ML20138B281
| ML20138B281 | |
| Person / Time | |
|---|---|
| Issue date: | 10/08/1985 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1454, NUDOCS 8510150309 | |
| Download: ML20138B281 (142) | |
Text
-
6 9
OR GWAL UN11ED STATES O-NUCLEAR REGULATORY COMMISSION IN THE MATTER OF:
DOCKET NO:
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS SUBCOMMITTEE ON REGULATORY ACTIVITIES OO LOCATION:
WASHINGTON, D.
C.
PAGES:
1-139 DATE:
TUESDAY, OCTOBER 8, 1985 Agi!80FF?!sECBFf hice f[
Jo No:Removefrom ACRS0 ACE-FEDERAL REPORTERS, LNC.
(03 OfficialRtporters 444 North Capitol Street Washington, D.C. 20001
( 02 W -3 M 8510150309 851000
$D-45 PDR NATIONWIDE COVERAGE
1 SuxW 1
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
-~ )
2 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 3
4 5
6 Subcommittee on The Regulatory Activities 7
8 9
Room 1046 1717 H Street, N.W.
10 Washington, D.C.
11 Tuesday, October 8, 1985 12 13 The meeting of the Subcommittee on the Regulatory 14 Activities convened at 9:00 a.m.,
Chester P. Siess, Chairman 15 of the Subcommittee, presiding.
16 17 PRESENT FOR THE ACRS SUBCOMMITTEE:
18 Chester P. Siess, Chairman Charles J. Wylie 19 Dade W. Moeller Max W. Carbon 20 ACRS STAFF MEMBER:
21 Sam Duraiswamy 22 CONSULTANT TO THE ACRS SUBCOMMITTEE:
23 R. Abbey
'~'
24 25
.._ __ _:. 2 _ _
- ._ _ _ _c_
. _ __ n _ _a _..
.. c,. -
._.___.a._.__.
O PUBLIC NOTICE BY THE UNITED STATES NUCLEAR REGULATORY COMMISSIONERS' ADVISORY COMMITTEE ON REACTOR SAFEGUARDS t
TUESDAY, OCTOBER 8, 1985 The contents of this stenographic transcript of the proceedings of.the United States Nuclear Regulatory Commission's Advisory Committee on Reactor Safeguards (ACRS), as reported herein, is an uncorrected record of the discussions recorded at the meeting held on the above date.
No member of the ACRS Staff and no participant at this meeting accepts any re.sponsibility for errors or inaccuracies of statement or data contained in this transcript.
1 i
i s
O f
._ ~-
m.
2-
- 1-1-SueW I
_P _R O _C _E E _D _I N _G _S
'u 2
(9:00 a.m.)
3 MR. SIESS:
The meeting will come to order.
4 This is a meeting of -the Advisory Committee on Reactor 5'
Safeguards Subcommittee on Regulatory Activities.
6 My name is Chester Siess, Chairman of the 7
Subcommittee.
8 We have several other members of the ACRS 9
present today, Mr. Wylie, Moeller, Carbon.
Mr. Kerr will 10 be in this af ternoon.
11 And we have a' consultant with us, Mr. Robert 12 Abbey, who is the - Director of Meteorological Research,
h.
-13 the U.
S.' Department of the Navy.
L-14 Did you used to work for NRC?
15 MR. ABBEY:
.Yes.
16 MR. SIESS:.Well, we won' t hold that against 17 you.
18 (Laugh te r. )
19 MR. SIESS:
Mr. Abbey is particularly interest-20 ed in one of the Reg Guides that has to do with meteorology.
21 The purposq of _ the meeting is to discuss three 22 items.
We have proposed Regulatory Guide' 1.23, Revision 1, 23 Meteorological Measurement Program for Nuclear Power Plants.
24 And this is one that has not gone out for comment.
t' 25 We have proposed Regulatory Guide 1.105,
.... _. a. r
_. n __ ;. _
n.'
1_
3
- 1-2-SueW I
Revision 2, Instrument Setpoints for Safety-Related Systems.
( 'T 2
This has 'been out for comments, for public comment.
3 And then we have proposed Regulatory Guide with 4
no number, designated Task Number IC 609-5, which is 5
Criteria for Power, Instrumentation and Control Portions 6
of Safety Systems.
And that also has been out for comment.
7 The cognizant ACRS Staff member for the meeting 8
is Sam Duraiswamy, sitting on my right.
9 And the rules for participation in the meeting 10 by ' members of the public has been announced as part of the 11 notice in the Federal Register published Tuesday, September 12 24th.
13 As you will note, a transcript is being kept and 14 will be made available as stated in the Federal Register 15 Notice.
And because there is a transcript, each speaker will 16 please identify himself or herself when they first speak and 17 then use the microphones.
18 We have received no written comments from 19 members of the public and no requests for time to make oral 20 statements from members of the public.
Are there any members 21 of the public here that would like to make an oral statement 22 at some time?
23 (No response.)
.O 24 If so, they can notify me or Mr. Duraiswamy at y
25 an appropriate time.
4
- 1-3-1':eW 1
We have an agenda, taking up the three items
[ ~b N~4#
2 in the order I've indicated.
The one on Instrumentation and 3
Control Portions of Safety Systems, we intend to take up 4
af ter -lunch even if we finish up the others early simply 5
because. Dr. Kerr who is daairman of our Electrical Systems 6
Subcommittee will not be here until then.
7 You have received a large stack from Sam on this.
8 It has been two handouts just prior to the meeting.
One 9
is from Dave Moeller on 1.23.
And the other is a side by 10 side -- well, it's side by side by side, three versions of 11 1.23, without dates on them.
Okay, the original Safety Guide, 12 23, was back in '72.
Then, in ' 81 when we first started 13 looking at this, that's the one in the middle.
And then we 14 have the current one over here.
15 And this is extremely. interesting.
It's going 16 to be a little difficult to go through it in the time we 17 have available, but I suspect there will be references to 18 it.
19 Of some interest might be the white space which 20 tells you what is now in there that wasn't, or what was then 21 in there that isn't.
I find this fascinating, because I've 22' spent the last six months taking the American Institute 23 Building Code and commentary and arranging it side by side,
());
24 jus t. like this.
The white space is the interesting part.
25 Okay.
Are there any comments from members of
m
.,~o.
. m 5
- 1-4-SueW-
-1 the' Subcommittee about the Agenda?
s./
2 (No response.)
s Then, we will start 'of f with 1.23.
.The history 4
of this is almost too long to relate.
i 6
(Laughter. )
6 Sam has summarized it in his September 16, '85 7
Status Report.
And we have been involved; CRGR has been 8
involved.
And this is one I think that after one look at 9
it, we said:
We don't want to see it again until CRGR has l
-10 looked at it, because we thought they were doing some of 11 our dirty work, cleaning up things.
12 And as I recall, on - the original Guide it was 13 considerable objection from Mr. Bender, who is no longer on 14 the. Committee, but he served as a Consultant to us.
And 16 he has been asked to-look at it.
And I think his objections 16 have gone away.
17 The Guide now endorses the. Standard'which, of 4
18 course, is becoming more and more the purpose of a Guide.
19 An.d it endorses a Standard with relatively few exceptions, so as I recall.
21 So, I think wida that. vert inadequate history 22 as a slight introduction, I will ask the Staff to tell us 4
23 what they think we need to know and summarize where we are
((])
24 and what they expect of us.
l 26 Mr. Beratan.
6
- 1-5-SueW 1
MR. BERATAN :
Mr. Chairman, I'm Leon Beratan, Od 2
the Earth Sciences Branch, Office of Research.
3 I think you probably capsulated the -- what we 4
have been trying to do over the last number of years to 5
bring : this Guide to fruition.
I would like to turn the 6
meeting. to Leta Brown who really has been the key person 7
responsible for getting this -- doing the drafting and put-8 ting this Guide in its present format.
~
9 MR. SIESS:
Let me say one more thing.
I'm trying 10 to recall, one of the hang-ups we had on this thing was 11 that the Guide was addressing the meteorology from two point 9 12 of view.
One was the routine police case which has been
()
13 the previous emphasis in the Guide, as I recall, back in 14 the Safety Guide 23.
15' And the other was the emergency case.
16 MR. BERATAN:
Yes.
17 MR. SIESS:
Which came out of TMI and 0727.
And i
18 I think that that's one thing that we got hung-up on.
Our 19 perspective at - that time might have been -- 0737, excuse me.
30 And I just want to mention that to the Committee 21 for those of you who were still around then.
I know Dave 22 was and Max.
I don' t think Charlie was around.
23 okay.
Le ta.
24 MRS. BROWN My name is Leta Brown.
We are pre-s-
25 paring proposed Revision i of Regulatory Guide 1.23, m...
. l.
7
- 1-6-SueW
~1 Meteorological Measurement Program for Nuclear Power Plants, I'\\
~ ' '
2 for public conment.
3 This draft essentially endorses an industry standard, 4
ANSI, ANS-2.5-1984, Standard for Determining Meteorological 5
Information at Nuclear Power Sites, issued in August of 6
1984 with the following exception related to quality as-7 surance.
Although ANSI /ASME ' nd QA-1-19 83, Quality Assurance a
8 Program Requirements for Nuclear Facilities, is referenced 9
in ANS-2.5 it is not endorsed in the Regulatory Guide for 10 use with quality assurance programs related to meteorological 11 measurement programs for operating nuclear power plants.
12 Further, quality assurance records need not be 13 retained for the lifetime of the facility.
Guidance concern-14 ing quality -- the quality assurance program recommendations 15 and record retention related to n.eteorological measurement 16 programs for operating nuclear power plants may be found in 17 Regulatory Guide 1.33 entitled " Quality Assurance Program 18 Requirements Operation."
19 As such, the current draf t of the proposed Revision 3 20 is intended to replace ' rather than modify the former draf ts.
21 As with the original version of this Guide, by endorsing 22 ANS 2.5, this Guide is. intended to provide guidance acceptable 23 to the NRC Staff regarding the meteorological parameters
')
24 that should be measured, the siting of meteorological instru-26 ments, system accuracies, instrument maintenance and servicing
8
- 1-7-SueW 1
schedules and the recovery reduction compilation data.
2 It is intended to provide detailed information on 3
an acceptable meteorological measurement program which could 4
be used by applicants and licensees as a basis for preparing 5
emergency plan as well as continuing to be used as a basis 6
for obtaining meteorological information needed for other 7
licensing actions.
8 It is anticipated that with the publication of 9
proposed Revision 1, inquiries related to current NRC 10 practice would be minimized.
11 The purpose of this draf t Regulatory Guide, there-12 fore, is to consolidate and clarify existing regulatory 13 guidance and Staf f practice regarding implementation of 14 existing Staf f position without imposing new requirements.
15 Although we've already had a brief chronology, I 16 would like to go ahead and reiterate some of the points of 17 the chronology and provide a little update.
Excuse me.
Could I interrupt just a 19 moment?
20 MRS. BROWN :
Yes.
21 MR. CARBON:
If I understand and caught what you 22 just said, you are endorsing the ANSI ANS Standard with the 23 one single exception calling for longer retention of QA?
24 MRS. BROWN:
No, it's not longer retention.
There 25 are two parts to it.
One is for the operating reactors,
9
- 1-8-SueW 1 rather nuclear power plant, we recommend using Regulatory
/
x >
2 Guide 1.33 guidance in general.
3 And then the second sort of subpart to that is, as 4
far as record retention rather than recommending permanent 5
retention of records for the lifetime of the facility, we 6
recommend using Regulatory Guide 1.23 again.
Certainly --
7 MR. SIESS:
Less than permanent.
8 MRS. BROWN:
I'm sorry?
9 MR. SIESS:
Which is something sort of being 10 pe rmanent?
11 MRS. B ROWN :
Right.
12 MR. SIESS:
Vis-a-vis the QA on the design and
)
13 installation or would it be QA on operation?
14 MRS. BROWN :
This is QA on operation.
15 MR. SIESS:
On operation.
16 MRS. BROWN:
On design for any part that may 17 apply.
As I understand it at this point, Regulatory Guide 18 1.28 was recently updated and endorsed the comparable 19 standard to what is cited in ANS 2.5, so there is no conflict 20 there.
21 MR. SPICKLER:
I think that's NT 58.2.
22 MR. SIESS:
I just tried to visualize what the 23 QA paper looks like for the operation of the met system.
(
24 MR. SPICKLER:
Do you want me to answer that?
I'm 25 Irwin Spickler with the Staff.
The QA records for the a-
c-10 9
- 1-9-SueW 1 operation --
74
(_)
2 MR. SIESS:
Use your mike.
3 MR. SPICKLER:
-- for the operational system 4
would include the routine inspection records, any maintenance 5
that had been performed.
6 It would also include the calibration records,
7 the records of the calibrations that were done.
It would 8
also include the records of inoperative measurements and 9
what was done to -- it's essentially the continuous record 10 that is normally kept in the shed alongside the tower of 11 any logs of maintenance or calibration checks or whatever 02 is done.
()
13 MR. SIESS:
What about the meteorological records 14 themselves ?
Are they retained?
15 MR. SPICKLER:
This requires five year retention 16 of the records themselves, the meteorological data itself.
17 MR. SIESS:
Wouldn' t those data be useful in is some scientific aspect of meteorology to somebody that 19 wanted to look at them twenty-three years from now?
20 MR. SPICKLER:
They would be extremely helpful.
21 We tried, as a matter of f act, some years ago to get NOAH to 22 work -- work out an arrangement with NOAH to send them the 28 data that -- very valuable data -- isn't available frankly rg 24 from anywhere else, to Ashville, North Carolina.
And their O
26 feeling was unless it's exactly in their format they don't
11
- 1-10-SueW 1 want it.
/^A:s c
(,/
2 And our format was different from theirs, so they 3
said:
Forget it.
We won't even bother with it.
4 I won't comment on the wisdom of that decision.
6 MR. SIESS:
If their computer can' t digest it, e
it's not worth having I guess.
7 MR. SPICKLER:
Yes.
Or, if it requires. any 8
manipulation on their part so that their computer can digest 8
it.
10 MR. SIESS:
That's interesting.
11 MR. SPICKLER:
In all fairness, their Staff is 12 pretty minimal at this point.
They have been cut back (v~3 13 pretty drastically.
14 MR. SIESS:
What does NOAH have as a source?
16 Is the airport information something NOAH has in their i
16 format?
17 MR. SPICKLER:
Yeah.
18 MR. SIESS:
That covers a lot of territory.
19 MR. SPICKLER:
Yeah.
30 MR. SIESS:
Abbey, do you have any comment on 21 that particular item?
22 MR. ABBEY:
No.
I remember the history of it.
23 And what's good for research is not necessarily good for 34 operation or.unless it was not considered to be cost bene--
36
.ficial for research to, you know, archive the operating record sc
%.. m
12
- 1-ll-SueW 1
MR. SPICKLER:
We, however, have the records.
We 2
do have tapes.
3 We, for example, do have data tapes from all of 4
the sites from some period of time on.
We do have joint 5
frequency distribution data that we collect each year as e
part of the Regulatory Guide 1.21 requirements, you know, 7
where they have to report how they are doing relative to a
their routine releases.
9 So, every six months we get six months' worth j
10 of meteorological data.
At the end of the year, we get 11 a years' worth of meteorological data.
3 MR. SIESS:
What do you do with it?
f 13 MR. SPICKLER:
We file it, archive it.
We use 14 it for -- we've used it many times in going back and looking i
is at the plants.
16 MR. SIESS :
Is this on tape?
17 MR. SPICKLER:
No, it's hard copy.
18 MR. SIESS:
Hard copy?
19 MR. SPICKLER:
Ye ah.
It's not too rough -- it's 30 not the raw datar it's the joint frequency data, so it's 21 relatively simple to put on tape if we need it.
1 22 MRS. BROWN :
I would like now to present a 23 brief chronology of the development of the guide to this 34 point.
36 In 1972, the original Safety Guide'23, Onsite
13
- 1-12-SueW 1
Meteorological Program, was issued.
And in late 1970s, j
2 particularly in light of the Three Mile Island accident, 3
a need for a revision was perceived and initiated.
4 As a result, proposed Revision 1 was issued for 5
public comment in September 1980.
In the Fall of 1981, a 6
modified draft which reflected public comment was presented 7
for ACRS review.
At the November 1981 meeting, the ACRS 8
Full Committee suggested that the guide be submitted to the 9
then newly formed Committee to review generic requirements,
10 CRGR.
11 In the Winter of 1981 and Spring of 1982, the 12 guide was reviewed by the CRGR, both as a stand-alone guide
)
13 and also with respect to other emergency preparedness guidanco 14 and policies which were then being developed at the time.
15 CRGR requested that we determine if the guide was still 16 needed in light of the then recently developed quantity of 17 other emergency preparedness guidance.
18 Inspection and Enforcement responded in the 19 affirmative.
Subsequently, NRR responded that the revision 20 of the guide was a lesser priority than,some of the other 21 licensing priorities they had at the time, and recommended 22 that the guide be revised after issuance of ANS 2.5, which 23 was anticipated.
24 g
In August 1984, ANS 2.5 was issued.
And a draft 25 of a new proposed revision of Regulatory Guide 1.23, based
14
- 1-13-SueW 1
on the endorsement of ANS 2.5, was begun.
Earlier this 2
year, the proposed revision was submitted to CRGR, and a 3
determination was made that their formal review was not 4
required.
5 Now with that the guide has been submitted for 6
ACRS review.
7 MR. SIESS:
There were a number of positiens in 8
the original guide.
How many of those got incorporated into 9
the Standard?
10 MRS. B ROWN :
All should be in there.
11 MR. CIESS:
All of them?
So, by delaying it we 12 ended up with a standard that is acceptable.
I 13 You were on the Standards Committee?
14 MR. SPICKLER:
I was Chairman of the Standards 15 Committee.
16 MR. SIESS:
Any questions so far?
17 MR. MOELLER:
I had just two on the Standard.
I 18 would --
19 MR. SIESS:
Ye ah.
20 MR. MOELLER:
At what point would it be appropriato 21 to ask those?
22 MR. SIESS:
I think this is an appropriate time.
23 MR. MOELLER:
Okay.
I didn't understand on 24 Page 7 of the ANSI Standard, there is a footnote and the 25 footnote baf fles me.
15
- 1-14-SueW1 MR. SIESS':
Page 7 of the Standard?
O,
\\
c A'
2 MR. MOELLER:
Yes, the Page 7 isn' t numbered.
3 Page 6 is Table 2.
4 And the footnote says --
5 MR. SIESS :
I don't have a footnote on Page 7.
6 MR. MOELLER:
We ll, excus e me, then.
It's the 7
last three lines on the right hand column.
8 MR. SIESS:
Oh, okay.
9 MR. MOELLER:
At the end of the references it to says:
Only the Standard explicitly referred to in this 11 document qualifies as a reference.
Subsequent revisions of u
this Standard shall not be substituted.
f 13 Now, the first thing is, I don't know whether 14 that refers.to the Standard quoted in Reference 5 or refers i
15 to this whole Standard.
And if it refers to this whole 16 Standard, why wouldn't you accept an updated revision of 17 it?
18 MR. SIESS:
Oh, it's a good reason.
You never 19 do that, because then you are passing the authority along 30 to somebody else.
21 You are endorsing something that somebody has --
22 MR. MOELLER:
That you haven' t yet seen?
23 MR. SIESS:
Yeah.
Q('T 34 MR. MOELLER:
Okay.
36 MR. SPICKLER:
This has been the verbage.
This
.....,c..
16
- 1-15-SueW 1
verbage was put in by ANSI.
This wasn' t -- as a matter of f
1
~ ' ~
2 fact, I didn't even remember this verbage.
It was put in 3
after the final draft.
4 MR. SIESS:
We -- we do this all the time.
5 MR. MOELLER:
So, ANSI -- this isn ' t an NRC 6
statement.
This is an ANSI statement?
7 MR. SPICKLER:
This is an ANSI statement.
8 MR. MOELLER:
And they won't accept a revision 9
of their own Standard?
10 MR. SIESS:
This Committee won't.
11 MR. SPICKLER:
This Committee won't.
12 MR. MOELLER:
Which Committee?
13 MR. SPICKLER:
The ANSI --
14 MR. SIESS:
The Committee that wrote this 15 Standard --
16 MR. SPICKLER:
The ANS 2.5 Committee.
17 MR. SIESS:
For example, in our Building Code 18 Committee, we list a whole bunch of ASTM Standards on 19 mate rials.
And by year, and if they change it we review 30 that change to see if it has any effect on what we've done 21 based on that Standard.
22 And if we don't like it, we don't endorse it.
23 MR. MOELLER: Okay.
So this -- what I was
( };
N' calling a footnote, these last three lines apply to these 26 Standards -- well, Reference 5 is a Standard but Reference 3
17
- 1-16-SueW 1
and 4 --
I/
2 MR. SIESS:
It really only applys to Reference 3-
- 5, doesn' t it, Spickler?
-4 MR. SPICKLER:
Yes.
5 MR. MOELLER:
Okay.
So it says:
If Reference 5 6
is revised we want to review the revision before we state --
7 MR. SPICKLER:
Correct.
8 MR. MOELLER:
-- that we endorse it.
8 MR. SPICKLER:
Right.
10 MR. MOELLER:
Well, I wish they had said that 11 instead~ of what they did say.
M MR. SIESS: - Actually it becomes redundant, because
(};
13 the Reg Guide doesn't endorse it.
14 MR. SPICKLER:
It doesn' t endorse that Standard 15 anyway.
16 (Laughter.)
17 MR. SIESS:
Ye ah.
18 MR. MOELLER:
Well, you can see that I was 19 confused.
20 The other one -- and these are nits.
On Page 3 --
21 MR. SIESS: - Again, of the Standard?
M MR. MOELLER:
In.the Standard, Page 3 of the 23 ANSI Standards, on the left hand column at the bottom, 24 Section 5.2 talks about data monitoring.
