ML20140D771
| ML20140D771 | |
| Person / Time | |
|---|---|
| Issue date: | 12/14/1984 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1362, NUDOCS 8412190175 | |
| Download: ML20140D771 (40) | |
Text
. OIG NAL bd2 EN11EU STATES XUCLEAR REGULATORY COMMISSION O
IN THE MATTER OF: DOCKET NO:
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 296TH GENERAL MEETING O
LOCATION: WASHINGTON, D. C. PAGES: 324 - 363 DATE: FRIDAY, DECEMBER 14, 1984
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UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION
<^s 3 ADVISORY COMMITTEE ON REACTOR' SAFEGUARDS 296TH GENERAL MEETING 6 Nuclear Regulatory Commission Room 1046 7 1717 H Street, N.W.
Washington, D. C.
8 Friday, December 14, 1984 9
The 296th General Meeting convened at 8:30 a.m., Jesse C.
10 Ebersole, Chairman, presiding.
11
-12 .PRESENT:
. r~s
-13 JESSE C. EBERSOLE, Chairrr n l DAVID A. WARD, Vice-Chairman 14 ROBERT C. AKTMANN,. Member MAX W. CARBON, Member 15 WILLIAM KERR, Member l HAROLD W. LEWIS, Member:
16 CARSON MARK,. Member CARLYLE MICHELSON, Member ,
DADE W. MOELLER, Member-I7 DAVID OKRENT, Member GLENN A. REED, Member 18 PAUL G. SHEWMON, Member CHESTER P. SIESS,. Member
-19 CHARLES J. WYLIE, Member 20 i 21 .I 22 23 24 l 4 4m-w neoma, rx.
25
c ..
f .4300 01 01 325
- 2' DAVbw 1 P R O C E E D~I N G S o
( 2 MR. EBERSOLE: The meeting will now come to 3 order.
~ 4 This is a continuation of the 296th meeting of the 5 Advisory Committee on Reactor Safeguards.
6 During today's meeting the Committee will hear 7 reports on and discuss the following:
8 Fire protection in nuclear powcr plants; 9 Ouantitative safety goals; 10 System interactions in nuclear power plants; 11 USIA 17.
12 And we'll have an election of officers for fiscal 13 year 1985.
/~ 14 The items scheduled for discussion tomorrow-are
(>} '
- 15 listed in the revised schedule which is' posted on the-16 bulletin board outside this meet'ing room.-
[ 17 The meeting is being conducted in accordance with 18 the provisions of.the_ Federal Advisory Committee Act and the l-19 government in the Sunshine _Act.
20 M r . II . Alderman is the designated federal employee
- 21. for this portion _of the meeting.
22 A transcript of the meeting is being kept, and it 23 is requested that each speaker first identify himself or 24 herself and speak with sufficience clarity and volume, so 25 that he or she can be readily heard.
) 4300'01~02. 326-f 1 DAVbw 1 Portions of this session will be closed, as
( 2 necessary, to discuss information, the release of which 3 would represent an unwarranted invasion of personal 4 privacy.
5 We have not received either written statements or 6 requests for time to make oral statements from any member of 7 the public.
8 The first item on today's schedule is a. briefing 9 by the NRC Staff on-the activities of the Fire Protection 10 Policy Steering committee.
11 Let me mention also that we do have a first-draft 12 of the letter on Hope Creek. I am passing it around. It's 13 largely boilerplate. I'm passing it around to you,
- 'T 14 individual copies, with a spare sheet. I'm anticipating f) 15 contributions in the nature of paragraphs on your pet We will put them all together, screen them and clean 16 topic.
f 17 up the letter and have a little chat;with Chet, who is 18 absent, and who is the Subcommittee Chairman, and so 19 integrate'the letter for cleanup by tomorrow. So we'll see 20 that probably in the course of the next hour or so.
21 Are there any statements by any members of the 22 Committee, in addition-to those?
23 DR. MARK: Have you been in touch with Chet?
24 MR. EBERSOLE: Yes. He's doing fine. He had a
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25 virus. He's loaded with antibotics, or whatever. I haven't L.
'4300 01 03 327 1 DAVbw 1 talked to him this morning, but that was the message from 2 last night.
3 Any other comments?
l\ ') 4 (No response.)
5 MR. EBERSOLE: I f not , we'll pick up the first t.
6 topic of the day, for which.Mr. Carlyle Michelson is the 7 Subcommittee Chairman, on the subject of the status uf the 8 fire protection business.
9 MR. MICHELSON: Thank you, Mr. Chairman. We have 10 a short presentation by the Staff this morning. I would l' 11 like to apologize that this presentation is coming without 12 the benefit of a subcommittee meeting first. It was our 13 understanding that the fire protection staff people had some rs 14 things that they wanted to talk to us about, so we agreed to
()
- 1) 15 give them some time to hear the current state of affairs..
16 We have actually, though, scheduled a Fire j: .17 Protection Subcommittee meeting. If the schedule works _ out, 18 it will be on February 5th. And if there are any s:
19 requirements for letters to be written, or whatever, it 20 would be following the February 5th Subcommittee meeting.
21 I believe, with that introduction, Mr. Vollmer.is 22 here to represent the Staf f and will tell us whatever the 23 current state of affairs might be.
f-c. 24 (Slide.)
- ) '
\_/
25 MR. VOLLMER: Thank you.
l i
1
'l
-4300 01 04 328 1_ DAVbw 1 For reasons which I'll get into in a moment, a 2 ~ steering committee put together by the EDO was formed and 3 asked to carry a specific assignment a few months ago, which
_( ,..l
'# 4 was prompted partly by the state of affairs of fire 5 protection implementation in the industry and also prompted, 6 in part, by a differing professional opinion which had been 7 raised by some of the fire protection reviewers and 8 inspectors and which had been brought to the Commission's 9 attention in late May.
10 These issues were addressed by a steering
! 11 committee of division director stature and recommendations
)-
12 wer made to Dircks in late October.
13 It appeared at that time that Mr. Dircks was r> 14 planning, and the Commission had requested the meeting in
> N-]
15 mid to late December of this year. So at that time I called 16 Ray Fraley and indicated that we'd be happy to brief the s
y 17 Committee on what's going on.
18 I thought the most appropriate time to do that 19 would be before we went to the Commission. As is often the 20 case, however, the Cotamission meeting is not scheduled at-21 this time. In fact , as I'll indicate later,_it might be 22 well off in the future, indeed, beyond the time in which 23 Carlyle had indicated the Subcommittee meeting would be.
g 3- 24 What I'd like to do is very briefly go over the y
25 status of the plants, as sort of background information to
'4300.01 05 329 1 DAVbw 1 -help you see where we are.
