ML20147A694
| ML20147A694 | |
| Person / Time | |
|---|---|
| Issue date: | 12/06/1978 |
| From: | Bender M, Etherington H, Seiss C Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T, NUDOCS 7812140193 | |
| Download: ML20147A694 (130) | |
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PUBLIC NOTICE BY THE 2
UNITED STATES NUCLEAR REGULATORY COMMISSION'S 3 - ADVISORY COMMITTEE ON REACTOR SAFEGUARDS '
4 ... .-
O. -
Wednesday, 6 December 1978
. 5 6 The contents of this' stenographic transcript of the 7 proceedings of the United States Nuclear' Regulatory
. 8 Commission's Advisory Committee on Reactor Safeguards (ACRS),
l 9 as reported herein, is an uncorrected record of the discussions 10 recorded at the meeting held on the above date.
II No member of the ACRS Staff and no participant at this l l
12 meeting accepts any responsibility for errors or inaccuracies 13 of statement or data contained in this transcript.
14 15 .
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. 16 -
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17 18'
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2
,T'(1568 i UNITED STATES OF AMERICA
(_,HEER:mp mask 2 NUCLEAR REGULATORY COMMISSION 3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS rm l
(-) 4 REGULATORY ACTIVITIES SUBCOMMITTEE MEETING 5
6 7 Room 1046 1717 H Street, N.W.
8 Washington, D. C.
9 Wednesday, 6 December 1978 p3 The ACRS Regulatory Activiti.es Subcommittee met, pursuant 11 to notice, at 9:50 a.m., Dr . Chespter P . Siess, chairman of the 12 subcommittee, presiding.
(~T 13 BEFORE: l
%-) l 14 DR. CHESTER P. SIESS, Chairman of the Subcommittee l l
15 MR. MYER BENDER, Member 16 MR. HAROLD ETHERINGTON, Member 17 18 ,
l 19 ,
l l
20 21 22 k/ 23 24 ,
Ac; r:I Reporters, Inc.
25
1558.01.1 3 j h 1 P-R C-E-E-D- I -N-0-S 2 DR. SIESS The meeting will come to order. This is l l
3 a meeting of the Advisory Committ ee or, Reactor Saf eguards, I) 4 Subcommittee on Regulatory Activities. I'm Cheste r Siess, 5 subcommittee chairman, and the other ACRS members present 6 today are Meyer Bender on my lef t, and Harold Etherington 7 on my far-.left.
8 The purpose of the meeting today is to discuss a 9 number of proposed actions of the staff relating to 10 regulatory guides and a couple of other related metters, 11 perhaps.
12 There are five guides that are on the agenda. The 13 first is a draf t regulatory guide on quality assurance
(') 14 program audit personnel for nuclear power plants. Second is v
15 a draf t revision 2 to Regulatory Guide 1.82 " Pe rso nne l 16 Selection and Training."
17 Then there's a draft of a new regulatory guide, 18 saf ety-related permanent dewatering systems, a draf t of a 19 proposed guide, " Atmospheric Dispersion Models for Potential 20 Accident, Consequence Assessments at Nuclear Power Plants."
21 And finally, there's a draft of Revision 1, Regulatory Guide 22 1.104, Single Failure Proof, Overhead Crane Handling 23 Systems for Nuclear Power Plants."
24 Now this meeting is being conducted in accordance
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( ), 25 with the provisions of the Federal Advisory Committee Act and p
's,1 ACE-FEDERAL REPORTERS, INC. (202)347-3700 ,
1.558.01.2 4 I the-government'in the Sunshine-Act. Dr. Andrew Bates on 2 myLimmediate right is the designated federal employee for 3 the meeting. The rules .for the participation in the meeting 4' today have been announced as part of the notice published.in 5 the Federal Register'on Tuesday, November 21st. A transcript 6 . of the meeting is being kept and will be made available, as 7 stated in the Federal Regist.er notice.
8 f t 2s requested that each speaker, eit'.ler at the 9 table or elsewhere, first identify himself for the benefit 10 of the reporter, and then speak with sufficient clarity and 11 volume so that everybody can hear 'him.
12 There are microphones there if you need them.
13 We have a written comment that has been received 14 from the General Electric Company on the draf t regulatory 15 guide relating - to " qualification of quality a ssurance program 16- au dit personnel for nuclear power plants."
17 That'is the guide that references ANSI /ASME 18 N45.2.23. We have had no requests to make oral statements at 19 the meeting. The staff has suggested the order of business
'20 is.that that I read ear 11er.
21 Does that still hold?
.22 MR. ANDERSON: Correct.
23 DR. SIESS: In addition to those guides, I will went
- 24. .to discuss briefly with the subcommittee what action we need O. 25 to teke simg1y es e precedure1 meeter end the cnenge to ACE-FEDERALLREPORTERS, INC. (202)347-3700 ,
mW*8 %rrpt-.
1558.01.3 5 h i Appendix 8 that we approved two months ago and has since 2 been slightly revised. But actually, it has been put back 3 the way it was when the staff came in and we approved
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4 something slightly different.
5 I will take that up with the committee at some time 6 during the meeting.
7 Okay, the.first item is the QA program, audit 8 personnel for nuclear power plants. Have you received GE's 9 comments?
10 MR. MILHOAN: Yes, we have, Dr. Sie ss. We received J1 them yesterday af ternoon about 2:00.
12 DR. SIESS* That is about the time I received it.
13 I have read it. I assume you have had time to read it.
14 MR. MILHOAN: Yes, sir.
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15 DR. SIESS: You will addre ss that.
16 MR. MILHOAN: In the time that we have had to 17 review the letter, we wi.11 address it, yes, sir.
18 MR. ANDERSON: Mr. . Richardson will make a 19 presentation.
20 MR. RICHARDSON: My name is Richardson. I work for 21 the reactor systems standard branch, draft Reg Guide 1. X XX ,
22 which endorses ANSI /AS1E N45.2.23-1978. It is entitled, 23 " Qualification of Quality Assurance Program Audit Personnel."
24 It has been forwarded to the ACRS for initial review prior to
(_) 25 going out for public comment.
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V ACE-FEDERAL REPORTERS, INC. (202)347-3700 ,
1558.01.4 6 h I The NRC staff has been involved extensively in 2 the development and approval of the ANSI standard, and with 3 the exception of one regulatory position, which is
"' 4 discussing the applicability of reg guides to other 5 N45.2 standards referenced in the ANSI standard, there is no 6 other exceptions to the standard proposed.
7 DR. SIESS: In the last sentence of 8, discussion, 8 well, let's say in the last paragraph, you point out that 9 this ANSI standard does not include the statement that is 10 contained in other N45.2 standards pertaining to its une for
.11 activities covered by the ASME boiler pressure code 12 Section I and 2 and Section Jl.
13 The NRC staff's review of the standard indicates 14 that it should be applied to these code covered activities.
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15 Now that is in the discussion, but it sounded more like a 16 position than anything in the standard.
17 That is a clearer statement than I find in 1.8 18 regarding the scope of the standard.
19 MR. MILHOAN: You may be right. It's just that we 20 were trying to point out that a commitment to follow this l 21 guide wo uld be a commitment applied to all types of activities.
1 22 DR. SIESS: But it is in the discussion, which is l 23 supposed to explain things. And I would not interpret it as 24 being a position, so I guess I don't know why you say it.
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/ 25 It seems to me in 1.8, you've got some very fuzzy A
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- ACE-FEDERAL REPORTERS, INC. (202)347-3700 ,
155 ,01.5 7 gsh I statements in the position as to the scope of the guide 2 and they're in a position and this is a nice clear statement 7- 3 that isn't in the position.
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4 So the question, is it a position or isn't it?
5 MR. MILHOAN: The answer is we consider it, yes, 6 a position that the standard should apply to. The code 7 covered activities, if it could be clearer --
8 DR. SIESS: It is perfectly clear now. It is not 9 a position. It is not in the position, so it is perfectly 10 clear to me. But if what is clear to me is not what you 11 intended, I would suggest that you make it clear to somebody 12 else.
13 There is no confusion.
MR. MILHOANs No, there should not be in that.
(]) 14 15 DR. SIESS: It is perfectly clear. It is not a 16 position. It comes under the section headed, dis c u ss io n .
17 MR. MILHOAN: We didn't think it needed to be a 18 position oecause the standard, the way it was written, did 19 not contain the exclusion statement.
20 DR. SIESS: Now wait a minute. The standard does 21 not include an exclusion statement?
22 MR. MILHOAN That's co rrec t .
23 DR. SIESS: You s ee, without -- I did not dig through 24 the standard because you did not re fer to the section. I
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(_) 25 thought that the standard did not include an inclusion q
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l ACE-FEDERAL REPORTERS, INC. (202)347-3700 .
1
0558.01.6 8 h I statement. And you're saying that it should be included.
2 MR. MILHOAN: Normally, the 45.2 standard series 3 . includes this inclusion statement in the first part of the
'\ > 4 standard. This one does not contain that exclusion 5 statement.
6 So we are trying to point out by this in the 7 discussion section that it does apply.
8 DR. SIESS: Why don't you say that, then?
9 DR. BENDER: I would like to raise a question about 10 this point because I gue ss I don't wholly agree with the J1 appropriateness of forcing the guide on the code business. l 12 The presumption is that the code does not have adequate 13 coverage of the auditing process.
I 14 DR. SIESS: Personnel.
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%., l 15 DR. BENDER: Well, the personnel for audit. The l 16 code has its own system projecting on the people that have 17 stamps, satisfying the code requirements.
18 In general, my observation about the audit groups 19 that do that is that they are people of very high qualification 20 and they have a range of capabilities that is somewhat broader (
l 21 than defined by this.
22 And the implication might be that you want to 23 substitute this kind of audit for that which the code ,
1 24 presently has. )
(o,) 25 DR. SIE3S: Mike, this does not refer to an audit.
,Y ACE-FEDERAL REPORTERS, INC. (202)347-3700 ,
1558.01.7 9 sh i This is audit personnel.
2 DR. BENDER: I can't help it, Chet. I understand 3 what you are saying, but it suggests --
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k' But I don't understand what you are 4 DR. SIESS:
5 saying. Are you saying that section --
6 DR. BENDER: This thing was written to cover 45.2, 7 as I understand it, which represent a s'et of quality a.ssurance 8 practices that are sort of apart from the code. And they 9 were written because the code covers certain things where 10 there was some kind of restraint on the other part of it that J1 left it outside the code.
12 Now what is being done here is to bring into the 13 code control some kinds of quality assurance arrangements that s 14 are going to be intermixed with what is already there.
V And it just seems to me it's going to confuse the 15 16 s it ua t ion .
17 DR. SIESS: Mike, I have a question for you. Does 18 the code cover the qualification of QA personnel?
19 DR. BENDER 2 Yes, it has certain kinds of 20 qualifications in it.
21 DR. SIESS: The audit personnel.
22 MR. MILHOAN: The article NCA 4000, I think you are 23 speaking of the inspection survey system of the code.
24 DR. BENDER: Well, that is a form of audit.
!) 25 MR. MILHOAN That is correct. But this, we are p)
ACE-FFDERAL REPORTERS, INC. (202)347-3700 ,
il558.01.8 10 t h 'l talking about'the applicants, audit personnel itself. We're j 2 not talking about the inspection, the code inspection and 3 survey system.
~s 4 ' The code in article NCA 4000 has general quality 5 assurance requirements that apply to the certificate holders.
6 In that article, they do have a general statement about 7 the qualification of personnel, but the' code does not provide 8 the guidance as contained in the 45.2.23 standard. And we 9 f eel this is guidance that should be applied to the certificate 10 holders audit personnel in determining their qualifications.
11 DR. SIESSs. Who is the certificate holder? ,
12 MR. MILHOAN The certificate holder being under 13 the code system who applies for the code, the tf stamp holders.
14 DR. SIESS: Not the applicant, though.
15 MR. MILHOAN: Not on this one, no.
16 DR. SIESS: Now this was written by industry, right?
17 MR. MILHOAN That is correct.
18 DR. SIESS: With participation by the NRC. And you 19 just gave a definition of who it applies to. Can I find that 20 in here? It just says any individual who performs an audit.
21 Didn't you just say it appl,ies to the certificate 22 holder? Is that all it applies to?
23 MR.'MILHOAN: We're saying under applicability 24 Section 1.2, for the auditor.
i
() 25 DR. SIESS: It'says audits for plant owner. That ACE-FEDERAL- REPORTERS, INC. (202)347-3700 ,
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I 1558.01.9 Ji kbh I would be the licensee, right?
2 MR. MILHOAN: Right.
3 DR. SIESS: Contractors or other organizations. Now t'%
(-) 4 Af I read that, I would not apply it to the stamp holder.
5 MR. MILHOAN: The stamp holder would f all into that. l 6 DR. SIESS: Under.which one? Other organizations? I 7 MR. MILHOAN: It could either fall into contractors 1
8 or other organizations, how the rel.ationship is between the 9 plant owner.
10 DR. SIESS: Now on the other N 45s, where they have Ji exclusion clause, where is that? In applicability?
12 MR. MILHOAN: It is normally in the applicability 13 section, in Section 1.2. For exampl e, in the 45.2.12 14 standard which is used in conjunction with 2.23, it's in 15 Section 1.2, the applicability section.
16 DR. SIESS: Could you read it for me? ,
17 MR MILHOAN: "The SME boiler pressure code, 18 hereaf ter referred to as the code, as we.11 as other American 19 national standards, have been considered in the development 20 of the standard. And this standard is intended to be 21 compatible with their requirements. However, this standard 22 does not apply to activities covered by Section 3, Division 23 1 and 2, and Section 11 of the code for those activities 24 covered by the code."
(]) 25 That is the code exclusion statement.
O ACE-FEDERAL RF. PORTERS, INC. (202)347-3700 ,
1
1558.01.10 12 h 1 DR.'SIESS: Now the people that wrote this 'l 2 deliberately left that out. I mean you were represented 3 on the committee.
4 MR. MILHOAN: I think Bill Morrison was on the group.
. 5 He was on an approval group. I don't think he was on the 6 . working. group. Frank Long of the Atlanta region office 7 was on the working group.
8 DR. SIESS: Am 'I correct that it was deliberately 1
9 lef t out and you're simply calling attention to the exclusion?
10 MR. MILHOAN: I'm not sure of that, whether it was i
Jl deliberately left out or not. But it is left out of the 1
12 standard. l l
, 13 DR. SIESS: Now if it were not covered by the 14 standard, is there anything in Section 3 or Section 1I that 15 qualifies auditors?