25' I would have said " data review and evaluation" or-
L18 1
41-17-SueW.
1 something.. It's monitoring data and you are talking about g};
data monitoring.
And.I'found the use of that particular
- ]
2
'3 word'quite confusing.
4
~
But we are not writing the Standard, and I I6
. realize that.
6 MR. SPICKLER:
I think the verbage tracks the 7
verbage in supplement 1 for 737.
And I think that's specifically why that' verbage was used.
f a
81 I think if'you look at Supplement 1 to 737, 10 that's - precisely how it's termed in - that Supplement.
11 MR. MOELLER:
Okay.
Thank you.
12 MR. SIESS:
Now, Dade, you had some comments 13 on the --
14 MR. MOELLER:
On the Guide itself.
15 MR. ' SIESS :
-- Reg Guide itself.
I think those is were provided to you.
17 MRS. BROWN:
Yes.
18 MR. MOELLER:
They are primarily editorial.
19 MR. SIESS:
They are primarily editorial.
30
- Have.you had a chance - to look at them?
21 MRS. D RONN - Yes, we have.
Are there any you 22 would like for.us.to address at.this point?
28 MR. SIESS:- Well, the thing is, can you take 24 care of them?
Do you want to. defend them, or do you want i
25
'to say you will change them?
o 19
- 1-18-SueW 1
MRS. BROWN :
Well, there are several that I 2
would like to --
3 MR. SIESS:
CPay.
4 MRS. BROWN:
-- make a comment on at this time 5
if I could.
6 MR. SIESS:
Just go down the list.
Has every-7 body got the letter addressed to Sam?
8 Okay.
9 MRS. BROWN :
The first comment concerns Pages 2 10 and 3 in the discussion section.
And it notes that Items 11 1, 2, 4 and 5 refer to the applicant or licensee and the 12 NRC Staff, where Item 3 refers to the applicant or licensee r~w (l
13 and other appropriate persons.
14 It's asked if there is a reason for the dif-15 forence.
And the reason for the difference here is because 16 Item 3 involves emergency preparedness and responso and, 17 therefore, it may involve local officials, state officials, 18 other individuals.
19 Whereas, Items 2, 4 and 5 normally would just h
be the licensee and the applicant and NRC Staff.
21 The second comment --
22 MR. SIESS:
Does that satisfy you, Dade?
Mk. MOELLER:
I think so.
23
[^^
24 MR. SIESS:
You asked if there was a reason.
25 The answer was yes.
20 1
- 1s-19-SueW MR. MOELLER:
I think that is adequate.
The next 2
one,. Page 3, actually even I withdrew it I think with my 3
footnote.
4 So, you can skip that.
5 MR. SIESS:
Okay.
6 MRS. BROWN:
The comments, let's see, 3 and 4 7
recommends some wording to clarify or otherwise --
i 8
MR. SIESS:
He said 3 he has withdrawn.
So --
9 MRS. BROWN :
Oh, I believe that was Page 3.
4 10 MR. SIESS:
That was Section C.
11 MR. MOELLER:
Page 4 is next.
12 MRS. BROWN:
Righ t.
Page 4, the first two t0 18
(;'
comments related to Page 4 we' agree with.
The third com-14 ment concerning Page 4 and Line 2, it says:
What is the 15 meaning and need for the phrase "and nothing more" which is is the end of a sentence?
17 And it asks what the results would be if this 18 phrase were deleted.
19 During our interf ace with CRGR Staf f -- there 30 was no formal review, but we still talked with the Staff, 21 this was something that they suggested be inserted in there 88 to make it clear that the purpose of the Guide was to 23 clarify and consolidate information.
(]
S4 And it was just words that they felt as though y
36 it stressed that much more that that was the purpose.
So
21 f,1-20-SueW 1
that they were interested in having those words in there.
(
Y k/
2 MR. MOELLER:
Fine.
If they are important to 3
them --
4 MRS. BROWN :
I think it's important to them --
5 MR. MOELLER:
Fine.
6 MRS. BRO!iN :
-- that they be in there.
7 MR. SIESS:
They could have said "only."
8 MRS. BROWN:
The first comment on Page 5 --
9 MR. SIESS:
Now, just a minute.
Did you get the 10 one, Page 4, Section C, first paragraph?
11 MRS. BROWN :
We agree with --
12 MR. SIESS:
Okay.
13 MRS. BROWN:
-- making the change there, the 14 editorial change could be beneficial.
15 MR. SIESS:
Okay.
16 MRS. BROWN :
The first comment concerning Page 5 17 and also the similar comment related to Page 12 has to do 18 with regulatory guide titles that are referenced by this 19 Guide.
30 As is pointed out in the comment, really at this 21 point with this Guide we are not in a position to change 22 the title.
However, I did get a little history of just why 23 the titles are as they are.
()
34 Evidently these are older guides, and at that as particular time the titles were chosen in an order not to l
22
- 1-21-SueW 1
cause confusion.
When the guides are revised, they are 2
hesitant to change titles unless there is some technical 3
reason or some other reason.
But as far as just changing 4
the titles because there are certain things that they would 5
do differently than what they've done previously, that is --
6 MP. SIESS:
Now you would say, how to comply 7
with the quality assurance program requirements or something 8
of that sort?
9 MRS. BROWN: That's right, perhaps.
10 MR. SIESS:
But the Guide didn' t include the 11 requirements --
12 MR.,MOELLE R:
Right.
13 MR. SIESS:
Okay.
14 MRS. B ROWN :
The second comment on Page 5 that 15 has to.do with Section B is similar in nature to the 16 comment on Page 4 in that this resulted from discussions 17 with the CRGR Staff in a selection of words.
18 However, this is one that I'really don't think 19 there will be any objection to changing the words, because 20 as you point out operating nuclear power plants really is 21 what the Guide is about, not operating reactors.
It's not 22 research reactors per se.
23 So, I think that certainly will be a comment we
[
24 will use in order to change the --
25 MR. SIESS:
And this applies to only power plants;
23
- 1-22-SueW 1
it doesn't apply to research reactors or --
7 2
MRS. BROWN:
Well, it potentially could be but 3
it is -- it was written for nuclear power plants.
That was 4
the intent.
5 MR. SIESS:
Okay.
6 MR. BERATAN:
Well, would it be wrong to leave 7
it generic rather than identify just for nuclear power 8
plants if it could conceivably be used for test reactors-9 or experimental --
10 MR. SIESS:
I've got a feeling that if you were 11 thinkin'g about power plants when you wrote it, and you 3
really wanted it to apply to research reactors it probably
)
13 ~
would be different than --
14 -
MR. SPICKLER:
As the Chairman of the Committee, 15 I can say undoubtedly that would have been the case.
16 MR. SIESS:
Ye ah.
I mean, some of these require-17 ments would be a burden you wouldn' t impose on a small M<
18 research reactor.
19 MR. SPICKLER:
No.
20 MR. SIESS:
Okay.
21 MRS. B ROWN:
The remainder ol the comments all 22 have to do again with wording to clarify the Guide and we 23 '
agree with the other recommended changes or the comment as p
24 suggested.
. cuJ 25 MR. MOELLER. Thank you.
That is_ appreciated.
b
24
- 1-23-SueW 1
MR. SIESS:
I would like to call attention to a
2 the wording and the implementation.
I think this is 3
probably the first guide we've looked at since the actions 4
on backfitting and so much on people's minds.
5 And there is a phrase at the last three lines 6
of 3 of the implementation, and then there is a whole para-7 graph at the end.
Is this now going to be pretty standard 8
language in non-backfitted regulatory guides?
9 The last paragraph of the implementation is very 10 strong, a very strong admonition to the regulatory staff 11 as to how this has got to be applied.
U2 MRS. BROWN:
Well, I will say that in developing 13 the implementation section that the CRGR did have input 14 into this, and this was at that time what they recommended.
15 I think they are attempting to develop some 16 standard wording to cover cases such as this.
I can ' t s ay 17 that this is what ultimately they will agree would be the 18 appropriate wording.
But I think this is a step in that-19 direction, what they are trying to achieve and what we are 20 trying to achieve by using what's here.
21 MR. SIESS:
Usually when I read the implementation 22 I look at it as an explanation to a licensee of the appli-23 cability of this.
And the words I see here are directed to 24 the reviewer.
It says -- in one place it says "The reviewer
~
m shall not."
l-
25
- 1-24-SueW 1
MR. MOELLER:
Yes.
I) 2 MR. SIESS:
You know, it's a change but it's a m
3 logical consequence I think of the new procedure section or 4
whatever it is.
5 Now, this has not been out for public comment?
4 6'
MRS. BROWN:
No, it has not.
7 MR. SIESS:
Did anybody have any comments on the 8
value, impact statement?
9 MR. ABBEY:
I did. I had just a couple of ques-10 tions.
11 MR. SIESS:
Sure, or anything else that you want 12 to-comment,on.
)
13 MR. ABBEY:
Looking at Page 7, Section 1.3.3, 14 under " Industry," the --
15 MR. SIESS:
This is of the Value Impact Statement?
16 MR. ABBEY :
Yes.
17' MR. SIESS:
Okay.
18 MR. ABBEY:
Coming down about the third line, 19 I recall Dr. Bender's comments.with regard to some of the 20 related discussion on costs, some of the comments by. consumer 21 Power and Stone and Webster with regard to how expensive Et.
it 'was going to be. to implement these contrasted with, at 23 that time, the Staff's position that:
Gee, it wasn' t so bad -
("]
24 after all.
b'
's 1md I suggest perhaps that the second full y
1
<a 26 fl-25-SueW 1
sentence should reflect that, namely by saying the follow-(3 5-2 ing:
Since the product document endorses an ANS Standard 3
in part -- after all, there is an exclusion there -- the 4
. nuclear industry has considered the recommendations and 5
any related costs to be acceptable -- not necessarily to be 6
reasonable.
7 I think the connotation there is that it implies 8-something on behalf of industry which I'm not necessarily 9
sure that we have the documentation, Lae Staff has the 10 documentation, to back up.
Maybe that's a nit.
11 on the other hand, you are not implying that u
industry has found the cost. to be reasonable, only that you 13 have found it to be acceptable.
I think there is a big 14 difference there.
15 '
fir. SIE'SS :
Yeah.
Actually,-the thing --
16 MR. SPICKLER:
That's a good change.
17 MR. SIESS:
-- that isn' t endorsed to some 18 extent is the relaxation.
That's really not too bad I 19 don't guess.
20 But you are right.
I don' t know whether the i
21 industry has commented on the Standard except industry 22 ~
helped write it..
s 23 MR. SPICKLER:
This'went through the full ANS and i
24 ANSI review, so'we've.got a stack of comments -- anybody
)
(-
25 that' has ever been ' on an ANS Committee, we 've got comments
- x -.
- ~ ~ _
I J
~27
, 41-26-SueW' 1-from everybody. and his brother.
And I would hate to tell
%]):
(
- 2
.you how many times this document has been written'and re-3 written to satisfy or to at least address comments from one
~
4' or the.other.
It has gotten pretty wide'--
'5
. MR. SIESS:
Would you'say that the --
}
6 MR. SPICKLER:
---review.
7.
MR. ' SIESS :
Would you say that the comments-t -
8 from the industry' did find it acceptable in terms of' costs?
8 BUR. SPICKLER:
Yeah.
To be perfectly honest 10-
- with you, there is only one operating plant that I. know of
~
11-
~ that hasn't already done Ithis.
4 H
MR. SIESS:
Which one is that?
)
v 13.
MR.. SPICKLER:- Big Rock, and it's.because they
'14 have _ an itty-bitty site and no place to-putf a tower.
15 MR. SIESS: -And-an'itty-bitty ~ plant.
16 hlR. ' SPICKLER:'
And'an itty-bitty plant.
17 -
MR. SIESS:
And.not anybody,around.
18
'MR. SPICKLER: LI won 't commenti on -that.
There may 19-be two.
Lacrosse may. be - the :other one ~, and the s ame' problem.
30 It's an itty-bitty site and with terrible topo.,
21' graphy.- so, I don' t _even knowt if they could find a_ good 22 place.to'put a tower at'that: site.
3 MR. '.SIESS :
Both'of.those-were-SEP plants?
^
~
f34 _-
MR. ; SPICKLER:
Yes.-
3
' 26 EMR.-SIESS:
Was imeteorology 'an' item 'in SEP review :
_1
,..~
d l
- 28
- 1-27-SueWL
~1 MR. SPICKLER:
Other than-extreme event.
Other 4 LL 2
- than extreme event, no.
3 MR. SIESS:
I didn' t remember --
. 4-
-MR.
SPICKLER:- But it was part of the emergency --
5 if you recall, in April of 1983 we completed what we call 1
s-the EPIA' program' which was the. preliminary appraisal of the j
i 7
emergency preparedness programs at all.of the operating 8
nuclear power plan.ts that were operating to that. point.
- 9 And part of that appraisal was' the operability 10 and~ the representativeness.of the meteorological data at i.
11 all of the operating plants.
1 12 -
So, all-of them were reviewed..
13 MR..SIESS:
You have no objection-to accepting 2
v J
14.
'Mr. Abbey's recommendation?
+
15 MR. SPICKLER:- No.
}
- 16 MR.- SIESS:
After this'goes out for public.com-F 17 ment, L you do prepare a note about th'e ' impact statements,
18 i:
. don' t you?
4 W
~ 19 -
MR. SPICKLER:. If one needs to be done, yes.
d 20J MR. SIESS:
Yes.
S 21:
MR.-CARBON:
I have ' another question onIthat-t
- 22 :
- same point, :that-the industry has cons'idered.the recommenda-3 4
23
. tions and accepts the cost.
= i 24 Sometimes'1the reviews'arelmadeLprimarily, for l
- 25'
- example, by'an-instrument company-rather-than -- let me I:
~
t i
m y
9 9 -- -
m g
a
- en s u( q W i-n--
eW--g y g m a-se eg g-g
+4-g-wg g wyg -pyg g g, qer w e gg w,99-p u, Wh M NT M 9 f e -w-y e w WM y)- m?W -ap'p*-D--*fT
(-'
ptWg^*g
- h W
i'
. 29
- 1-28L ueW'L1-take a gross : exageration here -- an industry part that has S
d 2-
- to-use', that.has to' comply.
Have both the utilities them-t 3
selves :as well as the sellers 'of -instruments -.
4
= MR. SPICKLER:
Oh, yeah.
ANSI doesn' t have any
'5-instrument vendors on:their.ANS -- their nuclear -- I 6
feel that -
there-is a Nuclear'Standaids Committee'on ANSI i.
d 7
that. reviews all of the. nuclear standards.
And they have 4
8 representat'ives from manuf acturers.
By manuf acturers, I 4
-9 mean General Electric, Westinghouse, et cetera from the ANE
^
4
' 10 area and from the utility -area.1
~
t-1 11 There are no meteorological vendors on the ANSI f
12 Committee'that reviewed this. ' And it also goes through ANS 2.
4 l
R
^
13 j g And ANS.2' has representatives across' the board.
14 The only place where there were meteorological
~
4' 15 -
vendors involved,'we.had two vendors I believe involved in 16 the writing'of the Guide..
'I believe MRI was one of the i --
-17 vendors. ' It's - -let' me see, ;it's listed ---
18 MR. SIESS: ' Yeah ~,'MRI'is on there.- Did you 4
19
- consider Dames-and' Moore-a vendor?.
- i i
' 80 ' ~
MR. SPICKLER:. Since.I was:at;-Dames and: Moore.at
~
["
- 21L the time I'wouldTsay'no.
We.were a consultant;to. essentially -- -
l=
22 -
putlin. equipment'that-we felt met!the' standards.
3:
- 23 -
~ So, we. didn' tireally -- y' u know, - Dames and ' Moore o
24 didn't manufacture equipment.
( 25 ;
'MR. SIESS:.. The more. complicated it'.was, the more -
L L
i " ten T t' W
-t*-
d'd ** f+ 9 Ft WhWe tr
- -c'irr
=
't-*'c9'9 W ar$r 1-
?
'd-te**
Y w
"*y
- 4T-
- M-t
-9 m--6p e
yr
- Th e e W-*wwe- * * - -
-'S*b4re M' Y" d
T' - "9 N1 m1tt
- = - ' * -
30
' il-2h-SueW 1
Dames and Moore had to do.
.,,- \\
U
'2 MR. SPICKLER:
That's true.
3 MR. SIESS:
And were in the business of selling 4
p rograms.
But, cgain there was Florida Power and Light and 6
Commonwealth Consolidat6d Edison --
4 MR. SPICKLER:
And Carolina Power and Light.
7 MR. CARBON:
Which page are you looking on?
8 MR. SIESS:
It's the second page of the Standards.
8 MR. SPICKLER:
It. lists all of the members of --
10 MR. SIESS:
It lists the Subcommittee that
- 11
- developed this as well as the ANS 2' Committee.
12 MR. SPICKLER:
Air Environment.
I'm sorry, there (m.()
13
'was also someone from Air Environment down there.
14 MR. SIESS:
That's McCready --
15 MR. SPICKLER:
That's right.
That's McCready's 16 outfit.
Yeah.
17 MR. CARBON:
Yeah.
The thing that I was really 18 getting at is that even on this Committee, it's true there 19 are two utilities but what are there, like, twelve. people 20
~on it.
21 -
LMR. SIESS:
Yeah,.but Bechtel is on there.
Yeah, but Bechtel doesn' t care.
23 _
I'm wondering about; the utility --
_ {])
24 MR. SPICKLER:
Ye ah.
As I say, it went out -- -
26.
Ithere were three, because there was also Bob. Stone who was l
31
- 1-30-SueW. I with Carolina Power and Light.
It says National -- U.
S.
()s National Oceanographic and Atmospheric' Administration, b
2
-3 formerly Carolina Power and Light.
And he -- when he was 4
on the Committee, he was with Carolina Power and Light.
5 So there were three actually.
6 MR. SIESS:
Actually, Max, one is a lot because 7
they are - on the consensus basis.
If they get negative votes, 8
they've really got --
9 MR. SPICKLER:
Oh, yes.
Two on here is really 10 significant.
11 MR. SIESS:
Well, there is two on the 2.5.
And 12 there is another three, four or five on the ANS 2 ' which 13
'has to prove this thing.
14 MR. SPICKLER:
It lists down below.
We not only 15 have to get consensus of the ANS 2.5 Committee.
We have to 16 go through ANS 2.
And you c&n see that there'are many --
17 MR. SIESS:
Different.
- 18 MR. SPICKLER:
-- differing types of sectors 19 represented in the ANS 2 Committee.
Those individuals are 20 Chairmen of individual ANS 2l Standard 3 Working Groups.
21-MR. CARBON:
So, what you are telling me is on ZF ANS. 2 here, if Tucker from Florida Power and Light had 23
. disagreed with this, it could not have gotten through?
(J) 24 MR. SPICKLER:
That's correct.
s 25 MR. SIESS:
It might have gotten approval but it
32 1
would have been after considerable discussion.
A dissenter
,#,1-31-SueW k+
2 doesn't have a-veto. _But his negative vote must be consider-3 ed.
A ballot to dissolve it must be at a considerably higher 4
level -- I don' t know what it is here, but it's usually quite 5
large.
6 MR. BERATAN:
Usually, all the documentation on 7
the resolving of the objection has to be filed with ANSI.
8 MR. SIESS:
Ye ah.
9 MR. SPICKLER:
You've never had a more frustrat-10.
ing experience than working on one of these committees.
I 11 think Bob can attest to this.
12 Oh, my God, they are~ frustrating.
What happens invariably is you satisfy the existing committee and then 13 14 this company decides to replace him with someone else and 15 he looks at.it and he says:
My God, I can' t accept this.
And you go through the whole -- it took about --
16 17 and I'm not exaggerating.
We started this Committee in 18 1978.- RNo, it started in about -- yeah, 1978 I think is t
~
when this committee was. fonned.
It took from '78 to '84 to le 20 get it published.
21 And - that' speaks for itself.
22 (Laughter. )
23
- MR. CARBON
You have my total sympathy on that.
~
.:N But I was wondering, and still I guess wonder at that, if -
(}
25 the user in this case really has a say-so in it.
33
- 1-32-SueW
~1 MR. SPICKLER:
He does.
He does.
c 2
MR. SIESS:
If you think you've got it bad, I 3
Chaired a consensus writing committee with thirty-nine 4
members.
5 MR. SPICKLER:
Oh, my God.
6
- (Laughte r. )
7 Look at the next page -- excuse me, turn to the 8
next page.
The next page has the ANSI Committee, the next t
9 page after -- you have the Working Group, you have ANS 2.
10 And the next page has the ANS Committee that reviews.
and #1 13 Joe flws 12 4
-13 14 13
- 16 17 f
18 19 i
M.
l 21 I
ss
!O 1 :
'w
34 2-1-JoLWal'
- MR. SIESS:
Wall, that Committco will concentrato 1
- on ' the resoluti5n of negatives,' 'wi.il' it noti?'
.R
_ (
2
'MR SPICKLER:. No. 'Again,* they get 'a full review and then se 3
have to address the comments, with all the negative comments 4
that have arisen from each of these..
5 MR. SIESS:- Oh, you.have another -- it is not i
6-the standards committee?
T 7
MR. SPICKLER:
No, it is each tier, and this was 8
the worst one.
This was the hardest one.
It is painful.
l 9
-It is painful.. You have to be dedicated to be 10 willing to work on one.of these committees as a chairman.
~
11 Once'you have been into it, you. don't realize how bad it is until you actually.get into'it.
12 13 MR. CARBON:
Okay, fine.
I am convinced.
~14 MR. SIESS:
It is one hell of a system to get 15 a standard out of.
It seems to be democracy.
~
16 MR. SPICKLER:
I'think they yank people off the 17 street to comment on it.
-18 MR. SIESS:
Any other questions?