2 The first item I'd like to mention, in the slide,
,_ 3 'there i s -- about in the middle, we call to your attention
(--) 4 that the rule which needed the exemption provisions in it, l; 5 because it was being back fit on a number of operating 6 plants, we did receive on the order of 500 exemption 7 requests. Roughly hal f of those were granted, hal f of them
-8 were denied.
9 In the period July through December of '82, we 10 worked with the Staff dealing with the technical exemption 11 requirements and set up an appeal process for the exemptions 12 which were denied, and, in fact, completed one round of 13 reviews for all plants by the end of 1982. We thought at j' 14 that time it would just be a matter of cleaning up the-
) \_]/ 15 exemption requirements which had been denied and a matter of 16 allowing the utilities to go out,and implement the 17 agreements that had been made'with the Staff, either as 18 technical exemptions in fire protection or the review of the 19- alternate shutdown systems. But we were a bit naive in 20 thinking that at the time.
21 In the period of time between '82 and mid '83, we 22 had a number of meetings with the utility fire protection 23 group. These meetings were to obtain clarification on what 7w 24 the Staff ws looking for an a clari fication on why we denied b 25 a number of the technical exemption requests by industry.
4300 01 06 330 1 .DAVbw 1 As a result of those meetings, we issued a generic .
2 letter in October '83, which gave a number of positions that 3 the Staff had been implementing, but put them into a generic N 4 letter, so that all licensees would be apprised of the views 5 that the Staff was taking and the type of information the 6 Staff was looking for in- doing the Appendix R reviews.
7 In November of '83, we meet iwth Mr. Dircks. This 8 meeting was prompted by his concern that, based on a number 9 of inspections that had been held to that date, and I 10 believe a number of complaints that he'd-heard from 11 industry, he wanted to say what, indeed, was going on in 12 fire protection.
13 I would categorize the problems he heard as the 14 following:
) %_)
i 15 One, industry indicated a great dealaof confusion 16 about the rule itself and how they should implement it. If f 17 you will, they didn't' understand the rule and didn't know
( 18 how to apply it to existing plants.
j-19 Secondly, there appeared to be an inconsistency 20 between certain reviews done by the Staff and an 21 inconsistency between inspections carried out in the field 22- in a rule that requires a great deal of judgmental 23 evaluation and is not surprising at all
-%. 24 Third, and this is really the bottom line, the 25 plants we had inspected up to that date had not met the
~~- - -
l l
'4300 01'07 331 1 DAVbw 1 rule, even those plants that came in to ut and said, "Yes, 2 we do. meet Appendix R," because at that time, our 3 inspections were initiated when a plant said that they
(\ ), 4 basically met the rule and it was time to come inspect 5 them.
6 MR. MICHELSON: May I interrupt for just a moment, 7 Dick.
8- Were there workshops or seminars or something 9 conducted with the utility industries, so that they were 10- aware of what the requirements were purported to be?
11 MR. VOLLMER: One of the recommendations coming 12 out of the meeting with Dircks at that time was that we, 13 indeed, do that. We had a number -- I think it was three.
14 generic letters that had been sent out. We had never dealt v
)
15 with industry as a body to see what their problems were of 16 implementation. So at that time, it was recommended ,that we 17 go out and set up a series of regional workchops. And.
18- before we did that, we solicitied industry's comments on how 19 the workshops should be conducted and also solicited a 20 series of questions from them that they wanted to be 21 addressed at the workshops.
22 We had targeted our workshops for the spring of 23 '84. Defore we got the workshops in gear, industry called 3 24 together their own seminar for the purpose of providing a
'd 25 forum to discuss the problems among themselves and to
j 4300 01 08 332
! 1 DAVbw 1 develop the list of questions that they would then present Y 2 to the Staff to be part of the Staff workshop.
3 The industry seminar was held here. We believe
/ ,)
V 4 something on the order of 280 industry representatives. I i 5 think every utility, maybe one or two were missing, but 6 almost every utility was here. We, the NRC, gave a couple 7 presentations, but it was mainly for industry to thrash out 8 and come to grips.with what they thought the problems were..
9 MR. MICHELSON: Did you finally hold NRC seminars 10 indicating what you considered the requirements to be?
- 11 One of your items here was that there was f-12 misunderstanding, confusion about requirements.
13 Was there a seminar actually held, though, by the
> +
i \
(s 14 NRC outlining your interpretation of the requirements?
15 MR. VOLLMER: Yes.
16 MR. MICHELSON: When was that held?
17 MR. VOLLMER: Those were really the regional 18 workshops. Based on the industry meetings.and the input we I
19 got from them, we developed a fairly thick package of 20 responses to all their questions. In addition to that, we 21 felt that the generic letter I had indicated previously, was 22 sent out to industry in October of '83. They fel t ' that the 23 Staff was treating certain things that were generally Staff s 24 guidance as parts of the rule. That is, the Staff was 25 asking the utilities to apply for exemptions on what the
4300 01:09' 333 1 DAVbw 'l 'i ndustry viewed as essentially Staff interpretations of the 2 . rules, in what were literally requirements of the rules, and 3 that would be improper.- So in addition to the questions and ,
4' . answers generated for the regional workshops, Staff and 5 . industry, if you will, negotiated a series of positions, c
.6 based on issues that they wanted to be addressed.
7 These positions basically gave industry more 8 latitude and flexibility in going out and solving their' fire 9 protection programs, subject to an eventual inspection by 10 the NRC for adequate compliance with Appendix R,-rather than 11 having a number of these issues brought in beforehand for I
12 prior review, for implementation. The industry said that
[
l 1 13 would give them flexibility. It would expedite compliance, f
>- 14 and so on, and eliminate confusion.
$N) 15 Staff prepared a differing professional opinion.
16 Some of the Staff reviewers and inspectors said, no, tht's-l 17 not right at all. Industry will go out and interpret things 18 the way the wish, then install them in the plants, and when 19 we go out to inspect them, the burden will be on the Staff 20 to show a safety basis for making them tear it out, if they 21 don't have it right to begin with.
22 They said the overall process of compliance would 23 he extended quite a bit by doing that. The DPO -- as I
- 24 indicated earlier, the Commission requested information on 25 it,-and it was discussed with them in the May 30th meeting.
4300 01 10 334 1 DAVbw 1 And as a result of the May 30th meeting, the Commission 2 said, "The information you send out to the industry, as a 3 result of these workshops, we would like to see it before it
\ 4 goes out."
i 5 MR.-EBERSOLE: Mr. Vollmer, may I ask a question.
6 Not very long ago, I think it was realized that-in 7 coping with this fire problem, one of the most effective 8 ways to do it was to devise an alternate shutdown point in 9 the plant, clearly distant and not at all connectable with 10 the fire in the other parts of the plant which are commonly 11 built and make it quite competent to shut the plant down, 12 particularly down to the containment, as well as the core, 13 and so forth.
s 14 Certainly, that would offer some release from very
(-s s_)
) 15 stringent requirements elsewhere in the plant, i f they were 16 granted, which I suspect they are not very much.
