTINE:
Trips, challenges to 2
safety systems, tailures of safety equipment, size of 3
maintenance backlogs, it is those kinds of things, indicators 4
that would point to the potential weak performer that needs 5
attention or the potential good performer that we could back 6
off a bit on.
7 MR. DIRCKS:
This is something that INFO was very 8
heavily inYolved in.
I think they have something like 32 9
performance criteria and that is another story but we have 10 been trying to 11 COMMISSIONER ZECH:
But you also have information 12 available to you on the number of trips and things like that.
13 MR. DIRCKS:
Thas may be an area that we could 14 jointly work with INFO on.
t 15 COMMISSIONER ZECH:
Sure.
16 MR. DIRCKS:
And work together with them on their 17 criteria.
18 COMMISSIONER ZECH:
But we should have some sort of 19 operational performance criteria that you are looking at, that 20 you can judge against, that we have enough experience by now 21 certainly in this agency to be able to find useful trends and 22 it is important that we do that.
It is a responsibility we 23 have, I think.
24 MR. DIRCKS:
In the implementation ph'ase of this and 25 they say develop these performance criteria to the maximum
o 40 1
extent possible work with the industry group such as INFO to 2
a s s ttr e a common or work toward - common set of criteria.
3 COMMISSIONER ZECH:
You know what we need though and 4
what we are looking for and that is the importtnt thing.
5 COMMISSIONER ASSELSTINE:
Yes, but it does seem to 6
me that the clements are a set of performance indicators that
?
we feel are an accurate measure of performance trends and
't i
8 secondly a system that assures that we get the information on 9
those so that we can keep track of where the plants are.
10 COMMISSIONER ZECH:
Sure.
11 COMMISSIONER ASSELSTINE:
Joe, if you want to go te 12 others, I have some more,i but feel free.
13 CHAIRMAN PALLADINO:
Let me go to Tom and then 14 meanwhile you can identify others.
15 COMMISSIONER HOBERTS:
I have numerous editorial 16 nits but in section tour of the policies and planning guidance.
17 CHAIRMAN PALLADINO:
What page is that?
18 COMMISSIONER ROBERTS:
I am on page 10, look, I 19 think the Research Program is important.
I don *t deny that 20 but you have 12 misston areas and they more than cover the 21 programs supported by research.
22 I just don *t see any need to have this long 23 dissertation on pages beginning at the bottom of page 10, 11 24 and 12 about the Research Program.
25 MR. ROE:
I think the point here is that we have
41 1
continuously spoken about the importance of our Research 2
Program, however we haven't articulated it in any of our 3
policy or planning.
4 I tnink it we take a look at what we have put in 5
research in the past PPG's, it is relegated to the last part 6
entybe three or tour sections.
?
I think it is time even in a document.ike this to 8
give them credit for the importance to our regulatory mission 9
and in many of our licensing activities and some of the 10 decisions you make are based on this fundamental research.
We 11 have done research in some of these areas.
12 I think that we have felt strongly about putting it l '3 in here and it has already been carved back by OPE once, the 14 amount that we wanted to put in.
We think it is time to make 15 that statement of the importance.
16 CHAIRMAN PALLADINO:
I think it is important 17 particularly because we don't have a special section entitled, 18 "Research."
Id MR. ROE:
That s correct.
20 MR. EYSYMONTT-Last year, Mr. Chairman, we had a
)
1 21 special section on research.
22 CHAIRMAN PALLADINO:
Yes, I now we did.
23 MR, EYSYMONTT:
This year because of the c'hange that 24 is being made in the structure of the document, there is no 25 place to put research.
It is really spread out throughout all 1
42 1
the 12 mission areas so that is why there are these paragraphs 2
on pages 10 through 12 which deal with research and it is a 3
structural problem.
4 COMMISSIONER ASSELSTINE:
I think where we have 5
tallen down in research in the past is in many instances not 6
being as ettective as we could in relating the research 7
program to specific regulatory objectives.
B MR. ROE:
Or to the missions such as we have here 9
COMMISSIONER ASSELSTINE:
YEs, that is right.
10 MR. EYSYMONTT:
That is exactly what is being 11 attempted here.
12 MR. ROE:
That is exactly what the focus is here, to 13 show that the research is related to the regulatory mission of 14 the NHC instead of as an independent stand by alone program 15 that is not relevant to any of our activities.
16 COMMISSIONER ASSELSTINE:
But isn't the better way 17 to do that to bolster the individual discussions of research 18 ettorts under each of the major topics than to put in this 19 couple of pages, i
20 MR. ROE:
We tried to ao that in certain areas, 21 also.
22 COMMISSIONER ASSELSTINE:
I think I am inclined to 23 agree with Tom that maybe you could pare back some more on 24 this discussion on pages 10, 11 and 12 but on the other hand 25 bolster the discussion in specific areas to show what specific
43 1
contributions we expect the research program to make in each 2
of the individual areas.
3 CHAIRMAN PALLADINO:
I have to get my two-cents in 4
here.
I think we have made a big improvement because we have 5
the research identified with the particular mission area and I 6
think that is a worthwhile approach.
7 But still we need to bring together in one point in 8
this document' the general importance of research and the 9
degree to which we have to rely on it in making sure that we 10 have the data on which to make regulatory decisions.
I would 11 be cautious about just cutting too much out of this.
I 12 certainly would be receptive to changes that would improve it 13 but I don't see it all that damaging.
14 As a matter of tact, I think it is a constructive 15 element in the proposal.
16 COMMISSIONER BERNTHAL:
I cert ainly don *t think it 17 is damaging.
18 CHAIRMAN PALLADINO:
I think it is helpivl.
19 COMMISSIONER BERNTHAL:
You all have long known my 20 views.