19 MR. ABBEY:
With regard ~to continuing on that 20 section on the public, is it acceptable-to have general 21 qualitative statements with regard to cost benefit in view
~ 22
'of -- cost benefit with regard to the~public actually 23 benefiting from the standard?
?
24 -
Since they.are going to' bear the cost, both v.
25' directly and indirectly.
s.
av--
no1-~mma+
~c
35 2-2-JoeWnl 1
MR. SIESS:
The question, of course, is a good 2
one.
3 I just think ACRS -- some people think cost benefits 4
is a great way of doing it; other people don't like cost 5,
benefit unless it agrees with what they think beforehand.
6 Whether the cost benefit has got dollars, or it 7
is qualitative, it is hard to say.
There is no way to 8
quantify this.
9 They go through this process because they have 10 to.
S' 11 I like the first sentence; no matter which way 12 you go the public is going to pay for it.
13 If anybody can figure out the reduction in man rem, 14 you know, versus a thousand dollars in man rem, it would take 15 a crystal ball.
16 I just don't know how you could do it.
It says 17 the public would benefit by an increased assurance.
It doesn't 18 even say increased safety.
19 MR. MOELLER:
It is interesting, though, that 20 l that justification is based on the data being crucial in an 21 emergency sicuation, and we heard earlier that we were 22 addressing, were we not, primarily routine.
23 MR. SIESS:
No.
24 MR. SPICKLER:
It has multi-purposes.
Routine and r
)
~
25 emergencies.
r
]
6 2-3-JoeWol 1
MR. SIESS:
It is multi-purpose except some 2
of the equipment got taken out.
3 MR. MOELLER:
Okay, thank you.
4 MR. SIESS:
It is still the two-fold plan.
The 5
public certainly doesn't benefit much from the routine.
6 releases.
7 If somebody is running high, you crack down on 8-them.
You translated that into man rem, it wouldn't justify 9
spending very much money.
10 Of course, in this case, the money has already 11 been spent.
n Max, you have nothing?
I) 13 MR. ABBEY:
I have one question then with regard 14 to the standard.
15 MR. SIESS:
Sure.
16 MR. ABBEY.
2.5, if I may.
I just noted with 17 interest that the references, numbering 5, what it would 18 be in the standard, that in essence three of the four 19 references were available, or at least conceptually available 20 when' Reg Guide 23 was advanced back in 1972, and only one
- 21 reference, that being a 1977 reference, is the only one 22 that was not, and that was.the result' of a workshop held 23 with regard to. stability ~ classification schemes.
(~)
24 Specifically, in light of the literally, deluge g.)
~
55 of research dollars put into it both by government as well 6
.m-a
2-4-JoeWal 37 1
as industry, I would hate to believe that little if any 2
significance, such that it was not referenceable -- was not 3
able to be incorporated in the standard.
4 MR. SPICKLER:
As you know, there could have been 5
hundreds of references.
6 Why specifically only these five, I think they 7
were chosen more as examples rather than trying to be a 8
complete' reference list.
9 MR. ABBEY:
That leads to my question.
My question 10 is, I guess, technically what has led in the last twelve
~ '
11 years, thirteen years, since Reg Guide 23, which led to ANS 12 Standard 2.5, has been changed.
gj 13 MR. SPICKLER:
You mean what changes were made 14 in this guide versus Reg Guide 123?
.a
[
15 MR. ABBEY:
Yeah.
That are not reflected by 16 more up to date and current references.
17 MR. SPICKLER:
They are more reflected by 18 actual experience with equipment.
If you look at discussions 19 of the instrument specifications, there is a major change 20 with regard to the sensitivity and accuracy of wind measure-I 21 ments.
22 And that is based on experience that the previous 23 standard really was inadequate in defining sensitivity.
(
24 i
For example, why would you want to have half a 25 meter, or a tenth of a meter per second accuracy if you
. 2-5-JoeWal 1-
-have a twenty meter per second wind.
2 The previous spec said that is what you had to 3
have.
~
4 There is -- there was a statement that you could 5
use' Sigma ~ Theda as a basis for doing your statistical 6
analysis of probabilities of stabilities, and yet there was 7
no methodology described by which you could do a Sigma 4-8 Theda analysis and there may be references that tell you i
g how to.do it, but it was more the statements are relative 10 to professional experience of individuals that have worked 4
11 with the equipment rather than something that you would ut find in a reference.
is As I say, the major difference between this one 14 and the original one is reflected in the experience of 15 people with systems, and a better understanding of sensi-16 tivities.
17 For example,'there was a extremely restrictive 18 relative humidity spec in Safety Guide 23 that required a
[
19 humidity instrument that was more expensive than all.of-the 33 other meteorological equipment combined, and yet-the humidity.
21 is a rather unimportant meteorological parameter from :a 22 safety point of view.
a 23 So, that is the kind of thing.
What you.are-l 24 talking here is more reflected in experience rather than f) 25 references, i
' ?
r'k p
t o 9
+ - +
y
,.,9 p-.. ~ -
_ -,. ~
a r.,
2-6-JoeW21 39 1~
So, what you are saying is -- as I say, a major
-(m,);
2 change based on twenty years of experience of working with 3
this kind of equipment, and looking at the holes that were 4
in Reg Guide 23, and plugging them based on the twenty years 5
of experience.
6 Because basically, the original Reg Guide 123 was 7
not written by people who actually had a lot of instrument 8
experience.
9 They had experience looking at data, but not 10 looking at instruments, or working with instruments.
This 11 reflects the experience of working with instrument.
El MR. ABBEY:
That ties in, then.
Dave and I had
()
13 a discussion prior to the meeting'with regard to the purpose 14 of the guide.
15 MR. SPICKLER:
Yeah.
16 MR. ABBEY:
And I guess in essence what I hear 17 Irv saying is that this guide strictly is data collection 18 guide, not a methodology as to how they have been used ---
19 MR. SPIC 1'.LER:
That is correct.
20 MR. ABBEY:
-- the information.
The references 21 certainly reflect that.
22 MR. SPICKLER:
That is _ correct.
'l 23 MR. ABBEY:
Albeit it eight years in the past.
r~s 24.
MR.'SIESS:
Each of the references -- it is not b~
25 a bibliography.
1
2-7-joe Wal 40 1
MR. SPICKLER:
No.
As I say, if were going to 2
put together a-full bibliography, -- there was no intent 3
to put together a full-bibliography.
There would literally 4
be hundreds, as you know.
5 MR. ABBEY:
I was driving home a point, I guess, 6
with regard to data collection as opposed to understanding s
7 of the methodology.
8 MR. SPICKLER: - And if you look at the open 9
literature, there is very little actually written on actual 10 experience with equipment, and operation and maintenance of 11 equipment, and that is why we had the type of subccmmittee u
that we did.
(.
13 We-had people on the subcommittee that had I
14 extensive instrument experience, and that is what is reflected 15 here.
16 MR. SIESS:
And I think that is reflected in the 17 title of the standard.
18 MR. SPICKLER:
That is right.
19 MR. SIESS:
Entitled, Guide.
20 MR. SPICKLER:
Yeah.
21 MR. SIESS:
Just don't agree.
Determining 22 meteorological information in one, and meteorological measure-23 ment program.
Measurement program is what you _ use to
/7 24 determine the information.
b-l-26
.You didn't change the Guide's name.
41
~2-8-Joe W21 1
MR. CARBON:
I have a couple of more questions, 2
if I may.
3 MR. SIESS:
Sure.
4 MR. CARBON:
The last sentence under industry 5
says:- Hence, there is no additional impact on industry.
6 I happen to be one of those dumb optimists that 7
think five or ten years. down the road there would be some 8
more nuclear power plants ordered, and it is probably so 9
that there would be no more impact on plants in existance, 10 what does the instruicentation cost here?
11 What kind of costs are involved in implementing 12 this?
13 MR. SPICKLER:
Let me clarify another point.
14 Just because somebody has all of the equipment now doesn't 15 imply that there aren't going to be additional costs over 16 the forty year life of a plant.
-17 You have to replace the equipment.
18 So, every year or so there is refurbishing.
So, 19 just because somebody has a system now doesn't mean that it 20 is not going to cost them anything in the future.
21 He has to refurbish it.
22-MR. CARBON:
Is that last sentence correct:
There 23 is no additional.
24 MR. SIESS:
Let me as a question. 'Is the value M
impact statement cover the guide as such, or the changes to the I
- 2-9-JoeWal 42 1
guide?
m
(~
MRS. BROWN:'It covers the guide as such.
What 2
3 do you mean by the changes ?
4 MR. SIESS:
From the original.
5 MR. SPICKLER:
This is changes to the original.
i 6
MRS. BROWN:
This is changes to the original.
7-MR. SPICKLER:
And the answer there, there isn't 8
any.
1 9
MRS. BROWN:
There aren't any changes from the 10 original, other than clarification.
11 MR. SIESS:
The value impact is on the revision, j
12 MR. SPICKLER:
That is right.
13 MR. SIESS:
And that doesn't add any cost you 14 say?
15 MR. SPICKLER:
It reduces the cost, actually.
16 MR. SIESS:
Now, Max's question really relates to 17 tie guide itself, and that is not what the value impact 18.
statement addresses.
N 19 MR. SPICKLER:
It addresses ' the change.
20 MR. CARBON:
Then, -let me address the other 21
' question.
Whht. is the cost to implement this?
j E
MR. SPICKLER:
I will -- I haven't put together-j 23 a met system in a few years.
I have been with the NRC for
(~%
24 four years now, but a tower, _a sixty meter tower with.
. %.)
25 instrumentation at ten' meters'and' sixty meters, wind speed, v
~
r
2-10-JoeWal 43 1
wind direction, delta temperature with height, generally 3
i' 2
-- although it is not required here -- people also take 3
absolute temperature and humidity, precipitation on the 4
ground, at ground level, strip chart recording in an air-5 conditioned, weather proof building at the base of the tower 6
normally, with digital system.
7 Now with supplement one to 7.37, generally hard 8
wired directly to the control room, which either goes into a 9
mini-computer that is used for multi-purpose, or into a 10
-- some other digitizer, which is then inputted into another 11 computer -- the reason I am going at it laboriously is that 12 I want you to understand what I am talking about when I 13 talk about the cost.
14 It also is hard wired into the technical support 15 center normally, and it has to be hard wired into the 16 technical support center and hard wired into the emergency 17 offsite facility, and there it would a'.so probably be going 18 into either a mini-computer of some sort or into a digitizer 19 which is then used as input to a computer.
29 When you are talking what I just described, and if 21 you assume that those mini-computers were there specifically 22 for the tower, and they are not, they are multi-purpose, you 23 are talking somewhere in the area of half a million dollars.
'~
)
24 MR. CARBON:
What is the maintenance cost?
25 MR. SPICKLER:
Maintenance per year, it is
2-ll-JoeWol 44 1
-- calibration twice a year -- it is about thirty-six
)-
2 hundred dollars. The equipment is not expensive to replace.
3 Wind instruments are in the one to two thousand 4
dollar range.
The expensive equipment is the digitizers, 5
and the strip charts.
Those are the most expensive, and 6
fortunately, the most durable.
7 MR. CARBON:
Does it take much operating costs?
8 MR. SPICKLER:
Well, no, because the facility 9
normally uses somebody who is a maintenance guy doing 10 something else.
11-Normally, what they do is they make a daily check Et on 'the way in and on the way out.
When he has time he does
/%
13 maintenance and what ever on the met tower.
, U 14 They don't normally have a dedicated technician, 15 so the only thing that really costs, I would think, is the is calibration.
The calibrations that are done during the 17 year, that takes some time.
18 MR. CARBON:
Presumably, though, if this person I
19 -
didn' t have some spare time, they would have to --
20 MR. SPICKLER :
You would have somebody about 21 half time, I would guess,, 1f you look'at the total.
22 MR. CARBON:
One last question then.
Mr. Abbey 23 made the suggestion that.it be stated industry believes-24 any related costs would be' acceptable.
O, 25 Could.I ask you, because you were in industry
2-12-JoeW21 45
~
1 at the time, I guess, would you-think the utility people 2
on this ANS Committee would have chosen the word, ' acceptable,'
3 or would they have chosen the word, ' inevitable?'
4 MR. SPICKLER:
I would suspect, ' inevitable.'
5 MR. SIESS:
Since they already have them --
6 MR.'SPICKLER:
There still is, for some reason, there 7
isn't a universality with regard -- in industry, with regard 8
to the need for this equipment to be perfectly honest.
9 Admittedly I am biased.
I am a meteorologist.
10 So, my opinion is biased.
11 MR. SIESS:
Part 20 says they have to report each n
year on releases, and they can't dc that without
()
13 MR. SPICKLER:- But he said inevitably, and that 14 is because the regulations require it.
15 MR. SIESS:--Yeah.
I~can't visualize regulations 16 that don't require some report each year on routine releases.
17 They are sort of basic into the system now.
18 MR. SPICKLER:
And from an emergency preparedness 19 point of view, I don't see how you can do without, but as I i
20 say I.am biased.
21 If you talk to vice president from Power Company 22 "X", he may not think so.
'30 -
MR. CARBON:
Yeah.
I am not arguing that you can l
~
r'] _
24
'do without.
I was wondering about the unanimity of opinion,
.(.)
l_
25 and I would ask the question:- Why.would the Vice_ President
2-13-JoeWal 46 1
1 of Mid-East Utilities think you don't need it.
[/
)
(,
2 MR. SPICKLER:
I don't know.
I frankly have never-3 understood that.
It is rather shortsighted, in my opinion.
4 You know,-as a consultant I have had many a 5
heated discussion with a utility executive on the worth of 6
-such equipment, and I don't mean from a nuclear point of 7
view, but from an air quality point of view also.
8 MR. CARBON:
Could he believe that you are way 9
overdoing this?
That not near this much is required?
10 MR. SPICKLER:
You see less and less of that today 11 than you did twenty years ago.
M Twenty years ago people thought if you put a
()
13 wind instrument up on top of the power plant, that was 14 enough.
15.
When I first started as a consultant in 1972, I 16 wish I had a buck for every power plant that I went to 17 that had a wind instrument sitting on the top of a building 18 that gave you absolutely worthless information, and that 19 is what it was.
20 What do you mean I don't have meteorological 21 data, take a look there.
And barely sticking up above the -
22 roof was a little pole with a wind instrument on it that 23 nobody had looked at for ten years, you k row.
~
24
- Q('N But it is' changing.
I think there is more
'~
25 enlightenment, and I think more the utility executives are t.
. 14-JoeW21 -.
47 i
1 more in tune to what they really need rather than what is (Aj' 2
it that is bringing money into a utility, and a meteorologiaal 3
tower brings not one dollars in terms of per megawatt into 4
the utility's coffers.
5 You know, it doesn't generate electricity, so 6
what the heck do we need it for?
That used to be the i
7 philosophy.
It is changed.
8 People are more enlightened.
9 MR. CARBON:
I do want to leave this with this 10 other thought, though, that I don't think we ought to 11 forget that strangely enough there may be some new plants 12 ordered some day, and we sure don't want to be imposing
(}
13 unnecessary requirements, even if they don't mean any money 14 on existing plant.
15 MR. SPICKLER:
I clearly don't think we are.
16 MR. SIESS:
I.think if you look at severe accident 17 analysis -in trying to do a converted man rem cost benefit, 18 you would have a real problem with this, but as long as 19 Part 20 requires reports on routine releasos, it can't-be 20 measured --
21 MR. CARBON:
Of course, that raises the question 22 if Part 20 requires something that is really not needed, we 23 ought to change Part 20, or I.would set up a new reg guide.
24 MR. SIESS:
Incidentally, Max, we will get a chance 25 to see the public comments on this.
And-that would be m.
.. =..
m
.... m m
=
.=.
48
.2-15-JoeWal 1
interesting, too.
f%
(_f 2-I wanted to ask a question.
I have been at 3
one plant, and perhaps two, where they had a program set 4
up on a micro-computer to take the met data and predict
~
5 doses out in various directions.
4 6
Is that something that utilities have done on 7
their own, or is there a requirement somewhere?
8 MR. SPICKLER:
It depends -- yes and no.
If 9
you look at NUREG 0654, I believe it is, supplement --
10 what is it, Supplement 2 -- Appendix 2 to NUREG 0654.
11 It describes the kinds of considerations that 12 we would like to see in emergency plans, and what many (r'},
13 of the people have done is to go to these mini-computers v
14 with a real time --
15 MR. SIESS:
These are on a micro.
16 MR. SPICKER:
It could be done on a micro.
It 17 can be done on an IBM PC, with no difficulty at all.
18 MR. SIESS:
Good graphics.
19 MR. SPICKLER:
Yeah.
Very nice graphics.
Giving 30 you real time display of dose versus distance, or varying 21 conditions with a time and-space variable model.
22 Most of the utilities are going to that kind _of 23 modeling for emergency preparedness.
,N:
24 MR..SIESS:
Are you projecting from site meteorology?'
9; 25 Or historical --
~
. ~
__m_
b 2-16-JoeWnl 49
\\
l 1
MR. SPICKLER:
No, it is being -- well, the
(~)%
's 2
historical is being.used to -- for example, general 3
climateological information is used to forecast in the
.4 future what is going to happen in th'e next few hours.
5 We have a dozen or so kind of conditions now, 6
what can we expect to be occurring over the next few hours?
7 That is particularly being done at places like, for example, 8
San Onofre, at an oceanside location where static conditions 9
just don't exist.
)
10 There are -- you have mountains, you have the
^
i 11 ocean, you have desert, you have all kinds of variables that 12 inpact that, and general climateological information is
(~'%
s,f 13 generally used to do the forecast of what is going to happen v_.
14 in the next few hours, and also.if you are talking only one 15 point measurement, like a tower at one site, the prediction 16 of what the wind field will be,-and where it will go once 17 it gets beyond where the data.at that site is really 18 representative for.
19 MR. SIESS:
A number of plants have these programs 20 operating.
21 MR. SPICKLER:
Yes, most of them have gone to 22 this kind of program.
23
-MRS. BROWN:
They do.use real time data, however~,
/~T 24 in an emergency.
They have that ' data.available.
. C/
25 MR. SPICKLER:
It is local, it.is onsite.
i
'2-17-JoLWal 50 1
MRS. BROWN:
It is onsite.
,C-()
2 MR. SPICKLER:
It is onsite.
They supplement it 3
with data from national weather stations, and frankly, some 4
have decided to put up other short meteorological towers,
.5 as supplementary stations, to provide additional information.
6 MR. SIESS:
Do they include the release point?
7 MR. SPICKLER:
Yes.
8.
MR. SIESS:. So they may know where it is.
9 MR. SPICKLER:
And they also include source, 10 depending on where the source. can be,, dnd some estimate of i
11 unmonitored sources.
M MR. SIESS:
I think ?.he first ene I.saw was Ft.
13
.St. Vrain.
14 MR. SPICKLER: Yeah, we have looked at that one.
15' MR. SIESS:
Any oth'er comments or questions?
16 '
MR. ABBEY:
There is one closing' comment, I guess.-
17 Having witnessed-largely -- apart from the whole process for 18 the last half decade, I have seen the evolution of the 19 revision to 1972 safety guide, and I certainly 'think that 20 time has blessed us with regard to presenting us.a standard s
21 now that can indeed be endorsed.
22 It has gone~through a review process ~that the 23 Staff can implement.
I'certainly see a great deal of progress 24 js being made in this regard, and wish the Staff well with regard
(_
'~
25 to the public comments.
I
1 2-18-JoeW21 51 1
MR. SIESS:
Well, between the ACRS and the CRGR
$(
2 we managed to delay it longer.
And lack of resources, is 3
that the other?
4 Well, gentlemen, the issue for us is to approve 5
this.
To recommend to the full committee that we write a 6
letter to Mr. Dirks saying that we are satisified for this 7
to go out as a public document.
8 Any objection?
9 (No response.)
10 So be it.
Do you want the standard back.
11 MR. BERATAN: - No, you can have them.
We ordered 12 '
extra copies.
You can have that.
We brought fifty copies, I'T is because we figured that is how many we needed.
V 14 MRS. BROUN:
If you are throwing it away, we will 15 take it back.
16 MR. SPICKLER:
If you want to return it, I know
'17 some people that would be tickled to have it.
18 MR. SIESS: I do not collect paper.
19 We will take a break until such time as the Staff shows us.
20 Thank you, gentlemen and lady, ti (Whereupon, a recess was taken at 10:10 a.m.,
t 22 to reconvene at 10:37 a.m.,.this'same day.)
2 MR. SIESS:
The next item on the. agenda is
.\\
,o 24 proposed Revision 2 ~to Regulatory Guide 1.105, instrument N
25 set points for safety-related: systems.
R:,
'k'
2-1D-JoeWal 52 1
This also has a history, that Sam has summarized 02Q
.()
2
- in his status report.
3 I think it was first -- Revision 1 goes back to 4
'76 I guess.
We first saw Revision 2 in ' 81.
That is before 5
your time, Charlie, but it is one that has been back to CRGR 6.
what -- three times?
7 And it, too, of course, endorses a standard, 8
which we have here. 'I-think without trying to go into the s
9 history, we will let the Staff remind us a little bit of the 10 history.
11 Let me mention to the subcommittee' members that 12 one of the charges of the Reg Activities Committee is to
(}
13 I' won't say monitor, to observe the activities of CRGR 14 as it relates to those things that we see, and in this 15 particular case, chiefiy as a result of CRGR review, the 16 positions in this _ guide have either been deleted or 'diluded.
17 I think deleted is the word.
18 And I understand that the Staff is not particularly
~
19 happy about it.
Some.of the deletions.
Is that true?
20 MR. MORRIS:. This is Bill Morris,1 Chief. of the 21 Electrical Engineering Branch, in the Office of Research.
22 I don't know that it would be fair.to characterize 23 the Staff's point of view on the CRGR interaction.
~
24 The CRGR makes recommendations ~ to the' Staff
,3 Y.-)
M management, to the Executive Director for Operations, and
.,) :.