. 17 Has the current trend been to do that or to 18 attempt to protect that which is already there.
19 MR. VOLLMER: The overwhelming choice has been to 20 protect that which is already there. There are a number of 21 plants which have used the dedicated shutdown provision in 22 the rule for attacking the fire protection problem.
23 I think I agree with you generally, that would 24 obviate the need for a lot of changes and, in fact, may, in
&gg 25 the long run have been cheaper to do, to begin with. I m
4300 01-11 335.
2 DAVbw . 1 guess 'at first blush, it probabl.y wouldn't appear. In most c
~2- plants, that would be.the best way to do, f ,, 3 MR. EBERSOLE: Having done that, and industry d 4 fighting to protect-that which it has, inevitably, what 5 comes up is, what's the fire source, what's'the fire t
6 loading, et cetera.. I long ago offered to be a strawman and-
.7 said, i f you can' t ' find any other basis for-it, we'll pick 8 five gallons of acetone, and if you want to pick one quarte 9 or-. ten gallons, or whatever you want to pick, you can be the 10 strawman, but that seemed a reasonable sort of condition at 11 various places in the plant, where the industry has not 12 adopted a remote shutdown facility, which would clearly 13 survive that sort of intrusion of a fire source.
-Q 14 Have they protected against intrusion fire of that kJ 15 caliber or have they not?
16 17 18 19 20 21 22 23 24 g 25
l 4300 02 01 336
[ l DAVpp 1 MR. VOLLMER: I think generally, yes, they have.
)- 2 As part of the Staff ~ review, we would look for that type of 3 intrusion as a basis for our review. As you know, the rules L'i r
4 do not specify any particular fire source.
) 5 MR. EBERSOLE: That's the problem.
6 MR. VOLLMER: That's one'of the problem besides
)
7 being a backfit problem but Staff, I would say, generally is 8 dealing with fires of that magnitude as initiation sources 9 in their review. ,
10 MR. MICHELSON: Isn't it a requirement though 11 that a backup operation location be provided at every plant?
12 MR. VOLLMER: To get around the control room fire I.
13 because you can't otherwise deal with a fire in the control 14 room. But in areas where you can protect adequately by fire
~
15 protection provisions, you would not necessarily need an 16 alternative shutdown from those areas.
}.
17 MR. MICHELSON: Could you give me an example of 18 what you're referring to?
19 MR. VOLLMER: If you had a control room ' fi re --
20 MR. MICHELSON: I understand the control room 21 fire. I wonder what these other areas are that you'could 22 get around.
23 MR. VOLLMER: Say, if you had dual cable 24 spreading rooms. That gives adequate protection so you 25 would not need all setdowns around your cable spreading 26 room.
J
1 i
i 4300 02 02 337 1 DAVpp 1 MR. EBERSOLE: Unfortunately, that still has a 2 common control room.
3 MR. VOLLMER: That's unfortunately the case.
/~T l l 4 That has a common control room.
5 MR. EBERSOLE: So, in essence, that really does 6 you nothing to avoid the distant control center.
7 MR. VOLLMER: That's true. Basically what you 8 said is true.
9 MR. MICHELSON: I thought one of the basic 10 probl ems here, though, is that although they provided these 11 remote locations from which to shut down for a fire in the 12 control room and although the wiring does not then loop 13 through.the control room, it loops through a number of other 14 areas where they have found the physical separation to be (w)
\J i
L 15 pretty tight relative to possible fire. situations.
16 You prescribed rather carefully how tight it can
, 17 be and I thought they were having trouble because they were 18 just closer than that.
19 MR. VOLLMER: In some cases that's true but I 20 have to say making the rule -- well, as far as I know no 21 plant meets the rule as far as I know.
22 MR. MICIIELSON: That was a little surprising, 21 wasn't it, that none of the plants -- I gather only one cane 24 even close.
O 25 MR. VOLLMER: The rule was for plants who had an
4300 02 03 338
.1 DAVpp 1 operating license before January 1st of '79. So these were 2 older plants. No plant could physically meet that rule 3 because they weren't built with that rule in mind. So it
/ ;
's 4 was not.possible. That's why the back fit ~ provisions were a i
l _
5 bit onerous, even for plants where the Staff had agreed with I
G the adequacy of fire protection.
7 I f you ' l l recall back in 1977-1978 there was a 8 great deal of Staff effort dealing with operating reactors 9 in Appendix A of the branch technical position. We had 10 reached an agreement with a utilities and adequate fire 11 protection.
L 12 However, there were still a number of utilities 13 that had outstanding issues that the Staff was unable to get r- 14 resolved in any way other than A, issue plant specific D) '
15 orders or B, issue a rule. The judgment was made to issue a L
16 rule. The rule originally was drafted such that the rule 17 would apply with the force of law to resolve any outstanding 18 issues that might resolve all issues in all plants.
19 The Commission decided to back fit certain 20 provisions of the rule to all plants regardless of previous 21 Staff agreement. Therein lies a number of problems but, in 22 fact, what you say is certainly true. The exemption process 23 is needed because you can find plants that have all the 24 speci fic ingredients of the rule and Staff has made a number
.( -
25 of signi ficant judgments on exemptions which, based on their
4300-02 04 339
-1 DAVpp 1 _best' engineering judgment, gives adequate protection to the 2 plant.
i h 3 MR. MICHELSON: For the plants coming up now for 4 operating licenses, they have to meet the rule, don't they?
5 MR. VOLLMER: No, they don't have to meet the 6 rule nor do they have to receive exemptions. What they're 7 being asked to do is to look at their plant and in'dicate 8 where they differ from the rule and it's handled by the 9 Staff as a normal standard review plan review. That is, if 10 the Staff agrees it's adequate it's written up in the SER as 11 a deviation. But the rule does not apply to the NTOLs.
I 12 DR. MARK: Could I ask in connection with the-1, 13 issuing of exemptions, which seem to have a good basis from 14 the way you describe it, if they were considered by 15 different people they wouldn't necessarily come out on the 16 same basis. Can one be confident that they have been 17 applied consistently. That is, that the same fault has 1
j _
18 been offered the chance to use the same exemption.
19 MR. VOLLMER: We've tried to do that. Obviously, 20 the success rate depends on the eyes of the beholder. We've 21 tried to do that. The reviewers go through a common section 22 leader or branch chief in the fire protection area and they 23 try to be consistent. There are a number of plants who've 24 come in for exemptions who have said, you don't need an
'g/- )
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25 exemption _in that area because you already meet it or the
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1 I
1 I
l 4300 02 05 340 l l' DAVpp 1 rule doesn't require'you to have an exemption. Of ' i f they l l
2 do require exemption we try to be evenhanded about what we j 3 feel is needed to backfit the rule. .