I think we need to be far more specific and I think 21 there needs to be tar more direction on what we should do 22 better and different in this research area perhaps to the 23 point even of specific problems directing the stait to be 24 setting acme goals and deadlines to solve specific or develop 25 the framework even for solving specific problems.
~_
l l
44 1
CHAIRMAN PALLADINO:
I don't follow you.
I thought 2
that is what we did.
3 COMMISSIONER BERNTHAL:
I will give you a copy of my 4
memo from a year or so ago. I just don *t think that there is the kind of direction and coherence in that ettort that is 6
going to keep us in the money.
That is all That is a crass 7
way to put it but the track record is one of continual decrease 8
in funding for research.
We have to ask ourselves why.
9 ColtMISSIONER ASSELSTINE:
Tom, did you have specific 10 problem with the stuft that was said in there other than you 11 Just thought it was a longer discussion than was necessary?
12 COMMISSIONER ROBERTS:
More than is necessary, I 13 question whether it is in the right place.
14, CHAIRMAN PALLADINO:
How do others teel about at 15 least that particular point?
16 COMMISSIONER BERNTHAL:
I don't have any problem with' leaving it in.
I think it is boiler' plate.
It doesn't 17 18 set"any new directions.
19 CHAIRMAN PALLADINO:
It'you have some suggestions 20 for improvement, I think those would be helpful.
21 COMMISSIONER ASSELSTINE:
I can take a look at it i
22 and see if I can come up with anything.
I didn't have any 23 real problem with what was said.
24 CHAIRMAN PALLADINO:
Tom, do you have more't 25 COMMISSIONER ROBERTS:
No.
I mean I have a lot more 1
- ---I
i
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I 45 l
I but I don't think this meeting is the appropriate place for 2
doing it.
3 CHAIRMAN PALLADINO:
I was trying to get on the 4
table items that we should discuss.
5 COMMISSIONER BERNTP. AL
- Let me put it this way.
I 6
think that the ettort that we apparently tried and failed at t
/
is one that we should try again at it if I had my druthers.
8 We ought to go through here and every place where 9
research has a program or an objective which relates to our 10 overall policy that should be met, we should state that it 11 should be met and tell what we expect to be done.
12 If you did something like that then you might begin 13 to achieve the objectives that we need to in those areas.
14 COMMISSIONER ASSELSTINE:
Joe, I have one or two 15 others.
16 CH A I L' MAN PALLADINO:
I think that is a good l '/
suggestion to the extent that it isn't done here.
Some places 18 it is done but not extensively.
19 COMMISSIONER BERNTHAL:
It is easy to forget it as 20 you go through.
21 MR. SCROGGINS:
Mr. Chairman, one area that can 22 certainly be done on and is usually attempted to is once we 23 take the policy and planning guidance and in etteet put out 24 the EDO program guidance which is much more specific is to 25 clearly in that type of guidance intended to be much more
46 1
specific as to what the deliverables and the milestones as to 2
how that research effort would meet the specific planning 3
guidance that was there.
4 That may be a vehicle where certainly one can 5
address that even more say.
6 CHAIRMAN PALLADINO:
Yes, I think that is true 7
although we should not miss the opportunity to indicate the
't 8
role that research is playing in the particular mission area.
9 MR. SCROGGINS:
I understand.
10 CHAIRMAN PALLADINO:
Fred, do you have mo r -
for the 11 moment?
12 COMMISSIONER,BERNTHAL:
I have some other comments 13 but Tom, did you have more?
14 COMMISSIONER ROBERTS:
No.
15 COMMISSIONER BERNTHAL:
Let me see if I can keep 16 away from editorials here and editorialising.
17 On page eight this is a thought, going down all 18 those bullets there, I don't quite know how to put this in a 19 delicate or a diplomatic way but it strikes me both in my 20 visits to plants in the field, visits to regional offices and 21 what-not, that we should have a greater consciousness and 22 concern and perhaps some kind of a program it we don *t already 23 on ciplomacy is too weak, maybe it is human relations or 24 scmething.
25 What I am trying to say is that there should be some
.s 47 1
kind of guidance, a program of instruction, or something to 2
our field staff in particular on the kind of demeanor and 3
professionalism that they s h o'ri d display in exercising dealing 4
with licensees.
5 I am not being critical I am saying that I don't 6
even know whether we have thought about it but it has struck
?
me on occasion that there is a certain attitude that is the 8
right attitude and then there is sometimes the attitude that I 9
don *t think is the right attitude that kind of we are the Fods 10 and we know how to tell you all what to do and there is a 11 palpable difference as you go from one place to the other.
12 From time to time it has struck me that our people 13 could use a little bit of guidance in that area.
I don't know 14 whether we try to do that or not.
I don't know how you can 15 word is delicately but we ought to do something like that.
16 CHAIRMAN PALLADINO:
You are talking about an aspect 17 of training perhaps.
18 COMMISSIONER BERNTHAL:
It is an aspect of our own 19 statt training, I think.
I don't know.
Bill, what do you 20 think?
21 MR. DIRCKS:
We oculd certainly give it a shot.
It 22 comes I think almost wit.. wearing the federal uniform.
It is 23 not only common to our agency but it is common to any federal j
l 24 otticial to tends to exercise some authority.
)
25 COMMISSIONER BERNTHAL:
Sure.
i
i 48 i
MR. DIRCKS:
I can see what you are driving at and 2
the possibility of introducing some training into this thing.
3 COMMISSIONER BERNTHAL:
There is an element of being 4
a r.d you want firmness and resolve and yet you don't want a S
kind of negative attitude that will get negative results.
It 6
is a delicate line to be trod and I suspect there are people 7
who worry about that a lot that teach management techniques 8
and what-not.
9 CHAIRMAN PALLADINO:
I wouldn't get into a lot of 10 detail in this document.
11 COMMISSIONER BERNTHAL:
No, I realize that.