'2-20-Jo;Wal:
53
'1-those recommendations are reviewed by the Office Directors,
~
mJ 2
Mr. Minot and Mr. Denton, who in this case is responsible a
for this guide development, and the Staff either takes the 4
advice of the CRGR or it doesn't.
5 It has a. option to do either one, and in this
~
6 case there.has been.a lot of deliberation on the development 7'
of-the guide, and after hearing a fairly clear statement of 8
what_the CRGR position is,.the Staff Management decided that e
the yuide, as it comes to you, is the guide that it should 10 now publish, and.there may be, indeed,.some cases where 11
.someselements of the Staff, some members, some individuals, 12 believe there could be a -different guide that could be
{} '
'Is published that they might prefer, but I don't think it is 14 -
fair to characterize the staff as having dissatisfaction.
i m
15~
MR.' CARBON:
In fact, the. Staff's official t
16 position'is approval.
17 MR. HORRIS:
Yes, that is right.
Now, you said NRR -- this guide 18 ~
MR. SIESS:
19
' originated'in Research or-NRR?
l 20 MR. MORRIS: -The guide is developed in Research, il
, ' '[3 21 :
through a great deal of. participation with NRR, and NRR is 22 essential 1Nthesponsoroftheguide.
Y m
~ SIESS:
You~ are all-in research.
.23 MR.
w
.24-
'MR. MORRIS:
Mr. Rosa is the representative from 26 NRR.
t f
I t
'D-h,[-.
r.,
,,,.i
,_,.m.,,._
._y
12-21-JoeW21'-
54 I'.
MR.'SIESS:. Where are you now?
f[ -
2 MR. ROSA:
Well -- this is Faust Rosa, Chief 3
of the Instrumentation Control Systems Brach, in NRR.
4-To characterize --
5-MR. SIESS:
Is that what you still are?
6' MR. HROSA:
That is where I still am, yes.
7 MR.'SIESS:
Under the technical group.
8~
MR._ ROSA:
I.am'in the technical group..Of course,
-9 there' is ' this reorganization, and I will be in another 10 position.
11
..MR. SIESS:
That is what I meant, under the ut reorganization,- but you will still have a group through -under 13 that technical, not under the project director?
)
14 MR ~. ROSA:
Right.
15 MR. SIESS:
Okay.
16 MR. ROSA:
Right.
We have interfaced with CRGR 17 -
through these years since this Revision.2 was first proposed, 18 -
and I think we. recognize that.CRGR has a function to 1S perform.
^
20 We think -- personally, I think that I would have 21 '
prefered-not to delete some of the guidance that was l included 22 in the prior. draft of the Revision 2 of the guide.
23 I think CRGR-in-this case has overlooked its other
'N function, which is to improve the effectiveness and efficiency
, k)3 l
. 25 -
of; the regulatory process.
- 2-22-JoeWal 55
~
1 MR, SIESS:
Okay.
I think you made a good point,
. C)3 7
(_
2 Faust.
As I recall, ACRS wasn't all that enthusiastic about 3
some of the positions.
4 There were what, about ten or eleven positions.
5 As I recall, almost none of them imposed different conditions 6
'than the standard.
7 They wanted guide amplications, explanations of 8
the standard.
Am I right?
9 MR. HINTZE: 'You are right.
I think it would 10 be well to state the principals of the regualtory staff are 11 all new to this guide just since the last revision.
H MR. SIESS:
Faust wasn't in on this?-
/'T 13 MR. HINTZE:
Faust was in it, but with different V
14 research that were involved in the actual writing.-
15 PiR. SIESS:
Now, I notice in Sam's report here, 16 and I don't remember whether he is paraphrasing, not quoting, 17 he said that some members'of the Staff seem to fhel that 18 failure to provide such clarification in the guide may result 19 in increased staff efforts, because the Staff may have to 20 provide such clarification at a later stage on a case-by-case 21 basis.
22 Does that sort of reflect what you were saying.
23 MR. ROSA:
That is a fair characterization of 24 what I believe, yeah.
l- (7-)
l 25 MR. SIESS:
You see,-this raises a question as I
O a
+-
56 JoeWa1.
1 to the purpose of the guide.
D
(,_)"
2 What that says is it would expedite the staff's actions, because they won't have to keep clarifying things 3
4 case-by-case.
5 Is the guide the only place to do that?
Can the standard review plan provide 'that sort of guidance to 6
7 the reviewers similar that the licensee would have?
8 I guess I feel it is sort of commendable in that 9
it will expedite the process.. I am not sure the purpose of to the guide is to reduce the staff's efforts.
It is supposed-11 to_ improve safety.
12 But you say the process would help.
/~
(~h 13 PJR. ROSA:
Well, as far as the standard-review
/
14 -
plan. is concerned -- assumin g a guide includes all the 15 clarifications we would like to see, then it is just a simple 16 '
matter of listing it in the table in the standard review 17 plan, whereas if it doesn't, perhaps, another paragraph or 18-so in the standard review plan would be. appropriate.
19 uMR. SIESS :
Now,. suppose you had a branch 20 technical position, or an item in the standard review plan 21 that provided these clarifications.
Would CRGR have objected 22 to that, or would they object to that if you came up with 23 one?
24 MR. ROSA:
I don't know.
25 MR. SIESS:
You see, I am really trying to get a.
L
1 2-24-JoeWnl 57 i
1 feel for'how they look at reg, guides.
f~y
(_/'
2 The reg guide originally was simply stating a 3
position that the staff had arrived at over a period of time 4_
when negotiations with licensees was inadequate, as you 5-recall, safety. guides.
6' I think when you look at a reg guide that endorses 7
a: standard, you sort of expected to see positions which 8
are of the same character as the standard, and not correction 9_
of typographical errors or clarifications.
10 Do you understand what I~am saying?
Now, if CRGR 11 looked at the guide as being.something of the same level Ut-of significance, of importance,'as a standard, I'can see why
(
13 they would object to the -clarifications and so forth that 14-were built in there which got to be fairly long, which really
-15 didn't change the standard.
16 It-really. didn't even change an interpretation in 17 your mind.
I think there were clarifications of the intent 18 of the standard.
I don 't believe there were any that dirfered.
19 Now, maybe that is the wrong way to look at a 20 guide.- Maybe a guide is supposed to be more than that, and 21 if it is, maybe that is something that needs to be brought 22 out in discussions with CRGR.
12 MR. WYLIE:
Isn't that?the case that it has
-( g 24 been in the past with the reg guide, stating what is y) 25 acceptable to the Staff, and how the Staff would interpret.
2-25-JoeW21 58 1
As I gather, what has been taken out of here is what 2
-- endorsement of the standard -- taking out, or has been 3
eliminated, how the Staff is going to interpret what is 4
acceptable.
5 MR. SIESS :
It is not quite that because --
6 MR. WYLIE:
Well, I mean for example, I believe 7
the one on the position that was taken out had to do with 8
the margin that was put in the set-point, a drift in 9
adjustment, and what was stated here was how the staff was 10 going to interpret that as acceptance.
11 Now, that has been taken out.
U MR. SIESS:
Went,through a process of taking all
^}
13 that and putting it in the discussion part.
I think the ACRS 14 sort of like the idea.
I think we even suggested it, and 15 then CRGR said take it out of there.
16 MR. HINTZE:
That was, I think -- part of the 17 problem was CRGR taking a position, just couldn't find a 18 convenient way of changing.
19 The reason I mention this, is because 6.he three 20 of us were not really involved in the original development is 21 that we think the word processing that we did, and then we 22 agreed that the ten positions really weren't that substantive 23 in terms of position, but we did not agree that the 24 guidance that was provided was not essential, and wouldn't
~s JEnd 2.
SW fols. 25 be a help and use to the guide in the discussion section.
.~
=
59
. 1-SueW ~
l MR. SIESS:
And I assume was some use to the
\\
2
-industry as well as --
3' MR. HINTZE:
Well, three of the four paragraphs 4
we had proposed to add were indeed responses for clarifica-8
' tion the~ industry asked for.
6 1G1. SIESS:
Now, why didn't the Standard include 7
enough information that it was unambiguous?
~
.8 Was that just because of the need to reach a 9-consensus on the Standard?
Who was on the Standards i
10 Committee?
11 MR. MORRIS :
Let me point out something.
I u-don't know that we would say-that this Standard is ambiguous.
f 13
.If we thought the Standard was ambiguous,
.we would-not be 14 here today with a guide that would have eliminated those two 15 positions _and simply endorses-the Standard.
18 And it's our judgment the Standard is _ not i
17 ambiguous.
Clearlyi there are points of view'-- Mr. Rosa
'V 18
- has:a point of view that if we said-more in the Standard we
'N could help implement the licensee process, make his job.
i 30 easier.. But if we look at the Standard and we say:- Is this
'21 Standard acceptable to the Staff in terms of its technical
'E content, thon'we'-- we are saying it is.
23
~MR. SIESS:
Agree with the Standard?
I h 24 MR.. MORRIS: -We are.not saying it's ambiguous.
26 MR. SIESS:
But if the Standard is unambiguous, t
..- - ~ _.
60 i:
j f 3--2-SueW 1;
there is no need to interpret it.
> f m,.
,' d 2'
MR. MORRIS:
We are simply endorsing it.
That's 3
our' final position.
.4 MR. SIESS:
But the positions did more than 5'
endorse-it.
'6 MR. MORRIS:' That's correct.
We decided to re-7 move those positions.
~'
8 MR. SIESS:
Were they interpretations?
i
'9 MR. MORRIS:
We are prepared to go through~-today, 10 to go shrough those positions, one by one, and explain to 11 you how we come to the judgment that they should be removed.
12-That could take a while.. But that was our idea
~ 13
.of how we would proceed.today.
t
~ Well, we would not want to go 14 MR.
SIESS:
15 through all of them.
4
-16 MR. MORRIS:
Okay.- You-approved a guide with'
[
17 tien positions, and we are ~.back to you with a guide with no
~
,18 positions.
And we felt that may be 'something you would 19 want.
i 20 MR. SIESS:
I' ve - worked 'on a standard, and we f
21'
.have.a code, a-standard, and then we write a' commentary-1 22 which' amplifien and.in some cases interprets.
23 And I think you will recall that I've suggested 24.
frequently that the-discussion'section of the guide is really
~
l
.25
- a. commentary on the positions.
r I'
2-
.a
,. --..u
61 (3-3-SueW 1
Now,.you don't have any positions.
. A~.
-(
b 2
MR. HINTZE:
Well,_ the positions really in this 3
case are the standards -- is the Standard itself.
They 4
have really become _ positions.
5_
- a. SIESS:
Right.
6 MR. HINTZE:
So, we could amplify on those without
-c 7
MR. SIESS:
Actually, at one point you had those 8
positions as discussion in the guide.
And CRGR told you to 9
take them out of there.
10 Now, as far as the implementation was concerned, 11 Faust, if those were in there as discussions they would H
be just as useful to you as positions?
(}
13 MR. ROSA:
That's _ true.
14 MR. HINTZE:
I would like to state personally 15 that I -- LI think Faust agrees with me, he will have to say 16 if he doesn't -- I would hate to see this guide delayed just 17
. because of this.any longer.
It -has been under development M
.for five years.
19 And I think it probably is better getting out the 20 '
way it is proposed now than delay and try to get some more 21 information in it.-
22 I think the problem is more fundamental than just 23 this one guide.
24 MR. SIESS:
I've got a suspicion that there are O
25.
enough previous draf ts around that the industry knows your
. ~-
A 62 i
interpretation by now. -
-# 3.-4-SueW. 1
[
2 (Laughter.)
[
- 3 MR. WYLIE:
Well, I would intend to agree with 4
you.. But 'let me ask another question.
J.
5 There has been some discussion that eventually U
s.
after some more work, that eventually the Standard Review -
~
i 7
Plan would. encompass the reg guides and you just would not 8
~have reg guides.
-9
-Is that --
4
- 10.
MR. SIESS:
No. :
Iheireg guide will endorse the standard.
)
i 11'
-It' takes.a reg guide to endorse a standard, doesn't it?
- 12 MR. WYLIE:
What I was saying there was some 18 discussion'about~the Standard Review Plan being revised 14 so that it' includes all the reg guides initially.
j
.15 MR. ROSA:
It does include the reg guides now.
16 -
MR. WYLIE:
Oh, it references'--
f-17' MR. ROSA:' It references and in some of the i
18 texts it also --
i
. 19 -
MR.-SIESS:
What's Charlie-is. talking about is 30 that, therefore, we've had recently, with more to come, of 21 where reg guides that are out of date are being replaced 'by r
. 22 sections of the Standard.
V i
~ 28 MR. WYLIE:
Right.
l p.
34 MR. SIESS:
This happened'with one guide just
. i
- v.
. 7 E,
26
- recently.. And.then we are told that there are about fifty l
^
4
,-y.
p 3
,e
~,,,
.._.._s.,..
.-w
..~,.-.,...-m.,.,m
63
'#3-5-Suew 1 reg guides-out there that need updating and they don't have A
(_)
2 the resources to do it.
And in many cases they have been super-3 seded even by stuff that's in the Standard Review Plan.
4 But those are not necessarily reg guides that 5
endorse Standards, I think, Charlie.
6 Is this the only_ mechanism you have for. endorsing 7
a Standard?
8' (No response.)
9 You can't just endorse it in the Standard Review 10 Plan?
11 MR. MORRIS:
I think Lhere are some cases where 12 standards are mentioned in the Standard Review Plan and are
().
13 not endorsed by the Regulatory Guide; isn't that true?
14 MR. ROSA:
That's right.
I think this is the 15 only mechanism for endorsing a Standard.
I know of no other.
16 MR. SIESS:
Well, if you just refer to a Standard 17 in the Standard Review Plan, that wouldn't have the same 18 effect?
~
19 MR. ROSA:
It wouldn't have the same weight, no.
20 It would be something that is a useful reference.
21 MR. SIESS:
All right.
22 MR. ROSA:
The endorsement is an official act of 28 the NRC Staff, also the -- supported by the ACRS and --
24 7-)
MR. SIESS:- Well, we are going to review changes V
26 -
to the St'andard Review Plan.
64 1
'4 3-6-SueW -I MR. ROSA:
That's true.
I9
- (_/
2 MR. SIESS:
The implementation is important.
-3 There is a decision in the implementation on backfit forward-4 fit'but that can also be in the Standard Review Plan, can it 5
not?
6 MR. HINTZE:
I suspect that it's just as difficult 7
to get a change in the Standard Review Plan as it is to get 8
a Reg Guide out.
9 MR. SIESS:
It probably is.
10 MR. MORRIS :
I think that you would find that 11 if you tried to use the Standard Review Plan as a mechanism ut to endorse industry standards, it would be a very cumbersome i
13 document to do that.
14 Each regulatory guide might have several substa-15 tive technical positions that unlike this Guide which 16 simply endorses --
17 MR. 'SIESS :
If these are endorsement exceptions, 4
18 then I --
~
19 MR. MORRIS:
You would have a Standard Review Plan that would have to contain"all of those exceptions, and it 21 would be a very cumbersome, very large document.
22 MR. SIESS:
We even have a Reg Guide that comes 23 out regularly, that updates the endorsements of ASME 3.
We 24
{}
don'.t review them anymore.
25 The thing is, I think historically it's the way
i 65
- 3-7-SueW 1
to do it.
Now, whether it's the only way to do it, I don't (R.T 2
know.
3 Now, what I hear is that both sides of the table 4-say, we really shouldn't try to hold up this Guide.
Get it 5
out.
And I think Faust could get get around some of his a
problems by branch technical position or something in a 7
Standard Review Plan to clarify interpretations.
8 But I personally think that CRGR threw out the 9
baby with the bath water on this.
I can't feel that it's an 10 issue, because they didn't throw out what I would call any 11 substantive things.
Et But there was a chance by putting this stuff in
(}
13
'the discussion to accomplish a useful function without making 14 a big deal of it.
I think to put the clarifications in 15 the discussion makes a certain amount of sense.
16 And I think they went too far when they said:
17 Take it out of there, too.
18 Because that would have a~ccomplished your purpose; 19 it would have done it in one step.
And it would have still 30 been a fairly clean endorsement of a Standard that, you know, 21 has had a lot of work done on it.
22 Is that about the way you feel, Charlie?
23 MR. WYLIE:
Yeah.
I think so.
Faust has a 24 point --
26
.MR. SIESS:
Well, for example, if we sent this t
~
\\
I
66
- 3-8-SueW 1
.back.to the EDO.and said:
Look, we think you went too far
(. s/
2 in. responding to CRGR, that those clarifications would be 3
useful if they were in the Guide as positions -- I mean, as 4
discussion, - then we've got, what, another two years.
6 MR. ROSA:
That's about'it.
6 MR. SIESS:
kad that doesn't make you.too happy 2
7 either, does it?
8 MR. ROSA:. No, it doesn't.
8 MR. SIESS:
I think we might want to say that we 10.
think they went too'far, but let's go ahead and get this lli thing out.
M MR. ROSA:
Well, there are plans now to go down
()
13 this other road and work with the Standards Committee to get 14 a revision of the Standard itself to include some of these is clarifications.
16 MR. WYLIE:
That may take two years.
17 (Laughter. )
18 MR. ROSA:
That may.take a long time, too.
19 (Laughte r. )
20 But nevertheless, that's what the plan is.
21 MR. SIESS:
Would you like to -
I remember these 22 things fairly well, amd I'm not -- I don' t feel a need for 23 going through item by item, but if you would like to go
(}'
through two or three of them as to what the clarification meant 24
~
26 l
and so forth to get a: feel for it - _ Charlie, I don't know how l-r I
3 c
4 w
y
'w--y-
67
!#3-9-SueW-1 familiar you are with it.
- ('l
' \\_/
MR. WYLIE:
I've read over it.
2 i
3 MR. SIESS:
You've read the whole mess.
- Max, i
4 do you want'to - -
i 6
MR.' CARBON:
I don ' t think so.
)
8 MR. SIESS:
You know, at the time this came up, l
7-we were just seeing LERs on setpoints like, you know,
[
t 8
volumes of them.
i 9
Now, that has cut; back, hasn' t it?
i 10 (No response.)'
i 11-At least, I don ' t see the LERs ' that --
I H
MR. SULLIVAN:
Well, I would certainly hope so.
13 I haven't followed the LERs on these setpoints.
1-14 You. are correct, when :this Guide originally, back 15 in '75, was prompted by reports'of instrument trips, hopefully 18 the Guide in all its forms, the early one and presumably this
~
17 one, has'and will continue to correct.the problem.
18
.MR. SIESS:
Let's see, this came out --
]
.19 MR. IIINTZE:
'82 I think.
i 3D MR. SIESS:
They do everything.but put dates on
-1.
21~
them.
I'veLgot '82 stamped on'it.
22.
MR.:HINTZE:
I think part of the problem in the I
28 development of this ' Guide is that it started ~ out.as an un-Se developed Standard.
-It was a draft-Standard.
And it had'to.
j wait unti3 the. formal Standard came out, f
as
68
- 3-10-SueWl' MR. SIESS: -Yeah.
What happened to Ed Woodson?
- )
().
2 MR. HINTZE:
He's in Region I.
3 MR. SIESS:
Oh.
He worked on it, didn' t he?
4 MR. HINTZE:
Yes, that's correct.
5 MR. SIESS:
Do you think that just the draft 6
Guide helped people a lot, cut down the --
7 MR. HINTZE:
I was thinking that that was part 8
of the delay in getting the Guide moving.
9 MR. SULLIVAN:
What I was referring to in total 10 was the ones all the way back to 1976 as well as the one 11 that's in force right now.
So, the entire effort over the 12 last ten years, including drafts and everything else.
(}
13 MR. WYLIE:
Aside from working on industry 14 standards, do you plan on a branch technical position to 15 help clarify this?
16 -
MR. ROSA:
Well, I might say this about what ICSB 17 has been doing since the middle 70s anyway.
We havd in 18 effect been applying the recommendations of this Standard 19 to the industry, doing it on a case by case basis.
20 And more recently since 1980, or around that-21 time, we've been working with those owners Groups that have 22 involved themselves in preparing submissions for their parti-23 cular plants on setpoint methodology.
So, the issuance of 24 this Guide endorsing this Standard won't really change our 26 method of operation and application of these recommendations
69
- 3-llL ueW 1 much.
S 7%,
(,_ l 2
MR. SIESS:
So, this does not have to go out 3
for comment again, does it?
4 MR. HINTZE:
No, sir.
This is the final issuance.
6 MR. SIESS:
So, if we pass on it it can go out 6
real quick like?
7 MR. MORRIS:
Well, we would hope so.
8 (Laughter.)
9 MR..SIESS:
Okay.
That's a lot of discussion 10 for preliminary.
11 Were there any things that you wanted to'tell us 12 about the Guide?
()
13 MR. MORRIS :
I think given what you have just 14 said and the satisfaction with the understanding of it, we 15 would not propose to make a presentation to you.
16 MR. SIESS:
Yeah.
You've still got a little 17 discussion but it's mostly just correlating some definitions.
18 Now, let's see, this isn' t the one that encourages the use 19 of instrument computers, is it?
20 MR. HINTZE:
No, sir, that's the next one.
21 MR. SIESS:
I see,.
That's the next one.
- Well, 22 you've still got a fair amount of guidance in your discussion.
23 MR. HINTZE Yeah.
I think if the ten positions
(~}
would have been put in the discussion section between the 24 h=
26 first and second review of CRGR, it would have gone through l
70
- 3-12-SueW 1 okay.
(\\~/"'t 2
MR. SIESS:
Yeah.
3
'MR. HINTZE:
It was the_ fact when we went to 4
CRGR with thirteen positions and came back with ten --
5-MR. SIESS:
Yeah.
How many.of those are in the 6
discussion now?'
7 MR. HINTZE:
Just about three.
Two and a half.