.(~
\' 4 But, again, when you get beyond the nuclear steam 5 supply system no plant out there looks the same or very few 6 look th, same. Each one is an issue in itself.
7 DR. MOELLER: Excuse me, on your list there, and 8 maybe you mentioned it or maybe it's hidden there, but it 9 seems to me I read a several page memo in the last week or 10 two from one of your NRC regions pointing at the high costs 11 of the implementation of this rule and the manpower that 12 would be required and so forth. Is that on there somewhere?
13 MR. VOLLMER: I'll address that a little bit 14 later but, if you will, to address it very briefly now.
15 This is not a procedure that we were going through i
16 cost-benefit through CRGR and so on to implement a Staff 17 wish. This is a rule. So we're taking the other approach.
p "
18 We have to justify any exemption we give to that
! 19 rule with a technical analysis that would stand the scrutiny 20 of the exemption process.
21 (Slide.)
22 As I indicated we did go to the regional 23 workshops. He had, I would say, about 750 participants in
- 24 the total aggregate of the workshops and did indeed address 25 all the questions and answers raised by industry. But the
4300 02 06 341 3
1 DAVpp 1 differing professional opinions put a different focus on it
)
2 as to the efficacy of the plans of the Staff in carrying out 3 the implementation.
I ks'i 4 So after the Commission meeting Mr. Dircks again I
5 called us together and said, you know, he'd like to know 6 what policy recommendations we could make to him in terms of 7 expediting compliance with the rule and assuring a 8 consistent level of safety at new plants and old plants 9 because one of the criticisms made by industry was that we 10 were doing more on fire protection safety fo. old plants 11 than we are for new plants and if that's a legitimate 12 concern or if it's a legitimate argument then we were 13 concerned too. Because it would indicate an inconsistency ry 14 in our process.
N-] 15 Dircks asked us for a two-month turnaround. The 16 Steering Committee Report was given to him on October 26 and 17 I'll go on briefly to summarize what we did and what we 18 found but indicating what's going on right now and what the 4 19 status of plant reviews are.
20 We have -- in particular, since the regional 21 meetings -- we have gotten a flood of new exemption requests 22 based on the regional meetings. There were a number of 23 plants, i f you ' l l recall, way back when the rule was first 24 issued that went in and told the Staf f we need the rule. No gS
%-) You can come inspect us. We did in some cases 25 problems.
i
. . . . .~ - _,
~4300102-07 342 l' DAVpp 1 and found that there was' signi ficant violations of the 2 rule.
3 But-I think industry as a result of the workshops 4 .has a fairly broadbased understanding of what the Staff was 5 looking ' for and hopefully an understanding of what the rule 6 requires. .More importantly, perhaps, the types of things 7 the Staff is willing to accept as exemptions to the rule the 8 plant meets anyway. The present status is that 8 plants --
9 or 8 units -- we have still not resolved the original 10 exemption request and I'm not sure when all these were 11 submitted, probably back in the '82 timeframe.
12 For one reason or another the appeal process and 13 the technical review-process has been ineffective in getting r~t 14 8 plants brought to resolution. If the utility wishes to 15 take certain courses of action as you probably.well know,-
16 they can flood the Staff with paper which can keep us from 17 coming to a resolution on an issue fairly effectively.
18 There are 38 units that have submitted new 19 exemption requests. Generally since.the-regional workshops 20 they said, oh, gee, we found out some new'information; we 21 went out and looked at our plant based on'these meetings or 22 whatever and said, hey, we need an exemption in-this area 23 before we do our implementation and since implementation 24 is not a cheap process -- it's not a process that you want
[ :
25 people changing wires, building walls and things like that
I 5300-02'08 343 I
- 1 11NVpp :11 ,for no good cause. We certainly are committed to entertain '
b 2 all these exemption requests or do the best job of '
3 evaluating them.,
4 -
4 Fifteen: units have asked for new alternate safe 5 shutdown: modifications and about one-third of the units out 6 there, in terms of the older reactors, have no exemption-7 requests.with Staff approvals pending. So we can only 8 assume that.they are in the process of. implementing the rule t 9 ~for_whatever Staff agreements have been reached.
10 I think, by and large, that's probably the case.
11- (Slide.)
'12 ' The next slide indicates only whatcinspections we-l 13 have conducted thus far and what the. schedule for:
14 inspections is.
rO e 15 DR. MOELLER: Excuse me. Could I ask a follow-up' 1 I
16 on my question to help me understand. In other words, this 17 is a rule so it's not open to cost benefit consideration and i
18 even if someone showed that it was perfectly ridiculous in i' -19 terms of cost benefit, they can't make any headwayzwith such 20 an argument.
21 MR. VOLLMER: I didn't quite mean to imply that.
22 What I meant to imply was that the Staf f has to make a type 23 of a finding to an exemption to the rule. Staff has to make 24 the finding that it's certainly in the public interest and
~
25 that sort of thing. I won't say that Staff's finding is not 1
w
{4300 02 09 344 1 DAVpp -1 . influenced by reasonableness, cost-benefit and things'1ike s-2 that., In some cases ~the utility will say,-I would have to P"
jl tear the plant-apart to implement the rule but here's.a way
()'
>r, f-4 I can get around it and the Staff has to make their best 5 . judgment lthat this gives adcquate protection to the 6 provisions.in the rule.
7 Of the inspections that have taken place there is
-8 one, namely Calvert Cli f f s 1 and 2, that I-would 9 characterize as a successful inspection in that these units 10 -- but, as best the inspection process could determine, met 11 the rule-since they were the only one that had been 12 challenged.
13 We had a number of discussions with Baltimore Gas 14 and Electric to find their secret of success. The view we V(~s 15~ got from them was a bit different from what we had gotten f i 16- for a number of plants that indicated the rule was.so p 17 confusing and unworkable, .they said they just broke down-the o
18 provisions of the rule. .They!sent an electrical engineer e
19 and a systems engineer out.to-the plant, chased the systems 20 need for a safe shutdown, and just systematically applied.
21 fire protection or alternate wiring to provide the 22 well-protected path to safe shutdown in their plant.. It 23 didn't come cheaply. I think'they indicated -- if my
-24 ' recollection serves me -- they spent something like_$50
' h .- 25 million on fire protection back in the '77, '79,.80
e 4300 02 10 345 11 RDAVpp' 1- timeframe. When the rule came out they spent another $10 or 1 .
2 $15 million getting their two units into compliance for a f
3 total bill of maybe about $30 million. But, indeed, they O/
4 did meet it and I'm not_ going to argue whether or not that's 5 cost' effective.
6 But, again --
7 DR. MOELLER: That's comparable to what's in this 8 memo I was referring to of November the 15th, 1984. It was 9 from region 2. It says that if one facility -- it will-10 require over 200 people working full-time for the next one 11 and a half years to implement the Appendix R requirements at
12 an estimated cost of about $30 million.