12 CHAIRMAN PALLADINO:
But you might include under the 13 training of NRC employees for a more ettective 14 interrelationship of licensees and then think through the 15 details of the program.
16 MR. DIRCKS:
And the public.
17 CHAIRMAN PALLADINO:
And the public, yes.
18 COMMISSIONER BERNTHAL:
The public as well That is 19 certainly true, too.
20 CHAIRMAN PALLADINO:
All right.
Do you have another 21 point?
22 COMMISSIONER BERNTHAL:
Page 13, point five, 23
" Emergency planning should be based on realistic assumptions."
24 You can't argue with that.
I am not sure whether that means 25 the others shouldn*t.
You might think about re-writing that.
1 49 1
Point six, it seems to me that the commitment to 2
occupational radiation protection should be more positively 3
stated.
It is kind of stated as a -- we ought to consider it, 4
it says, and it struck me that we should be a bit more positive 5
und forthright in saying that that is an important 6
consideration.
?
Page 15, on point six there one of the real 8
ditticulties it seems to me that we have and have talked about 9
and continue to talk about is this problem of license 10 amendments, technical specifications, how far behind we are 11 and I don't see any new ideas.
We say continue to provide 12 timely response to the public at least but this is a serious 13 problem area and I would sure like to see some new thoughts nd 14 ideas there it that is possible.
I am not sure I have any.
15 MR. DIRCKS:
This doesn't take account of some of 16 the work that is going on that I think is pretty nea truition.
17 Certainly the approach to technical specifications, how we le write them and how we put them in the licenses is due to come 19 down to the Commission very shortly.
20 COMMISSIONER EERNTHAL:
Right.
What about 21 amendments?
22 MR. DIRCKS:
How to amend licenses, I think we are 23 back into "Sho11ey Land" and we can take another shot at that 24 but technical specification changes and how we deal with them 25 will make a major, I hope major, dent into this-problem, u.
i
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I 1
COMMISSIONER ASSELSTINE:
We c ett l d be honest and 2
drop the " continue to."
3 COMMISSIONER BERNTHAL:
We realLy are not timely and 4
that is the problem.
It we are the verge of solving at least 5
the tech spec problem maybe we should put in there what 6
milestones we expect to achieve or expect the stati to achieve 7
and then I sure would like to hear an idea or two on the 8
amendment problem.
9 MR. DIRCKS:
That I guess would be followed up in 10 the detailed program guidance that flows from that where we 11 establish more specificity.
12 COMMISSIONER BERNTHAL:
What should the Commission 13 be saying as a matter of policy?
My policy at least wod1d be 14 that we have to do something better here but I think we ought 15 to try to do better than that in providing guidance.
That is 16 enough comment ior the moment on that.
17 CHAIRMAN PALLADINO:
But I think your emphasis on 18 technical specifications is a very important emphasis and 19 should be highlighted.
I am not demeaning the others but I 20 think we have 3 lot of important work to do on technical 21 specifications.
22 COMMISSIONER BERNTHAL:
Then I am still troubled by 23 70 license amendments in at least one case and I am sure there 24 are others that sit there and we don *t seem to get the backlog 25 cleared away and it it is Sholley we are told lately that it
e 51 1
isn*t Sholley.
2 COMMISSIONER ASSELSTINE:
It is not Sholley, that is 3
right.
4 COMMISSIONER BERNTHAL:
It it is not Sholley, what 5
is it?
Well, enough said.
6 Point seven again on the TMI business, I was not 7
sure that that was not out of place because it appears under 8
operating.
9 COMMISSIONER ASSELSTINE:
It ought to be under waste 10 management.
11 COMMISSIONER BERNTHAL:
It ought to be somewhere 12 other than operating.
13 COMMISSIONER ASSELSTINE:
It is also someplace else, 14 too.
It is back on page 13.
Both of them should be someplace 15 else.
16 COMMISSIONER BERNTHAL:
That's editorial Let's 17 see.
I would suggesl that on page 19, point one under planning 18 guidance, I have to read this.
Listen to what you have 19 written.
20
" Consistent with maintaining adequate levels of 21 protection and without meeting legal requirements for operating 22 facilities 23 COMMISSIONER ASSELSTINE:
There is a typo in there 24 someplace.
There is something missing.
25 COMMISSIONER BERNTHAL:
Then beyond that, staff
{
1 s
t 1
52 1
reviews and public hearings should be completed on a schedule 2
that assures the licensing process will not be a critical path 3
item which could unnecessarily delay reactor startup."
4 I know what you are trying to say but the licensing 3
process is indeed critical path and there is no way to avoid 6
that.
7 COMMISSIONER ZECH:
You have to re-word that whole s
3 thing.
9 COMMISSIONER BERNTHAL:
It doesn't sound right.
10 Then at the very bottom again it reads as follows, "The stait 11 should carefully censider, on a plant-specific basis, the 12 necessity for some reactor operators with commercial experience 4
13 at every plant."
14 I thought it would'be nice to have that as a 15 requirement.
16 COMMISSIONER ASSELSTINE:
In fact, we have issued 17 guidance that takes ettect now in terms of what they have to 18 have.
I think the business of the shift advisors is'over 19 with.
20 COMMISSIONER BERNTHAL:
Yes, it isf 21 COMMISSIONER ASSELSTINE:
In which case this ought 22 to retlect what the policy statement says.
23 MR. DIRCKS:
It also gets back to the policies the 24 Commission adopted on hot operating experience.
25 COMMISSIONER BERNTHAL:
Exactly.
That's right.
f 8
53 1
MR. DIRCKS:
I think we covered that issue.
2 COMMISSIONER BERNTHAL:
Yes.
3 COMMISSIONER ASSELSTINE:
We did.
4 COMMISSIONER BERNTHAL:
It is settled.