1 16 MR. MILHOAN: No, sir, not other than that i 17 ' general statement about you will have qualifled personnel, 18 that audits will be conducted by qualified personnel.
19 That is the extent of what the code has in 20 Article NCA 4000. . ,
1 21 DR. SIESS: It doesn't define what is qualified?
22 MR. MILHOAN: No, sir. ]
23 DR. SIESS: Who does define what is qualified? !
24 MR. MILHOAN: We are in the situation of having O 25 the person wne is eoing tne eudit determine the gue11ficetions.
ACE-FEDERAL REPORTERS, INC. (202)347-3700 ,
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.1558.01.11 13' Jh I It' is done on a case-by-case basis. ,
t 2 DR. SIESS: Now in other areas of the code, the 3- . inspection-type personnel, their qualifications are spelled j 4 out',.are they not?
5- MR. MILHOAN: In some instances, that's true. For 6 example, in Division 2, concrete inspection and testing i
7 personnel, there is a separate Appendix'to the code which 8 addresses that type of perso.nnel. -The code also has 9 provisions for using SNTC 1A with certain additional provisions 10 a pplying .
11 DR. SIESS: On the Division 2, I know they went 12 to put in the appendix for the concrete and inspection 1
13 personnel.
14 Now is there a parallel in Division I?
15 MR. MILHOAN: No , s ir , no , s ir . Not for those.
16 ' DR. SIESS: Why not? Because of the national 17 society that sets the requirements?
18 MR. MILHOAN: To give an answer on that one, I J 19 would say it probably is not. Something -- it just has not 20 been addressed. The detailed qualification is something ;
21 that needs to be developed.
22- I know we have provided correspondence to the 23 code groups requesting that they provide guidance.
24 DR. SIESSt.Now what is the national group, the 25 boiler' pressure vessel inspectors?
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ACE-FEDERAL REPORTERS, INC. (202)347-3700 ,.
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1558.01.12 14 h ! MR. MILHOAN The National Board. But we are 2 not dealing with that. We are dealing with actually inside 3 the code itself.
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> 4 DR. SIESS: Yes. But the Division 2 requirements 5 ..I thought were intended to parallel some national board I
6 requirements for Division 1.
7 MR. MILHOAN: For concrete inspection and testing 8 personnel?
9 DR. SIESS: Concrete is in the appendix. Steel 10 isn't, you said. But I thought the national board took care 11 of the qualifications of inspection and testing personnel 12 for steel. !
13 MR. MILHOAN: For the national board inspectors, l I think those are addressed in the 6.26 standards.
{} 14 There are some standards.
15 DR. SIESS:
16 MR. MILHOAN: That's correct.
17 DR. SIESS: And it's not Just left up to somebody.
18 MR. MILHOAN No, no, not for those. Not for the 19 inspectors that do the third-party inspections we are 20 talking about.
21 DR. SIESS: The ones for Division 2 will parallel 22 those because there was no comparable national board.
23 MR. MILHOAN I don't think that is the basis for 24 developing of the qualifications in the code.
(8 I think the 6.26 standards we are talking about,
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yh 1 'the qualifications of the authorized inspection agency 2 personnel, are the authorized nuclear inspector, as the code
.3 calls it.
O 4 But then within the certificate holders' organization 5 you also have personnel who perform inspections, and in the 6 code that is referred to as a small I inspector instead of 7 the capital I inspector.
8 So you've got other qualification requirements for 9 those type of personnel. And in Division 2, the concrete 10 inspection and testing personnel f all into the latter 11 category of the inspection personnel of the certificate holder 12 or the o'rganization performing the work. )
13 DR. SIESS: And you don't know the answer to the f 14 question as to whether this exclusion statement was lef t out
(~ )
15 deliberately, but you think it's a reasonable assumption 16 since it was included deliberately and the other standards 17 left out this one.
18 The last paragraph in B would be a lot easier for l 19 me to understand, and I think maybe some other people. If 20 it said what it really wants to say -- it does not include 21 the statement, excluding ASME 3 and 11 from the applicability, 22 and it is, therefore, assumed that it is applicable.
23 DR. BENDER: I think it is going to be done, but 24 we ought to get some response from the code committees first
$j 25 as to why, whether they think it is a good idea or not,
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15 .01.14 16 h I because it seems to me --
2 DR. SIESS: That is what I was tryir.g to find out.
3 If it was excluded deliberately, then pr esumably --
4 MR. MILHOAf4 In this regard, I might say that there 5 is activities presently underway with the boiler and 6 pressure vessel code people on the Section 3 and the Section 7 3 people, including in the code detaileci OA requirements.
8 Mainly it is in the e ffort of addressing the 1145.2 9 consolidated standard. l 10 I don't know whether you're aware of the consolidated
.11 standard effort which is underway, which will incorporate 12 a number of these standards inside of one standard, this 13 being 45.2.23 being one of those st an da rds .
The code -- we have an exchange of correspondence O 14 with the national board with the Section 3 code people, which, 15 16 af ter the publication of the consolidated standard, the code l 17 will take action to review the consolidated standard and 18 reference the consolidated standard in the code as appropriate.
19 The mechanism of doing it has not been decided yet.
20 DR. SIESS: Well, at least some of the members of 21 the 1145.2 subcommittee must be members of the code corrnittee.
22 Isn't Bill Morrison on the code committee?
23 MR. MILHOAllt flo , he is not. I am on one of the 24 code working groups. I'm on the working group on QA and n 25 V stamping.
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4 17 558'01.15 h 1 This .will be going out for public comment, the L,
2 code working group on OA.and stamping. I provide a report-to 3 it on each meeting on which' quality assurance guides we have 4 published for public . comment.
5- And in this particular one, I would supply copies -
6 of the regulatory guide to the working group on OA and 7 stamping at the time this' was published'for public comment.
8 DR. SIESS: I think that that might be a way of
- 9. finding out what they think , Mike. It is going out for 10 comment and it will be referred to the code committee. ,
11 DR. BENDER: Well, I certainly am. willing to have 12 it out for comment, but I don't want to sanction a position l 13 that 'should incorporate code practices in this, or vice i versa, without knowing that the code committees recognize
(} 14 15 that they need to do that.
16 DR. SIESS: Well, I'm not sure about the vice versa.
17 I hope the code committee would not have any objection to 18 them using code procedures. But to impose these on the code 19 is another thing.
20 DR. BENDER: That's what I'm concerned about.
21 DR. SIESS: Also, what he said, I'm not quite sure 22 that I really understand what the criteria' are f or personnel
- 2) in doing code QA work.
24 DR. BENDER: I would say that these requirements are
([ 25 . not very substantive as. written, but they are better than O
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1558.01.16 18 l fh j n thing.
2 DR. SIESS: How about a response to the GE comments?
3 I wonder if the point count system that they have been
' ,)
' 4 complaining about -- that was one of their comments -- I 5 don't know what term they used, whether it was arbitrary.
6 MR. RICHARDSON: Co un te r-produc t ive .
7 DR. SIESS: That's true of most standards, but I 8 don't think I would condemn it on that basis, but 9 nonrealistic. And then they do have a comment in here which 10 is a legalistic one, but I don't think is one that can easily 11 be ignored about the validation of examination criteria, l 12 gentlemen, in Title 41.
13 What is Title 41, anyway? I know what they are 1
14 re f e rring to, this business about tests and validation of
('~j}
15 test. But I'm not sure whether HEW or who promulgated it --
16 MR. MILHOAN: I think on the examination criteria, 17 we have to examine that question prior to it being published i 1
18 for public comment. We have not talked to our lawyers. We l 19 plan on talking to our lawyers and referring that comment to l
20 the lawyers for them to address prior to it being published.
21 The first question on the credit point count 22 system, I don't think that at the present time we have looked 23 at it, that we would agree with the GE proposal that it be 24 included as nonmandatory guidance. But I think it is a r-)x i
x 25 co mment that we can f urther consider with all other public q
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1558.01.17 19 h I comments we received during the public comment period and 2 provide a further resolution to you when we come back.
3 DR. SIESS: In developing that point system, do k~ 4 you have any idea how they go about it? Those things contain 5 one pitfall after another. You need to check the thing to 6 see if it works. It is like scenarios like they have drawn 7 there.
8 How extreme can you get on something like that?
9 What is the lowest qualification that will add up to the 10 points and what is the highest qualification, the qualified 11 person who won't add up to the points?
12 It is almost like their example. Obviously, there 13 is an infinite number of possibilities. I've seen things like
(~T 14 .this that look logical until somebody sat down and wrote q,.!
15 them. But when you applied tests to them, they looked 16 absurd.
17 Was it checked against people that hold positions 18 like this to see if they were qualified?
19 MR. RICHARDSON: I could not answer that.
20 DR. SIESS: How many lead auditors are there in 21 the business?
22 MR. MILHOAN: I don't have the numbers.
23 DR. SIESS: Are we talking about ten people or 50 24 people?
()j
?
25 MR. MILHOAN: We're talking much more than that, but
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h 1 I don't know the number.
2 DR. ETHERINGTON: How many Rhodes Scholars have a 3 Ph. 0 In nuclear engineering, et cetera?
4 DR. SIESS: What I would do if I were going to l 5 write the standard with the kind of committee that existed 6 here, because the subcommittee, obviously, contains (
1 7 representatives of B&W, and I don't see' combustion, but people 8 that employ lead auditors. I would have picked a random 1
9 sample of 15 people or some significant number, and checked 10 their qualifications against this.
JI MR. MILHOAN: I don't know whether that was done, but 12 it would not surprise me if the working group did not do that.
1 13 I was looking at the composition of the working group, and
{} 14 15 you Love a broad representation on the working group itself.
B&W, you have GE, you have American Society for l
16 Quality Control represented on the working group. I 17 DR. SIESS: Now comments like the ones submitted 18 by GE will obviously be considered by the NRC as part of 19 your process. But since this is a comment that .is directed 20 at the standard, is there some mechanism for transmitting 21 GE's comments to a standards committee for comment?
22 MR. MILHOAN: We have done that in the past and 23 we can do that with this letter. We do forward comments that 24 are on the standard to the standards working group and we
(,) 25 will, in this case, we would certainly do that.
I'D v
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1.558.01.19 21 h 1 DR. SIESS: Would we get their response back? I 2 assume that that would be a part of the public comment.
3 MR. MILHOAN: We can certainly ask for a response
\- 4 back when we forward it to the working group and include 5 it in the package that comes back for your consideration.
6 DR. BENDER: Well, GE gets the same notice of the 7 standard as every other industrial participant gets.
8 DR. SIESS: I'm concerned about us seeing the 9 ccmment and response from the standards committee, not from 10 NRC.
.11 DR. BENDER: Well, that'may be appropriate, but 12 gosh, there is all kinds of chit chat of that sort going back 13 and forth.
/~3 14 DR. SIESS: Well, you raised the question as to the
's_/
15 adequacy of the standard rather than of the Reg Guide. And 16 I think if we are going to endorse a Reg Guide or concur 17 with a Reg Guide that endqrses a standard, we had better be 18 sure that the standard we are endorsing is one we agree 19 with.
20 DR. ETHERINGTON: It would s eem reasonable f or the 21 guide to provide for an alternative on a case-by-case basis, 22 wouldn't it?
23 DR. SIESS: That sort of defeats the purpose of 24 the guide.
() 25 MR. MILHOAN: That is true, but that is stated in I
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15 01.20 22 gsh I each Reg Guide that is issued on the first page of the Reg 2 Guide, that alternatives are acceptable.
cm 3 DR. SIESS: Well, let's remember that statement
) 4 when we look at the next Reg Guide, will you, please, because 5 you have clearly made case-by-case exceptions.
6 In the next Reg Guide we are looking at -- you know 7 what I'm talking about, Harold?
8 DR. ETHERINGTON: Sure. But here there is a real l 9 question. So it might be we.ll to state it specifically.
10 MR. MILHOAN: I think it is something when we J1 consider the GE comment in further detail during the public 12 comment period. It may be that we might want to add the 13 additional suggestion to the Reg Guide.
() 14 DR. SIESS: I just wanted to check something.
15 General Electric was represented on the working group 16 as a secretary. I guess it would be reasonable to assume 17 that GE nade that comment when the guide was being written.
18 DR. ETHERINGTON: That may be and may be not. It 19 may be an afterthought.
20 DR. SIESS: Mr. Hossack of GE was secretary of the 21 working group.
22 Mr. Shirley, do you know whether GE's representative 23 made this connent to the ANSI working group?
24 MR. SHIRLEY: Noel Shirley, General Electric. Mr.
r's LJ 25 Chairman, GE offered both of these comments to the working
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- 1558.01.21 23 h 1 group. The working group did not accept either of the 2 comments and consequently, GE cast a negative ballot on 3 this standard because of these comments.
(,. s)
4 DR. SIESS: I .think we definitely would like to 5 see the working group's response to GE's comment because I 6 think it is a substantive question. And if ANSI is not 7 looking at negative votes as strongly as they ought to be, 8 then you guys should be.
9 They are supposed to resolve negative votes. There 10 must be somewhere in the.f r flies a resolution of that ll negative vote. If they can find it is not substantive, they l
12 can overrule it. But it is a consensus standard and they've 13 got an obligation.
<T 14 And I would assume that the staf f looks at
(>
15 resolutior s of negative ballots on standards that they are 16 endorsing.
17 Do you? l l
18 MR. MILHOAN: When it goes through the nuclear power l 19 codes and standards committee level, we do see the negative 20 ballots at that level.
21 DR. SIESS: Well, the negative ballot would have to l 22 go all the way up.
1 l
23 MR. MILHOAN: That's correct.
24 DR. SIESS: If they cast a negative vote in the im
(_) 25 working group, that would have to be resolved. Now the thing is ACE-FEDERAL REPORTERS, INC. (202)347-3700 ,
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15 01.22- 24 h l' 'the subcommittee, tne N45 subcommittee can accept the
-2 : working group's' resolution of a negative ballot. I don't 3' know what the procedure is, whether that is passed on to the 4 next level or not.
5 I know in the ASME code that I review standards ---
6 I'm chairman of the standards board and we see their L 7 talleys of negative ballots and resolutions at every level 8- from the working group right up to the full committee. And 9 that if there is a negative in the working group, we'd know ;
10 that there was a negative and we know how it was resolved.
-11 And it gets up through. ,
12 It might have been no negatives at the levels 13 above, but that negative carries through. And it seems to i 14 me the staff -- these are very knowledgeable working groups.