13 MR. VOLLMER: I'm not sure that concludes the 14 construction or the down time if you've had to extend it out
(~
N.s 15 to implement the rule and a lot of other things.
F 16 Well, as you probably are also aware, based on 17 a region 2 inspection of one of the TVA plants, TVA said 18 that primarily because of fire protection they were going to
' 19 extend the fuel load for Watts Bar a significant amount of 20 time. There are enormous costs associated with that.
21 22 23
- 24 25
346 4300 03 01 l1 DAV/bc 1 I guess, in response to that, Watts.Bar again does 2 not have to meet Appendix R. I'm not very familiar with the
~3 totality of their problem, but I think they found some clear jn -
k/ t 4 deficiencies in the fire protection provisions for the plant 5' that even they perhaps were not aware of,.and that they
.i '6 perhaps thought were fixed.
7 MR. EBERSOLE: Did they find inadequacies in the 8 auxilliary shutdown complex?
4 9 MR. VOLLMER: Yes.
10 (Slide.)
11 Getting on to the steering committee work, as I 12 indicated before, we had a fairly limited charter, which is 13 fortunate, since we had fairly limited time also. That r- 14 charter was to look for policy recommendations, not any
%-]/
15 detailed, technical recommendations but policy 16 recommendations aimed at getting Appendix R behind.us, and
- 17. somehow getting the job done; because it appeared, again, as 18 if it were.a tar baby, that nobody could seem to let go of.
19 The people on the steering committee or myself, Nelson Grace
, 20 over in I&E. We had John Osinski, Lee Spessard, Ken Martin, 21 who are regional division directors in Divisions'1, 2 and 3.
22 And we had Tom Lombach, the Secretary, as our counsel. You 23 can tell we needed counsel as part of our process. But,.
24 indeed, it was a difficult situation because it does have a
.G 25 lot of legal implications.
V:
-4300 03 02 347 DAV/bc: 1 And as youlare probably also aware, the industry h- ~
2 did take the NRC to court on this rule, and our 3 implementation of the rule has always been one which we
' 4 .tried'to keep in mind. We've tried to keep in mind the 5 importance of the exemption process,.the importance of t
6 dealing with them even-handedly.
t
)
- i The issues that we considered first and foremost 8~ were the adequacy of current guidance. We felt it was 9 important to take a broad look at that. If you go back and 10 look at the documents that have been promulgated on Appendix 11 R, it's a several foot stack. And we know that would lut L
12 expected to help industry.
l -
13 The interpretation of Appendix.R, those are the 14 interpretations I talked about before where we negotiated an O'- 15 understanding with industry on what needed~toube in Appendix-t L 16 R and what needed to be interpreted as guidance from the.
l 17 staff.
18 That was the subject ' of a di f ferent profescional' i: 19 opinion. The treatmentlof exemptions was a corro11ary, the 20 comparison of old and new plants, which 1. mentioned before; 21 whether or-not our inspection program is adequate, and 22 whether or not there were any outstanding technical issues.
23 By " outstanding technical issues", I'm really.
24 talking about things that were not necessarily future in A terms of stuff the staff should be dealing with. They were 25
'4300 03 03 348 11 DAV/bc 1~ long-term fire protection. But were-there issues such as 2 . comparability of water and CO2 that we should be deal'ing
'3 with as part of this process.
\- 4 The steering committee met with the office p 5. directors, with Vic Stello. I met with Vic Stello to get.
6 .his thoughts. We met with the reviewers and regional 7
7 inspectors at a very large meeting to.get their input.
8 Since this issue had been sort of visceral-in 9 nature and evokes a lot of strong reactions and feelings, we -
10 tried to talk to everybody, at least in the Commission, that 11 we felt would give us a slant on how best to approach the
- 12. problem.
L 13 As a result of that, we prepared the report to.
' ~ 14 Mr. Dircks, which you have seen a copy of, and I'll very
' ~
J 15 briefly indicate what our major recommendations were.
1, 16 They simply indicate why these were important 17 things to do.
18 (Slide.)
19 The major recommendations, where we felt that, 20 first of all, we needed a complete regional workshop package 21 back in March and April, when we'left these regional 22 workshops, we told people that we would get back with them.
' 2 3'- We would revise the package of information we had given gg 24 them, update it, clean it up and send it out to them so they
'(_) 25 could go on their way and complete'their compliance with
r 349
~
4300 03 04
-1 DAV/bc 1 Appendix R. We envisioned that happening in about a month 2 or two.
3 As you can tell, the innovating thing with the O
l \~/ 4 Commission and Mr. Dircks' assignments kept us from doing 5 that. We feel now that we have a package which is not l-6 substantively different than what we gave out at the
( -7 regional meeting, and one that needs to get out there
- j. 8 because there are a number of plants that are in the middle, t
9 of spending a heck of a lot of money trying to meet Appendix 10 R.
11 There are also some plant, I must confess, that 12 are probably in the middle of deciding what they want- to do 13 to meet Appendix R. So you have all spectrums, a large 14 spectrum of compliance at the plants themselves.
15 MR. MICHELSON: This package you are referring to, 16 roughly, how big is it? Is this 50 pages of material? Five i 17 hundred?
18 MR. VOLLMER: The package basically is -- this is 19 it here.
20 MR. MICHELSON: It's attached to which? I just i
21 wondered i f I have the package. Since it is not a very big 22 document, I'll make sure I get one. I'd like to see the one 23 that you now are happy with and have gone out with.
- . 24 MR. VOLLMER: To give you the size, it's this.
'~ This was sent out for region comments and office comments.
25 i
(
~. _ .- . _ _
f 4300 03 05 350 1' DAV/bc. 1 MR. MICHELSON: I have a copy of.that dated
~2- October 26, '84.
3 MR. VOLLMER: That's it.-
n
- 4 MR. MICHELSON: That is-the one you're happy with?
5 MR. VOLLMER: .That contains the sam and substance 6' of what the committee felt they.were happy with. -
7 . MR . MICHELSON: It hasn't-been revised since?-
8- MR. VOLLMER: It has not been revised.
9 MR. MICHELSON: That's what I. wanted clear. Thank.
10 you.
i 11 MR. VOLLMER: Upon receipt of that, Dircks sent a
- 12 letter to Denton and the Regional Administer saying give me 13 your comments. He recently received a letter from j s., .
14 Mr. Dircks as a result of those' comments, characterizing it
'\,)
15 as generally supportive of what we had done here. But he 16 asked a number of additional questions. The questions
- 17 we r e-- I ' l l characterize them in a-couple of areas
18 One, do we have the resources to expedite our 19- inspection program? And, secondly, is what we're doing i
!- 20 necessarily safety-effective.