5 CHAIRMAN PALLADINO:
That ought to be reflected.
6 COMMISSIONER ASSELSTINE:
It should be retlected but 7
it is not.
8 COMMISSIONER EERNTHAL:
That has been long settled.
9 COMMISSIONER ASSELSTINE:
That's right.
10 COMMI'SSIONER BERNTHAL:
On page 24 on the business 11 of source terms, point number five, I thought that we ought to 12 do a little better on that.
13 I realize the ditticulties and I guess maybe I am 14 accused as well of being among those who think we ought to 15 settle the science before we charge ahead here.
But on the 16 other. hand I would like to say something along the lines that 17 when on an issue by issue basis when we see that a regulatory 18 item has sufficient justification in the record, in the 19 scientific record, that we are going to go ahead and pursue 20 those items on a case by case basis when the record is 21 sutticient.
22 I can give a broad example here and that is the 23 case, let's suppose, of the large dry containments.
If the 24 couple of remaining outstanding issues are resolved in that 25 area and we find that the Commissicn can take action for a
l i
$4 1
large class of reactors I think we ought to go ahead and do 2
it, 3
Some people won't like that but I think we ought to 4
be prepared to discriminate among plants.
5 MR. DIRCKS:
I think the critical element there and 6
maybe you can get at it this way will be that the scientific
?
and technical basis behind the establishment of a methodology 8
for source term calculation will be completed expeditiously 9
and finalized.
10 Application of this methodology then could proceed, 11 application of the finalized methodology then could proceed on 12 a case by case basis with Commission a p'p r ov a l.
13 I think what you want to do and I hate to go back 14 into a source term discussion, but the essential element here 15 is to finalize and accept the source term methodology.
16 COMMISSIONER BERNTHAL; What does that mean, Bill?
17 MR. DIRCKS:
That means the codes, 0956, that we 18 said we would now, is out for comment and we have extended the 19 comment period and we intend to close the comment period 20 February 2 and once we have closed the book on the methodology.
21 then you can take the methodology into case by case 22-application.
23 I think maybe that is what you want to achieve.
You 24 want to achie7e finalization of.this methodology.
25 COMMISSIONER BERNTbAL:
I guess I feel a little bit
i 1
about that the way I did about standardization.
You will 2
recall my protesting a couple of years ago on that subject 3
that it is certainly true here whether or not it was true in 4
standardization that you are always going to be in an evolving area of knowledge and I 3m not sure you are ever going to get 6
to the polnt where you have it in hand, everything you ever 7
wanted to know about source terms is in this NEC NUMEG and now 8
we can move grandly ahead on all fronts.
9 I am not sure we will ever get there, Bill It 10 seems to me that wr.*n we are justified in moving in a given
]
11 area and when the data s*tpport it, we ought to have it as a 12 policy that we are going to move and not necessarily wait for 13 the last --
14 CHAIEMAN PALLADINO:
But I don't think, Fred, he is 15 ccJnting on that.
I think he is coun*ing on general to methodology and how would we want to apply it.
17 COMMISSIONER ASSELSTINE:
It is the approach.
18 CHAIRMAN PALLADINO:
I think it is meritorious to 19 wait for that but I agree with you when we can apply it and 20 make some gain on a particular case we ought to do it.
21 MR. DIRCKS:
What you want is an acceptable 22 methodology for calculating whatever source terms you need to 23 calculate for whatever purpose you need to calculate.
l 24 Until you get that acceptable methodology, the 2$
reverse of that is you are dealing.with unacceptable 1
l i
e u
r v
t I
$6 I
methodology.
2 COMMISSIONER BERNTHAL:
I don't know what the word 3
methodology means.
If you are talking about computer codes, 4
they are going to evolve.
5 MR. DIRCKS:
That is what I am talking about.
6 COMMISSIONER BEMNTHAL:
'fhey are going to change
?
every year and get better and taster.
8 MR. DIRCKS:
That's true.
I would agree.
However 9
you want to explain it, you are going to have to have some 10 approved methodology at whatever stage that methodology may be 11 in at that time before you can apply it.
12 COMMISSIONER BERNTHAL:
We are the ones that approve 13 it.
The staff decides that this particular area, let's say 14 for large drys is good enough and it is time move ahead on 15 that front.
This area maybe for BWR ones, we don't know 16 enough yet and we can't move ahead.
17 CHAIRMAN PALLADINO; I thought the issue on 18 methodology has been that we didn't have consistency among the 19 ways the people did things.
20 COMMISSIONER ASSELSTINE:
that's right.
21 CHAIRMAN PALLADINO:
I agree with you that the 22 methodology will continue to evolve but I think getting to a 23 point where we have a methodology that we have confidence in 24 to get started would be worthwnile.
25 COMMISSIONER BERNTHAL:
I think methodology then is i
$7 1
not the right word.
What we mean is that we don't trust yet 2
what we have seen and we are trying to' verity it.
Is that 3
what you are saying?
4 CHAIRMAN PALLADINO:
No.
5 MR. DIRCKS:
I think what was looking for is a -- I 6
hate to say it, a methodology that you can then apply to 7
individual plants and the i n d i v i. d u a l plants will vary.
Some 8
will be PWR's with large dry containments and the application 9
of the methodology may result in a fairly clean o te t answer.
10 COMMISSIONER ASSELSTINE:
That's right.
11 MR. DIRCKS:
Some may be other types of plants with 12 more complex risk factors and you are not going to get a clean 13 cut answers in applying the methodology.
14 COMMISSIONER BERNTHAL:
All right.
It is a fairly 15 esoteric discussion.
16 CHAIRMAN PALLADINO:
But I do think Commissioner 17 Bernthal is making an important point, that we should not 18 hesitate to go forward when we have reasonable set of data 19 that could lead it to a conclusion even 11 it is on a 20 particular type of plant.