( 15 I'm sure that's true. And negative ballots are not minor 16 things, obviously. 17 .MR. MILHOAN That's right. Well, in this instance, 18 .we can certainly retrieve the material. 19 DR. SIESS: Well, you can check with Long. He would 20 know. But what I'm saying is I think as a general rule, when 21 the NRC staff is endorsing a consensus standard, they should 22 get a pretty good feeling from the NRC representative, and 23 you almost always have one on.there, as to just what he 24 thought about-a negative ballot and how well it was resolved. O 25 oa. esNosa, 01d Os neve some e1ternet1ve t
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c P S I)S58.01.23 25 Clw sn- I -qualification approach .that they would use in lieu of 2 examination? 3 MR. SHIRLEY: Dr. Bender, I was not involved with 4 the writing of that standard, so I really can't respond one 5 .way or another. . I simply don't know at this point in time. 6 I can, however, get that answer for you. 4 7 DR. BENDER: It does just seem to me suggesting 8 that something is nonmandatory without offering some kind of 1 9 alternative. It's hardly a basis for determining whether it 10 made any sense or not to make it nonmandatory. 11 DR. SIE.SS: Well, they say it deprives management 12 of a selective prerogative. They're simply saying they 13 would like to be able to make the subjective judgment 14 assisted by a point. count. [ ); 15 DR.-BENDER: That is your interpretation but not 16- my interpretation. 17 DR. SIESS: We would need to have something like 18 a point count, or do it subjectively. I don't know which is 19 best. ; 20' DR. BENDER: My presumption is that when the group 21 that wrote the standara initially decided to put in an 22 examination procs s ha:cuse they concluded there wasn't any i
-23 basis for qualif ying -- !
24 DR. SIESS: It is not an examination process.
-. () 25 DR. BENDER: We11, it is a form of it. It is an a
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1 l =155 01.24 26.
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gsh 1 evaluation procedure. 4 2 DR. SIESS: They don't even evaluate the experience. ( 3 .You just exist two years in the business and you've got two , O 4 points. Performance doesn't even enter. 5 Do you have any objection, then, to let this go 6 out and we will take a good look at .it when it comes back? i 7 DR. BENDERS No. l
, i 8 DR. ETHERINGTON:. No.
9 DR. SIESS: Okay. Now the next item, then, is 10 draf t 1, revision 2 of Reg Guide 1.8, which is designated JI personnel selection andftraining.' And this one endorses 12 an ANSI standard, ANSI /ANS 3.1-1977. j 13 And before you start presenting this, let me make , a comment that you can address .in your presentation. We do (]) . 14 15 have your le tter of November 27, 1978 from Arlotto to 16 Fraley, containing a revision of position I, which is one of 17 the nicest pieces of double-talk I have ever read and which l 18 ends with'the sentence, "These will be determined on a 19 case-by-case basis." 20 I would just recall what I was mentioning before. 21 I found the presentation on the standard confusing. And I. 22 - gue ss I am talking about the whole thing. I have been following 23 my usual practice of concentrating on the regulatory position
. 24 and then looking at the value impact statement. And I sort
) 25 offgot-lost-in here.
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1558.01.25 27 h I You took-out the radiation protection manager 2 stuff because it is in the new standard, right? 3 MR. RICHARDSON: That's. correct. O~- 4 DR. SIESS: It is almost word for word. And then 5- you added, what you mean, equivalent to bachelor's degree? 6 Has that been done in any other? 7 MR. RICHARDSON 2 I don't thinic that wording has
'8 been added.
9 DR. SIESS: I can see the importance because our l 10 equivalent appears most of the places. And I guess that 11 is almost a point count. thing again, gentlemen. And part of 12 that, the problem most was one equivalent bachelor's degree I 13 is four years of formal schooling. , 14 Now a bachelor's degree is usua.11y four years of 15 formal schooling completed at a level high enough to get a degree.- And I would have to assume that the alternative to 16 17 ' that is four years of formal schooling, of which the guy 18 flunked out in his senior year, or something of that sort. 19 I guess I'm trying to make a distinction in my 20 mind be' tween a degree and four years of schooling. There must 21 be some . difference. Being a f ormer professor, I was trying 22 to.think-of the cases where they are now equivalent here. 23 And I would like ' for you 'to try to explain by means of a 24' scenario how they are different in real life, but similar h 25 in qualifications. O- -
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s l'55 .01.26 28 h: .I My first impression is it is a guy that -flunks out. 2 Is he as qualified as the guy that got a degree? 3 But if there. is a better interpretation of that,
-; 1:). 4 explain it to me.
3-5 MR. BECKHAM: The alternative to completing four 6 years and ge.tting a degree is completing four years and having 1 7 to change curricula sometime in the midst of that.four years. 8 And because of rigorous requirements for. degrees.in most 9 universities, not getting a piece of paper that says you have , 10 completed three courses inithis and four courses in that, 11 although the four years perhaps started out as a chemical 12 engineer in the midst of the course of studies switched over 13 .into a pure science curriculum, at the end of four years, {) 14 did not have.a degree for lack of having met the degree requirements for either one of the majors, but having finished 15 16 four years of science or engineering training. , 17 DR. SIESS: Well, they are not nearly equivalent 18 in my mind. A degree curriculum in any reputable university 19 has been very, very carefully worked out, ti11 the student L 20 completes courses that the professors .think are essential to 21 get a degree in that field. 22- And what you're saying is those requirements are 23 just meaningless and if he goes to school for four years and 24 doesn't take the sequence of course that the professional d) 25 faculty thinks l'eads-to a degree, he is st.ill qualified, i e ACE-FEDERAL REPORTERS, INC. (202)347-3700 , i
11558.01.27. 29-h I although they don't think he'is. 2 Now I will give you another scenario. It used to 3 be- more true- than it is now. , 4 Very few students got a degree in four years or 5 eight semesters because they either could not take enough 6 ' credits each semester, and they used to take 9 semesters or J 7 sometimes 10. And.this would say that a' student could attend , 8 8 semesters, taking less than, say, the 15 credits, as it 9 may be in some schools, and not enough credits to get a 10 degree, but he still could qualify. J1 But you don /t define it'here. But neither of those 12 to me seem equivalent. 13 Degree requirements are just not arbitrary. You j l say science, and that .may not be a professional school, but {} 14 15 engineering is a professional school in most places. And 16 tho s e . degree requirements are not arbitrary things. They are I 17 things that the f aculty Have decided are requirements to 18 become a professional person, to meet professional requirements l 19 in the field. J 20 And we are talking about professional people here, 1 21 because you aren't. requiring too much beyond that in some 22- cases.. How much are you requiring beyond a bachelor's degree? 23 It is that plus experience, but it varies for the positions, 24 .doesn't.it? , j[)I 25- I find it hard to see a one-to-one equivalence there. ,
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o- !!558.01.28 30 ; v jhj i MR. BECKHAMs The reason the equivalency is 2 included:In the-standard, the phrase, " bachelor's degree or 3 Lequivalent," is to preclude the situation where you are 4 saying-the requirement for a bachelor's degree on most of 5 the positions that are considered advancement positions in 6 a utilities organization. 7 Obviously,.if you require a bbchelor's degree for 8 most of the positions described in the standard, you are 9 severely restricting your chances of advancement for anyone 10 unless he has a bachelor's degree. 11 Therefore, the standard and NRC practice in the 12 past has included "or equivalent." 13 DR. SIESS: I don't object to your setting your 14 standards. If you want to set your standards as 4 years of 15 college or 4 years of experience, or any combination thereof,
-16 I think that is somebody that can judge what the job requires.
17 My only question is that I' don't. think 4 years of 18 co.llege is equivalent to a bachelor's degree. You don't have 19 to require a bachelor's degree if the job does not need it. 20 But I don't.think that you have a right to say that 4 years
, 21 of. college without a degree is equivalent to 4 years of 22' college with a degree.
23 MR. BECKHAM: The only problem is that we don't 24 restrict the f ormal schooling. () 25 MR. MILHOAN You are talking about a Reg position 6. Q ACE-FEDERAL REPORTERS, INC. (202)347-3700 , t i e-- ,. ,. s . -- , , -~ws -.
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1558.01.29 m 31
- q\vJh I. Really,'you're saying, if I read it carrectly, 2 that you have no objections to the ABCs and Ds if we' thf nk 3 those are what is acceptable. But we should not equato them 4 to being equivalent to a bachelor's degree.
5 If we would reword that position, that would be 6 cl ea re r. 7 DR. SIESS: That's right, because I don't.think they 8 nec'e ssarily are. I'm not sure that A and B are equivalent 1 9 without some judgment. Four years of experience may or may not 10 be equivalent to four years of schooling. It may be better, J1 it may be Ir;ss. 12 MR. MILHOAN: So if the Reg position said, instead 13 of places where it says a bachelor's degree or equivalent,
, 14 the following is .also considered acceptable.
)
15 DR. SIESS: You could list your minimum requirements 16 and one could be a bachelor's degree and one could be four 17 years of college. ^ 18 I guess it just bothers me that you're calling it 19 an equivalent when I don't think it is. 20 MR. BECKHAM: Dr. Siess, the problem that we have 21 got is the' standard lists minimum requirements for each
- 22. position and typically, when it has these requirements, it 23 lists a bachelor's degree or equivalent without giving any 24 qualifications.
() 25 We have, therefore, said when the phrase, 0; ACE-FEDERAL REPORTERS, INC. (202)347-3700 4
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h'558.01.30 32
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(vdh I bachelor's degree or equivalent" is used, the qualifications 2 that are considered equivalent to a bachelor's degree are 3 high school diploma, or equivalent, and the following. 4 DR. SIESS: I see what you are getting at. l 5 MR. BECKHAM8 If we say, when the phrase, " bachelor' l l 6 degree or equivalent" is used, we consider the following as 7 minimum substitutes for bachelor's degrse. 8 DR. SIESS That would help, I gue ss. I think the 9 standard is poorly written. I think the standard ought to 10 say that meets the requirements of section so and so, and l
.11 then that section lists the equivalent requirements.
12 I think this bachelor's degree or equ.ivalent is a 13 phrase that has cropped up without anybody. thinking about what it means. p)
\-
14 l 15 MR. SULLIVAN: There is a qualifier there in the 16 first line that says, "For the purposes of this guide." In 17 othe r words , we're not trying to set academic standards. It 18 Jus t says within the constraints of this guide that an 19 individual could be considered to have a bachelor's degree. 20 I don't know if that helps or not. 21 DR. SIESS: It helps a little. 22 MR. BECKHAM: I think the problem that we have 23 gotten into is high school diploma or equivalent has become 24 a well accepted phrase, and there are well accepted () 25 equivalency examinations and procedures f or determining ACE-FEDERAL REPORTERSr INC. (202)347-3700 ,
1558.01.31 33 h I equivalency for high school education. 2 DR. SIESS: I guess I'm prejudice. I think there's 3 a great deal of difference b9 tween the high school equivalency ('-)' 4 and a professional degree equivalency. l 5 MR. BECKHAM: I agree with you entirely. 6 .Unfortunately, the phrase got into the vernacular and has l 7 been carried over here. And we are trylng to address what 1 8 we consider a deficiency in the standard by giving something And this is what I 9 that says we qualify that, or equivalent. l 10 we will accept as a substitute for a bachelor's degree. 11 DR. SIESS: Well, there are a number of other 12 deficiencies in these requirements. The science or 13 engineering, there's an awful big difference between the 14 science curriculum and an engineering curriculum. And there
)
15 are differences between degrees, whether a school is 16 accredited or not in engineering. And there is some 17 accreditation in science. 18 So even your bachelor's degree sets a pre. tty low 19 absolute minimum. And I think that people -- what bothers 20 me, I guess, going back to that other guide with the point 21 system, that removes any judgment from the picture, I think 22 your standards have gotten awf u.lly low. I mean these 23 standards applied with judgment can be very good. You judge 24 a man's experience by what kind of positions he's held. () 25 If he is a physics major, you see how he is
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( jh I performing in engineering situations and you judge that. 2 But as soon as you get to something like that point down 3 in the other guide where there is no judgment involved as
') 4 to what kind of degree he has or what kind of experience 5 he has, or how well he did, your minimums have dropped I 6 think a lot lower than these words sound. j 7 The words sound good until you look at what they g,( 8 mean.
9 j 10 l 11 12 l 13 l 1 IA ("% U/ 15 16 . i 17 j 18 19 I 20 21 22 23 24 (~) 25 t, O ACE-FEDERAL REPORTERS, INC. (202)347-3700 I A
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,t-2 mte 1 ; MR. BECKHAM: I think here we're trying to give some i indication of the f act that we will accept an evaluation of 2
3 this other experience or alternatives to bachelor's degree, so
] 4 that we clear that ambiguity up. We are not holding anyone specifically to a bachelor's degree, and I don't think that !
5 using these words, we are holding anyone to a rigid set of 6 standards that don't allow for this eval'uation. 7 1 DR. SIESS: I'm not sure you were here, but the other ; 8 l guide that GE objected to the point system, you are. I'm 9 10 trying to relate -- your approach here is more nearly consistent, jj and I'm sure it's not exactly the same as GE is proposina as a 12 m nagement preroaative. But it tends to recoanize GE's comment on the previous one. 13 ja Well, while we are on that list, the difference between B and C, I guess the people that apply this know what 15 16 it means. But the difference between four years of applied i p experience at a nuclear facility and four years of operational r technical experience / training in nuclear power. Now, one is 18 j9 nuclear facility and the other is nuclear power. One is applied 20 experience and the other is operational or technical experience, 21 or o erational or technical trainina or technical trainina -- 22 I'm not sure whether the " experience /trainina" applies to peration" or " technical". !: 23 24 I ascume the slash is eauivalent to an "or," is that ; Acefedtrtl Reporters, Inc. 25 right? ( l 4
% [. .
mte 2 36 (~3 1 MR. BECKHAM: Yes.
\.)
2 DR. SIESS: I would sugoest you might use the word 3 instead of synbols . , () 4 Can you explain a little bit as to the difference ' i 5 between B and C? 6 MR. BECKHAM: B is applied experience. 7 DR. SIESS: Define what is applied experience. What l 8 other, what experience does it exclude? I 9 MR. BECKHAM: It excludes situations such that a 10 person is merely observing. You have to be in a nuclear II facility working in the area to which you seek oualification, 1 12 rather than as an observer watching someone else perforring ; 1 13 the Inanipulations, performing calculations, e'
- etera.