3 MR. SIESS:. Yeah.
But not'as much as Faust would e
like to have.
10 MR. ROSA:
I've got a list of the five paragraphs i
11 that we were going to put in and what the issues involved l
12 were.
(
13 MR. SIESS:
No, I've read that.
And the
~i 14 implementation -- really, since this'is operational --
15 it's not quite clear from the implementation -- we put 16 through another Guide earlier that had some real strong i
17 language about this not being backfitted by reviews to is individual plants, and it's not quite clear to me looking f
19 at the implementation to what extent this is' backfit.
30 Would you like to comment on that?
It says -,
1 21 MR. HINTZE:
I think it says -- excuse me.
t l
22 Faust, did you want to --
03 MR. ROSA:
Yeah.
I can comment on-that.
q{s~}
S4 MR. SIESS:
You are the guy that will be doing '
l-
. 26 it.
4
.=-
m
r 71
- 3-13-SueW MR. ROSA:
Right.
The implementation section, g
em 2
of course, the words say, limits within technical specs for 3
all construction permit applications docketed after issue date of the Guide.
4 6
However, we have a Revision 1 of that Guide that 6
dates back quite a few years.
And when you are seeking 7
practically about implementing, there is sufficient flexibility 8
in that original Guide so that you could take this Standard g
that we are endorsing with Revision 2 and apply it under the 10 recommendations of Revision 1.
11 And that in effect is what we have been doing a
for quite a few years.
(~])
13 MR. SIESS:
Thati doesn' t mean it isn' t a backfit.
v 14 (Laughter.)
15 What does the last sentence in the implementation 16 mean?
It says:
Ilowever, the Staff does not intend to recom-17 mend the systematic application of every aspect of this Guide 18 to plants currently operating.
19 There are a couple of words in there that intrigue 20 me.
One is "to recommend" which is different than require.
21 When the Staff recommends to a licensee u.tless the backfit 22 rule is invoked, that's a requirement.
23 MR. !!INTZE:
I think that was in consideration r-24 that the Guide is just a guide anyway and not a requirement.
i
~
25 MR. SIESS:
Yeah.
And it says "every aspect."
72
- 3-14-SueW1 That does say that the Staff will or can recommend some
(.
k-?
2 aspects of the plants currently operating.
3 MR. HINTZE:
I think if there is some situation 4
that proved that, hey, if you did this the plants would be 5
safer, they wanted that option to be able to do that, but 6
not flat across-the-board requirement.
7 MR. SIESS:
It seems an awful lot of this was 8
to improve the reliability and availability of plants rather 9
than for safety.
It would help a lot of people,
10 That was approved by CRGR?
11 MR. HINTZE:
Yes, sir.
12 MR. SIESS:
And this doegn't have the boiler
/3
( _ )
13 plate like the 1.23 we just looked at.
14 MR. HINTZE:
No, sir.
They've taken a stronger 15 position since this guideline.
16 (Mr. Duraiswamy is conferring with Mr. Siess.)
17 MR. SIESS:
Yeah.
18 MR. HINTZE:
The next guide we have up has 19 the different one from what we gave you, because CRGR 20 proposed that we modify it a little bit.
It doesn' t say 21 anything.different but uses their words.
22 MR. SIESS:
What's your pleasure?: Do you want 23 to go through a couple of positions?
Or, do you want to go 24 through that list of what ended up in the discussion and what
)
25 didn't?
. -~
... ~ -
d 73 lt3-15-SueW 1~
Or, are you satisfied in looking at it de nova?
L 2
MR. WYLIE:
I'm satisfied.
3 MR. SIESS:
Max?.
4 MR. CARBON:
I think I'm satisfied.
5_
MR. SIESS:
I'm pleased to see a Guide, you know,
'6' endorse the Standard'in toto, because I think it means that 7-somewhere along the line that not just CRGR but there has 8
been: improved cooperation of the industry in writing. guide j
9 that.the.NRC can endorse in: toto.
I think this is a. healthy 1
10 situation.
11 You probably gave up something in the process, I
u somebody else did, too.
But'if you can reach agreement on a j
l- ( )
13 Standard it's a lot cleaner, and I feel a little more com-i.
14 fortable with~it.
5 I think it helps the Standard process to get i
{;
16
'the disagreements straightened out in the Standard rather l
17 than have the Staff have to come in and impose its will,
~
18 right or wrong.
19 MR. CARBON:
May I comment here?
30 MR. SIESS:
Yes, Max.
t 21 MR. CARBON:
I share that view completely.. And 22
'I would ask'you, are we correct in our beliefs, that this L
M does represent a more cooperative approach?
I i
34 Are our conclusions correct?
26 MR. IIINTZE:
The answer to that is yes.
Ed
=.
a.-
.~
74
- 3-16-SueW Winzinger was a member of the Committee that developed the
'q
,('
2 Standard, and I'm not so'sure but what he wasn't part of
-3 the reason for it being developed in the first place, stating 4
the.need for some guidance in setpoint settings and so forth.
t 5
And industry was'very willing to pick it up and l
6 go ahead and develop it.
7
'MR. CARBON:
And it truly is an example of 8-cooperative effort and everybody sort of feels good about I
9' it?
10 MR. HINTZE:
That's my feeling about it, yes, 11 sir.
12 MR. SIESS:
Let me ask you something about the
(-
13 process.
I guess Ed was the only NRC representative on 14 the Subcommittee at that time.
15 He would bring that back and it would go through 16 a Staff review, not just in Research but --
17 MR. ROSA:
Right.
18 MR. SIESS:
-- but in NRR. - And he would pass j
18F those comments back and try and get them accepted.
I 20 MR. ROSA: Yes. There were a considerable number 4
21 of iterations like that throughout the process of the 22 development of that Standard.
1 23 MR. SULLIVAN:
In fact, the Staff -- the entire
! (}
M-Staff ' participates in the members' ballots that -- by that, 26 I mean sending comments to those of us oh the Committee, and
75
- 3-17-SueW 1 then that assists us in formulating the ballots, where we
~-)
2 include the ideas as we see them properly into the ballot 3
process.
4 MR. HINTZE:
A draft standard under development
'5 gets the same Staff review as a regulatory guide under 6
development.
7 MR. SIESS:
Now, the Staff review involve inter-8 action with the man who is on the Committee so that he can 9
explain why things are there?
10 MR. SULLIVAN:
You mean the man from NRC, I take 11 it?
12 MR. SIESS:
Yeah.
(o,j 13 MR. SULLIVAN:
Well, specifically, no.
We had v
14 Ed Winzinger on.
I will broaden this a little bit.
15 Al Hintze has taken -- is taking Ed's place on 16 the main ISA Committee.
The other gentleman, Jerry Mauck from 17 NRR has been appointed to the Working Group that's working 18 on the setpoint, collectively reviewing and revising the set-19 point Standard.
20 So, there is, number one, very active participa-21 tion by the Staff in all significant aspects of Standards 22 work, not just this one.
23 And to answer the other question, there is a
( ')
24 process whereby the individual such as the gentleman that is 25 on the Working Group can send the draf t out to the Staff to
76
- 3-18-SueW 1 assist him in preparing his ballot for the Working Group vote IJ 2
as well as the Full Committee vote after the Standard has 3
been prepared to the point of being forwarded to the Main 4
Committee which Mr. Hintze is sitting on.
5 MR. SIESS:
Now, if the guy on the Working Group 6
sends something out, and he gets comments back in writing from 7
somebody that's involved, and it's something they have already 8
discussed extensively, does he sit down with that man and 9
explain why that was in there and maybe the guy withdraws his 10 concern, or does he automatically pass it on back to the 11 Full -- the Working --
12 MR. SULLIVAN:
No, it's not.
It should not be (s
(_ )
13 automatically passed on.
That's what I meant before when I i
14 used the word " proper."
15 The individual on the Committee,is supposed to, 16 let's say, process the comments from the Staff.
By that, 17 I mean not blindly send them on.
He is supposed to resolve 18 them.
And, in my own case, I have sat down'with people and 19 discussed it..
20 MR. SIESS:
Now, this kind of activity on the f
21 Standards Writing Committee takes a fair amount of time 22 and a certain amount of travel.
23 Are you getting all of the support you need from
({}'.
24 the Commission to do this?
25 MR. MORRIS:
In our branch, we do have participation
77 43-19-SueW1 in the various Working Groups and Committee, and I don't nkl 2
remember hardly any case where we haven't had enough funds 3
to support travel for that.
4 MR. ROSA:
In NRR, the situation is a little 6
different.
It varies.
A couple three years ago, we were 6
quite limited in travel money.
And we just about eliminated 7
all Working Group Standards travel.
8 Thinga have loosened up considerably since then.
9 In fact, I think this past week I've approved a couple of 10 travel authorizations for Standards travel.
11 MR. SIESS:
Now, people that serve on the 12 Standards Writing Committees, I'm sure Research has quite a 13 few, but there are people from NRR --
14 MR. ROSA:
Yes.
15 MR.'SIESS:
There are from I&E'I think.
I know 16.
some from I&E Committees I'm familiar with.
So, this does 17 cut across the Commission lines.
18 MR. SULLIVAN:
Oh, yes,-that's our intent.
We 19 try to get as broad a representation as possible.
20 MR. SIESS:
You don't have any, problems now in 21 support?
22 MR. SULLIVAN:
I haven' t per ived any.
23 MR. SIESS:
I just wondered.
I assume that at
(~}
24 the management level they understand the.importance of this, s-26 If they don't, I would like to be sure they do.
4 78
- 3-20-SueW 1 MR. HINTZE:
I ndght mention from Mr. Carbon's o
2 question that we have ' kind of an unend rule.
I guess it's 3
an unend rule.
I haven't really seen it written down, that 4
we shouldn't or can't take exception to any standard unless 5
we have written proof that we tried to get it included in 6
the Standard in the development process.
7 And if it's of sufficient importance to make it 8
part of the regulation or part of the guidance, then we can 9
take an exception to the Standard.
But if we haven't done 10 that much, we are told that we shouldn't --
11 MR. SIESS:
That is, if you have a member of the D
Working Group after consultation with the Staff has a position I
13 and he tries his best to get the Standards Committee to accept 14 it and they don't, then he would be justified --
15 MR. SULLIVAN:
I hope I understood that correctly.
16 MR. HINTZE:
I hope you did, too.
17 MR. SULLEVAN:
We are -- I may have'to contradict 18 you.
19 MR..HINTZE:
Okay.
That's fine.
~
30 MR. SULLIVnR:
We are free to include anytding 21 in a g'uide that we feel is'a safety issue, totally irrespective 22 of Standards quoting.
?
23 MR. HINTZE:
Did you say'that?
24 MR. SULLIVAN:
If we don't include it, we still --
. (g}.
38 it's preferable.
The Standards can --
l
't b
L
.1,-
79 a
MR. HINTZE:
That's not what I said.
- 3-21-SueW 3
)
MR. SULLIVAN:
Okay.
Then, I beg your pardon.
2_
MR. HINTZE:
What I said was that, Mr. Alato has 3
made itt a point to me that unless we have shown to him that 4
we have in writing taken a position on the Standard and it 5
6 didn't get in, we have no basis for taking an extra position.
Now,.that doesn't mean if you are down out and 7
8 out wrong after --
g MR. SIESS:
What I would say is first.you try 10 to get it in the Standard, if you don't succeed, you put it 11 in the reg guide.
n MR. SULLIVAN:
We can, yes.
. ()
13 liR. SIESS:
You can?
v 14 MR. SULLIVAN:
Yes.
We are not prohibited just L
15 because we didn't get it'into the Standard --
16 MR. SIESS:
No.
-- or even just because we forgot 18 to think of it at the time.
19 MR. SIESS:
Now, that latter bothers me a little 90 bit, because it sort of upsets the Standards process.
- 31 MR. SULLIVAN:. We are only human.
~
22 liR.-SIESS:
Yeah, I know it.
28 MR.~SULLIVAN:
And public safety comes first.
i.
24 MR. SIESS: 'Those are not common. -The situation l (}
m we don't want to see, I don't want to see,.is where a man L
s'a.
V, L,!.
\\,.
N Yt?
80 63-22-SueW i sits on the Standards Committee, Standards Writing Committee, kf' 2
and presumably a Concensus Standards Committee, and anything 3
that he doesn't -- that he is overruled on, he says:
- Okay, 4
I will go put it in the reg guide.
6 He has got to convince a few other people in NRC 6
whether it's important enough to put in there.
7 MR. MORRIS:
I think if I understood what Al a
said, I' don't think you could actually implement that policy e
on the whole Staff because when the, Standard is developed 10 and it's issued, and then it goes to the ACRS for review.
11 We may learn something during that review that would' include u
a position.
We go to CRGR, we go to public comment.
O.
r:-o 13 And that process could certainly provide a new
\\_-'
14 insight that would put a position in there.
15 MR. SIESS:
There are other internal NRC reviews.-
16 That's important, because what I can visualize -- and I've 17 served on committees where I would have loved to have that 18 clout, saying:
Okay, fellows, here is what I think you ought le to do.
If you don't do it, I'm.go,ing to go home and put it se in the reg guide.
21 Now, that would be a great position if I could do
~
22.
that. -Now, if-I've got to go home and convince a dozen people 23 that know as much as-I do that it ought'to beein.the reg
()
24 guide, I've got to be more careful.
~
25
.I've got'to figure if I can't convince that y
k 9
e _,,_
-t 81 3-23-SueW1 committee, maybe I can't convince these other fellows.
g# -
2 MR. HINTZE:
I was only, I guess, speaking from i
3 my own experience with Mr. Alato or maybe he didn' t have 4
any confidence in me, I don't know.
5 MR. SIESS:
No, I think it's important, because 6
unless there 'is a requirement that we be responsible for what
' 7 we put in the reg guide, nobody is going to want us to serve 8
cn1 Standards ' Committees if you are not doing any good.
1
.9-If.the NRC's position"is always going to appear 10 -
in the. reg guide, why have them sitting on the Standards 11 Committee?
A lot of the things should be threshed out in H
the Working Group.
O<:
13 MR. SULLIVAN:
I didn' t mean to ---
Q 14-MR. SIESS:
And that's the attitude most people 15 ~
take.
16 MR..SULLIVAN:
I didn't mean to imply that at all.
17 I'm saying, dhe-point-is we work as closely as we ca'n.
We i
18 are supposed to tell'the Committees' that we are working with
' 19 exactly what all our positions are so there are no surprises 30 later on.
21 we try to resolve comments.and-then that-becomes
~
7:
M' a matter of recbrd~for the legislative history of the Standard l,
23 and then that:--
)
24 MR. SIESS:.On reg guides ~--
?
25
.MR..SULLIVAN:
-- we go forward.
a 82 1
- 3-24-SueW MR. SIESS:
I'm not sure whether it was this g
l
( ;/
2 one or the other one one of the public comments says:
3 You know, this is a lousy way.
You guys are adding all this stuff in at the last minute.
You should have brought it up 4
in the Standards Committee.
5 6
And the response says:
Well, a lot of it are 7
things that nobody thought of at that time.
And we are r ot 8
bringing up stuff that should have been brought up then.
We g
are bringing up stuff that came up later.
10 And I thought it was an acceptable answer.
11 After all, anybody that writes Standards and u
takes five years to get one of them approved, if you have g3 (i
13 some way of coming up with a good idea in the last year, 14 and you can' t get it in the Standard it shouldn't be tossed 15 out.
It would be nice if it was a way to do it.
16 But I do think that the industry type consensus 17 standards are a very valuable way to reach good positions 18 and you shouldn't do anything that kills it.
19 And we are not, I'm satisfied.
20 This is proposed to go out finally.
It includes 21 no new positions.
It has changed since the last one, but 22 the changes have all been in a direction Unat has completely 23 satisfied public comments I guess.
^'
24 That's the reason it doesn't have to be re-s
~
25 issued for comment, right?
83
- SueW 1 MR. HINTZE:
I think we have taken the best 2
alternative, and that is to inform the Standards Committee 3
what the public comments were so that they can consider 4
them in the next Standard.
Yes.
5 MR. DURAISWAMY:
I think his question, however, 6
is how much is it different from the one that was issued 7
for public comment, this version, the first time you issued 8
something for public comment?
9 MR. HINTZE:
Yes, it's quite a bit different.
10 MR. SIESS:
So, it's different in the reduced 11 direction.
It has --
12 MR. HINTZE:
I think so, yes.
t i
b-4 13 MR. SIESS:
It has no new positions.
s.e 14 MR. HINTZE:
It's different in that regard, 15 there's no positions.
16 MR. SIESS:
There are three or four points for 17 guidance that are in the discussion that were in there 18 previously as positions.
There was nothing new there.
19 MR. SULLIVAN:
Right.
' 20 MR. SIESS:
And you have had all the advantages 21 from public comment you can get?
All the benefit you can get?
22 MR. HINTZE:
It went out for public comment M
with two positions and we really don't have any now.
24 MR. SIESS:
The question before the Subcommittee
~
25 -
then is whether we recommend to the Full Committee that this
84
,#3-27-SueW be issued as a final reg guide with the ACRS concurrence sVf 2
in the position.
That's all we ever concur with officially.
3 And I would propose in this case we really not 4
say anything about CRGR since what they did was not substantativG 6
in terms of public safety, but nevertheless I think it was 6
wrong.
Maybe they will read our Minutes.
7 (Laughter.)
8 We read theirs.
Any objection to that recommenda-9 tion?
10 (Mr. Wylie and Mr.' Carbon nodded in the negative.)
11 Okay.
That concludes that subject.
Does anybody 12 want the Standard back?
I hate to throw away something you
/
(
13
(_,:
paid good money for.
14 Now,'we.have another' guide, and.it's again one 15 that we've had for some time.
It was sent out -- it was 16 sent to our Electrical Systems Subcommittee to review and 17 they apparently didn't review it, or have not reviewed it.
18 We had hoped that Dr. Kerr would be here to 19 look at this thing, or that he would have looked at it.
I 20 understand that he will be in around noon time.
21 -
Since we promised him that.we would delay things 22 until he got here I would suggest that we take an hour for 23 lunch.
It's an awful early hour for' lunch.
And get back here
)
'24 about 12:30.
And I hope Kerr will be here.
And we can 25
~
then.
.take that up,
85
- 3-28-SueW 1 Okay.
We will be back at 12:30.
g'r' -
2 (Whereupon, the meeting is recessed at 11:25 a.m.
3 to reconvene at 12:30 p.m., th'is same date.)
ENDD 4
5 6
7 8
9 10 11 12 m
13
[^
14 15 16 17 18 19 20 21 22 23 n
24 tG
~. -.
~
.............. ~.. -.
5930 01 01 86
(~3 MPBagb 1
AFTERNOON SESSION
\\-)
2 (12:30 p.m.)
3 DR. SIESS:
The next subject is Regulatory Guide 4
for Task Number IC 609-5, " Criteria for Power, 5
Instrumentation and Control Portions of Safety Systems."
6 This_ guide doesn't have a number yet.
It endorses the 7
standard and we have seen a draft of it in '82 -- I'm sorry, 8
a draft was sent to us in '82 but we weren't doing many 9
Reg. Guides at the time and.I didn't see a need for a 10 meeting for this one guide that was going out for public 11 comment and we suggested that it go out for public comment 12 and in the meantime we sent a copy to the Electrical Systems
()
13 Subcommittee.to see if they wanted to comment on it during 14 the comment period, which they didn't.
So we have in our 15 package, we should have the public comments and the Staff
~
16 responses to them and some revisions to the guide based on 17 that.
18 And Bill, have.you had a chance to look at some 19 of this?
20 DR. KERR:
Yes.
21 DR. SIESS:
Okay.
We have a copy of the Standard 22 IEEE 603-80.
Is that right?
23
.MR.
SULLIVAN:
That's correct.
24 DR. SIESS:
Okay.
)
25
.And we have a couple of additional items that l
' ACE-FEDERAL REPORTERS, INC.
5930 01 02 87 7~ 9 MPBagb 1
have been passed out.
One is a revised -- or some revisions V
2 to the implementation to get out the part that goes out for 3
public comment updated.
And the second item then I guess is 4
the CRGR and this is what?
Is this part of the guide?
5 MR. HINTZE:
That is really a Xerox of one of the 6
pages in the standard.
I just passed it out with the 7
highlight to show the scope of 279 and the scope of 603.
8 That is just for discussion right now.
9 DR. SIESS:
Okay, fine.
10 DR. KERR:
Are you talking about the section 11 labeled " Implementation?"
12 DR. SIESS:
Yes.
()
13 DR. KERR:
What Sam sent me?
I have something 14 else.
15 DR. SIESS:
This is a replacement.
16 Now with that introduction, I think we will let 17 the Staff give us the story.
18 MR. HINTZE:
Okay.
I will try and not repeat
[
19 what you said, Dr. Siess.
Revisions of the guide encompass 20 the position of 279 and as far as IEEE is concerned, it 21 replaces this -- the standard replaces 279 and so I pass 22 that sheet out which is in the standard but just to show the 23 scope of 279 and the scope of 603.
24 DR. SIESS:
This whole thing is 6037 c+
t
( )
25 MR. HINTZE:
Yes, sir.
ACE-FEDERAL REPORTERS, INC.
.m,,,- e -
x,. :_u. c_...
L
5930 01 03 88
(~*)
MPBagb 1
DR. SIESS:
And that was the old 279?
V 2
MR. HINTZE:
That's it.
3 We think this guide is important because it I'
4 covers now the whole safety system and not just the 5
protection systems; 279 covered them.
Using this guide will 6
provide design criteria for the complete safety' system 7
within the umbrella of one document.
8 DR. SIESS:
Excuse me.
9.
MR. HINTZE:
Yes, sir.
10 DR. SIESS:
Did.you have a Reg. Guide endorsing 11 2797 12 MR. HINTZE:-
No, it was put into the regulations
()
13 before Reg. Guides were started.