21 MR. DIRCKS:
And an approved acceptable method or 22 way of calculating the source terms.
23 CHAIRMAN PALLADINO:
Yes.
24 COMMISSIONER ASSELSTINE:
That's right.
It is a 25 structure or framework for making decisions that you have o
m-
58 1
confidence that it is going to lead to sound results and those 2
results may oiffer depending upon the plant type or the 3
individual plant.
4 COMMISSIONER BERNTHAL:
That is a good discussion 5
and we should pursue it sometime but the statement as 1,t reads 6
says, " Changes to current regulatory policies will be
?
considered 11 the reassessment of the radioactive source terms i
8 and their risk importance so warrants."
9 That is pretty weak stuff and I would suggest at 10 least that we say specific changes to regulatory policies will 11 be timely pursued when the reassessment, et cetera, et cetera.
12 I don *t know.
Let*s true to get across the message.
13 MR. DIRCKS:
I was trying to be helpful in this 14 thing by giving you t i r m e'r words.
15 COMMISSIONER BERNTHAL:
It is worth thinking about.
16 I don *t want to worry about re-writing it here.
17 COMMISSIONER ASSELSTINE:
As long as the concept is 18 in there though that changes will take place 11 and when we 19 have the framework and the sound science that demonstrates 20 that those changes are justified.
Those are the two elements.
21 COMMISSIONER BERNTHAL:
To me, the framework is 22 science and i guess that is the operative word here.
23 Page 35, I guess that is mostly editorial.
Let me 24 not get into that on the HED/ LEU thing.
25 That is all I have for now.
59 1
Ch. one other broad point.
In view of what we have 2
undertaken yesterday and I guess in one or two additional 3
meetings I was wondering whether there shouldn't be some words 4
in nere 11 the Commission agrees that the Commission expects 5
of staff evaluation of IAEA adequacy, the adequacy of IAEA 6
safeguards, to come out of this process that we have begun
?
here.
8 That is a policy matter that we need to settle now.
9 Now whether we want to put it in the PPG or not, I don't 10 know.
I am inclined to think that we may want to have some 11 record.
12 CHAIRMAN PALLADINO:
It is a tricky question.
I 13 think we want the best assessment we ca pet but we have had 14 division among Commissioners on what application of the IAEA 15 safeguards means.
I remember when Commissioner Ahearne was 16 here, he and I joined forces to say well Congress ought to 17 tell us better so that we don't have to guess.
I guess I am 18 supporting you but it may be a broader issue than just making 19 an assessment for the present time based on the issues that we 20 have before us.
21 COMMISSIONER BERNTHAL:
Let me put it this way.
22 Somehow in the next few months we ought to have some document 23 or piece of paper that represents Commission policy in this 24 area.
25 If one of us needs to go somewhere to a meeting as
60 1
I did, we ought to have something that is later than 1982 to 2
point to.
We don't have it.
3 CHAIRMAN PALLADINO:
I think among other things you 4
are suggesting that we ought to look at these things at least 5
every five years so they don't sit forever.
f 6
COMMISSIONER BERNTHAL:
That is the point.
?
CHAIRMAN PALLADINO:
Let me give Lando a chance to 8
bring up points he has and then I can come back.
9 COMMISSIONER ZECH:
Now that you have heard my 10 suggestion on the format and I do think it would be helpful to 11 have that kind of format as we have discussed before, let me 12 just say that I think that both OPE and the _statt have done a 13 very good job in trying to put together this ditticult PPG as 14 we working toward a Five Year Plan and I have a real 15 appreciation for the task that you had ard that you still have 16 to work through this.
17 I t h i a.k as the Chairman has pointed out that the PPG 18 dooument itself is a very important piece of work and it does 19 have a standing of significance that we should all respect so 20 I do have an appreciation of what you are doing and that is 21 why I think it is important that we do the best job we can.
22 What I would like to do is just point out several 23 things here and I do have some editorials, too, that I will be 24 happy to get together in a very short order.
25 I think the goals that we have mentioned before
o 61 1
probably do need to be expanded a bit and I would suggest that 2
the statt and OPE see where you feel that needs to be done and 3
give us your suggestion in that regard.
4 CHAIRMAN PALLADINO:
This is strategic goals?
5 COMMISSIONER ZECH:
Strategic goals.
I think they 6
should flow right into the policies and planning, into the
?
mission areas that we have discussed.
8 Let me just say on the mission areas I am looking 9
now at the table of contents and it is easier to look at it 10 that way because you have them all listed together, I would II suggest that we consider combing these major mission areas.
12 Rather than have 12 of them, get it down to a number of maybe 13 about seven.
14 I think some of them would combine very easily.
F 15 example, I would suggest you combine "A"
and "C"
and then 16 combine "B,"
"D" and "F."
That makes two out of five, two 17 from tive.
18 CHAIRMAN PALLADINO:
Which were the first two?
19 COMMISSIONER ZECH:
Combine "A"
and "C,"
" Oversee 20 Operating Meactor Fertermance" and combine that with " License 21 Current and Future Reactor Designs."
Then combine "B,"
"D" 22 and "E."
just'trying to get less than 12 major areas so 23 I am 24 that we can have a little bit better number to start with.
We 25 might break these down further in the subdivisions.
62 1
Then I would suggest combining "G"
and "H,"
"Megulate l
2 High Level Waste," combine that with " Regulate Low Level 3
Waste."
4 I would suggest combining "J"
and "K,"
- Review 5
Al1egations and Conduet investigations" and combine that with 6
"Take Enforcement Actions.'
It seems to me that is a rather 7
logical combination.
8 CHAIRMAN PALLADINO:
Which two were those again?
9 COMMISSIONER ZECH:
"J" and K."
You end up 11 you 10 do that with seven instead of 12 and it is just a little more 11 manageable.