21 .Those issues, i f you ' l l recall, I was very. careful 22 to say we didn't look at whether or not it was worthwhile to 9
23 meet Appendix R from a cost-benefit point of view. But 24 since that was the rule, we were charged with trying to find C's- 25 the best way to implement it.
i
F-
- l 4300:03'06 .351 1.'DAV/bc .1 MR.'MICHELSON: Ik) ycu contemplate-issuing this 2 October 26th document?
. .3 MR. VOLLMER: Yes.
(~N
\- 4 MR. MICHELSON: But not when?-
5 MR. VOLLMER: Dircks also asked-that this be sent 6 out for public comment, which I'll do as soon as I can. 'And 7 he also asked that I solicit comments from the public and 8 evaluate those comments, and then ask for a response in 9 early' February. I don't think I can do that-by early 10 February. But I think it might be well when you go'through 11 this process, I. hope this would be a good timely place to j 12 have our subcommittee meeting with you at that' point.
13 MR. REED: Looking at this package I got confused fs 14 at looking at it.- I guess the question that Carl asked was u.)
^
, 15 how big was the package. If you' re going to have a sel f-
{ 16 standing package other than the_ question and answer thing we 17 see here, which relates to many.other documents, and you're 18 going to.go cut there with the intent of straightaway laying
{_
y.
t 19 it out like it-is supposed to lua according to the best 20 judgments of the day, what kind of a package would it be?
21 How many inches thick would it be?
22 MR. VOLLMER: I would say, if that were the 23 package, it would probably be twice as. thick as this one.
24 And it would contain the branch technical positions and'
) '25 documents which are pertinent to the review process, .and
- f. 4300~03 07 352
- 1 DAV/bc 1 which are referenced here. You rightly bring up the point.
2 This is question and answer, and this was in response
_. 3 strictly to the industry's request that we give_them answers b.
4 to their specific questions, because they already had the 5 other documents in hand.
6' If I interpret what you are saying a little bit
'7 differently,-could.we give a friendly guidance document 8 which would help people along the path of compliance, nobody 9 has addressed that.
10 MR. REED: What I'm thinking about is unconfused, 11 straightforward, not subject to millions of interpretations 12 type of documents to overcome what I think have been a lot 13 of past sins. You've got to keep in mind that the fire (g 14 insurance business was an insurance company business. The x_)
15 whole fire protection company was an insurance company-16 business up until about 1977 in nuclear plants. And,-
17 typically, utilities, they had the rules of the fire 18 insurai.ce companies. And'they'd go ahead and make their 19 design and they would submit their drawings and 20 speci fications - to the fire insurance companies.
21 They would mark up the drawings and send them back 22 to try to get into compliance, or pay penalties. Then the-23 Nuclear Regulatory Commission started to get into the fire 24- insurance business and we have to admit, as a result of O 25 probably knee-jerk initiation from, I gues s -- wha t wa s i t ?
4300103 08 353 (11 DAV/bc- :1 The'Dresden fire?.
2 MR. VOLLMER: Brown's Ferry.
3 MR. REED: There was one before that in the p...
= %/ .i -41 midwest somewhere. Quad Cities, or something? San-Onofre,
'5; yes.; 'Then, Brown's Ferry.
6 What I think.has been happening is that there has 7 been a fragmented approach,-a transition from insurance 8 company thinking and utility thinking over to NRC thinking.
9 There's been, in the early days, a lot of-repetitious'and
- 10. conflicting field inspections and directions from the-11 Brookhaven' Lab. Consultants were involved. They came out 12 and said, "Do this."
13 And then the next. wave of people would come out'
? 14 and say, "Do that." And the paper was not very clear in 15 those days.
16 Then I think there was some one-up-manship in 17 these'early inspection teams. . Confusion grew. Corporatism 18 flourished. There were diverse interpretations of differing 19 professional opinions within the NRC itself. .There was 20 hindsighting, vascillation, false starts, ' changing 21 quarterbacks. I can go down the list here. And there were ;
22 perhaps too many cooks stirring the broth.
23 Exemptions and perhaps variances on all those.
24 Even within our own regulatory area here, we see Chairman l .
25 Palladino's recent letter; that speaks to some problems. l I
l I
1 l
' .)
4300 03 09 354 1 DAV/bc 1 And then we've heard the comments of Mr. Tourtelette, and 2 kind of 'seen what Mr. O'Reilly has' written. Then I read the 3 steering committee report.
1 k 4 And I just wonder i f out of all of this past 5 history, if we'll be coming out with clear direction, 6 consolidated direction, that will lead us out of the 7 quagmire. And when you lead us out of the quagmire, as you 8 have pointed out, there are some structures in concrete that 9 are munk. They're sunk. They're fixed. And you just can't 10 modify those.
11 And I'm saying, well, decommission the plant. Ont i
12 thing that's always bothered me --
13 DR. SIIEWMON: Are you asking a question? I'm-14 waiting for the question.
15 MR. REED: Is there going to be a consolidated 16 document thet you think we can defend. I know that will i 17 take a lot of time.
18 MR. VOLLMER: I would certainly hope so. I share 19 many of the things that you've said. I think the feeling in 20 the staff back at the time the rule was initiated or was 21 initially promulgated was we didn't necessarily anticipate 22 backfitting the plants, that we'd alteady come to a general 23 agreement on fire protection. I think the staff felt that 24 industry and the staff would have an easier time of O 25 achieving two fundamental objectives:
4300 03 10 355 1 DAV/bc 1 One, good fire protection, and protection of 2 safety equipment. I f you ' ve got - fire suppression
-3 protection, protect.your safety equipment from fire. That's 4 one thing. And, secondly, that you have a well-protected, E well-charted course to safe shutdown in the event of a fire.
3 7
8 9
10 11 12 13 14 15 16 I. 17 lI 18 f
19 20 21 22 23 24 O 25
4300 04 01 356 1 .DAVbw 1 I think perhaps we were awfully naive, although, 2 of course, we knew we were backfitting our older plants. To 3 think that these fundamental objectives could be achieved
- Ch kJ 4 with a well-thought-out process didn't really happen. And 5 I'm not sure what we can do now, with the plants in various 6 statuses of implementation of the rule, to chart a new 7 course. What we're looking for is to try to, as you put it, 8 get out of the quagmire and get it behind us as cheaply and 9 effectively as possible.
10 MR. REED: Let me make a point. Throughout all of 11 this, I have been sympathetic that it's not easy for a new 12 organization to come into the fire protection business, pick 13 up all the old rules and move forward in a more g3 14 straightforward, more documented matter. It's not easy.
L) 15 It's a tough job. But one of the things I've found out 16 throughout my life is, you can get 10 fire experts. They'll 17 all go out and give you a different set of rules and 18 different judgments. It seems to be one of those skills at 19 variance, where these judgmental factors of old pros, as 20 they like to be known, just vary all over the place.
21 It seems to me, that this di f ficult job which you 22 started to f.ee, perhaps in 1977 or so, you would have to 23 try to come out with -- and keep in tind that the lightwater 7~ 24 reactors are not the toughest fire problem in the world.