Had we been making 14 Reg. Guides, I believe that it would have been a Reg. Guide 15 rather than --
16 DR. SIESS:
279 is two separate versions?
17 MR. HINTZE:
There are two separate versions, 18 yes.
i 19.
DR. SIESS:
Okay._
Please go ahead.
20 MR. HINTZE:
A draft copy of this proposed --
21 well you already stated we sent it to you and you ' decided 22 that it should go out without your review.
-23 During the public comment period there were 14 24 letters received from 13 dif ferent commentors:
eight were
()-
25 from utilities, three from technical societies, two-from-f ACE-FEDERAL-REPORTERS, INC.'
.a n-
...: =
=
=
l 5930~01 04 89
{
MPBagb 1
A&E firms and one from the manufacturer.
There were no 2
stated objections to the issuance of the guide.
All 3
comments were suggestions for clarification.
The most 4
frequent comments were, number one, the most frequent one 5
was the guide should reflect issuance of the qualification 6
rule. -There was a position in the For Comment Guide that 7
had a lot of instruction as far as qualification goes and 3
8 they said why is that necessary?
So we took that out of the 9
guide.
10 There was a conflict between one of the Staff 11 positions in the guide and Regulatory Guide 1.47 and we have 12 taken that position out.
()
13 There were comments that the backfitting should 14 be made more clear.
We think we have done that by a 15 different implementation statement.
16 And there were comments that the modified Figure 17 7 still had a problem.
The Figure 7 in the standard was 18
' ambiguous.
The' Figure 7 that was put into the guide to 19 replace it still needed further clarification.
And we have 20 done that by providing a different Figure 7.
21 DR. KERR:
This is the one that was in what
'22 Sam --
23 MR..HINTZE:
That's in'the one that we:now 24 propose, yes.
( ).
25 DR. SIESS: -That has been issued by whom?
ACE-FEDERAL' REPORTERS, INC.
5930 01 05 90
}
MPBagb 1
MR. HINTZE:
That came from the IEEE working
/
2 group that developed the standard.
3 DR. SIESS:
That is to go in the guide?
4 MR. HINTZE:
That will be in Position, I think, 4 5
or 5 of the guide, yes.
6 DR. SIESS:
So in effect you are doing -- you are 7
helping the Standards Committee by providing that?
8 MR. HINTZE:
Yes.
9 DR. SIESS:
They have no way of doing it --
10 MR. HINTZE:
Without revising the standard, which 11 we are in the process of doing.
But we cannot get the guide 12 out faster waiting for the revised standard.
p) 13 We believe that we have resolved all of the
(
14 public comments to the satisfaction of the commentor.
The 15 guide has been prepared in comparative text to using the For 16 Comment issues as a base with the script type.
It shows the 17 additions -- or the line out shows the deletions from the 18 Before Comment Issue.
Just to now go over what changes have 19 been made now since the For Comment Issue --
20 DR. SIESS:
Let me make a comment.
I was pleased 21 to see that the discussion addresses each position by 22 number.
23 MR. HINTZE:
Thank you.
24 DR. CARBON:
And before you go on, I have another n
! )
25 question about public comment, specifically, the letter s,
ACE-FEDERAL REPORTERS, INC.
.m,,,,,,m e.:~~...
-,,,,, ~
5930 01 06 91 r~1 MPBagb 1
from Wisconsin Public Service where they talk about the NRC L) 2 representatives from the IEEE Committee not apparently 3
bringing up objections.
Is that taken care of now by the 4
admonition you state you received this morning?
5 MR. HINTZE:
I thought we responded quite 6
detailed to that comment.
7 DR. KERR:
Any resemblance to an NRC position or 8
position representative is purely coincidental.
9 MR. HINTZE:
We didn't answer your question 10 directly.
11 DR. SIESS:
No, but they responded to it in the 12 response to public comment.
Did you read that?
fl 13 DR. CARBON:
I missed that.
v 14 DR. SIESS:
I will find it for you.
I think ie 15 is on page six.
They give a really good response to that.
16 MR. HINTZE:
Okay.
Starting with the For Comment 17 Issue, the position number one of that issue was slightly 18 modified and we now find it as position number two to the 19 new draft.
20 Position two was deleted.
This was the position 21 that talked about the qualification and that has been found 22 unnecessary and has been deleted.
23 Position three was also deleted because it was 24 redundant with the current position five.
This had to do
,()
25 with the reference standards that were within the body of ACE-FEDERAL REPORTERS, INC.
,m u-um u., _ a,c m,...,
mu -
~.
1 i
5930 01 07 92
(~ ;
MPBagb 1
the standard itself.
,.J 2
Position four was deleted.
This was the conflict 3
between 1.47, Reg. Guide 1.47 and the standard which we 4
eliminated conflict by eliminating the position.
5 Positions five and six were deleted.
These 6
positions in the For Comment Issue were merely 7
cross-referencing different sections of the standard which 8
were really not necessary; the standard stands by itself.
9 Position 7 was the modified figure and it now 10 shows up as position four with the new figure.
11 DR. KERR:
Excuse me, from what are you reading?
12 Are you reading from the discussion for public comment
~
()
13 document?
14 MR. HINTZE:
No, I am just reading from my notes 15 here.
What I was attempting to do is go through the 16 positions that were in the For Comment Issue --
17 DR. SIESS:
You should be looking at the guide 18 starting on page six, Bill.
19 DR. KERR:
Okay.
That is entirely logical.
I 20 wasn' t sure where we were.
21 MR. HINTZE:
I'm sorry, I should have made it 22 clearer.
23 We have a new position one now which is added for 24 clarity, just to clarify the terms that have been used in (m) 25 the regulation process and in the --
ACE-FEDERAL REPORTERS, INC.
initAtt7fYi N11rinnwide Inurrnor M 11 M.
5930 01 08 93 1
DR. SIESS:
Now that says that the safety system
}
MPBagb
/
2 is one that is safety-related, not one that is important to 3
safety.
4 MR. HINTZE:
Yes, sir.
5 DR. SIESS:
This is a narrower definition.
6 MR. HINTZE:
Yes, sir.
7 DR. KERR:
On page five, I think, of the same 8
thing you are reading from --
9 DR. SIESS:
No, five is a discussion.
10 DR. KERR:
I am unable to address the issue I 11 want to address unless I also look at the discussion.
12 DR. SIESS:
Okay.
(Ol 13 DR. KERR:
-- if that is forbidden, I will....
14 DR. SIESS:
No, no.
15 DR. KERR:
Under discussion I find the term 16
" safety system" and the term " safety related" ar. it pertains 17 to systems are logged separately and it is essential in 18 applying the terms that the relationship of the terms be 19 understood.
20 Now in the position it seems to say that the 21 safety system and safety-related systems are synonymous.
22 Why doesn' t it say that in this same -- is this supposed to 23 mean the same thing?
24 MR. HINTZE:
Well what we are trying to do is
'[ [1 25 justify the position in the position section without stating ACE-FEDERAL REPORTERS, INC.
,n, m rmn m,m., m,c m....,
m-
i 5930 01 09 94 1
(~}
MPBagb 1
what the position was, I guess.
j t./
2 DR. SIESS:
If you would read these --
3 DR. KERR:
If I would thoroughly understand it, I 4
would understand that they mean the same thing?
5 DR. SIESS:
Right.
6 MR. HINTZE:
Yes, sir.
7 DR. SIESS:
Bill, if you would read the positions 8
first and the discussion next it would be easier.
9 DR. KERR:
I read this first and this and then I 10 read this and then I read that.
11 DR. SIESS:
I know.
12 MR. HINTZE:
If we would follow Dr. Siess'
,s
(
)
13 recommendation, the discussion would be after the position 14 section.
We appreciate that.
15 DR. KERR:
The discussion section seems to imply 16 that there is some hidden meaning which one might miss if 17 one just assumed they meant the same thing.
18 MR. HINTZE:
Well okay, we are advised that we 19 shouldn't use the word "should" in the position section --
20 in the discussion section, excuse me.
So we have to make a 21 discussion that doesn't state a position, we just tried to 22 justify it.
23 DR. SIESS:
I think Bill's point is -- I think 24 their point is that safety system is not a term used by NRC (j
25 and they wanted to relate the safety system term that IEEE ACE-FEDERAL REPORTERS, INC.
-e.-,.
m..._
_.a. c_....._.
-m-
l
'5930 01 10 95
{
MPBagb l'
used to one of the terms that the NRC uses.
Safety-related 2
has a very specific definition.
3 DR. KERR:
Would it violate NRC protocol to put a 4
parentheses after that that says see position one for NRC's 5
definition?
6 DR. SIESS:
Well that's obvious, because it says 7
we are going to discuss each one of them.
8 DR. KERR:
I'm sorry, it was not obvious to me.
9 This says it is essential that the relationship of the terms 10 be understood, 11 DR. SIESS:
But that's a discussion of the 12 regulatory position.
The trouble is if you read the
()
11 3 discussion before you read the position it confuses you.
14 DR. KERR:
I understand your point, 7 just happen 15 to disagree with it.
16 DR. SIESS:
Well you wouldn't disagree with the 17 argument that the position ought to come first and after you L
18 read that --
i 19 DR. KERR:
I wouldn' t agree with anything if the i
i 12 0 discussion wasn't there at all.
Presumably the discussion 21.
is there to clarify things.
'22 DR. SIESS:
No.
23 DR. KERR:
What I'm saying is in my mind it l
.4 didn't clarify things, but that may be a very personal 2
- h 25 thing.
l ACE-FEDERAL REPORTERS, INC.
m, u,
,,,m
- m.,
m c-
-m.~
L
5930 01 11 96
( ~
MPBagb 1
DR. SIESS:
But would it have been clearer if you
)
2 had read the position first and then -- this is the reason 3
why they felt they had to put the position in.
4 DR. KERR:
No, because it seems to me the 5
position is very clear, it says they mIean the same thing.
6 DR. SIESS:
Yes.
But now why do they have to say 7
that?
That's what they are trying to justify.
8 MR. DURAISWAMY:
It is a justification.
9 DR. SIESS:
It is a justification rather than an 10 explanation.
11 MR. DURAISWAMY:
The definition should be 12 understood, (o) 13 DR. KERR:
It is clear that that is going to 14 cause nobody a problem but me, and under the 15 circumstances --
l 16 DR. SIELS:
Well it causes me a problem but for 17 different reasons.
18 DR. KERR:
So I now understand what is meant.
'19 DR. SIESS:
I will help you a little bit more.
20 We don' t have to approve anything but the positions.
21 DR. KERR:
I am just trying to simplify it.for 22 the people who have to interpret this and use it, Chet.
23 DR. SIESS:
Look, I agree with you, Bill.
I 24 think it is the wrong way to go about it.
I always read the
,m()
25 positions first and then I go look for the discussion ACE-FEDERAL REPORTERS, INC.
e_.:_m_r_.____
m m,,,,
5930 01 12 97
(^}
MPBagb 1
relating to the position.
That's why I congratulated that a R.;
2 number of them are the same.
I can now find them.
All 3
Reg. Guides don't do that.
4 DR. KERR:
I'm not trying to be critical here.
5 I'm just saying to me it was somewhat ambiguous, it may not 6
be for anybody else.
7 MR. HINTZE:
I think perhaps we can straighten it 8
out with no problem.
9 DR. SIESS:
You can straighten it out by saying 10 since these have evolved separately we consider it important 11 to point'out that they are synonymous in this instance or 12 something.
()
13 MR. HINTZE:
Yes, I think we can do that with no 14 problem.
15 DR. SIESS:
You can combine your justification 16 with the reason, the position, I don't know how far you can 17 go with that.
18 MR. ROSA:
You can probably put that one sentence 19 paragraph on the bottom of page four, just preceding the 20 discussion.
21 DR. SIESS:
It ought to be tied to one, it ought 22 to be tied to one.
23 MR. HINTZE:
We can add to the end of that this 24 relationship is defined in position one.
Would that help?
- 8()
25 DR. KERR:
It would help me.
ACE-FEDERAL REPORTERS, INC.
,m,,,-,,m m,.m
_ a. cm......,
m-
.a..
5930 Ol'13 98
(~~ T MPBagb 1
DR. SIESS:
Are you going to do that to each one L) 2 of them?
Each discussion is corresponding to the part of 3
the position.
4 MR. HINTZE:
If that would help I wouldn' t see 5
any reason why we couldn't do it.
6.
DR. SIESS:
I think it is editorial.
Bill Kerr 7
says he understands it now.
8 MR. HINTZE:
Okay.
9 DR. SIESS:
This happens all the time if you read 10 these things straight through, you read a discussion and you 11 really don't know what it is discussing.
12 DR. KERR:
The only reason I commented was
()
13 because I found -- when I write something I thoroughly 14 understand it.
Frequently when other people do, they 15 don't.
And I just wanted to point out that to me this one 16 was a little ambiguous and look at it and if you think it is 17 not....
18 DR. SIESS:
If I know what the position is, you 19 can start off the statement here in the discussion by saying 20 the definition of safety system as being synonymous with 21 safety-related has been included because and then go on with 22 that sort of thing and the*. would_get you out of that.
In 23 other words, you sort ~of restate what the position is and 24 then explain it.
And if you-will read the discussion first,
()
25 you sort of know it.
ACE-FEDERAL REPORTERS, INC.
.J
..; ~ >
5930'01 14 99 i
[
MPBagb 1
MR. HINTZE:
Okay.
I think we can do something V) 2 to make that a little better.
3 DR. SIESS:
That wasn't in there to begin with, 4
right?
5 MR. HINTZE:
No, sir.
6 DR. SIESS:
Did this get put in because of all of 7
the safety-related -- important to safety discussion that 8
has come along?
9 MR. HINTZE:
That was part of it, yes.
Part of 10 it was we were interfacing with the committee.
I met with 11 them to....
12 DR. SIESS:
Why would the committee not have
()
13 adopted the same terminology they have always used?
14 MR. HINTZE:
I don't know.
15 MR. SULLIVAN:
The companies' -efforts have 16' evolved somewhat separately.
They are an indenendent 17 group.
For example, we refer to nuclear power plants, they l
18 refer to nuclear power generating stations.
I think it is 19 all evolutionary.
For example, we started years ago with 20 protection system, then we had tc expand and we gave it a i
i 21 name -- we and the committee gave it a name, safety system.
22 Then the regulators -- regulation developed something called 23 safety-related.
I think.there is a. separate path of 24 evolution, b'ut I think these terms have in fact come n
25 together as we point out in here.
ACE-FEDERAL REPORTERS, INC.
~
5930 01 15 100 1
MR. HINTZE:
We haven't been exactly clear in our
[ }
MPBagb 2
language either, all the time.
3 DR. SIESS:
That's correct.
4 MR. HINTZE:
That's an understatement, I 5
suppose.
But in the process of making sure that we could 6
make this statement that these two were synonymous, thanks 7
to word processors, I was able to go through the regulations 8
and find out if there were any places where we used the 9
words safety system.
The answer was yes, there are eight 10 places in the regulation where safety system is used.
And 11 in every place that we used the term safety-related, it 12 would have fit properly.
So we have used the term safety
<s( )
13 system.
It isn't quite as common as safety-related.
14 DR. KERR:
Is there any easy way to distinguish 15 between safety system and protection system?
16 MR. SULLIVAN:
Yes.
The protection system is a 17 subset of the safety system, as is indicated on the drawing 18 with the yellow marker on it.
I don't know how many people 19 have copies of the one with the yellow pencil, but thic is 20 in the standard, page 12 without my glasses -- yes.
21 DR. KERR:
The same with your glasses.
22 MR. SULLIVAN:
The same with my glasses, too.
23 The upper corner is the scope of the protection system or, 24 more accurately, the scope of the standard that covers the 25 protection system.
The protection system is that small
(,)
i l
ACE-FEDERAL REPORTERS, INC.
5930 01 16 101 MPBagb 1
part.
It is the instruments and signal conditioning 2
equipment, amplifiers and such that go to the input to the 3
actuators, say, down to the contactor coil but not the 4
contactor per se.
5 DR. KERR:
So it is an arbitrary definition.
6 MR. SULLIVAN:
Oh yes.
7 DR. KERR:
That separates safety -- the 8
protection system from the safety system.
9 MR. SULLIVAN:
Well a protection system is part 10 of the safety system, it is a subset of the safety system.
11 DR. KERR:
Okay.
12 DR. SIESS:
In order to be clear, Bill, it has to I)
13 he arbitrary.
U 14 DR. KERR:
I was not using the term 15 pejoratively.
I was just saying one has to see the table in 16 order to be' -- you couldn' t say here is the way I make a 17 choice, you have to know what choice has been made.
18 DR. SIESS:
Rig ht.
19 MR. HINTZE:
Okay.
20 To further explain, that is the new position one.
21 The new position three was added to correct an 22 error in the standard.
We object with IEEE, they tried to 23 copy from 279 une of the p.ovisions of the standards or one 24 of the requirements and in the process of copying somehow
( 'j 25 they got it garbled.
It is perfectly logical the way it ACE-FEDERAL REPORTERS, INC.
?D7 W47m Nationmide Coverane 800 336-fi646
5930 01 17 102
( 'l MPBagb 1
reads but it isn't correct and so we are helping them out by V
2 adding that position to clarify that.
3 DR. SIESS:
And this is where CRGR said you were 4
using a position that contained a typographical error?
5 MR. HINTZE:
But it was a substantive 6
typographical error.
7 DR. SIESS:
It says to detect the event and limit 8
the consequences.
9 MR. HINTZE:
Right.
10 DR. SIESS:
And this is just a limit, purely 11 substantive.
12 MR. HINTZE:
That's correct.
()
13 DR. SIESS:
Now all that stuff you left out in 14 Old Two?
15 MR. HINTZE:
Old Two is qualification that was 16 covered oy the qualification.
17 DR. SIESS:
Okay.
18 MR. HINTZE:
The new position five has provided 19 kind of a boilerplate statement on regard to reference 20 standards.
21 DR. SIESS:
Four is the figure?
22 MR. HINTZE:
Four is the figure, yes.
23 DR. SIESS:
Five was boilerplate, right?
24 DR. KERR:
What is five?
It isn't clear to me (j
25 what guide five provides except to say that there are some ACE-FEDERAL REPORTERS, INC.
,m m,-
m, _ a,c m....,
m-
A930 05 01 103
~ 's MPBagb 1
reference standards which haven't been approved by NRC.
(G 2
DR. SIESS:
No, it says endorsement of this 3
standard does not endorse the standards it references.
4 5
6 7
8 9
10 11 12
^
/
')
13 V
14 15 16 17 18 19 20 s
21 22 23 24
/~
()
25 ACE-FEDERAL REPORTERS, INC.
SA* 1A9 1*An NotinnwiA, enuarna, SAfL11LAKAA
~... -.. = -.
l i
5930 02 01 104
/~l MPBmpb 1
MR. HINTZE:
It is essentially to prevent a V
2 blanket endorsement.
3 DR. KERR:
That may be what it is meant to say,'
4 but that isn't what it says.to me.
5 MR. MORRIS:
It says.more than that.
I think it 6
says in addition where they'are included, where we haven't 7
got reference standards you use this standard in conjunction 1
8 with them.
You should use them in a manner consistent with 9
current regulatory practice.
10 There may be a rule --
11 DR. KERR:
Is it clear what that means?
4 12 MR. MORRIS:
It just says that.
That's not what
()
13 it says, but it is slightly more than what was just stated.
14 DR. KERR:
No, I agree.
In fact, I don't think 15 it said what Chet said at all.
16 DR. SIESS:
No, I agree with you, Bill.
17 What it says is some of the standards that are 18 f
referenced are standards that are endorsed by a RegGuide and 19 probably modified with exceptions.
The other standards that' '
i 20 haven' t been endorsed by a RegGuide may or may not be in i
21 accord with regulatory _ practice.
We haven't issued a 22
/RegGuide to tell you the extent to which they have.
So it
.i 23 is a warning.
4 24 MR. HINTZE:
It is a warning essentially.
Before (3
(_j 25 we used to just blanket and throw them out.
And --
-t g
-ACE-FEDERAL REPORTERS, INC.-
m______.a,_..___
- m uu
~.
v l
5930 02'02 105 i
1 DR. KERR:
I'm trying to understand how a person
{ }
MPBmpb 2
-uses it.
3 He says,
'I'm using it in a manner consistent 4
with current regulatory practice,' and you come back and you c
E 5
- say, Uh-uh, you aren't.'
Who wins the argument and on what-6 basis.
7 DR. SIESS:
You' re not serious, are you?
You 8
know who wins the argument.
9 DR. KERR:
Supposedly this is here to give 10 somebody'an idea of what the NRC position is.
Me, I would-4 11 interpret this position as saying if it hasn't been endorsed 12 you had better come to us to. find out what our position is.
- ()
13 But instead of that --
14 MR. HINTZE:
I thi nk that's fair.
15 DR. KERR:
Is that-what is meant by "not f
16 inconsistent with current regulatory practice"?
17 1CR. ROSA:
Well, given a standard that is not 18 endorsed, - if it is applied its application must be in accord 19 with whatever criteria and guidance and requirements that 20 -
are presently on the books in the standard review plan.
1 21 EDR. SIESS:
And absent the regulatory guide, 9
22 those aren't spelled out in any one place.
'23' MR. ROSA:
That's right.
24 DR. ' CARBON:
That seens'so obvious, why put this j_
()
25 paragraph in here?
i-l ACE-FEDERAL REPORTERS, INC.
~~-
i
.s J
5930 02 03 106
/~)
MPBmpb 1
DR. SIESS:
Because they used to have one that
-L) 2 said they don' t apply.
3 DR. CARBON:
Well?
4 DR. SIESS:
This says they may be good standards
' hey may not be completely in accord with regulatory 4
5 but t
6 practice, and you have got to use them with care.
7 DR. CARBON:
It says the same thin'g.
8 MR. ROSA:
There-are_a lot of standards that d
L 9
contain very good engineering practice.