12 Alsc, while we are looking at this and I think we 13 have already talked about the research area but I am not 14 exactly sure of the best way to hit research.
15 I see I think what the staff is telling us and I 16 appreciate the fact that they are trying to show us that
$7 research should be blended in across the board in all of our 18 areas and I submit that is a logical way to look at it.
19 On the other hand you can see as we get to -- let's 20 see.
I am going to skip over to page ten where they talk 21 about research and Commissioner Roberts already talked about 22 this and pointed out that it kind of hit him as it did me, 23 too, that all of a sudden we are talking research in a way we 1
24 are not talking other areas.
1 1
25 I appreciate wha.t we are trying to say.
I don *t i
63 1
know that we have hit the right way to execute what we want to 2
do.
I think we need to think about this a little more.
I 3
think we are trying to emphasize the importance of research 4
because you have taken it out of all those mission areas as a headliner and I appreciate that but I would say that we should 6
think about that to see whether it is the best way.
1 It just kind of hits you like you had a package and 8
you ju.t kind of put it all in here and all of a sudden we are 9
talking research.
It needs to be said a little differently I 10 think.
11 If I could go back to page nine on goal four where 12 it says, " Clean up TMI-2 expeditiously," I think we have 13 touched on that, I just said that we should change the 14 wording of that to something like support ettorts to clean up 15 TMI-2 expeditiously rather than imply that we are cleaning it 16 up because I don't think it is the agency's job to do it 17 directly but I think we certainly should support the ottorts 18 to clean up TMI-2 or continue to support or words to that 19 ettect.
20 In goal five, I think we ought to have a bullet, the 21 first bullet, somewhere or other should reflect our people 22 programs and our emphasis on our people resources.
It says, 23
" Reorganize value of NRC employees."
I think that should be 24 expanded a bit so that we do more than recognize the value of 25 them but that we find other words to show the importance we
64 1
give our people.
2 I am not going to go over them all, Mr. Chairman, 3
but let me just hit on a couple of other things I had.
I 4
guess we have talked about page 11, the planning guidance 5
number cne.
I think we have talked about that one and I guess 6
you agreed to re-write that one.
?
Also on the bottom, have we talked about this, I
- \\
8 think we did, too, "The statt should carefully consider plant 9
specific basis the necessity of some reactor operators with 10 commercial experience."
Yes, I think we already hit on that 11 one.
That is another one that I think should be reworded.
12 I have some more editorials but they are small 13 suggestions.
I could skip to page -- let's see, more
~
14 editorials.
If you go bsck to page 38, again we talk about 15 NHC's greatest resource is its employees.
i
~
16 I submit that is almost an understatement and 17 someway or another I think we should talk about ways to 18 encourage more effective and productive use of our people but 19 also the recognition of our people across the board in the 20 agency, their overall importance to us.
21 I am talking about such things as their professional 22 competence as well as their integrity, all around performance 23 and even something about service to your country and our 24 responsibilities to our fellow citizens.
25 I just think that this is an ideal document to state i
l e5 1
some of those things that I nelieve very strongly and I think 1
2 this would give us an opportunity to do that.
{
3 I have other suggestions but they are really not of 4
a nature that I think we need to take more time today.
I do 5
think 1 hat we should all try to get in our specific comments 6
as soon as we can and I would hope that we could get them in 7
sometime like by the end of next week.
Maybe that is too 8
soon.
9 CHAIRMAN PALLADINO:
The end of next week being 10 what?
11 COMMISSIONER ZECH:
Something like the 6th of 12 December, I think, isn't it?
13 CHAIRMAN PALLADINO:
Yes.
I was going to ask for 14 them by the oth.
15 COMMISSIONER ZECH:
That*s fine.
I think we ought 16 to be able to do that.
It is not an easy task and the program 17 is very important and we cannot do that in a manner that we 18 are not reasonably confident, they are putting out a 19 first-class document.
20 So it does take an effort but I think we should 21 shoot for that.
I certainly will 22 CHAIRMAN PALLADINO:
Yes.
I was going to suggest 23 thrt we try to get our comments both the specific and editorial 24 comments to OPE I was going to say by the 5th.
25 My target was to see it we could have a document on
l l
i 66 1
which we might even vote by the 18th of December.
I 2
COMMISSIONER ROBERTS:
Would you refresh my memory, 3
Mr. Chairman?
Did all of us support last year's PPG?
4 CHAIRMAN PALLADINO:
I don't remember.
5 COMMISSIONER ASSELSTINE:
No.
I did not support the 6
regulatory philosophy.
?
CHAIRMAN PALLADINO:
That's right.
But I think when 8
we get close enough, there are preferences where somebody 9
might prefer to say things one way as opposed to another but 10 when we feel that we have the points covered and we get them 11 covered at least to the extent that the Commission feels is 12 warranted, then I would suggest we try to approve it.
13 COMMISSIONER ZECH:
I think the schedule is 14 reasonable as far as I am concerned.
15 COMMISSIONER ASSELSTINE:
Sounds good.
16 CHAIRMAN PALLADINO:
Why don't we make our next 17 target, try to get all our comments in by the 5th of December, 18 MR. EYSYMONTT:
Mr. Chairman, does that mean you 19 still want a document which shows the differences.
20 CHAIRMAN PALLADINO:
I am going to ask indulgence of 21 the Commission to do the following, they don't_have to indulge 22 me but I would suggest we do the following and I hope it is 23 okay with you, Lando, that we get our comments in including 24 the comments that we want to have some indication, we want to 25 have indication of what things were in last year's version and
67 i
1 then have them modity the document to reflect all the comments 2
they get as much as they can.
3 When we get the new document, then I would expect to 4
4 see a line-in/line-out of this document because I would expect 5
that you are not changing the whole format.