I4 DR. SIESS: I will buy that, i 15 MR. BECKHAM: And C, when you're talking about 16 operational technical experience or training. 17 DR. SIESS: Well, let's zero in. Let's take experi-18 ence first, because that parallels the other one. 19 MR. BECKHAM: Experience, I acree, does parallel the 20 other. 21 DR. SIESS: And operational and technical experience, 22 do you think means the same thing as applied experience? p- , A/ 23 FR. BECKHAM: To me it does, yes. 24 DR. SIESS: To me it doesn't, because if it meant the I Ace-[edirst Fleporters, Inc. (_) 25 sane thing you would use the same word. I nean, I am a literal 4
ate 3 - 37
/'~T 1 reader, and I don't equate three words. I assume that the V
2 writer chose words because they had different meanings. 3 MR. BECKHAM: I acree with you, and I think that that () 4 might be clarified. The words selected here were taken because 5 they were a position approved by the RRRC. They were taken 6 verbatim. 7 DR. SIESS: That doesn't explain them. 8 MR. BECKHAM: I agree with that also. They were 9 taken because they are an existing approved staff position. 10 They were therefore put into the reg auide word for word. l 11 DR. SIESS: I was coing to try some cobbledyaook to 12 see if I could make ten bucks. l l' em 13 (La uchter . ) (%s) l 1 14 MR. DECKIIAM: The purpose is to recoanize -- 15 DR. SIEES: The standards have already been made once. 16 MR. DECKHAM: C was intended to recognize training 17 programs such as participation in research reactor studies, on 18 the job trainino in nuclear facilities. 19 DR. SIESS: Now, nuclear facility here -- you see, you 20 use "in nuclear power" rather than "at a nuclear facility." And 21 I got the impression that every thino in C would be done not at 22 a nuclear facility. n) (- 23 MR. BECKHAF: Mell, that is what it is supposed to 24 apply ' is experience at a nuclear facility, because you i A not Reporters. Inc. 25 are'lookii ' for --
m mte-4 38 r 1 DR. SIESS: The nuclear facility need not be a power ( . 1 2 plant. 3 MR. BECKHAM: That's right, it need not be a power
.( ) 4 plant. But C is intended to be more restricted to power plant 5 experience or training for or at a power plant. ;
i 6 DR. SIESS: But you did not say facility or plant ! 7 there, so I was trying to get what you meant by "in nuclear I 8 power" and where you get the training if it wasn't in a facility l 9 or a plant. 10 Does it really mean power plant? 11 MR. BECKHAM: A course of study in nuclear engineerind. . l 12 DR. SIESS: Nell, that is neither a bachelor's degree 13 or A. 14 DR. BENDER: Well, it might be a nuclear laboratory. 15 MR. BECKHAM: That's right, it could be a national 16 lab. l l 17 DR. SIESS: But it would be in nuclear power? l 18 MR. BECKHAM: Right, 19 DR. SIESS: So 4 could be nonformal schooling, but 20 training? 21 MR. BECKHAM: Right. Another good example -- 22 DR. SIESS: And training is different than education?
- 23 MR. BECKHAM: Another ocod example is the Navy's 24 nuclear power training procram.
' Ace fedirtl Reporters, Inc. () 25 DR. SIESS: And you understand that and I understand. myg s g.w w . 4
mte 5 39 (') v 1 Does anybody else understand it? 2 PP. . BECKHAM: It has been used for about two years. 3 DR. SIESS: That doesn't answer my cuestion. ()
/m 4 MR. BECKHAM: When we ask the question, we get the 5 reply that we want. That is one reason that it is in the guide 6 in the present form. It is the approved position. And this is
. 1 7
going out for public comment, and hopefully we would find out 8 if people understand it or not. 9 DR. SIESS: Not necessarily. What you would not know 10 was whether they understood it the same way vou do. They might i 11 think they understand it, but actually what you cet when they 12 submit something is a list of experience and education and so
- 13 forth, and you then apply the criteria. And if they didn't ja understand it right, you tell them they did not understand it 15 rich t , and they would try it anain, like a lot of other things.
16 DR. BENDER: This is about the most confusing wording 17 you could find. 18 DR. SIESS: These very short statements, f recuen tly 19 when you start analyzina ther and you get to the point count 20 type of approach, they are -- well, we pre-empted your presenta-21 tion. I think you might start in and oive it to us, and then 22 we will no through this, r~~ ( >} 23 I think there are a few minor cuestions in it that I 24 have. But while we are on enuivalent, on 1.8-6 in Section 4, , Ace-Federd Reporters, Inc, the staff specialist, you state: "In view of the important llh. 25 I
mte 6 40 r-(g / i nature of those ~ reviews , the experience requirements should be 2 a bachelor's decree in engineering or the physs ,a1 sciences - 3 and" -- and then there is no eauivalent. And I read that that, _ () 4 gee, this is more important, and therefore we really want a 5 bachelor's degree and no equivalent. It may be that what you 6 want is the five. years of experience. And frankly, where you ; 7 require a bachelor 's degree and one year 's experience, I think 8 the difference between the degree and four years of school is 9 a lot more irportant than where you reauire a bachelor's degree 10 and five years of experience, beca.use af ter the five years of 11 experience the dif ference in the forral trainina becins to 12 diminish . 13 So do you want to explain which of the criteria 14 result from the importance of this? 15 MR. BECKHAM: The way this particular section is 16 written, it is a bachelor's decree in enoineering or physical l l 17 sciences and five years of professional experience in the field ! l 18 of his specialty or, in special cases, ten years of experience 19 in a specialized field. That was written to give different 20 qualifications for someone who had a degree and someone who 21 did not have a decree, but who had a great deal of experience 22 in the area. 23 DR. SIESS: But you don't have here equivalent. 24 MR. BECKHAM: No, because the eauivalencv is handled AceMersl Reporters, Inc. [) 25 in the special cases. In the bachelor's degree and five years
mte 7 41 j of experience, we do not allow for an equivalent to a degree. (). l 2 It has to be a bachelor's degree. 3 DR. SIESS: Now, the equivalent of four years applied
..[~s) u - 4 experience plus six years of experience in a specialized field, 5 wouldn't that qualify? You see, all of the alternatives to a 6 bachelor's degree were experience, except the four years of 7 schooling without the degree. So this m'eans that for this job 1
8 you really want a bachelor's degree. 9 MR. BECKHAM: That is the way it is written. 10 DR. FTHERINGTON: Then shouldn't it be education and 11 experience requirements? Repeat the wording that vou use in 12 Section 3? 13 DR. SIESS: Yes. 14 MR. MILHOAN: YEs. 15 DR. SIESS: And there's another interesting difference 16 th ere , that if you have a bachelor's deoree, you want five years 17 of professional experience, and that nade some sense to me since 18 the bachelor's degree is a professional degree. At least most 19 engineering schools now think of themselves as professional 20 schools. But in special cases, vou have ten years of experience ,l 21 and that does not say professional experience. 22 MR. BECKHAM: The distinction between professional 23 experience and experience is professional experience -- 24 DR. SIESS: Comes after the degree? Ace Fn11rst Reporters, Inc. () 25 MR. BECKHAM: Mell, is in a supervisory position,
mte 8 42
~h j whereas experience may be in a non-supervisory position.
(G 2 DR. SIESS: Is that your definition of professional? 3 MR. BECKHAM: It is not my definition, but it is the a definitioh that has been relayed to me when I ask the question. 5 DR. SIESS: You see, it made some sense to say a 6 bachelor's degree and five years of professional experience or 7 five years of experience in lieu of the bachelor's degree and 8 five years of professional experience. I could read it that 9 way. 10 The ten vears does not have to mean the last five 11 professional. Really, vou mean supervisory instead of profes-12 sional. It is not a. definition of professional that I ever heard before. {]) 13 14 MR. BECKHAM: The professional experience is included 15 to differentiate between someone more involved in the overall 16 area rather than specifically doing one task or one type of 17 task in an area. 18 DR. SIESS: And that is a generally accepted defini-19 tion of professional? 20 MR. BECKHAM: I don't know how cenerally accepted 21 that is. 22 DR. SIESS: But if I accept that, do you require that 23 kind of experience to ao along with a bachelor's degree, but 24 the ten years of experience that you'll substitute for four i
-AC1up Reporters, .ne, j l (sf ~ 25 ~ years of school. or one and a half plus five years of professional f
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mte:9 43 1 experience -- ten years does not have to be any professional. 2 MR. DECKI!AM: I think that was intended to be covered, 3 in the "in special cases," where it is a more stringent review
*O 4 or the vers a's e"e11ricetiou -
5 DR. SIESS: I am satisfied that you know what you 6 mean. Now, professional experience directing the activities of j 1 7 radiation health technicians , that profe'ssional experience ' s means supervisory? 9 MR. BECKHAM: " Directing the activities of radiation 10 health technicians" is intended to mean just that, actually 11 involved in the day-to-day running of the radiation health 12 program. 13 DR. SIESS: It is a measure of a person's experience 14 in leadina and supervising. 15 MR. BECKHAM: It is a measure of the person's actual I 16 involverent in the running and administration of the radiation 17 health program, 18 DR. SIESS: Okay. These are some very subtle dif fer-19 ences. I am inclined to think it would help if there was a 20 dictionary or a clossary or a list of definitions on meanings. 21 But 1 don't think you could write it. 22 Is there anything else you want to tell us now, that
'O 23 we heve gicked some nies2 24 MR. MILHOAN: No.
Aes Fedtral Reporters, Inc. [ 25 DR. SIESS: Okay, let 's ao through it.
mte'10: m44
-1 Harold, do you have anything on page l?
O 2 DR. ETHERINGTON: No. 3 DR. SIESS : Pace 2? l l 4 DR. ETHERINGTON: No.
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5 DR. SIESS: In lines 8 and 9 you are talking about 6 ALARA, . and you say, "The importance of this concept is reflectea 7 in the cualifications recommended by the' staff for the radiation 8 Protection manager." Actually, somebody readina this is not 9 aoing to find any aualifications recommended by the staf f, ! 10 because he doesn 't know where to look. They were recommended 4 11 in the previous guide. Is that the ones . that you are referring ! 12 to, that are now incorporated in the standard? 13 MR. BECKHAM: Well, the whole guide has to be taken l 14 as a unit, with the standard, and the staff is endorsing this 15 ouide as the recommended method of implementing. l 16 DR. SIESS: But it says recommended by the staff. l 17 MR. MILHOAN: Recommended by the staff -- the wording 18 is not necessary. We could remove that. ) 19 DR. SIESS: Aren't they reouired? 20 MR. MILHOAN: We could just say: "The importance of 21 this concept is reflected in the cualifications for the 22 radiation protection manaaer. " , () 23 DR. SIESS: I.think that richt be better. I was look-24 ing for somewhere the sta#f, and I was very conscious of this Ace Federst Reporters, Inc,
,G '25 because of Dr. Poeller's concern.
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nte 11 45 1 On page 4, you need to cet straiohtened out on what 2 you capitalize. But that is an editorial thina. 3 DR. ETHERINGTON: What is the reason for keepina and {) 4 repe a ti ng, -- 5 DR. SIESS: I ' m s o rry . We skipped 3. Did you have 6 something, Harold? 7 DR. ETHERINGTON: This is on 4'. At the time the test 8 is conducted, it seems to me that repetition -- well, it has 9 me wondering why it is emphasized. 10 MR. BECKHAM: It is emphasized because there has to be 11 a cutoff point for meetina these recuirements . 12 DR. ETHERINGTON: Do you mean he can prepare for the 13 test before he has cot -- before he is aualified, and then he () ja must have the cualification when the test starts? It seems ; i 15 artificial . I 16 MR. BECKH7F: It is individuals that direct or super- , 17 vise the conduct of operational tests at the time of the tests. 18 Eecause of the variation in schedules from initial test proarams 19 there is some doubt as to the actual day that a particular test 20 will be run. 21 DR. SIESS: What you mean, I think , is that when they 22 subnit the FSAR, the person has to be cualified at the time. () 73 MR. BECKHAM: That's right. They are presenting this 24 information with their FSAR, and it may be two years from that i Ace Ftderh! Heporters, Inc. (')
\_f 25 time until they even start the program. And thev have someone
l mte 12' 46 (~3 I whom they are actively trainina, v. 2 DR. BENDER: In fact, I thought that it was the other 1 3 way around. I th6ught the concern was that they had somebody l l () 4 cualified when they s ubmitted it, but by the time the test came 1 5 around he had disappeared. 6 DR. SIESS: Well, that could happen, too. l That has happened more of ten than the 7 DR.'BEMDER: 8 other. l 9 DR. SIESS : Did you get my comment on the capitaliza- l 1 10 tion? In iline ill you capitalized " Pre-operational test" and 11 in line 20 you did not capitalize " start-uo test." This is 12 just to get your style straiahtened out. i Yes, sir. I {} 13 MR. BECKHAM: 14 DR. SIESS: Anything else on page 4? 15 On page 5, just editorially, on line 3, I think "or 16 equivalent" has been accomplished. 17 DR. ETHERINGTON: Also editorial, on 5 I think you 18 want to rewrite that Item 2 at the bottom, to get away from 19 talking about standard personnel. You could write, for example, 20 " exempt from the required cualifications those persons who are 21 temporarily filling," or something else. 22 DR. SIFSS: Yes. Qualifications called for in the O k# 23 standard personnel. 24 Anything else on 5? ; Ap"yeral Reporters, Inc. V 25 On 6?
mte 13 47 1 DR. ETHERINGTON: On 6, the bottom line, the bottom ggi 2 full line, should be applied only to licensed operators. This 3 does not permit a trainee to take the course. Unless you () 4 really want to exclude a trainee from :kina the course, I thinP 1 1 5 you might say "specifically" instead of "only" or something 6 else. l 7 Do you want to prevent a trainee from takina a course? I 8 Because that is what you are saying. The standard implies that , 1 9 trainees may take the course. 10 DR. SIESS: Well, 5.5.1 is for licensed operators, 11 the standard. That is what it says. l 12 DR. BECKHAM: Yes, it is. That is why we had to put l l l r- 13 this in. In the previous version of the s tandard, it was just Q)N 14 a reaualification procram for operators. 15 DR. SIESS: Since the standard says recualification 16 procram for licensed operators, and you are sayina it should 17 be applied only to licensed operators? 18 MR. BECKHAM: We're sayina that Section 5.5 is 19 typed: " Operator retraining and replaceront training." 20 DR. SIESS: But Section 5. 5.1. 21 DR. ETHERINGTON: You see, but 5.5 starts out: "A 22 training program," and a training program presumably could be f k/ 23 for trainees who are not licensed. 24 MR. BECKHAM: True. You see, 5.5 -- A Tr 1 Reporters, Inc. 25 DP. ETHERINGTON : But 5.5 covers 5.5.1 as well.
mte 14 48 1 MR. BECKHAM: But 5.5.1 is the retraining program, 2 and you won't have any licensed trainees in a regualification ; 3 procran. () 4 , DR. ETHE RINGTON: So you do want to exclude trainees? 5 MR. BECKHAM: Yes, we do want to exclude trainees . 6 It only applies to those people who are cualified and are under-7 going a requalification for license reaualification. 8 DR. SIESS: Let me ask: 5.5.1 is headed "Reaualifi-l l 9 cation program for licensed operators," and you say that that 1 10 section and its . subsections, 5.5.1 through 5.5.1.6 should be 11 applied only to licensed operators? 12 MR. BECKHAM: Righ t . , 1 13 DR. S IESS : It seems to me that by title it applies O 14 only to licensed operators. 15 MR. BECKHAM: Yes, it is. We are caught in a problem 16 with the way the standards are numbered. We want to specify 17 that Section 5.5 applies not only to licensed operators , but 18 also to other cualified personnel in the plant. If we just sav 19 that 5.5. applies to other personnel, then it leaves in doubt 20 whether in 5.5 we include all of those subsections. So we are 21 saying 5.5 and only 5.5 applies to other plant personnel and 22 excludes ...em from 5.5.