And we encourage 10 their use even though we don' t endorse the particular 11 standard.
12 DR. CARBON:
I don't think this says anything but,
()
13 what people already know and expect.
j y
14 DR. SIESS:- I think if you left it out, after 15 having put it in a lot of other RegGuides, what kind of 16 problem would that cause?
17 DR. CARBON:
Well, that'1 a different an'swer.
18 MR. WYLIE:
Well, if you don't say something, 19 aren' t you endorsing - those standards that are referenced?
20 MR. SULLIVAN:
That's the ' whole problem.
21 MR. WYLIE:
That's ' the reason you put it in 22 there.
23 MR. SULLIVAN:
Not only that, but we are endorsing the references i,n thh references, ad infinitum.
24
()
25 DR. CARBON:
I don't see that.at all with this t
ACE-FEDERAL bPORTERS, INC.i m _.. _ __ m_ c__ _ _
m
t a x,;
-i j
0.4 5930 02 04 107 MPBmpb 1
wording here.
2 MR. WYLIE:
Well, you see the reference -- In the 3
standard they are referencing all these standards without 4
any explanation.
And'I think what they're saying here is, 4
5 okay, this contains good information; but if you use it you 6
had better be careful and find out what is an acceptable 7
position.
8 DR. CARBON:
Well, isn't that just common --
9 DR. SIESS:
No, no.
10 DR. KERR:
You consider this information 11 providing some guidance to somebody?
12 MR. WYLIE:
Yes.
I think it is a flag.
' ()
13 DR. KERR:
Okay.
14 MR. WYLIE:
And if you don' t put it in I think in 15 essence then you are endorsing these references.
16 DR. KERR:
No.
17 You see, I would understand a sentence that said, 18 "Those reference standards ~not endorsed by a regulatory 19
' guide are not approved by this RegGuide."
If it said that I 20 would understand that.
MR. MORRIS:- But if you did just that then you 21 22 would leave in doubt what is the designer to do about the 23 use of those standards which are included in this, j
24 EDR. KERR:
But you still leave that in doubt n
(_)
25 because you say " consistent with current regulatory l
- ACE-FEDERAL REPORTERS, INC.
4eu
- -.. ~ - -..
5930 02 05 108
{'s}
MPBmpb
?
1 practice."
When I asked what that was I got the answer it s
2 may be a decision; that that means come and tell us what you 3
plan to do and we will tell you whether it is in accord with 4
current regulatory practice.
5 DR. SIESS:
Well, a lot of designers will know 6
already.
7 DR. KERR:
Well, I defer to Mr.-Wylie.
He thinks 8
it is useful guidance, and he sure knows a lot more about 9
this than I do.
10 DR. CARBON:
I agree because I think the 11 paragraph really doesn't do any good.
12 MR. HINTZE:.Does it do any harm, do you think?
()
13 DR. CARBON:
No 14 MR. HINTZE:
Okay.
15 DR. CARBON:
Well, it is more paperwork.
16 DR. SIESS:
When people use standards they tend 17 to use everything in them.
18 MR. HINTZE:
Okay.
That takes care of the new 19 positions.
20 Now there are a couple of changes that are in the f
21 guide, and I think I should mention the new implementation f
22 statement --
23 DR. SIESS:
Before you get to that, whatLabout 24 the things.you took out?
What about the old four?
()
25 MR. HINTZE:-
The old four.
The old four created
. ACE-FEDERAL REPORTERS, INC.
muuw w.
=um c_.
mw-m
5930 02 06 109 (J
MPBmpb 1
a conflict between the standard or the guide and 1.47.
1.47
~T 2
requires bypass indication at the system level.
This was 3
sent up the channel.
That was a conflict and we just took 4
it out.
5 DR. SIESS:
And five?
6 MR. HINTZE:
Five cross-referenced different 7
sections of the standard itself.
It said consider this, 8
consider this.
We thought that was really not necessary.
9 The standard stands by itself without us telling them how to 10 use it.
11 DR. SIESS:
Six was the same thing?
12 MR. HINTZE:
Yes, sir.
('%;
13 DR. SIESS:
Seven just added a number?
m-14 MR. HINTZE:
That's correct.
15 DR. KERR:
Are we discussing seven?
Because if 16 we are, I want' to --
17 DR. SIESS:
We are discussing -- The old seven or 18 the new seven?
19 MR. HINTZE:
There is no new seven.
It is the 20 old four -- new four, excuse me.
21 DR. KERR:
When we get to it I want to ask a 22 questien _ about Figure One which replaces Figure Seven.
This 23 may not be the time to do it.
24 DR.'SIESS:
This is the time to do it.
(m_)
25 DR. KERR:
I just wanted to see if I understand ACE. FEDERAL REPORTERS, INC.
l 5930 02 07 110
. /~l MPBmpb 1
it.
LJ 2
You start with postulating a credible event and j
3 then you ask yes or no.
We get down to 'Does originating I
4 event or its consequences also prevent protective action in 5
the facility.'
6 Now I assume that's an undesirable situation, 7
isn't it, if the answer is yes?
I'm talking about the new 8
one.
9 MR. SULLIVAN:
Well, maybe we can answer the 10 question by explaining what was wrong with the original i
11 one.
Would that -- No, we don' t want to do that.
12 DR. KERR:
I don't know.
()
13 If the answer is yes, that situation is 14 undesirable, isn't it, the answer to this diamond right 15 here?
16 (Indicating.)
17 MR. SULLIVAN:
Yes, the bottom diamond does all 18 of these bad things, yes.
19 DR. KERR:
But following, I find some 'This is a 20 design basis event and all criteria of this document shall 21 be met.'
22 Now does that mean that if you meet the criteria 23 of the document it is still okay to have a credible event --
24 MR. SULLIVAN:
No.
It means that if the
(~%
(_)
25 circumstances occur, you meet all of the requirements for ACE-FEDERAL REPORTERS, INC.
, c__
m-
5930 02 08 111
('l MPBmpb 1
the document -- but including 6311 and 6322, which have to V
2 do with the application of diversity.
In other words, this 3
delineates the common mode failure required in the 4
application of diversity, not merely the application of a 5
single random failure criteria.
That's what that means.
6 That's really what that means.
7 DR. KERR:
Does it in effect mean that if you 8
find a credible event that produces the diamond --
9 MR. SULLIVAN:
Produces all of these things, 10 right.
11 DR. KERR:
-- you have to go back and change 12 things so it won't?
f)
13 MR. SULLIVAN:
- Right, w/
14 DR. KERR:
The rectangle doenn't say that to me.
15 But maybe if I understood the implications it would.
16 It sort of seems to say it's okay to have that as 17 long as you know it is a design basis event and it meets all 18 the criteria of this document.
19 MR. SULLIVAN:
It say that the designer, in doing 20 his analysis of this scenario, can determine that, yes, 21 these channels are liable, these four channels, identical 22 channels, are liable to common mode failure with all of 23 these things here -- also meaning they are tied into a union 24 of control and safety -- then he must design with diversity, s
(. )
25 which is really what it says.
These apply.
ACE-FEDERAL REPORTERS, INC.
if1S_id?_17tY)
NarinnwiAs enuarne, etYLitA u aA u
5930 02 09 112
(~]
MPBmpb 1
MR. HINTZE:
He goes back to square one.
J 2
DR. KERR:
But then if he does that he won't get 3
a yes for that diamond, will he?
4 MR. WYLIE:
That's right.
5 MR. HINTZE:
That's right.
He's going to end up 6
over on --
7 DR. KERR:
You see, the thing that had me puzzled 8
was it almost seemed --
9 MR. SULLIVAN:
Yes, he would because it would be 10
-- it would prevent protective action, and the protective 11 system was designed to provide principal protection.
That 12 is the four non-diverse channels, the original channels.
He
()
13 now has to put in four backup channels.
14 DR. SIESS:
But what you're saying is that the 15 design at some point has to end up over here.
16 MR. HINTZE:
That's correct.
17 DR. SIESS:
If it ends up at the bottom you go 18 back and change something.
19 MR. HINTZE:
Start over again if you end up down 20 here.
But if you end up over here you're okay.
21 DR. SIESS:
Now what Bill is concerned with is 22 this seems to say, okay, it is all right if you end up down 23 here as long as you have met the requirements of this 24 document.
And that is not what you mean.
(.)
25 MR. SULLIVAN:
I'm not sure.
ACE-FEDERAL REPORTERS, INC.
muu,m mma, c-m.,
muum
5930 02 10 113
(~}
MPBmpb 1
MR. MORRIS:
You can either -- This is a process
\\_-
2 for evaluating the design.
3 DR. SIESS:
Yes.
4 MR. MORRIS:
When you go through this process you 5
will either find out that criteria -- that you will have j
6 no's on all the arrows pointing to the right and you will 7
wind up in that rectangle over there.
If instead you wind 8
up finding a yes for this question in the lowest diamond you 9
wind up applying all the criteria of this document with 10 particular attention to these subjects.
That's what it 11 says.
12 DR. SIESS:
And if you apply all of those you es()
13 won' t end up down there.
14 MR. SULLIVAN:
That's right.
15 MR. MORRIS:
Yes.
16 MR. SULLIVAN:
At least that's the way I 17 interpret it.
18 MR. HINTZE:
That says you have to go back and 19 redesign until you don't end up there.
~
20 MR. MORRIS:
I guess I interpreted this to mean 21 that you have to define the design basis event to include 22 all the causal events that occur with it.
23 That is, if there is a broken pipe and that 24 causes you to get an inaccurate reading in one of the s
l (,)
25 impulse lines attached to that pipe, that you have to l
ACE-FEDERAL REPORTERS, INC.
,,,,-nn u..,.. a. c _.....
amnum
5930 02 11 114
}
MPBmpb 1
monitor that accident and detect it and respond to it, still 2
taking the single failure criterion --
3 DR. KERR:
Let me see if I understand what it 4
says in non-standard language.
5 Suppose that I put in that rectangle the 6
following sentence:
7 "This is unacceptable.
Go back and 8
redesign so this won' t occur."
9 Is that what is -- I'm not suggesting that 10 language be used; but is that what is meant?
11 MR. SULLIVAN:
What it says is if you wind up 12 losing the primary or principal channels then -- you are
( ')
13 that far in your analysis -- you must then meet the analysis 14 of 6312.
That says you must provide additional channels, 15 alternate backup channels that won' t be f ailure events.
16 DR. CARBON:
Excuse me.
Would you answer his 17 question yes or no?
I would like to know the answer to it.
18 MR. SULLIVAN:
You can get down here --
19 DR. CARBON:
Yes or no?
20 MR. SULLIVAN:
Have him state his question 21 again.
22 DR. SIESS:
If you get down to there, down to the 23 square -- the original one was much better.
If you got down 24 to the bottom it says do one of the following.
That means p) 25 change the design.
And this doesn't say do one of the
(
ACE-FEDERAL REPORTERS, INC.
w.wmnn n im m iae co m - e muwa
5930 02 12 115
'~ 3 MPBmpb 1
following; it has got some fancy language, w) 2 MR. SULLIVAN:
Well, you could still have a 3
system where you had the two sets of channels, the diverse 4
channels, and in fact get in a real reactor, get the 5
scenario that does exactly this, and you would wind up 6
depending on the diverse channels.
I think you can get into 7
this.
This is a design requirement.
8 MR. MORRIS:
You can get in here.
9 I think the thing that bothered me about it is 10 that you don' t necessarily have to change the design.
You 11 simply go and find out whether you meet the criteria 12 specified here.
()
13 It may be that you could have an event such that 14 this occurs and you still may meet the requirements of this 15 standard -- with particular attention to these two criteria 16
-- without going back and redesigning the system.
That's 17 the thing I wanted to stress.
18 DR. SIESS:
Now would you say if you end up in 19 the bottom box you must have a design that meets those 20 criteria; and if the design meets those criteria you would 21 expect the probability to be significantly decreased?
Is 22 that right?
23 MR. SULLIVAN:
The probability of an uncontained 24 accident.
In other words, you could --
(m()
25 DR. SIESS:
In other words, you would be getting ACE-FEDERAL REPORTERS, INC.
HM 117 17(n hlntinnwirls (1wernor M11dL66M
r_...__
'5930 02 13 116
~1 (G
MPBmpb 1
down here?
2 MR. SULLIVAN:
No, not really.
3 MR. MORRIS:
I think what it says is if you meet 4
-the criteria then it is acceptable to get here.
5 Dr. Kerr suggested that this was an undesirable 6
situation, but it-is not necessarily an unacceptable 7
situation in the bottom line.
8 DR. SIESS:
Why is it acceptable?
9 MR. SULLIVAN:
Well, acceptable is a relative 10 term.
But it is a last ditch acceptable.
It is acceptable 11 because you have the diverse channels to stop the 12 excursion.
.( )
13 DR. SIESS:
It is a lower probability of getting 14 there.
15 MR. SULLIVAN:
Of getting -- Not of getting the 16 excursion,-but of getting any damage.
17 DR. - KERR:
Okay.
Now I think I understand what 18 you're saying.
19 DR. SIESS:
All diversity will do is reduce the 20 pr bability.
21 MR. SULLIVAN:
The probability of what, sir?
22 DR. SIESS:
Of having failure of some sort.
23 MR. SULLIVAN:
Of having an uncontained 24-transient.
fs(,)
25 I'm thinking, for example, of a Surbo system on a ACE FEDERAL REPORTERS, INC.
2n, u,s,nn w., _w c-meu ~
- 5930 02 14 117 j'~( MPBmpb
'l power train that starts to raise the power.
The diversity V
2 will not prevent raising the power through a malfunction 3
control; it will prevent damage to the core by virtue of the 4
excursion.
5 But this is -- We are saying you have to provide 6
backup.
7 DR. KERR:
The key word in the bottom diamond is 8
principal protection,-isn't it?-
9 MR. SULLIVAN:
Right, in the bottom diamond the 10 principal channels or whatever words they use, yes, as 11 opposed to the alternate channels.
12 DR. KERR:
Okay.
()
13 Now it would seem to me that if we find that 14 there are some other channels that would provide this 15 protection then they sort of automatically become the 16 principal channels because they are clearly the ones that do 17 the job.
18 MR. SULLIVAN:
They might not do it as fast.
You 19-cculd --
20 DR. KERR:
Well, you have got yourself in a 21 situation in which the channels you looked at won't work.
22 MR. SULLIVAN:
Well, they are failed by accident, 23 not failed because they aren't designed properly.
But --
24 DR. KERR:
But they don' t provide the protection
()
25
'you want.
i l
ACE. FEDERAL REPORTERS, INC.
m.. _.1
5930 02 15 118
(~1 MPBmpb 1
MR. SULLIVAN:
Because we presume that they are 1, '
2 arbitrarily failed.
3 DR. KERR:
Well, for whatever reason.
4 Now you tell me that I can go now and look and 5
see if other channels provide that protection.
I would 6
argue, maybe just to be difficult, that if I do, those are 7
the principal channels, the ones that provide the 8
protection.
9 MR. SULLIVAN:
No.
10 DR. KERR:
If you find them and they provide the 11 protection it is hard for me to see how they can' t be the 12 principal channels to provide protection.
/~T
()
13 MR. MORRIS:
They become the principal channels 14 for an event that leads you down to the bottom box.
15 MR. SULLIVAN:
Exac tl y.
16 MR. MORRIS:
But they weren't the principal ones 17 for the event that was postulated at the top.
18 DR. KERR:
Well, they provide protection against 19 it.
Otherwise you wouldn' t have gotten yourself into this 20 rectangular box.
21 MR. MORRIS:
They provide protection if you don' t 22 happen to get into the bottom track.
23 DR. KERR:
To me it seems that it's ambiguous.
24 It may not be to anybody else.
And I don't want to pursue n
()
25 it any further.
ACE-FEDERAL REPORTERS, INC.
i
,m,,,-,,.
....;.......c........
.no, u u m
5930 02 16 119
, ' 'l.
MPBmpb 1
DR. SIESS:
Whenever we get into a discussion J
2 like this I always look back at the definitions.
And of 3
course it is not there.
4 MR. SULLIVAN:
Well, the top of page 20 discusses 5
alternate channels.
6 DR. SIESS:
But it still uses the word " principal 7
channels."
8 MR. SULLIVAN:
And alternate channels at the top 9
of page one -- of page 20.
10 DR. KERR:
Chet is saying it doesn' t define which 11 is which.
12 DR. SIESS:
The principal channel is not
( )
13 de. fined.
One' of them is principal and one of them is 14 alternate.
And that's about all I can figure out so far.
15 MR. SULLIVAN:
Well, the principal channels are 16 designed to give a greater level of protection assuming that 17 they don't fail.
They will catch the -- They might allow a 18 DNBR of 1.7 whereas your alternate channels which were 19 selected would allow a DNBR to perhaps 1.4.
They are 20 selected only because they do that, not deliberately to make 21 them do that.
22 DR. KERR:
Mr. Wylie, you have had a lot more 23 experience in standards than I have.
In your view is this 24 clear?
r~S
( )
25 MR. WYLIE:
Well, it is clear to me.
ACE-FEDERAL REPORTERS, INC.
m...... m. c__ __
- m mm
5930 02 17 120
_( ~,
MPBmpb 1
DR. KERR:
Okay.
2 MR. ROSA:
If I may add something, I think it 3
would be clear if you added some sort of a conclusion to 4
that square block down there to the effect that in fact now 5
you have performed your safety if you have applied the 6
criteria of those particular sections of the standard.
7 DR. KERR:
It sure would help me, what you said.
8 MR. ROSA:
It is pretty obvious that you can go 9
back to the diamond immediately above the square, and then 10 go over to the right, because then it says that those 11 particular paragraphs don' t apply.
12 DR. SIESS:
I'm looking at the words.
And this
()
13 is not supposed to say anything different than the words; am 14 I right?
15 MR. SULLIVAN:
I'm not sure I understand.
You 16 mean the text is the same as the words?
17 DR. SIESS:
Yes.
18 MR. SULLIVAN:
Yes, the text is the same as --
19 Well, the figure is to illustrate the text.
20 DR. SIESS:
It was supposed to clarify the text.
21 MR. SULLIVAN:
Yes.
22 DR. SIESS:
And as I read the text I get a lot 23 less confused than when I am looking at the figure.
24 What the text says is that I can put in alternate
(
25 channels to get out of any one of those three diamonds.
ACE-FEDERAL REPORTERS, INC.
,m,,,,,m u.. a. c.....
mmu.a
c930 02 01 121
( ~
MPBmpb 1
That's what the figur< 3ays, right?
2 MR. SULLIVAN:
You can put them in.
They are 3
required only -- well, not to get out of all of them.
The 4
top one, if the event only causes action by non-safety 5
systems you wouldn' t need alternate channels.
6 If a fuse could blow and just send the controller 7
on its merry way with no thought of -- no possibility of a 8
common mode failure we wouldn't need the first channel.
It 9
would go over to the criteria on the right-hand side, which 10 is the random failure criteria.
11 All we're really trying to say is if we can get 12 common mode failures by losing control on safety.
You need
()
13 diversity.
That's really the bottom line.
14 DR. SIESS:
Now if Charlie understands it, I 15 guess that's all that's important.
16 DR. KERR:
I have never used a standard in my 17 life, so it is not a good idea for me to comment on it.
18 DR. SIESS:
If Faust understands it --
19 MR. ROSA:
I understand it.
But I would still 20 like to see something like -- In the square down at the 21 bottom the following could be added:
22 "The application of these criteria 23 assure the performance of the cafety function."
24 DR. SIESS:
I sort of liked the old one.
When
,m
(
)
25 you got to the bottom it says do one of the following:
ACE. FEDERAL REPORTERS, INC.
,m,
,,-,,mn t....__.._2.r_.._____
om m mu
c930 02 02 122
'}
MPBmpb 1
6311 or 6312.
q 2
I think if you went back to the original you 3
would be having a figure that didn't use different language 4
than the text.
5 MR. HINTZE:
You mean use the words out of the 6
old one?
The old one is ambiguous.
7 MR. WYLIE:
I think that first part in that box 8
basically is defining the design basis event.
And whereas 9
that may not be a well understood --
10 DR. SIESS:
But where is that in the text?
11 MR. WYLIE:
It is not.
12 DR. SIESS:
I'm reading 6.3, and it talks about
( })
13 where a single credible event, and so forth, does all three 14 of these things one of the following requirements shall be 15 met.
Okay?
And 6.3 tells you when you must do 6311 or 16 6312.
And it doesn't define the design basis event.
And if 17 you changed that to read like it did before then you will be 18 paralleling the words in 631.
19 MR. HINTZE:
Yes.
20 DR. SIESS:
631 defines these three things and 21 says if any of those happen you apply 6311 and 6312 -- is it 22 in 6312?
23 MR. HINTZE:
I think you're right.
We can just 24 delete that -- put this into the old block.
( j 25 MR. SULLIVAN:
Put the old block in.
26 MR. HINTZE:
Yes.
27 MR. SULLIVAN:
You're right, it's clearer.
ACE-FEDERAL REPORTERS, INC.
m.. _. 2. m.. _
.m m -
5930 03 01 123 MPBeb 1
DR. SIESS:
It is a minimal change to what is 2
already in there.
3 Does that help you, Bill?
4 DR. KERR:
To me it would be clearer.
5 DR. SIESS:
You have got to watch figures that 6
don' t agree word for word with the text.
7 Any other positions?
I want you to explain the 8
implementation.
9 DR. KERR:
Are we supposed to comment on impact?
10 DR. SIESS:
Impact after we finish 11 implementation.
12 DR. KERR:
Oh, I'm sorry.
/( )
13 DR. SIESS:
They are related.
14 MR. HINTZE:
Well, we had supplied for us the new 15 implementation statement which we think says the same thing 16 as what we had but, you know, to be accommodating, we 17 proposed to change it to what I just passed out.