25 Certainly, the big fossil 1000 degree, oil and coal, i
l
4300 04 02 357 1 DAVbw 1 lubricants all over the place, storage tanks, are the big 2 problems.
3 MR. EBERSOLE: May I cut in just a minute there.
'J 4 You can let the damn fossil plant burn completely 5 to the ground, and it's no public hazard.
6 MR. REED: I agree to that. So there's a 7 different ramification. That's why the NRC got into the 8 business, but the technology doesn't have to be the toughest 9 in the world in a lightwater plant. It seems to me, there 10 are weapons you ought to have headed for, and maybe you 11 are. Some minimum standards, in view of the environment, 12 temperatures and these kind of things. Clear standards, 13 clear rules. Then you can go on into the greater process,
<3 14 where you can do anywhere.
( )
'~'
15 MR. EDERSOLE: Mr. Vollmer, may I add a bit to 16 that comment 17 This fire business, there's nothing new about it.
18 It was known as far back as 25 -- 20 years ago. And I want 19 to comment about some of what he said here. All of these -- i 20 the arguments about whether you're protected or not 21 protected -- you know, they'll never go away -- that it will 22 burn or it won't burn.
23 This was brought out in '68 or '69, and the
,s 24 decision was made to interpret GCD-19 at Browns Ferry to
~'
25 absolutely include a remote disconnect shutdown system,
4300104 03 358 1 DAVbw 1 -which was placed off in a carbon dioxide storage room and 2 even only voice transmission, to prevent it's being a scene 3 of fire-actuated disaster itself. As you know, Browns Ferry
-N' 4 burned down. They'let it burn for six hours, and-it 5- survived anyway. And in the report that followed, NRC-6 prudently did not discuss at all, the merits or benefits, or 7 for that matter, shortfalls of having the aid of that 8 facility,-because it was unique to the business. I think 9 that report might be reexamined in this context as to 10 whether it did any good or not. It was a political-11 problem. But clearly then as now, you'll never settle the 12 issue of whether something will burn or not, if.it can burn 13 at all. And this is a complete noncombustible,-especially f- 14 if you bring in a transportable source.
-h-15 And the clear-cut and only solution to survive 16 fires is to have a truly independent and competent function.
17 to shut it down, when the rest of the plant burns out.
18 You never will escape having to do that. Any f
19 compromise at trying to protect what you've already got is 20 inevitably going.to wind up in interminable argument, and I 21 suspect that's where all the flap is. You can tell me I'm 22 wrong, but I suspect I'm right.
23 MR. VOLLMER: You're right, but on the other hand, 24 the option of how to make the rule is-not something.
25 MR. EBERSOLE: Maybe the rule has gotten too much
4300 04 04 359 1 DAVbw 1 protection of the old system and not enough independent 2 aspects of what should be there.
3 MR. MICHELSON: Dick, are we about finished up
. ,D
\
4 with your material, because 9:30 was kind of our drop-dead 5 date?
6 So if you want to take a couple of minutes to 7 summarize and finish up.
8 MR. VOLLMER: Yes. I'll just summarize. Again, 9 we felt that we needed to get the system package out to the 10 industry, although I think these are not too much different 11 responses to the answers that we had done in the regional 12 workshops.
13 There shouldn't be any surprises there, and we 14 have no indication since then that there are technical 9
15 issues that industry feels they're in the dark on, as far as 16 the Staff positions are concerned, or implementation 17 positions, for that matter.
18 We felt that the best way to get compliance with i
19 the rule to get things behind us, would be to expedite the 20 inspection program. This sounds like.the wrong way to go, 21 but the inspection program we had in mind was sending out a 22 team of people, fire protection reviewers, inspectors, 23 systems guys, electrical guys, out to the plant to look at 24 what the licensee is doing and make judgments as best they O
)
25 could on the direction that the licensee was taking and, if
)
- ~
'4300 04 05 360 2 DAVbw 1 you will, try to give them helpful inspections, try to say 2 you know, this looks like the type of approach the Staff 3 would find acceptable. This looks like it's a problem k l- 4 here. And to make suggestions. We're trying to be helpful 5 to expedite the process, to be as responsive as possible to 6- what the utility is doing currently; however, since.it is an
- 7. inspection, if the utility had failed to implement some 8 specific inspections, the rule should have been implemented 9 a long time ago, and we've never said they wouldn't be 10 liable to civil penalties.
11 Basically, the thrust of the inspection is to get I 12 out there in a hury with a team of people who understand the 13 problems, understand the issues and deal on a good basis 14 with the licensee's engineering organization. To do this, x-) 15 we thought it was necessary to have a good workshop for the v
16 NRC participants in this inspection. That goes without 17 saying.
i l 18 Two other things that we felt that our licensees 19 should have, standard fire protection license conditions 20 rather than the hodgepodge that's been out there, and 21 secondly, they should have standard toch specs, and whether 22 or not those tech specs need to be as detailed as what we 23 have in some plants or not, is another matter of opinion
~ 24 We' asked the working group that was dealing with bg one of our technical issues to look at standard tech specs.
25 t
_ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ . _ ___--__ _ _ = - - _ - . _ _ .
.4300 04 06 361 1 DAVbw 1 They have given us a package to deal with, and I 2 think you'll find that some of the tech specs that are 3 . currently existing in the plants just aren't really A
hs) 4 appropriate to -- in the tech spec package. They aren't 5 that safety-significant.
6 So those were basically the. recommendations of the f
7 Steering Committee. As I said, Mr. Dircks has responded 8 with a letter to make us look at the. safety implications of 9 some of this'. We'll put them out for public comment, and 10 that's something we'll pursue immediately, and I'll be happy 11 to hopefully have the results of those the next time the 12 Subcommittee meets.
13 MR. MICHELSON: Does February 5th seem a-14 reasonable time for a Subcommittee meeting?
%J 15 MR. VOLLMER: Mr. Dircks had asked for a February 16 1st response. I don't think we can go out for public 17 comments and get it back and go by February.
18 MR. MICHELSON: But would it be a good time to sit 19 down?
20 MR. VOLLMER: It could very well be.
21 MR. MICHELSON: If we're to provide any input or 22 help, or whatever, we'd want to be in the process yet, not 23 af ter the fact.
24 MR. VOLLMER: I think that's a reasonable time.
O 25 MR. MICHELSON: So you're going to check to see?
1 l
1
4300 04 07 362 1 DAVbw 1 MR. EBERSOLE: Mr. Vollmer, there are about 20 2 plants that you list here completed safe shutdown 3 inspections? What are there, about 60 plants or about 707
^
(~/
s
\- 4 Does this mean about a third of them or thereabouts haven't 5 been inspected, or is there a degree of inspection that's 6 going on all the time? How can I feel -- is this a 7 wilderness out there that nobody knows anything about, or 8 what?