.O(,I 23 DR. SIESS: I see your problem. The problen is they 24 did a lousy numbering job. They 've got a 5.5 and they 've cot Ace-Federal Reporters, Inc.
() 25 a 5.5.1 under it, but no 5.5.2 or 5.5.3. They should be
-1 mte 15 ;
l 49 j -numbered 5.5.1 and 5.5.2, I think. What you really want to say ( l 2 is that the first paracraph of 5.5 -- 1 3 MR. BECKHAM: Applies to the entire plant staf f.
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, DR . SIESS: I think it would help, because as I read
) 4
. 1 5 5.5 is the hold chapter, the whole section, and 5.5.1 has to be 6 part of it.
l 7 MR. BECKHAM: So what would yo'u like to see, some-8 thing like the first paragraph of Section 5.5 -- 9 DR. SIESS: Is written to apply or should be applied 1 10 to the operating organization and not just to the operators, 11 It is not the whole section that should be applied, not j us t to 12 the operators . I l 1 13 It's the first paracraph, richt? That 's what you' re i
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14 trying to say? i 15 NR. MILHOAN: Yes. 16 DR. SIESS: And the remaining parts of Section 5.5.1 17 applies only to licensed opera tors . 18 MR. BECKHAM: If it had read -- the first paragraph 19 of Section 5.5 is written to apply and should be applied to the 20 operatino organization and not just to the operators, to the 21 licensed operators. Section 5.5.1 and its subsections, et 22 ce te ra , should be applied only to licensed operators. () 23 DR. SIESS: Yes. I think the second is redundant.
- 24 The second sentence is probably redundant now that you have the A&Fxtercl ReWrters, inc, j
(~ 25 first one straightened out in the first paracraph. But you are 2 6
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mte 16 - 50 1 trying to say that by excluding 5.5.1 -- it is a poor numbering
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2 system. 3 Let's see , that is page 6. Anything else on 6? 4 Okay, on 7. I did not check the whole thing, but [} , 5 you've gotten sexist in line 16. Have you had any standards 6 about he 's , she's and it's? 7 MR. RICH ARDSON : We will take ' care of that. 8 DR. SIESS: Do you have any female operators? 9 MR. S ULLIVAN : There may well be. 10 DR. SIESS: 'I would be surprised if there weren't some. 11 Anything else on 7? You caught this in line 16, this 12 two " E ' s " ? 13 MR. RICHARDSON: Yes, sir. 14 DR. SIESS: Let's s ee. This for a for-connent imple-15 mentation, isn't it? 16 PR. RICHARDSON: Yes, sir. 17 DR. SIESS: Okay. Anythina else, anybody? Any 18 objections to letting this ao out for comment? 19 (No response.) 20 DR. SIESS: So approved. 21 We did not discuss your revised regulatory position 22 one. Let's see, in the original draft you say, "In some cases () 23 plant design features or unusual ope: rating conditions may 24 indicate that an additional or more specialized expertise ; Ace Federal Reporten, Inc. 25 'beyond the cualifications presented in ANSI /ANS 3.1 is needed.
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mte 17 51 (~) 1 This determination will be made on a case-by-case basis ." G' 2 You have, presumably, explained that in what you have 3 added, is that richt? You have added the sentence? t (,m) 4 MR. RICHARDSON: The original reg' position pointed 5 out that maybe plant features or whatever may aive you an 6 additional expertise. Now we have added in the new rec position 7 the additional concern by NPR that an applicant may try and come 8 in with a plant staf f that satisfied the bare minimums at every l i 9 position and only those people. In other words, that although ' 10 the minimum acceptables are, c uo t e_, unauote, " acceptable," we i 11 would expect a plant staff to actually have additional qualifi-12 cations above th a t . rs 13 DR. SIESS: I hear it. You are goina to combine t v) 14 them by the absolute sum or the sum of the sauares? 15 DR. BENDER: Is this more than a synergistic effect? 16 MR. RICHARDSON: I would refer to the NPR norson, l'7 We had similar concerns on some of the wordina and how you would 18 go in for such a thing as a collective qualification level. 19 DR. SIESS: It is absolutely incredible, centlemen. 20 I have never seen a statement that was more open 'and gave you 21 nore room for judgment, with less guidance to the person who 22 you were judging. It tells me absolutely nothina about what o
- 23 you want except that you want more, and that is the motto of the 24 NRC, "More." i Ace Federti Fleporters, Inc, llh 25 MR. BECKHAM: The problem that exists is the standard i
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mte 18 52
.(] j as written says minimum qualifications for each position. 'w) 2 Meeting the minimum qualifications, you can present an overall 3 P l ant staff with little or no nuclear operating exnerience.
() 4 We are reserving the richt to disapprove that staf f, and I think 5 rightfully so. 6 DR. SIESS: But it is saying your minimums are not 7 high enough. 8 MR. BECKHAM: The minimums for each position are 9 acceptable, but as you know, of ten the sum of the parts does 10 not equal the whole. , 11 DR. SIESS: I know what you mean. 12 MR. BECKHAM: This position arose from an actual 13 licensing case.
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('T ja DR. SIESS: What vou're sayina is that you have i j 15 stated a minimum, position by position , essentially, but that l 16 you will not accept the minimum in a position unless it is off-37 set by something creater than the minimum in some related 18 Positions, either above it or below it or beside it? 19 MR. BECKHAM: Yes, sir. 20 DR. SIESS: That has really got to be what you mean. 21 If somebody is richt at the mininun and you see that everybody 22 associated with him is also at the minimum, you say that is not (\-. enough. But on an individual basis, that is the ninimum you'll 23 24 accept. Ace'=dsrcl Reporters, Inc. U '25 .MR. BECKHAM: Yes, sir. I
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mte 19 53 l 1 1 1 DR. SIESS: But you won't accept too many minimums?. l 2 MR. BECKIIAM: Yes, sir. l l 3 DR. SIESS: But how you can object to a judgmental 4 basis instead of a point count in other areas -- that point 5 count leads you to the same situation, the point count by 6 De0P l e P l us another point count that is hinher. It is the same 7 kind of thing. 8 Okay. Let's take ten minutes. 9 (Brief recess.) 10 DR. SIESS: The next guide we will take up is a draft 11 guide that will be brought out, a new guide entitled, " Safety-12 Related Permanent Dewatering Systems . " 13 Let me make a comment before you present this, because O 14 I would like to give you an impression rather than hearing your 15 story first, because I think a lot of people read these without 16 the benefit of the staff's explanation. And as I looked at j 17 this acain, more or less starting, concentrating on the position, 18 I got a strance impression that the guide, first of all, 19 endorses Appendix A and Appendix B to Part 50. And I foraot 20 to look up what Apoendix B is. It isn't referenced in the 1 21 introduction, where we usually reference the justification. 22 It endorses Appendix C and Appendix B to the regula-( 23 tions of the NRC, with an exception that is not spelled out. 24 It endorses another reg guide, 1.70, in standard format. It i Ace Federal Reporters, Inc, 25 says you've cot to have technical specifications, and it says
mte 20 54
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<] 1 you've got to be sure the system works . And I guess from read-w/
2 ing the value impact statenent, I cet the impression that it 3 endorses a branch technical position, t} (_s 4 Now, I found these rather strange things in a guide. 5 So would you try to dispel that impression when you exnlain 6 what the cuide is all about? And again, I am concentrating on 7 the position. I will admit there is some stuff in the discus-8 sion that I don't find clearly, and I tried to relate the 5 9 items -- the 4 items in Position (c) (5) . I tried to relate 10 those back to some items diat were in the discussion, and was 11 not completely successf ul . 12 I can find (c) (1) , (c) ( 3) , and maybe -- I can find 13 ( c) (1) in the discussion, something on (c) (3) and raybe (c) (2) , V,r's 14 and (c) (5) . I can find something on (c) (5) . 15 But I was having trouble relating the position with 16 the discussion. And as I said, when I read the value impact 17 statement, I found out that this thina is endorsing a branch 18 technical position that has the detail in it, And I'm not sure 19 we've ever seen a guide that endorsed a branch technical posi-20 tion. 21 Okay. Wi th that introduction , you've got the floor. 22 MR. NILSEN: Okay. I'n Chuck Nilsen from the Office
,S x/ 23 of Standards Development, the Fuels Processing Systems Standards 24 Branch.
Ace arII Reporters, Inc. 25 The guide, as indicated, is "Saf ety-Related Permanent i , l
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'mte 21 55 l j Dewatering Sys tens . " The guide does track a draf t standard u branch technical position. The reason -- well, the branch l
i 2 l 3 technical position was reviewed by the RRRC and the recommenda-(] 4 tion was' ,that the branch technical cosition be included in the 5 reg auide series. 1 6 Now, the branch technical position has been included in the reg guide series through the posi' tion that is indicated l 7 in this guide, and through the details of hydroloay that are 8 1 9 covered in the revision to the standard format and content 10 which you referenced in Reg Guide 1.70. And so a lot o'f the
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11 details which you referred to which were in the technical 12 position are included in the standard format. 13 All this guide does Lis give you the reculatory ja position under Item C. 15 DR. SIESS: But now, do we need a guide or anything 16 else to tell people that they should follow the standard format?' ; i 17 That is, another reg cuide? Now, I don't think an applicant 18 is recuired to follow the standard format, any nore than he is 19 required to follow a reg guide. l 20 So let's take up Position 1: "It should reet the 21 critoria of Appendix A and B." Everythina should meet the 22 criteria of Appendix A and B. That's the regulations of the 23 Commission. You don' t need a guide to tell somebody they 've 24 got to meet A and B. It has got a "however" which is two-part, Ace F dstrl Reporters, Inc. (J L T 25 that says: "However, all portions of the system need not be l
mte.22 56 I designed to . accommodate all design basis events such as earth-2 quakes and tornadoes, provided that such events cannot either 3 adversely influence the system or that the consequences of
-()- 4 failure from such events are not important to safety."
5 Now, if an event cannot adversely influence the 6 system, I would say it is designed to accommodate it. That is 7 my definition of designed to accommodate: It is desioned in 8 such a way that it is not ~ adversely influenced. So that's 9 not really an exception. The exception that the consequences 10 of failures are not important to safety, that isn't an exceptior , 11 is it not? 12 How we do that now, you don ' t have to design a waste 13 tank to resist an earthquake if the failure of that tank would 14 not exceed, what, ten percent of Part 100, or not exceed l 15 Part 20, right? So "not important to safety" is defined for ; 16 certain parts of the systems, I know. I think for something l 17 like that, if the failure would not exceed Part 20, then it is i I 18 not important to safety and it doesn't have to be category 1. 19 And the first proviso here, if the event cannot 20 adversely influence the system, that is a criteria for design. 21 If I design the containment to resist an earthquake, I design 22 it so the earthquake will not adversely affect its ability to k/ 23 contain. So I really don't see that the admonition to follow 24 Appendix A and B is necessary, because that is required of
' Ace 593ral Reporters, Inc,
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ate 23 57 gg 1 Now, the fact that the consequences of failure are not V 2 important eliminates the need to design for earthouakes and 3 tornadoes. I don't know whether that is covered anywhere else ; i 4 or not. f^/) r 5 MR. NILSEN: Could Mr. Hulman speak to this? 6 MR. HULFWN: My nare is Gerry Hulman from NRR. The 7 problem we had in formulating the branch' position that this 1 8 particular regulatory nosition tracks is portions of permanent 9 underground systems need not be Category 1. Obviously, if a 10 tornado occurs, it won 't influence certain parts of the system, 11 so you need not design for the pressure drops and wind speeds . : 12 And by the same token, you need not design for the earthouake 13 if the earthquake would not cause a failure of the system such 14 that would cause a failure of the buildings or any of the 15 systems inside the building. 16 The problem we had was distinguishing between Category' ! 17 1 and non-Cateoory 1 portions of the system. For example, there-18 is in sone cases a porous drain underneath the reactor buildina, 19 porous concrete, on some of the plants we have reviewed. Since 20 that has an added responsibility of carrying normal loads as 21 well as accidental loads, as well as serving the function in 22 the under-drain system, it has to be Cateoory 1. But some of I
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(G _/ 23 the punps outside the buildings need not be Category 1. . l 24 So the problem we had was distinguishing for not only l AmFMetal Retorters, lnc. ' (~j)
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. 25 the staff, but for the applicants,- the difference between
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mte 24 58 1 Category 1 and non-Category 1~ portions of the system. But we 2 still wanted the appropriate OA and the appropriate design for , 3 other phenomenon for the entire system. () 4 . DR. SIESS: I see your point. This is addressed, as 5 nearly as I can tell, on page 4 in the draft -- 6 MR. HULMAN: Basically, all No. 1 says is you've 7 got to design for natural phenomenon, dbat is, Appendix A to 8 Part 50. Appendix B is QA. We want the whole system to be 9 designed for the normal QA, but it need not be desianed for 10 earthquakes or tornadoes. So the problem . was. . liv. distinguish-11 ing between Category 1 portions of the system and non-Category 1 . 12 DR. SIESS: And the attempt to distinguish is in the 13 discussion on page 4, at the top of page 4 down to about the O. 14 middle. 15 MP.. HULMAN: That is part of the discussion that is 16 attempting to support -- 17 DR. SIESS: (c) (1) ? f 18 MR. HULMAN: Right. 19 DR. SIESS: Which I had to go hunt for. 20 Now, again, on page 4, I find the statement: "Or the 21 system could be expected to perform an underdrain function in a 22 degraded condition." Now, to me , you 've got to analyze it for ( . 23 the earthquake and see how much darage is done and see if there 24 is'no performance function. So that, to me, is designed for Ace-Fsdetal Reporters, Inc. ( ). 25 earthquakes; it is designed to be able to perform its function
nte 25 59 1 after an earthquake. It may be degraded, but the level of e-i b 2 behavior following the earthquake is satisfactory for the - i j 4 3 performance function. ! 1 i MR. JOHNSON: I would like to say one thing. My name ! ((} 4 , 5 is Ted Johnson. 6 I think this is referring more toward a situation 7 where, if the filter layer that is in th'e underdrain could l 8 become clogged so it could become partially degraded in that ! 9 condition. There are other things other than design basis l 10 events that need to be considered in the design of a drain i 11 system. And so, some thing like this, I think, is what we are l 17 referring here, more here than an event such as an earthquake or 13 a flood or whatever.- O 14 DR. SIESS : But you see, one refers to earthauakes and 15 to rn adoes , "such as earthquakes and tornadoes." They are really ) 16 spelled out. 17 ME. HULMAN: Those were the specific items . 18 DR. S IESS : And I would say a system that in this type l 19 of an earthquake can still perform its function as designed 20 af ter the earthauake -- j l 21 MR. HULMAN: Portions of it can withstand the 22 ear thq uake , Dr. Siess. But, for example, if we have a manhole d () 23 with an : active pump system outside the containment, it need not I i 24 be Category 1 and could fail. I Ace Fedtral Fleporters, Inc. (")
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25 DR. SIESS: I did not say it was Category 1. I said
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.mte 26 60 ,7 1 it was designed to function. Well, what is Category l? It has j 2 to be able to function following an earthauake?