18 DR. SIESS:
I don' t think it says the same 19 thing.
Is there a difference between CP applications issued 20 and CP applications docketed?
21 MR. HINTZE:
Yes.
I beg your pardon.
There is 22 that difference.
23 DR. SIESS:
Docketed is earlier than issued by 24 two or three years.
I don't know whether it would be in the b
25 future, so this is somewhat more restricted.
It isn't ACE-FEDERAL REPORTERS, INC.
.m,,,,,,_
m... _..2.
c_.._____
.m m um
5930 03 02 124
('l MPBeb 1
unreasonable.
~J 2
MR. HINTZE:
No.
We had an agreement with the 3
Legal Department that we would change ' issued" to 4
" docketed," the word " issued" to " docketed."
5 DR. SIESS:
Now it seems to me that, too, the old 6
one read pretty much like the one we looked at earlier.
It 7
says staff does not intend to recommend the systematic 8
application of every aspect of this type of plants currently 9
operating under the review, which means that the Staff could 10 recommend some aspects.
11 And the revised implementation says that you 12 can' t backfit it on anything.
()
13 MR. HINTZE:
That's correct.
14 DR. KERR:
For my own information, what is meant 15 by the " power portion" of the safety-related system.
16 MR. SULLIVAN:
The electrical portion of it--
17 Well, no, it is broader than that.
It also goes into 18 hydraulic power, air power.
19 DR. KERR:
Does it include, for example, power 20 supply?
21 MR. SULLIVAN:
Yes, sir, it is very broad.
It 22 includes powcr supply.
It includes power in the broadest 23 sense where it is in a safety system, as I said, the 24 electric power, hydraulic power, air-driven devices.
(
25 DR. KERR:
Okay.
But if you didn't have l
ACE-FEDERAL REPORTERS, INC.
,m,,.,,,_
..c.
-,,,,,u
5930 03 03 125
/ 7, MPBeb 1
anythi ng but electric systems then would " power system" mean
~
,./
2 the power supplies?
3 MR. SULLIVAN:
It would broadly mean the 4
electric.
I am distinguishing between instrument supply 5
and--
6 MR. HINTZE:
It does mean power supplies offsite 7
and onsite.
8 DR. SIESS:
It is defined on page six in a 9
footnote.
Power includes electric, pnaumatic, and 10 hydraulic.
11 DR. KERR:
I just didn' t know what a " power 12 system" meant in 'h23 context.
/m t
)
13 MR. HINTZE:
The diesel generators would be a 14 power system.
The offsite power would be in a power system.
15 DR. SIESS:
Batteries?
16 MR. HINTZE Batteries?
Yes.
17 DR. KERR:
What about a power supply?
18 MR. HINTZE:
That is part of the power system.
19 MR. SULLIVAN:
It is in the broadest sense.
What 20 I'm trying to say is we didn't--
21 DR. KERR:
No, I'm not trying to be critical at 22 all.
23 MR. SOLLIVAN:
I uaderstand.
So we started off I 24 believe with tae word " electric" and then we found, well, h
25 there are pneumatic and all those other things, so we used ACE-FEDERAL REPORTERS, INC.
m.-
J5930 03 04 126 MPBeb 1
the wo rd ' " powe r. "
2 DR. KERR:
If you had a pneumatic, what would the 3
power' system be?
4 MR.-SULLIVAN:
It would be the air system.
f i
5 DR. KERR:
The air system?
6 MR. SULLIVAN:
Yes, like some of the boiling
)
7 water reactors have air systems.
They are part of the scram 8
system.
That is part of the safety system.
9 DR. KERR:
Now what is meant by the " air system"?
10 The compressor and all the piping-and valves and stuff like 11 that?
12 MR. SULLIVAN:
Ir sofar as it relates--
Yes, if
()
13 it impacts on safety, it is part of the supply system.
14 Simply in the negative, we didn't want to restrict to 15 electric.
16 DR. KERR:
That is why I asked.
17.
DR. SIESS:
Well,-this is absolutely strictly 18 forward-fitting.
19 MR. HINTZE:
-Yes, sir.
4 20 DR. SIESS:
Whst were the significant changes as 21 far as 279 is concernad, as far as IEEE 279?
This now
'l 22 replaces 279.
t 23 MR. SULLIVAN:
Yes, it does.
24 MR. HINTZE: -Wait a :niaute.
He said the Guide
().
25 replaces 279.
No.
l t
l
- ACE-FEDERAL REPORTERS, INC.
w u,sw w a c-muuu.ua
m,,
z:
5930 03 05 127
(~l MPBeh 1
MR. SULLIVAN:
We are saying the number--
-- V 2
DR. SIESS:
603.
3 MR. SULLIVAN:
603 replaces 279.
MR. HINTZE:
The standard for 279 would still be
'5 part of the regulations.
6 DR. KERR:
Wait a minute.
Part of what 7
regulations?
8 MR. SULLIVAN:
IEEE 279 has been and continues to 9
be a part of the regulations.
10 DR. SIESS:
It is written into the regulations, 11 just like the ASME code is.
12 DR. KERR:
Which regulation?
()
13 MR. SULLIVAN:
55-A.
14 DR. KERR:
So it is still there even though it 15 has been superceded by this?
16 MR. SULLIVAN:
Even though IEEE has put.
- ceded it 17 in their viewpoint, which is perfectly fine for chem because 18 this standard contains the information, the staff does not 19 consider 279 to have been superceded.
We had a legal 20 opinion on this.
I have a copy of it if anybody would
-21 like--
l 22 DR. SIESS:
Let's say a new application 23 comes in.
Do you review it against 603 or 279?
24 DR. KERR:
Tell me why a legal opinion would
()
25 influence whether or not you wanted to supercede 279.
It ACE-FEDERAL REPORTERS, INC.
5930 03 06 128
( })
MPBeb 1
seems to be technical-position considerations would come 2
first.
Then you would have to figure out how to do it 3
legally.
I am not being critical.
4 MR. SULLIVAN:
No, I understand, sir.
5 DR. SIESS:
But with 279 not having been 6
superceded,--
f 7
MR. MORRIS:
Perhaps I should just say first that 8
we have concluded that there is complete consistency between 9
this standard which we are endorsing and 279.
This goes 10 beyond 279 in the territory or scope, at least in terms of 11 this picture.
(Displaying document.)
12 So we don't feel that there is any problem, any
( );
13 inconsistency any place where applying 279 to the protection 14 system would keep you from applying this guide or this 15 standard to other portions of the safety system.
16 DR. KERR:
279 has some virtues which this itself 17 does not contain.
18 DR. SIESS:
Suppose I had a plant that had been 19 designed with 279 in mind, and it is docketed after this and 20 you review it against 603 now.
You would still review it 21 against 279 because that is in the regulations.
22 MR. SULLIVAN:
That's right.
It would have to be 23 279.
24 D?L SIESS:
But if somebody came in and said this I
25 thing will meet 603, would you say it would meet 279?
ACE-FEDERAL REPORTERS, INC.
5930 03 07 129 l ];
MPBeb 1
MR. ROSA:
I would say that we would conclude v
2 that it did meet 279.
3 MR. HINTZE:
We have that statement in the e
4 discussion section.
It says:
5
" Compliance with the provisions of 6
Section 603 as supplemented by Section C...."
7 which is the Positicns --
8
....is considered by NRC staff to satisfy 9
the provisions of 279."
10 The converse is not true. going through the 11 larger scope.
12 DR. SIESS:
Now all the rest of this matrix here,
()
13 is that covered anywhere now?
14 MR. SULLIVAN:
It is covered, well, in a number 15 of standards, let me say " scattered around," not in a 16 derogatory sense, but some aspects of it are covered in IEEE 17 308, which is power systems, and some parts on bypass 18 indication, some battery standards have covered this, 19 different aspects.
20 So what this standard does is it makes the whole 21 thing cohesive.
It looks at the entire -- all the parts of 22 the safety system as a system, as a cohesive system.
23 DR. SIESS:
Within the regulatory process, that 24 should be an advantage if it's applied, and none of the 7,
(
25 others are written into the codes.
' ACE-FEDERAL REPORTERS, INC.
Sn?.W.Um Narinnwide Crnermar En1%MM
5930~03 08 130
('Jl? MPBeb 1
MR. ROSA:
If you look in the introduction u.
2 section of the Guide, you will note that all of the criteria 3
for safety systems, safety-related systems are listed there, 4
and I would conclude that this standard and the endorsing 5
Guide in effect cover this whole area.
t 6
You could conclude, I think, if the 7
recommendations of the standard and Guide are applied 8
throughout, you would be able to meet all of those criteria.
9 DR. SIESS:
Okay.
10 And you added the--
You have got in there 5055, 11 the 279, and then in the discussion you mention that that is 12 not in the position.
Okay.
()
13 So forward-fitting this thing really doesn't 14 change any basic criteria.
15 MR. ROSA:
No, sir, I don' t believe it does.
And 16 I might--
17 DR. SIESS:
Nor would back-fitting.
18 MR. ROSA:
That's what I was going to add.
19 DR. SIESS:
So it really doesn't make much 20 difference.
It just collects stuff that is already being 21 done.
22 MR. ROSA:
Yes, sir.
23 DR. SIESS:
Bill, do you have any more comments,
l 24 or questions?
()
25 DR. KERR:
Are we to " impact" yet?
ACE-FEDERAL REPORTERS, INC.
-a a-6:_..__.
2a_
e_... _ _.
.N u
f 159'30~03:09-131
~
TL MPBob 1
DR. SIESS:
No.
.d 2
Are you through?
3 MR..HINTZE There' is just one thing I promised I 4
would. mention.-
On page five--
-5 DR. SIESS:
Of what?
6' MR. HINTZE. -- of the Guide, part of the
-7 Discussion section--
I'm sorry, it is page six.
8
-DR. SIESS:
Page six?
9 MR. HINTZE:
Yes, sir.
.10 DR. KERR:
I'm sorry, there is one thing on page 11 five,.the new Number 2, the second sentence.
The word 12
- " replaced" with reference to "is -being replaced," where is
(]
13 it being replaced?
In this Guide?
14 MR. HINTZE:
In the Position section,1yes.
15 DR. KERR Okay.
I guess that's clear.
Yes.
16 Okay.
Thank you.
17 Go ahead.
18 MR. HINT 2E: -Under Item 4 at the top of the page, l
-19
-to say a modified chart has been supplied by IEEE and is fl 20' included in Figure 1.
The working group asked me to take l-21 that "has been supplied by IEEE" out because they-don't feel
-22 thatJit had the same review as didLthe standard-itself.
The L
23
- new figure was provided by the ' working group and-just 24 transmitted by. the chairman, 'and it. didn' t get the. full
(
25-
' review.
.They'would prefer that-I-take that out.
l ACE-FEDERAL. REPORTERS, INC.
t minen
- e-anmans.ma
5930 03 10 132 l'
MPBeb 1
DR. SIESS:
Would they object if you said "by the 2
IEEE working group"?
3 DR. KERR:
Why don't you just say a modified 4
chart is included as Figure 1 of this Guide.
5 MR. HINTZE:
That's what I intended.
Just strike 6
out that phrase.
7 DR. SIESS:
All right.
No problem.
8 MR. HINTZE:
That's all I have on that.
9 DR. SIESS:
Now Bill has some questions on the 10 Impact Statement.
11 DR. KERR:
Very minor.
12 On page 12--
I) 13 DR. SIESS:
Wait until I find it.
v 14 DR. KERR:
-- five lines down from the top of the 15 text:
16 "No new requirements are imposed."
17 I assume "on others" is left out, "other than 18 those already included."
19 DR. SIESS:
Which page, Bill?
I'm sorry.
20 DR. KERR:
Page 12.
21 DR. SIESS:
Thank you.
22 DR. CARBON:
Excuse me.
On that one, they are 23 already in the Code of Federal Regulations.
They are not 24 new requirements, are they?
( ))
25 DR. KERR:
That's my point.
ACE-FEDERAL REPORTERS, INC.
SA9 1J'1*Ad M stinnaids Irwernor BlYL11L/Jnd/i
5930 03 11 133 MPBeb 1
DR. CARBON:
Oh, I'm sorry.
2 DR. KERR:
But thank you.
3 And indeed at the bottom of the page this says:
4 "No new requirements are imposed."
5 That could be viewed as being inconsistent 6
statements.
7 MR. MORRIS:
If we took "new" out it would be a 8
more accurate statement.
Is that what you're getting at?
9 DR. KERR:
If you just put "No new requirements 10 are imposed," then the two would be consistent.
I mean if 11 that's true.
I assume it is since a Reg. Guide is not a 12 requirement.
(a')
13 DR. SIESS:
The standard of in-plant isn't a 14 requirement either.
We work it into the regulations.
15 MR. HINTZE:
I have no problem with taking that 16 out.
17 DR. CARBO ' :
When you say "taking that out," on 18 the fif th line you are putting a period af ter " imposed," and 19 taking out "than those already...."?
20 MR. HINTZE:
That's correct.
21 DR. KERR:
That was my only comment on " impact."
22 DR. SIESS:
That's all?
23 DR. KERR:
Yes, sir.
24 DR. SIESS:
What about on the back?
()
25 DR. KERR:
It is hard to disagree with anything ACE-FEDERAL REPORTERS, INC.
uum cm am6
5930 03 12 134
{~'}/
MPBeb 1
else.
\\_
2 DR. CARBON:
I would like to go back to page 11, 3
the next to the last line on the bottom.
4 Just for my own understanding, the phrase "on a 5
national consensus standard" doesn't add anything to that.
6 Am I correct that from my understanding I could delete that 7
phrase?
Is that correct?
8 DR. SIESS:
fou could probably delete it, Max, t
9 but it wouldn't quite mean the same thing.
10 DR. CARBON:
Well, that's my question.
Would it 11 mean the same thing?
12 MR. SULLIVAN:
Well, what it says is it shows how
()
13 we are utilizing the National Consensus Standard, and part 14 of our policy is to cooperate with national consensus 15 groups.
4 16 DR. CARBON:
But the value here is this action 17 establishes the NRC position, or an NRC position and 18 therefore reduces uncertainty.
That's what it means, isn't 19 it?
20 DR. KERR:
It would seem to me to say on the 21 standard....
I think I'm missing your point.
22 DR. CARBON:
Well, you could have a consensus,
4 23 standard that the NRC didn't really agree to of ficially and 24 it would only muddy the water.
()
25 DR. SIESS:
You could have an NRC position that l
ACE. FEDERAL REPORTERS, INC.
2L M 4 M 700 Nationwide Covernae 800 3M-6646
\\s 5930'O3 13 135
(
MPBeb 1
didn't endorse a standard, which to me is not quite the same 2
as an NRC position that does endorse the standard.
3 DR. CARBON:
This doesn't say " endorses the 4
standard."
5 DR. SIESS:
Well, it is a position on a standard.
6 DR. CARBON:
It establishes a position on a s
7 standard, and it may agree with it totally or it may agree 8
with it in part.
There may be exceptions.
9 DR. SIESS:
I just have a feeling that a position 10 on a standard reduces uncertainty more than just a position.
11 DR. CARBON:
Well, I would argue that in some 12 cases it would and in some cases it wouldn't.
()
13 DR. KERR:
You college professors will argue 14 about anything.
15 DR. CARBON:
We will.
16 (Laughter.)
17 DR. CARBON:
We had one this morning where the 18 Reg. Guide endorsed a standard and another one where the 19 Reg. Guide endorsed it with exceptions, and just to endorse 20 a consensus or--
21 DR. KERR:
It doesn't say " endorse."
22 DR. CARBON:
No, no, it certainly does not.
Just 23 to establish a position on a standard when you don' t say 24 whether establishing that position endorses it or endorses
,n
( l 25 it in part, I don't see--
ACE-FEDERAL REPORTERS, INC.
5930 03 14 136
(^}
MPBeb 1
MR. MORRIS:
We would say that there is value in x_)
2 any of those, endorsing it cleanly, endorsing it with 3
exceptions.
At least we have established a position in 4
addressing it at all.
We have established a position with 5
respect to a National Consensus Standard.
We are removing 6
uncertainty about what the industry -- how the industry 7
could use that standard.
Now we are saying it is acceptable 8
to us for you to use it.
9 DR. CARBON:
I am not pushing you to take this 10 out, but I am asking the question if it really makes us any 11 clearer or has any meaning in there in fact.
12 DR. SIESS:
I think there is value in the staff's
()
13 having a position on a National Standard.
14 DR. CARBON:
Sure there is.
15 DR. SIESS:
And this is what it is listed under.
16 DR. CARBON:
But that's not the point here.
17 MR. WYLIE:
Well, the true meaning of that 18 sentence is that it reduces the uncertainty of the 19 interpretation by the staf f of the standard -- Right? --
20 without saying that?
In the last sentence of the first 21 paragraph up there it says that this Reg. Guide does endorse 22 the standard with certain supplementary material.
23 DR. CARBON:
Well, I don' t want to push that.
24 DR. SIESS:
Okay.
(~')
25 MR. ROSA:
I would like to make a suggestion a
l l
ACE-FEDERAL REPORTERS, INC.
202-347 1700 Nationwide Coverase
&W1136-6646
5930 03 15 137 MPBeb 1
here.
If you took " reduces uncertainty as" out and replaced 2
it with " adds weight to what the staff considors acceptable 3
in the area covered," that might be a little clearer.
4 DR. SIESS:
I have seen some regulatory positions 5
that were developed entirely by the staff, and I didn't 6
think they reduced uncertainty, safety-related and important 7
to safety, and a few others.
This is not something the 8
Committee has to endorse.
This is advice from the staff.
9 You have heard Max.
I don' t agree with him.
We 10 are not even going to bother to take a vote on it.
We don't 11 have to approve the Impact Statement anyway, so you guys do 12 what you want.
We get a lot of good advice from individuals 13 that way..
{}
14 DR. KERR:
Advice anyway.
15 DR. SIESS:
No, we get a lot of good advice.
We 16 have never gotten bad advice.
17 Anything else, gentlemen?
18 (No response.)
19 DR. SIESS:
The matter before the Subcommittee is 20 what we recommend to the full Committee, and the 21 recommendation in this case will simply be that it go out 22 for public comment.
23 MR. SULLIVAN:
.No, final.
24 DR. SIESS:
Oh, I'm sorry.
This is final.
I'm
(~)
25 sorry, we got mixed up.
s_/
i ACE-FEDERAL REPORTERS, INC.
. 8 347-E O)
Nationwideh 800 336-6646
5930 03 16 138 MPBeb 1
The recommendation in this case is that we concur 2
in the positions of the staff.
3 DR. KERR:
I would be willing to favor that.
4 DR. SIESS:
Would you vote in favor of that?
5 DR. CARBON:
Yes.
6 1
DR. SIESS:
Charlie?
7 l
MR. WYLIE:
Yes.
8 DR. SIESS:
We will so do, gentlemen.
9 MR. HINTZE Thank you, sir.
10 DR. SIESS:
I think we don't need you for the J
11 full Committee.
12 Sam reminds me that in the discussion there was a 13 new paragraph added on page four; the third paragraph, in
(}
14 which the staf f encourages the application of advanced 15 technology such as programmable digital computers, and we 16 suggested that that belongs in here rather than somewhere
-17 else, the software program, and they have put it in, so I
18 don't anybody object to that.
19 (Laughter.)
20 DR. KERR:
I didn't object to it at all.
I have 21 no idea what it means.
22 (Laughter.)
23 DR.. KERR:
I take it you guys settled the Set 24 Point issue.
(}
25 DR. SIESS:
Set Point issue?
What Set Point i
-ACE-FEDERAL REPORTERS, INC.
._202-347-3700 Nationwide Coverage, 800-336 4646
5930 03 17.
139 MPBeb 1
issue?
s._/
2 DR. KERR:
The Set Point issue for safety-related i
3 systems.
4 DR. SIESS:
Yes, we really thought that was a 5
good idea.
6 DR. KERR:
I'm glad you did.
I tried to follow
,7 the trail and I finally gave up.
4 8
(Laughter.)
9 DR. KERR:
It had been reviewed and re-reviewed 10 so much it had to be in good shape.
11 DR. SIESS:
Sam is going to write a history of 12 that one--
He's already got it.
O 13 The meeting is over.
14 (Whereupon, at 1:40 p.m.,
the meeting of the 15 Subcommittee was concluded.)
16 i
17 18 19 20 21 23 24 h
25 l
i ACE-FEDERAL REPORTERS, INC.
'X12.1471700 Nationw& Coverase
-800 33(M m
l 1
NUCLEAR REGULATORY COMMISSION
- C 2
This is to certify that the attached proceedings 3
before the Subcommittee on the Regulatory Activities 4
Date of Proceeding:
October 8, 1985, Tuesday 5
Place of Proceeding:
Washington, D. C.
6 were held as herein appears, and that this is the original 7
transcript thereof for the file of the Commission.
8 8
GARRETT J. WALSII, JR.
GARRETT J. WALSII, JR.
10 Court Reporter Ace Fe cral Reporters, Inc.
al P/JL
>=
GARRETTJ.[LSII, JR.
14 15 MYRTLE II. WALSII I
MYRTLE !!. WALSII-Court.. Reporter
' Ace Federal Reporters, Inc.
18 W& A) > )
JA !4[-
8 MYRTLf II. WALSil
=
21 Y
23 24
,a
CERTIFICATE OF OFFICIAL REPORTER O
This. is to certify that the attached proceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in the matter of:
NAME OF PROCEEDING:
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS SUECOMMITTEE ON REGULATORY ACTIVITIES DOCKET NO.:
' PLACE:
WASHINGTON, D.
C.
DATE:
TUESDAY,, OCTOBER 8, 1985 were held as herein appears, and-that this is the original transcript thereof for the file of the United States Nuclear Regulatory _ Commission.
(sigt) I (TYPED)
MADELON P.
BLOOM Official Reporter' Rep ^okeE[Ni((aggS, INC.
[%
-