9 MR. VOLLMER: Pretty much so.
10 MR. EBERSOLE: You didn't make me feel any 11 better.
l 12 MR. VOLLMER: I'd have to say that I think an 13 awful lot has been done in fire protection since the 14 1977 '78 time frame. A lot of protection's been put out
-}
L,'
15 there. Whether or not the plants meet the rule is a 16 different subject. Whether or not the plants are safe from 17 fire is different. The level of safety is not -- is hard to 18 pin down. I think an awful lot of work has been done.
19 MR. EBERSOLE: It's been advertised, anyway.
20 MR. VOLLMER: But in fact , we have not gone out to 21 many plants and done an Appendix R inspection.
22 MR. EDERSOLE: Thank you.
23 MR. MICHELSON: I believe that completes our one 7- 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Thank you. Thank you, Dick, and we'll look forward 25 to our Subcommittee meeting.
I
4300.04 08 363
-1 DAVbw ~l MR. EBERSOLE: The next session wilI be closed.
2 it's the llope Creek letter. It's'the reading of a 3 Sta f f-writ ten first dra f t. As you recall, I asked you 4 earlier.- We'll have a look at this, and I'll be expected 5 contrioutions on your pet topic by way of additional 6 paragraphs. Just append it to the copy that you have.
7 Do you want to clear the room?
8 (Whereupon, at 9:30 a.m., the General Meeting was 9 recessed, to enter upon a closed session.)
10 11 12 13 14 O 15 16 17-I 18 19 20 21 22 23 25
LICENSING MILESTONES NOV 19, 1980 FIRE PROTECTION RULE ISSUED FEB, 17, 1981 FIRE PROTECTION RULE EFFECTIVE
' ~
(72 UNITS LICENSED PRIOR TO 1/1/79) i MARCH 19, 1981 SUBMITTALS DUE FOR EXEMPTIONS AND MODIFICATIONS FOR ALTERNATIVE SAFE SHUTDOWN--60 PERCENT REQUEST EXTENSION 2 PLANTS (FT ST, VRAIN AND D.C. COOK) CLAIM COMPLIANCE JULY 1, 1982 REVISED DATE FOR COMPLETING SUBMITTALS JULY-DEC. 1982 RECEIVED APPR0XIMATELY 500 EXEMPTION REQUESTS, 10 UNITS REQUESTED N0 TECHNICAL' EXEMPTIONS AT THIS TIME, 30 UNITS COMPLETED
! DEC, 1982 APPEAL PROCESS FOR EXEMPTION DENIALS ESTABLISHED 225 EXEMPTIONS DENIED q JAN.-SEPT 1983 RESOLVING 225 EXEMPTION ~ DENIALS THROUGH REVIEW 0F REVISED EXEMPTION REQUESTS AND NEW PROPOSED MODIFICATIONS FOR ALTERNATIVE SAFE SHUTDOWN l CAPABILITY OCT, 19, 1983 ISSUED GENERIC LETTER 83-33, STAFF POSITIONS BASED ON REVIEW 0F EXEMPTION REQUESTS AND INSPECTION RESULTS NOV, 1983 Q EDO MEETING ON INSPECTION RESULTS
)
FEB. 1984 . INDUSTRY SEMINAR BASED ON GENERIC LETTER 83-33 0 '
AN INSPECTION RESULTS
~
( MARCH 1984 INDUSTRY APPEALS GENERIC LETTER 83 STAFF L
INTERPRETATIONS OF APPENDIX R MARCH-APRIL 1984 REGIONAL WORKSHOPS MAY 1984 DIFFERING PROFESSIONAL OPINIONS OF FPE'S, COMMISSION MEETING-COMMISSION TO APPROVE STAFF INTERPRETATIONS AND POLICY AUG. 1984 ED0 APPOINTS STEERING COMMITTEE OCT 26, 1984 STEERING COMMITTEE REPORT i JAN. 1984-PRESENT SUBMITTALS OF NEW EXEMPTION REQUESTS AND l ALTERNATIVE SHUTDOWN MODIFICATIONS BASED ON 83-33, WORKSHOPS AND INSPECTION RESULTS
) PRESENT STATUS - ORIGINALLY SUBMITTED UNRESOLVED EXEMPTION REQUESTS: 8 UNITS
- NEW EXEMPTION REQUESTS - 38 UNITS
- NEW ALTERNATIVE SAFE SHUTDOWN MODIFICATIONS -
15 UNITS
- ABour 1/3 ORS HAVE NO EXEMPTION REQUESTS O OR STAFF APPROVALS PENDING
- NT0L REVIEW FOR B0UT 10 PLANTS ONG0ING
I
. COMPLETED SAFE SHUTDOWN INSPECTIONS O .
! hRE-79 POST-79 l
FY 82 D.C. COOK 1/2 FY 83 FT. CALHOUN, TROJAN, DAVIS BESSE, FT, ST. VRAIN, VERMONT YANKEE FY 84
! SALEM, CALVERT CLIFFS 1/2 WATERFORD 3, FERMI 2, WOLF CREEK, BYRON 2 LIMERICK, MCGUIRE FY 85
! MAINE YANKEE COMANCHE PEAK, BYRON (REINSPECTION), FERMI (REINSPECTION, SHOREHAM
.O I
)
STEERING COMMITTEE REPORT
,O .
CHARTER - DEVELOP POLICY RECOMMENDATIONS AIMED AT EXPEDITING APPENDIX R COMPLIANCE AND ASSURING CONSISTENT LEVELS OF FIRE PROTECTION SAFETY ISSUES CONSIDERED: - ADEQUACY OF CURRENT GUIDANCE
- INTERPRETATION OF APPENDIX R O - TREATMENT OF EXEMPTIONS
- COMPARISON OF OLD PLANTS AND NTOLS
- ADEQUACY OF INSPECTIONS
)
- OUTSTANDING TECHNICAL ISSUES O
I <
lg n e
O .
RECOMMENDATIONS COMPLETE REGIONAL WORKSHOP PACKAGE EXPEDITED INSPECTION PROGRAM WORKSHOP FOR NRC INSPECTION PARTICIPANTS STANDARD FIRE PROTECTION LICENSE CONDITIONS O --
STANDARD TECH SPECS O
CERTIFICATE OF OFFICIAL REPORTER This is to certify that the attached proceedings before h the matter of:
UNITED STATES NUCLEAR REGULATORY COMMISSION in the NAME OF PROCEEDING: ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 296TH GENERAL MEETING DOCKET NO.:
PLACE: WASHINGTON, D. C.
DATE: FRIDAY, DECEMBER 14,1984 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission.
(sigt)
(TYPED)
DAVID L. !!OFFMAN Official Reporter ACE-FEDERAL REPORTERS, INC.
Reporter's Affiliation