3 MR. HULMAN: It has to survive and function. () 4 , DR. S IESS : But it does not say at what level it has l 5 to do the things you want it to do follovino an earthauake. 6 MR. HULMAN: That is true. But if all portions of 7 the system would f ail and the sys tem as a whole would still 8 continue to function at some dearaded level, that is what we 9 were willing to accept, that is what we were tryina to -- l l 10 DR. SIESS: But isn't that what we were willing to I l 11 accept on anything, that it would survive the SSE and do what I 12 it was supposed to do? Not what it was supposed to do before 13 the earthquake, but what it has to do af ter the earthquake? l
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14 MR. HULMAN: I understand that. I think part of the 15 problem we had was with the structural engineers ' need to design 16 the systen to curvive an earthquake if it was labeled Category 17 1. 18 DR. SIESS: I see. Your problem is , you feel that if 19 you say it is Category 1, it has to survive completely intact 20 and do the same thing it did without an earthouake? 21 MR. HULMAN: Exactly. 22 DR. SIESS: Which is true of some systems. I think I 1() 23 can find something, some other parallels where the condition 24
- Ace Fedtrst Fleporters, Inc.
af ter the earthauake is not the same as the condition before i ('} s 25 the earthauake,. but it still can do what it has to do. haf $ .+.wm '. m 2.- -
;c I t mte 27 >
61 j MR. HULMAN: If we were to say this had to be a 2 Category 1 sys tem, the problem I am having -- 3 DP SIESS: Category 1 means everything. Nothing s 4 changes.. 5 MR. HULMAN: Not 6nly nothing changes, but the 6 structure is designed for it, the system is d esigned for it. ' 7 DR. SIESS: .They are designed so nothing changes. ! MR. HULMAM: Pight. 8 9 'DR. SIESS: Without defining the functional level. 10 MR. HULMAN: Right. ! 11 DR. SIESS: There is no distinction between the 12 functional level before the earthquake and the functional level 13 post-earthquake. 14 MR. HULMAN: Pight. 15 DR. SIESS: I can't think of a good example. Maybe 16 there'is one. That's all'right. I accept your intent, and I 17 think it is all right. 18 I was juc t trying to think if you were plowing new 19 ground here, and maybe you are. Maybe there is no other case 20 where we could do the same sort of thing. 21 MR. HULMAN: I was about to comment on that. This has 22 been run through PERC, and to my knowledge this is the first time () 23 we have accepted something of this nature or proposed something 24 of this-nature, a safety system, an important safety system,. Acefpderat Reporters, Inc. (,1 25 Portions of which need not be Category 1.
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mte 28- 62 r- - 1 DR. SIESS: Well, maybe so. I still have a problem.
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2 This one is not much of a problem. I guess I can find what 3 this means if I hunt through the discussion. I've got my old () 4 problem of having the discussion not keyed to the position and 5 not even in the same order as the position. Unfortunately, 1 6 that comes first in the position. l 7 I think you could find what you said, that the system B should neet all of Appendix B, th e Q A. Now, do you have to say 9 that? Doesn't everything have to meet Appendix B? 10 MR. HULMAN : If it is not labeled, if it does not 11 have a bright red tag saying " Category 1," it need not unless j l 12 we specifically ask for it. 13 DR. SIESS: Now, you've got " appropriate criteria of 14 Appendix A and Appendix B. " The exception you are making, i 1 15 however, is to Appendix A? 1 16 MR. HULMAN: Righ t . ' 17 DR. SIESS: I think since Appendix B isn't even 18 mentioned in the introduction -- was that just an oversight? 19 Because usually you cite in the introduction all of the regula- j l 20 tions that justify the reg guide. I think you could say it i 21 should neet the approoriate criteria of Appendix B, and maybe 22 start off a new sentence with Appendix A, so that the exception () 23 is clearly to Appendix A.
.e-2 24 MR. HULMAN: Fine.
Ace-Fedsrel Reporters, Inc. (} 25 DR. S IESS : Have you got a definition of when the
i i* mte 29 63 importance of consecuences is not imrortant to' safety? That 1 2 to me is a pretty substantive thing. MR. HULMAN : Yes , we have a two-level -- 3 f DR. SIESS: Is it in here. I'm going to let you hunt 4 5 f r it. 6 MR. HULMAN: On the bottom of page 4, the fourth line from the bottom that starts: "For example, if structures can , 7 accomendate hydrostatic loads that would result in the total 8 9 failure of the dewatering system, that is the degraded condi-10 tion." 11 DR. S IESS : Well, that is essentially saying that 12 there would be no releases, righ t? The important safety is not 13 ing t be quantified in terns of doses?" O ja MR. HULMAN: It could be quantified in terms of ' 15 structural integrity. 16 DR. SIESS: But wouldn ' t what you jus t have there j7 say that it would not adversely influence the system? You see, 18 ;l you have two provided's" in (c) (1) : "Provided that such events. [ 19 cannot adversely influence the system or that the consenuences 20 f failure are not important to safety. " 21 Now, the first says no adverse influence, which means, 22 presumably, no accident, no releases. The second says that (3 there is some adverse influence, but that the failure is not V 23 24 important to safety. Now there is a clear "or" in there; it is Ace federal Reporters, Inc. an either-or, and the thing you just cited at the bottom of h.- 25 ,
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c mte 30 64 1 page 4 would seem to refer to the first one.
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2 PR..HULfMN: In practice, we have tried to apply the 3 second part of that se.itence: "or that the consecuences of such a failure are ne c important to safety." We have applied (]) 4 5 that in several cases. The answer that we get back from 6 applicants is that, rather than analyze the structural failure, 7 potential structural failure, they would prefer to design the 8 structures for the hydrostatic loads that result from the 9 system failure. 10 Nobody has taken us up on that opportunity. 11 DR. SIESS : Incidentally, where it says "cannot either," 12 I think it should be "either cannot. " > 13 DR. BENDER: Can I go back to this Item 2 of the O 14 position? l 15 DR. SIESS: Well, let's take -- I understand what 16 you are trying to do in 1. You are saying that the second 17 exception you haven't had to define because nobody has aske 1 18 for it, is that right? 19 MP. H ULMAN : Me have of fered them the opportunity, l 20 and rather than go through a lengthy analysis of failure, they 21 have decided, well, they will just assure us tha t the s tructures 22 can take the hydrostatic load. ( 23 DR. SIESS: And if they did not want to go through 24 that, do you know what you would accept, Part 20? Ace #ederst Reporters, Inc, O 5 "n "utt'^": e is re1et a t ebe sst, "r bed 1v i
65 mte 31 1 Part 100. 2 DR. . SI ESS : All right. Now, 2. Mr. Bender has a 3 cues ti on. () 4 DR. BENDER: I just wanted to see if I could under-5 stand what is reant by the guidance in the Standard Revies 6 Plan for Category 1 structures. 7 DR. SIESS: It is the standard format. No, I'm sorry. 8 Y es , both . 9 DR. BENDER: There see~s to be some contradiction 10 between that statement and the one, previously, which says you 11 are not going to require it. How are you going to deal with 12 that? 13 MR. HULMAN: I'm not sure I . understand your cuestion. 14 DR. SIESS: Let's back off, th en , and say: Why is 15 2 necessary? 16 MR. HULMAN: Because the present standard format 17 content does not contain any discussion of underdrains, and 18 until such time as Reg Guide 170 is modified again to contain j 19 specific requests for information relating to underdrains, we 20 want to provide the applicants with cuidance as to where to put 21 their analyses . i 22 DR. SIESS: But it says all analyses as requested in O
\s 23 Section 2.4 and 2.5. I read this to say that it is there.
24 MR. NILSEN: It is in there. ' Acejfederal Reporters, Inc. () 25 DR. SIESS: Well then, why does the reg ouide have to l i
mte-32' 66~ 1 say: Follow the standard format?' Have we ever had any reg (). guides that say you've got to follow the standard format? 2 3 MR. HULMAN: This particular regulatory position was ()
! -4 lifted, qgain, from the approved branch position.
5 DR. SIESS: But wait- a minute. Let's stop right i 6 there. I don't see any reference to branch technical position. 1 7 If I had not read the value impact statement, I would not even 8 know one existed. There is one attached to the value impact 9 s tatement, and a good portion of it is in the discussion. But 10 you keep saying -- you said this tracks the staf f's position. 11 But it doesn' t say that. q 12 MR. HULMAN: Let me see if I can clarify it. When 13 the joint branch position -- and it is not j us t the Hydrology ? 1 14 Branch, it is the Hydrology, Meteorology Branch , and the , 15 Geosciences Branch -- when it wa, written and approved by RRJ C, 16 the standard format and content did not contain any discussion l 17 of underdrains or the information required to support it. is DR. FIESS: But it in th ere now . 19 MR. NILSEN: But it is there now. There is a 20 Section 2.4.13.5.2 for plants employing permanent dewatering l 21 systems. ;
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i 22 i MR. ANDERSON: it was published in November.
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f)- 23 DR. SIESS: Is Position 2 necessary now? 24 MR. H ULMAN : No, it is not necessary. Ace-Federal Herorters, Inc. () 25 DR. SIESS: Okay. Me've got Position 2 taken care of. I i I 1 s @--
mte 33 67 j-) 1 You don't ha've to tell people to follow the format in the review (/ 2 plan. Now, does that take' care of you, Mike? 3 DR. BENDER: No. I didn't care whether it was in or () '4 not. You took it out altogether, that's what you did just now? 5 MR. HULMAN: Okay. 6 DR. BENDER: Okay if it 's gone, and that takes care 7 of me completely. 8 DR. SIESS: Now Position 3. It says you've got to have 9 bases for tech specs to assure that, in the event of system 10 failure, remedial action can be implemented before design 11 conditions are exceeded. Isn 't that true of any safety system? 12 MR. HUL?%N : Those safety systems -- I 13 DR. SIESS : Even if they are redundant. This starts I ( i 14 of f where the system is not totally redundant or is not desioned i I 15 for all design basis events. But even if I've got a redundancy l l 16 like a diesel generator, I 've not to have a tech spec basis 17 that says, if I start operating, what do I do and how long I've 18 got to fix it before I can go to hot shutdown. 19 MR. HULMAN: You are correct that mast safety systems 20 would require tech specs if they are degraded. The problem 21 the staff had with. underdrain systems is that industrial 6xpe-22 rience with underdrain experience hasn't been, at best, good. 23 Me wanted specific -- we wanted a specific tech spec proposed 24 and revirsed by the staff in advance of anticipated operation, i Ace Fedtest Reporters, Inc. () 25 to asstre us that if something went wrong, the applicant would
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mte 34 68 i be prepared to cope with it. 2 DR. SIESS : Now, aren't all tech specs reviewed in 3 advance? I see what -you are driving at. The experi&nce you've 4 had on the nuclear plants and other experience has not been L() , 5 great on this. I can think of a few other places where they 6 haven't been so hot, ei th er . But are you calling for something 7 different or are you just pointing out that this is not neces-8 sarily a very reliable system, so you want some special 9 provisions? But couldn't that be in the standard review plan 10 or the standard tech specs or something? 11 MR. H ULMAN : It could be. We have had little expe-12 rience with these. We don't have any operating safety system. 13 We don't have any operating underdrain systers 'that are consi-O 14 dered safety-related that we are aware of. He are trying to 15 generate the experience. 16 Me're not sure that a standard tech spec exists . One 17 certainly does not exist. 18 DR. SIESS: Are all the underdrain systems, all the 19 plants with underdrain systems, also desioned for full hydro-20 static?
- 2) MR. H ULMAN : Some are and some are not'.'
22 DR. SIESS: You said no operating ones. () 23 ' MR.- H ULFAN : And I also said that I was aware of. 24 DR. SIESS: There are some that are designed? Ace Federal Reporters, Inc.
] 25 MR. HULMAN: Yes, there are some that are designed.
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mte 35 69 g~s j MR. ANDERSOM: Possibly this belongs in the standard
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2 format. But I would suggest leaving it here until we pick it 3 up in the standard format. () 4 . DR. SIESS: It seems to me that some of the conditions 5 have changed since you've started this guide. I know, obviously, 6 the one on Position 2 -- and I recoonize the problem you've 7 got. But I'm wondering if the solution is a guide and not just 8 a change in the standard formac and the standard review plan. 9 Hell, let's go on to another item for a minute. Let's 10 look at 4. Again, isn't that true of all systems? I will 11 admit some systems are replaceable and this one is not replace-12 able. c 13 MR. HULMAN: Not without creat expense. I (m/ 14 DR. SIESS: But a containment isn't reolaceable with-15 out great expense, either, to take an example. I ouess I have 16 never seen a requirement that the containment must be expected 17 to have a reliable safety performance function. You can have a 18 direct parallel. I guess you could replace the containment, 19 but a t great cost. I l 20 pp. . aunMan : Let me see if I can give you some back-21 l Pround on No. 4. DR. SIEGS: Keep one thing in mind: We understand 22 l
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() 23 the problem. It is just whether the solution -- whether the 24 Problem is unique and recuires a uniaue rea cuide. Right now i Ace a<1eral Reporters, Inc. 25 I think this one is unique. I have never seen one quite like l
mte 36 70 j 'it.