6 MR. EYSYMONTT:
- Right, I don't see any problem with
?
that, Mr. Chairman.
The issue still is what do we do with a 8
comparison between this year's and last year's document.
9 CHAIRMAN PALLADINO:
All right.
I will make a 10 suggestion on that, that you actually put as part of the 11 document some of the principal changes that occurred during 12 the past year that impact on this document such as you did in 13 a summary form here.
14 Then I think for Commission use, give us marginal 15 notations on the changes in specific areas as you go through 16 the document and 11 there is no change, I don't know that we 17 need to mark "no change" but 11 there is a change then indicate 18 it.
i 19 Jim, you had not finished?
20 COMMISSIONER ASSELSTINE:
Yes I have a couple more 21 that I found that are more than editorial that might be l
22 worthwhile just to mention.
23 CHAIRMAN PALLADINO:
All r i g h t..
24 COMMISSIONER ASSELSTINE:
Page 10, item number five.
25 calls upon the statt to propose policy guidance and develop
68 1
licensing criteria to define requirements for operating 2
license extensions, the plant life extension question.
3 I agree that that is an important thing to begin 4
working on but it struck me that this next year might be a little early for us to be actually 6
MR. ROE:
No.
7 COMMISSIONER ASSELSTINE:
You are going to be ready 8
to promulgate licensing criteria by then?
9 MR. ROE:
That is one of the things that when we 10 have seen the scheme it is time to start to address them so 11 that they can go through the process as the first ones come i
12 up.
At least that is the assessment from the statt, that it 13 is not too early to start looking at this issue because of the 14 time trame it may take.
15 COMMISSIONER ASSELSTINE:
All right.
16 MR. ROE:
Some of these are very unique issues that ly we have never addressed before is life extension past 40 years
- 18 and if you lay out the diagram it may not be too early.
19 COMMISSIONER ASSELSTINE:
All right.
20 MR. RATHBUN:
I think that is a timely issue.
We 21 wrote a paper to the Commission on that within the past two 22 weeks and we are getting some reaction from the Commissioners 23 now.
24 COMMISSIONER ASSELSTINE:
All right.
25 MR. RATHBUN:
So I think it is timely.
I agree with
o j
09 1
Jack.
2 COMMISSIONER ASSELSTINE:
Good.
The next one is on 3
page 23, we talk about on'page 22 containment performance.
I 4
think it is something that is called for under the Severe 5
Accident Policy Statement.
It seems to me that we ought to 6
have an item on page 23 that says the statt should develop a 7
set of containment performance criteria that will ensure the 8
safe and ettective containment performance by all plants, just 9
put it in specifically.
10 The next one is on page 24, item number six, on 11 safety goals.
It looks to me like that ought to be updated.
12 It is the same thing from last year and it is not a question 13 of the preliminary safety goals and you won't use them.
It is 14 now we are going to be revising, finalizing or whatever it is 15 we are going to be doing over the next year.
It ought to be 16 current.
17 MR. RATHBUN:
We left that the same the reason being 18 that the evaluation period has not concluded yet, has not been 19 completed yet and the Commission's guidance to the statt was 20 and I assume remains this sentence at least at this time not 21 to use the preliminary safety goals as a basis for making 22 regulatory decisions during the evaluation period.
23 COMMISSIONER ASSELSTINE:
All right, 24 MR.
RATHBUN:
If you want to go beyond that, that is 25 fine.
a 70 1
COMMISSIONER ASSELSTINE:
I think it could be 1
2 updated to say that the Commission is going to be working to i
3 develop a final set of safety goals during the current year.
4 In the meantime, the previous direction stands that you don't l
5 use the interim one.
6 COMMISSIONER BERNTHAL:
It seems to me that the 7
planning guidance or policy guidance should be to plan for
't 8
implementation.
I would hope that we would have that thing 9
out of here in the next few months.
10 COMMISSIONER ASSELSTINE:
At least we ought to be 11 addressing it.
12 COMMISSIONER BERNTHAL:
You all look so skeptical.
13 CHAIRMAN PALLADINO:
I am with Fred on that one.
14 COMMISSICEER ZECH:
I am not so sure either but we 15 can try to work some other words but I am not so sure that it 16 is going to happen anytime soon.
17 CHAIRMAN PALLADINO:
I think the statt owes us 18 something on safety goals.
We had a presentation.
They had a 19 steering committee that worked for a couple of years and came 20 out with a report that covers a lot of territory.
We had an 21 informal presentation that I think grew out of management 22 review-of that report.
23 I think the staff owes us a recommendation now on 24 what we ought to do on safety goals.
It it is the steering 25 committee report, fine.
It it is some modification of it,
l 71 1
fine.
I think that would give us something on which to act.
2 Right now we are in limbo and that is why it is 3
going to take a long time but I don't see why we couldn't get 4
a report by April or even earlier.
5 MR DIRCKS:
You don't want to take that up now, do 6
you?
?
CHAIRMAN PALLADINO:
No.
8 MR. DIRCKS:
I could say something.
9 CHAIRMAN PALLADINO:
I am just giving you 10 COMMISSIONER ROBERTS:
I am sure you could.
11 (Laughter.)
12 CHAIRMAN PALLADINO:
I just took this opportunity to 13 make my little speech on safety goals.
14 COMMISSIOr*ER ASSELSTINE:
We can take it up at the 15 next meeting.
16 COMMISSIONER BERNTHAL:
Oh, yes.
17 (Laughter.)
18 CHAIRMAN PALLADINO:
Since we were talking about 19 what the PPG ought to say, I am with Fred on that.
20 COMMISSIONER AmsELSTINE:
I think it ought to say 21 something about what our intentions are for this year as well 22 as Just the old direction that they are not to use the interim 23 ones.
24 COMMISSIONER BERNTHAL:
It is like saying, "What are 25 you intentions, young man?"