'O MR. HULMAN: Let me see if I can explain to you why 2
3 I believe No. 4 'is necessary, or at least the thought behind No. 4. T,he designs we've seen for underdrain systems are {}- 4 5 tailor-made to each site, to each design , reactor design. We 6 have seen no consistency between not only A & E's and licensees, 7 but between sites . Some of daem are uni'que designs . We haven't 8 seen any industrial applications anywhere close to some of the 9 designs proposed for nuclear plants, j 10 There is a staff concern that if the utility tries 11 something new, there should be some pretty darn good basis for 12 it. 13 DR. SIESS: That doesn 't take a reg guide; that just , ( takes a lot of questions. It is done every day. 14 15 MR. HULMAN: Except if we can eliminate questions and 16 forewarn an applicant that we are concerned with reliability of 17 the systen. 18 DR. SIESS: This does not eliminate cuestions, and we 19 are always concerned about reliability of the system. I ree j 20 your problem, but it isn't that unique. 21 MR. NILSEN: Now, there is one other aspect of it, 22 too. (f 23 DR. SIESS: It may make it nore difficult, but it is 24 not unique. Ace Federst Reporters, Inc. f() 25 MR. NILSEN: The reason it care to our branch , the
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nte'37 71 Fuel Processing Branch, was because our branch has the progran
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V. 2 with respect to decommissioning. And if you look at the aspect 3 of decommissioning, Item 4 savs "until termination of all 4 licensed , activities . 5 DR. SIESS: Now, that is pretty darn subtle. 6 MR. NILSEN: We also spell it out in 5.4 that they 7 should include in their discussions thes'e aspects . Now, 8 admittedly, the item for No. 4 was not primarily in there. That 9 was put in there -- that was principally there because of what 10 Gerry was saying. 11 But it does have the aspect of saying that we are 12 looking for all licensed activity. 13 DR. SIESS : That is pretty subtle in 4. It ,is pretty O 14 clear in 5.4. But I understand the problem. There are other 15 things that are fairly site-dependent, but are not necessarily 16 unicue. I think heatLsinks tend to be fairly site-dependent, 17 and I've seen a variety of ultimate heat sinks. And the first 18 time somebody wanted to put the underwater dam in to provide an 19 ultimate heat sink, he got a #cw ouestions on it, as I recall. 20 I think the second and the third and the fourth time they did, 21 because each one had dif ferent . soil conditions and different 22 earthquake levels, and so forth . ,
)' .23 And so I don't think it is all that unioue . And it is 24 a motherhood statenent, if you will excuse the expression.
Ace Federal Fieporters; inc. (} 25 MR. ANDERSON: You're speaking of Item 4?
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mte 38 72
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DR. SIESS : You see, I have a peculiar impression s 2 about this thing. And again, reading it without knowing it was 3 a branch technical position that this was supposed to be 4 endorsing or incorporating -- and let 's face it, I don't think everything in a branch technical position is in here. The 5 6 branch technical position is good. It has got a heck of a lot 7 of guidance in it. And if the reg guidd said read the branch 8 technical position -- but most of what is in here from the 9 branch technical position is in the discussion and not~ in the 10 position, and I don't find a one to one between positions and 11 dis cus sions, so I can't even say the position tells you what to 12 do and you look back in the discussion and it tells you how to 13 do it, therefore the discussion replaces the branch technical O ja pos it.t o n . 15 There's a lot more in the branch technical position, 16 a 1 t of things in there. It is excellent. It is an excellent j7 guide to the reviewer and it ought to be an excellent guide to 18 the designer, because it tells them what is poing to be looked 19 at. But it doesn't come out of this thing. 20 I4R. NILSEN: Most of that information is included in 21 the standard. 22 DR. SIESS: Well, the 5 ceneral- areas of review are 23 identified bectinning on page 5. 24 Let ne go back through the positions, the discussion. , ! Ace Federal Reportres, Inc. L- 25 Page 3 of the discussion is sort of general, and I suspect that l t i
mte 39 73 3 is out of the branch technical position, at least the first few O 2 sections of it. When you get to the top of page 4 and you 3 begin to talk about how you design for this dearaded condition
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4 that we discussed earlier -- at the bottom of page 4 is still 5 that subject that is essentially relating to (c) (1) . 6 The top of page 5, that is the same thing. If it 7 can be designed acainst the full static ' loading, you don't need 8 it. 9 Now, incidentally the last sentence before it says, 10 " 5 general areas ," "If a plant is designed to withstand full 11 hydrostatic loading, the review includes consideration of the 12 time available for reredial action af ter detection of system 13 dearadation and timeliness and implementation of a backup O ja system." 15 Now, that seers to address your nosition (c) (3) . 16 That says it has to be reliable, and there 's got to be somethino-j7 .in the tech specs about how you maintain the reliability. I'm 18 sorry -- yes, (c) (3) . 19 MR. HULPAN: It supports (c) (3) . 20 DR. S I E S S .: Except shouldn ' t the words " prior to an 21 earthquake" be added there? You want the timeliness and imple-22 mentation of. a. backup system before the next earthquake occurs? 23 MR. I!ULMAN : Not necessarily before another earth-24 cuake. , Ace-Federel Reporters, Inc, 25 DR. SIESS: I nean, you haven't had an earthouake and
mte'40-74 j something goes. wrong with the system. Now you 've got it down-
.o 2 now, in other words. Is this for outdoor maintenance and repair 3 or whatever -- and what you are concerned with there is the probability that an earthauake can occur within the time it
[]} 4 5 takes you to get the thing working. 6 MR. HULMAN: Or a LOCA could occur if the reactor 7 starts up again before they get the unde'rground system fixed. 8 DR. SIESS: A LOCA could lead to releases that would 1 9 go into the groundwater if the underground systen didn 't work? ) l l 10 MR. H ULMAN : Not only that, but the structural ' 11 integrity might be questionable if the groundwater level has 12 gone up. l 13 DR. SIESS: So it's not just an earthquake; i t 's O 14 anything that requires it to be needed. I don't think a LOCA 15 is really the challenge there. l 16 MR. JOHNSON: How about priority design basis? 17 DR. SIESS: That is an important point to me. Then 18 you get into five general areas of review, and I will have to 19 admit I did not try to compare those with the branch technical 20 position. But I tried to relate them to the positions . Ei ther j 21 the discussion has to lead me to the position or the position 22 has to lead ne back to the discussion. And estimating and () 23 confirnina permeabilitv values, what position does that refer 24 to? I had it referring to (c) (2) , which I assume there was i ' Ace Federst Reporters, Inc. () 25 something in. That is in the branch technical position, I
mte141_ 75 1 beli eve; isn ' t- it? i) 2 MR. JOHNSON: Basically, it refers to 2, which we 3 just took out. ( 4 , DR. SIESS- And now it refers to the branch technical 5 position, right? 6 MR. HULMAN: Pight. 7 DR. S IESS : Which is a lot more pages than that. I 8 mean, the position is 11 pages . So it can't all be in the 9 position. 10 2 on page 6 is operational monitoring requirements, 11 and I assume that refers to (c) (5) (2) pretty specifically . 12 MR. HULMAN: And also 4, (c) (4) . I 13 DP. SIESS: But it is f airly specific to (c) (5) (2) . I 14 MR. HULMAM: Right. 15 DR. SIESS: Pipe breaks I can ' t relate to any one of l l 16 the (c) (5) 's . I 17 MR. JOHNSON: 5.1. j 18 DR. SIEFF' I could not find anything on the pipe 19 breaks in the discussion that referred to localized water i 20 -pressure. So I was in trouble relatina the two. I was looking j 21 for something that talked about that localized water pressure. 22 MR. HULMAM: It is not clear. f 23 DR. SIEbS: And you say that pipe breaks also refers 24 to what, (c) (2) . Secuence of review, that wc uld be, I guess, Ace Fedsrst Fieporters, Inc. (} 25 (c) (2) , right?
76 mte 42 ) i
.1 FR. HULPAN: Yes.
2 2 DR. SIESS: That stands pretty well by itself, and. 3 then the (c) (5) , decommissioning, refers to (c) (5) (4) . () 4 - Now, where is (c) (5) ( 3) discussed, filter clogaing 5 and renoving material? 6 MR. JOHNSON: I think operational monitoring ties intc 7 it. 8 DR. SIESS: But you see the point I 'm making? 9 MP. HULPAN: You are having an organizational diffi-10 culty. . . 11 DR. SIESS: Yes, and without the branch technical 12 position in front of me I an having trouble, and I think there 13 are things in the branch technical position that are not in
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14 the reg guide . I doubt if there 's anything in the reg guide 15 that is not in the position. 16 MR. HULMAN : There are only a couple of things th at 17 are in there specifically with respect to deconmissioning. 18 Everything else is purported to be the same. 19 MR. NILSEN: Ri gh t . 20 DR. SIESS: Now, am I richt that the Position (c) (1) 21 does address the problem of desioning a system that doesn't 22 have to be completely Category l? 23 FR. HULPAN: Right . 24 DR. SIESP- But the rest of this is really endorsing i AceAdoral Reporters, Inc.
'k ) 25 a branch technical position, and that is the way it originated, e . -,r e,-e ,
mte'43 77 g 1 is n ' t i t?. It says write a branch cuide endorsing a technical V 2 position? 3 MR. NILSEN: We did add a little statement with 4 respect to the considerations for the decommissioning.
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3 DR.'SIESS: Why didn't you add that to the branch 6 technical position? this something that you're going to be
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7 doing in the future? Now, I know there have been complaints 8 that branch technical positions don't get reviewed and don't 9 get public comment. I 'm sure you get private comments . And one 10 of the arguments on value impact statements for issuing a reg 11 guide is that they do cet comments. But usually, when you have 12 issued a. reg guide to replace a branch technical position, it 13 has incorporated in it a large proportion of the branch techni-14 cal position. You haven't just endorsed the branch technical 15 position; you have incorporated it in the reg guide. 16 Now, it seems to me that here you are endorsing a 17 branch technical position and that, from adequate review of 18 this, with public comment, the position ought to be looked at. 19 And yet, it doesn't reference it. 20 Is the position going to stay as a branch technical ! 21 position? The standard review plan cannot reference this rea 22 guide as replacing the branch technical position, can it? And 23 you won't need those 11 pages. You've act everything in here 24 you need. . Ace-Federtl Reporters, Inc. 25 MR. HULMAN: The standard review plan is the latest i
mte 44 78 (m 1 revision that references the branch position. V) 2 MR. NILSEN: The standard review plan has several 3 pages talking to these subjects, on how you analyze.
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(_h) 4 - DR. SIESS : Okay. So the stande,rd review plan will 5 reference the branch technical position? 6 MR. HULMAN: Righ t . Not the reg cuide. I 7 DR. SIESS: 8 MR. HULMAN: Correct. 9 DR. SIESS: Then why do we need the reg guide? 10 MR. HULMAN: Only as a replacement for the branch 11 technical position and a vehicle. 12 DR. SIESS: Will the branch technical position be rs 13 taken out completely when the reg guide is done? l () 14 MR. HULMAN: Upon receipt and acknowledgrent and l 15 consideration of public comment. 16 DR. SIFSS: A year and a half from now, let's say this 17 rea guide is accepted. 18 MR. HULMAN: Wei will replace it. 19 DR. SIESS: And this has got everythinc you need in 20 it without that branch technical position. 21 MR. HULMAN: Then we will replace it. 22 DR. SIESS: I don't see how these few pages are going n/ K- 23 to replace all you've got in the branch technical position. 24 MR. HULMAN: Agair., the problem we had when w e wrote ! A eral Reporters, Inc. 25 the branch technical position was that the standard format was l
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!mte'45 79
<- 1 inadecuate to cover the subject. Now that the standard format 2 has been updated, all we need in the way of a regulatory guide 3 is the raterial that is not called for from applicants.
() 4 . DR. SIESS: You have essentially taken what was in 5 the branch technical position and put some of it in the standard 6 format and some of it in the reg guide. And I 'm not about to go
^
7 check and see if you did it that way, because that's your 8 problem. And you have used the reg guide, plus the changes in 9 the standard review plan, to replace die branch technical 10 position.
-11 Now, you really haven't accomplished completely the 12 idea that by publishing a reg guide you get more public comment,
- 13 because you're only going to get the public comment on the part 14 that you put in the reg guide and not the part that you put in l
15 the standard review plan. 16 MR. HULMAN: Unless you publicly display -- 17 DR. S IESS : The branch technical position is already 18 a part of the standard review plan. 19 MR. HULMAN: That is correct, unless you-publicly 20 display the branch technical position. 21 DR. SIESS: No, no t tha t . What a person has to look 22 at is the standard review plan plus the reg guide, and they only A (_f 23 have the right.now, before this group, anyway, to comment on 24 the- reg guide . Ace Fede'r al fleporters, Inc. () 25 MR. HULMAN: Well, the staff and Mr. Denton has
mte 4 6 80 1 recently changed the rules for RRRC, so that in the future 2 branch technical positions will also be advertised for public 3 comment. () 4 . DR. SIESS: But you've taken it out of the standard 5 review plans. i 6 MR. H ULFAM : Well, the standard review plans are I 7 another RRRC action. 8 DR. SIESS: And . that can be commented on? 9 MR. HULMAN: That can be commented on. 10 DR. SIESS : That is all right. It takes some of them 11 o f f of our ba cks . 12 Nell, I understand now what you are doing. The 13 transcript will provide a similar explanation for interested i 14 members of the public, I assume. The value impact statement, 15 that could have been written better. It could have explained 16 that you were taking the branch techni' cal cosition and putting 17 part of it in the standard review plan and part of it in a rea 18 guide, and will thereby climinate -- maybe you have done that 19 all along and we just did not know it. 20 MR. ANDERSON: Pardon me, Dr. Siess. A couple of
'21 times you have said we've taken par t of it and put it in the 22 standard review plan. You mean in the standard format. '
O 23 DR. SIESS: You have not changed the standard review (_/ 24 plan at all? i Ace Federal fleporters, Inc.