72 1
MR. DIRCKS:
I don't want to prolong this.
l 2
CHAIRMAN PALLADINO:
Go ahead.
I think I have to i
3 give the EDO a chance to respond.
4 MR. DIRCKS:
We did have that meeting and we took the safety goals basically as developed and we didn't come in 6
with a proposal to change the sciety goals but we came in with 7
a matrix proposal to implement it.
3 Now as a result of that I think how we left it is we 3
would get some guidance back from the Commission and then we 10 would incorporate that and then go to the ACRS.
11 CHAIRMAN PALLADINO:
I will get back to you.
I s
12 didn't mean to debate it all here.
13 MR. DIRCKS:
I didn't want it left that we were just 14 sort of sitting here not doing anything.
We were waiting to 15 move in certain directions.
16 CHAIRMAN PALLADINO:
I will come back to that.
17 COMMISSIONER BERNTHAL:
That is my recollection too, 18 Bill, in fairness and I think that right now the monkey is on 19 our back and with all due respect to the ACRS-11 we wait until 20 they finish their debates on this subject, I am sure we will 21 be able to look down the road at least a year or two and I see 22 no reason to do that.
23 I think that this issue becomes rather simple when 24 you really sit down and ask what we are going to need to 25 achieve.
If someone wants to demonstrate to me why it is
73 1
complicated, then I am happy to listen but I would like to 2
hear some ideas and thoughts from the staff or anywhere else.
3 CHAIRMAN PALLADINO:
1 apologize for getting us off 4
the track.
It is one of the items that is very dear to my 5
heart and I would like to see us get somewhere but we ought to 6
talk about this in a different forum.
7 Mit. DIRCKS:
It is not simple because I got an ear 8
full when I was in Paris from other countri s on the issue of 9
safety goals.
10 COMMISSIONER BERNTHAL:
Let*s get at it then.
I 11 think it is time to get moving.
12 CHAIRMAN PALLADINO:
Let*s see it we can cover some 13 more points.
14 COMMISSIONER ASSELSTINE:
Why don *t I stop at that 15 point.
I think essentially the rest of mine are largely 16 editorials so I would stop at that point.
17 CHAIRMAN PALLADINO:
All right.
Let's see it we can 18 agree 19 COMMISSIONER BERNTHAL:
Joe.
20 CHAIRMAN PALLADINO:
I am sorry.
l 21 COMMISSIONER BERNTHAL:
I have one more point of 22 substance that I neglected to mention.
I am not sure that vie 23 can settle it here but I am more convinced than I have ever 24 been that we should think about some new guidance on our 25 entire handling of data, ADP data handling, document ha.Taling,
T a
74 communications, in this agency and if the Ccmmission could 2
find its way clear to issue policy guidance on that I would 3
uTge us to do so.
4 It is just becoming as clear as can be that we have 5
not given adequate guidance there and I think it is time to do 6
Jo.
That is a new thought.
?
COMMISSIONER ASSELSTINE:
Let's start with let's not 8
throw good money after bad.
9 COMMISSIONER BERNTHAL:
Yes.
10 CHAIRMAN PALLADINO:
Why don't you propose something 11 that might be incorporated or at least let them try to propose 12 it and return.
13 MR. ROE:
We can put something in there.
14 COMMISSIONER BERNTHAL:
I could revert to my mentor, 15 Victor Gilinsky, here on this point.
16 COMMISSIONER ROBERTS:
I am anxious to hear this 17 one.
18 (Laughter.)
19 MR. EYSYMONTT:
That has perked things up!
20 (Laughter.)
21 MR. DIRCKS:
I thought we dealt with all of Victor *s 22 suggestions.
23 COMMISSIONER BERNTHAL:
I think we need somebody 24 that manages that for the entire agency and his long idea of 25 combining all of those-functions including communications in
._ o-
?$
1 one shop, one oliice, was correct.
I think we are having it 2
demonstrated more year by year.
That is all I wanted to say.
3 CHAIRMAN PALLADINO:
Why don't you make the proposal 4
or any suggestion to OPE.
11 you don't make a suggestion let 5
them try to ocme back to you.
6 COMMISSIONER BERNTHAL:
I think George might be able
?
to work something out like an addendum.
8 CHAIRMAN PALLADINO:
While I am trying to be helpful 9
on the PPG, I wouldn't want to be appearing to endorse the 10 complete criticism of all our ADP work.
11 COMMISSIONER BERNTHAL:
I realize that we probably 12 are not ready to agree and we shouldn't make PPG an area to 13 settle detailed guidance but we might at least say a few words 14 about the policy in this area and where the Commission thinks 15 we ought to head.
16 CHAIRMAN PALLADINO:
It we are through on PPG at 17 least for the time being, let me suggest that we get all of 18 the comments in that we have by December 5th and,then you try 19 to give us a document by at least a week-later, 20 1ine-int 1ine-out showing the changes that you made i ne l u rli ng 21 a general statement of the broad changes over prior years and 22 then identification in the margin for Commission use, changes 23-that apply to specific areas or topics of discussion.
24 Unless there are others, I am going to adjourn this 25
-meeting, I was going to suggest that we delay affirmation for.
i
e 76 1
15 minutes.
I have been alerted to the need to discuss a 2
question with OGC.that might affect our affirmation.
So 3
unless there are other. comments at this time, we will stand 4
a d j ourr, e d.
5 Thank you.
6
[Whereupon, the Commission meeting was adjourned at
?
3:45 o' clock p.m.,
to reconvene at the Call o the Chair.]
8 9
10 11 12 13 14 13 16 17 18 19 20 21 22 23 24 25
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19 Date:
Tuesday, November 26, 1985 14 15 were held as herein appears and that this is the original 16 transcript thereof for the file of the United States Nuclear 17 Regulatory Cemmission.
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