/~T 25 MR. HULMAN: We have chanced the standard review plan k/ '
mte/47 81 i 7-s 1 and it directly references the branch technical position. 4 2 DR. SIESS : But after this guide comes out, it will 3 no longer reference the branch technical position and the words
-( ) 4 in the standard review plan will not be changed, except to ;
5 remove that reference? It will tell you to only look at the 6 things rentioned in the reg guide? 7 MR. HULMAN: That is the intent. 8 MR. NILSEN: The reg guide as presented includes 9 all iters which i.the branch position lists on the proposed staf f 10 position. All those items are in here, and then they get into 11 the information type aspects which are now in the standard l 12 fo rma t . 13 DR. SIESS: 1 see what you're doing. It has taken i
}
14 quite a bit of time to understand what vou are doing, and I 15 don' t know where you put that in, although it seems to me that 16 belongs in a value impact statement, which wasn't all that 17 cl ea r. le Now, I still have a problem, and it is not unique to 19 .this guide , in that I have difficulty relating the discussion 20 to the positions. And that is just a matter of organization, of 21 format. And I don't know what the answer to that is . , 22 Harold, do you understand the situation? ( ' 23 DR. ETHERINGTON: I thihk so, yes. 24 DR. SIESS: Shall we put it out to see if anybody else Ace. Federal Reporters, Inc.
- h. 25 understands ~it?
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f- 1 DR. ETHERINGTON: Yes. (- 2 DR. SIESS: Do vou send a transcript of these meetings 3 out or do you get enough auestions without it? ! () 4 . Let's go through page by page to see if there are 5 any comments. 6 Harold, page l? 7 DR. ETHERINGTON: Nothing on p' age-1. l i 8 DR. SIESS: Page 2? I 9 DR. ETHERINGTON: Pace 2, the third paracraph, "The l 10 Permanent dewatering system lower groundwater level," et cetera. 11 There is an additional application to stabilize the ground 12 level that was applied in North Anna. You said stabilize the 13 water level, the groundwater level. 14 DR. SIESS: It is to stabilize it? Is that what you 15 mean? 16 DR. ETHERINGTON : Here it did not mention reduce it. 17 It just said reduce in-leakage. 18 DR. SIESS: It says " lower aroundwater level." 19 MR. HULMAN: " Stabilize" is another good descriptive 20 word. 21 DR. SIESS: It just may keep it from rising. 22 MR. HULMAN: Yes, good connent. 23 D P. . SIESS: Anything else on 2? 24 DR. ETHERINGTON: Nothina else on 2 -- oh , yes , down Ace eral Heporters, Inc.
mte 49 83 7- dewa tering systens are not a required feature . " I would say (,) 1 2 "not normally" are a required feature, because it was required 3 in North Anna by the s taf f. g i.s ,) 4 - DR. SIESS: The point that you're tr0ing to make is 5 that you can always design a structure to take a groundwater 6 level at the surface, if you want to. 7 MR. HULFAN: North Anna is an cnomalous case, because 8 that was a post-construction problem. l 9 DR. ETHERINGTON: And you are making that distinction 10 here? , 11 MR. HULMAN: Yes. 12 DR. SIESS: It can be a recuired remedial feature, l e- 13 but it's not a required design feature. t ( 14 DR. ETHERINGTON: All richt. 15 DR. SIESS : Page 3? 16 DR. ETHERINGTON: Page 3 on the seventh line. I 17 don' t understand the "therefore. " What is that a consequence 18 of? They vary,<certainly, but that doesn't seem to me cuite to 19 follow from the argument. 20 DR. SIESS: No. 21 MR. JOHNSON: The levels vary considerably from site 22 to s ite .
/ \ \- 23 DR. ETHERINGTON: Well, they do certainly.
24 DR. SIESS: Why the "therefore"? A erci F?eporters, Inc. 25 DR. ETHERINGTON: They vary, of courso. I 'm jus t I
mte 50 84 7.,x ; succesting deleting the word "therefore ." L) MR. HULf 4AN : Fine. 2 3 DR. SIESS: Anything else on 3?
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(;\ 4
. Okay, page 4?
5 DR. ETHPRINGTON: Page 4, line 6 -- or 7, rather, the 6 w rd " fully" at the becinning. It seems to me vou don ' t need that wo rd " fully . " If you have a system that is not required 7 g to operate during an earthquake, then the word " fully" should not be there. And if a system depends upon a cump that fails, 9 then the failure is complete. 10 11 Do y u want that word " fully"? 12 MR. HULMAN: We have a two-level review option: The r~s 13 1 wer level that the systen can operate normally, and the N-] l 34 degraded level. What we are using is the lower level as a basis 15 f r review. 16 DR. ETHE RINGTON : But then you have to desian for , j7 the design basis earthauake on some basis . You can't disreca.J 18 the design basis. It says it need not be desioned for desion 39 basis earthouakes if they are not intended to acrform fully. 20 S there is a contradiction th ere . One is partial, the other is complete. 21 MR. HULt1AN : That was, again, a term put in there to 22 n (,)- 23 take care of some portions of the system must function during 24 the earthauake. i Act- mietal Reporters, Inc. 25 DR. SIESS: Let me try something else here diat might i
mte 51 85 1 help. 2 DR. ETHERINGTON: If vou said those portions of the 3 underdrain system not needed to design -- O 4 "8- not"^": rnet te e better ae-5 DR. SIESS: Don't leave it. Now, the last part of 6 the sentence, "or if the system could be expected to perform an 7 underdrain function in a degraded condition." Now, that "an 8 underdrain function" could either be the full function, even 9 though degraded it could perform its full function, or that, 10 though degraded, it could perform a degraded function. Di'd you 11 intend to take account of the degraded function in the previous 12 part? 13 You see, the function could be dectraded or the system 14 could be degraded or both. You could have a degraded system and 15 still perform its full function, and have a dearaded system and , i 16 only perform a degraded function. And I think the two are in 17 there and are sort of confused. 18 MR. . HULMAM: I would agree that the word " fully" should 19 come out. i 20 DR. SIESS: I think that helps. 21 PR. ANDERSON: Would we want to direct this at only 22 portions of the system, then? 23 DR. SIESS: Well -- 24 DR. ETHERINGTON: I don ' t think it matters , as long asi Ace Federsi Reporters, Inc. 25 you get the point that something needs to be adiusted there.
mte 52 86 1 DR.'SIESS: Anything else on 4? 2 DR. ETHERINGTON: No. 3 DR. SIESS: 5? 4 , DR. ETHERINGTON: (]) No. 5 DP. SIESS: 6? 6 DR. ETHERINGTON : No. l 7 DR. SIESS: 77 l 8 DR. ETHERINGTON: No. I 9 DR. SIESS: 89 l l 10 DR. ETHERINGTON: No. I 11 DR. SIESS: 9 we discussed a while ago. Anything 12 els e? 13 DR. ETHERINGTON: Are you on 10? ( 14 DR. SIESS: Me can go to 10. ) i 15 DR. ETHERINGTON: On 5.2, there's a word at the end l 16 of the line that does not belong there. On 5.3, it doesn't 17 quite come apart. And this also applied to the discussion, 18 that there are two things involved. There is the loss of foun-19 dation raterial, which is per se undesirable, and there is the 20 consecuent clogging, which is another undesirable effect. The 21 two are separately undesirable. 22 5.3 seems to convey a little bit that the clogging is D) i s 23 the result of the entrainment, which it is. But it doesn't 24 quite get across the idea of the loss of foundation strength , Ace Federal Reporters, Inc. 25 through the- renoval of the material. We might say the potential
)
6 y .
'mte 53 87 l l j for entrainnent by flowing ground material and the potential for l 2 the clogging of the filter, and then you would have the two 3 thoughts, p 4 Am I making myself clear on this? O 5 MR.-NILSEN: Yes , you're making yoursel f clear. l 6 DR. SIESS: Suppose it was j us t "or" ins tead o f "and"? 7 DR. ETHERINGTON: That's righ t , the second does follow 8 from the first, but the first -- 9 DR. SIESS: But the fact that one is a consecuence of 10 the other -- each is important. 11 MR. JOHNSON: How about "and subseauent clooging"? 12 MR. HULMAN: No, the clogging is not necessarily -- 13 DR. SI ESS : A result of removing a substantial amount ja of entrainment. 15 FR. HULMAN: It can be caused chemically as well as 16 other wavs. So you have to make them mutually exclusive. 17 DR. SIESS: Why don't we just say "or," then? 18 DR. ETHERINGTON: And then you might want to go back 19 in the discussion and develop that same point. 20 DR. SIESS: I mean, you could cloa the filter without 21 removing enough material to be worried about the foundation, and 22 y u could remove enough material to be worried about the founda-O 3 'i ""i'""* ""*"" '" 'i '*""- "it" " " i" i " "*""'- 2d Anything else on 10, then? Ace Feders! Fleporters, Inc. 25 As I read the value impact statement, it talked about
mte 54 88 g~) 1 definitive design criteria, detailed criteria. Again, I guess
'uJ 2 I get a little bit bothered. I don't find the definitive 3 criteria well spelled out in the position. They are more in
() 4 the discussion, and I have trouble relatina one to the other. 5 I tend to look at the nosition as being a position, and it may 6 be definitive by reference, but when I can 't find the reference 7 I have trouble. And I think next year I'm going to start in 8 on the staff again about the format of these cuides. I don't 9 see any reason for perpetuating a lousy format just because it 10 has been there. And the relations between positions and discus-11 s ions , instead of getting better, is getting worse. 12 Do you agree , Harold, to let them kick this one out 13 for comment? s 14 DR. ETHERINGTON: Yes. 15 DR. SIESS: We 'll see if anyone agrees with us. 16 Okay, gentlemen, we are down to -- let's interiect 17 into the agenda at this time a brief excursion to discuss the 18 items expected to be reviewed at the January 3, 1979, meetina. 19 lie have Peg Guide 1.141, Containment Isolation Provisions for 20 Fluid Systems, which endorses an ANSI standard with some ,
.21 exceptions.
22 I ' don't know that we have any particular question or
.]k- 23 comment about that.
24 And then Regulatory Guide 1.XX, a proposed guide on ) l Amjf mI Remru'n. Inc. (j 25 lightning protection for nuclear power plants, which we have l l l
mte 55 89 seen a few times in the past. And would you like to nive us i (/ r-] 1 2 a brief rundown on where that one stands? 3 MR. ANDERSON: Mr. Sullivan can sneak to that. ( 4 - MR . S ULLIVAN : My name is Donald Sullivan. 5 DP. SIESS: Why don't you sit over there by the 6 table, Don, and use the mike, since there are some people 7 sittina in the back of the room. 8 MR. SULLIVAN: We are bringing the lightning ouide 9 back in January, and it will be coming down with a staff posi-10 tion which quite obviously you might expect. Also, we have not I 11 resolved all of the comnents on the guide. That is , all of the ! l 12 staff connents. And rather than comino down with a list of 13 unresolved comments , the individuals whose comments are not 14 resolved h9ve written an alternative staff position, Position C, 15 which we will be sending down also with the cuide, for your l 16 consideration. 17 DR. SIESS: I think we have already cot thos e . l 18 DR. BENDER: We anticipate that we are going to take l 19 a vote on the alternates? How do you plan to address that, 20 the availability of the alternate position from those dissentingI 21 staff nerbers? 22 MR. ANDERSON: How do we handle the proposal to A kl 23 publish this and present it to the public with regard to this 24 dif ferent opinion? Acefederal Reporters, Inc.
/ \
(,) 25 MR. SULLIVAN: We are planning on -- well, at this
mte 56 90 g- I particular point we are preparing the package to be cent c'own. V 2 And we haveh't fully determined ourselves exactly how we're 3 going to handle this. There are several alternatives open to (O,j 4 us. One is simply to attach them to the posi tion, to attach 5 the position as part of the value impact statement; or to 6 actually make it a part of the value impact statement, that is , 7 to describe it as an alternate position,' with the pros and cons . 8 But we are still, within the staff, discussing this 9 point, and hopefully we will have our own house in order within 10 the weckhor so before we send it down to you. II DR. SIESS: I doubt if this Committee is going to 12 resolve the cuestion as to which position. We may have an 13 opinion, but it is still only another opinion. And I have a 14 strong suspicion that both suspicions probably ought to go out 15 for public comment. 16 MR. SULLIVAN: We intend to send the alternate posi-17 tion out for public comment. I hope I made that clear. l 18 MR. ANDERSON: Under the new procedures , the value i 19 impact statement goes for public comment. If this were listed 20 as an alternate technical approach , it would have to be in that 21 value impact statenent with a value inpact on the alternate 22 position also. (s) . 23 DR. SIESS: The meeting in January will be a half-day 24 meeting. We will start at the usual 8:45. I assune the bus i Ace Federal Fleporters, Inc. () 25 schedule has not changed. And we will try to be sure by as i l
mte 57 91 1 'close to '12:00 as we can. I have another meeting scheduled in 2 the af ternoon. I think it is due to start at 1:00. 3 Okay. Let's go now to the proposed rep guide, draf t () 4 regulatory guide: "Atnospheric Dispersion Models for Potential 5 Accident Conseguence Assessments at Nuclear Power Plants." We l l 6 have seen this before. We've had a very fine presentetion of 7 the staff on it. 8 There was a problem within the staff at a level of j l detail, almost, as to the percentage pro tability level, which I 9 10 I understand has been resolved. 9 11 We have had this reviewed earlier by one consultant, 12 who did not have much problem with it at that time. It has been 13 revi ewed by another ACRS consultant, Frank Gifford, and we don 't 14 have his comments in writing. We got daem orally. He thought 15 the major organization was a significant improvement, which I l 16 have to agree with. It would have been difficult not for it to 17 ; be. He is satisfied. 18 I would just like to mention for the staff that I ! 19 think at some point, probably during the public comment period -- 20 and it could be later -- I think we would like to ask the , I 21 staff to rake a presentation on the technical nature of this 22 to the full Committee, simply for information as much as anythina () 23 else. But I think it would be desirable that something as 24 complicated tus this , even though it doesn't represent a major Acefederal Reporters, Inc. ( ), 25 change in siting criteria, but it does represent a change in 1 l l' { l l
. s , e. - ,'
92 mte 58 } 1 siting criteria, that the Committee shotild understand it a 2 little better than I think they do now. ; 3 The Committee is aware that this has been used in O 4 ceees. we heve eeen szne thet use these etmospheric diesersion 5 models. There has been some discussion of their effect one way 6 or the other. I think the Committee knows aenerally that they 7 involve direction-dependent dispersion factors. But I don't 8 think they have had explained to them the probabilistic basis 9 and how it relates to previous practice. And so I think at somq 10 convenient time, we will ask for a technical presentation on P-3 11 it. 12 O 14 15 16 17 l l 18 19 20 l 21 22 O O 23 24 i Ace Federst Fleporters, Inc, O 5
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() pv i MR. HULMAN: Would you like us to arrange it, or 2 would you like to request it? 3 DR. SIESS: I think you should arrange it. And I () 4 am talking about an hour ought to be enough presentation, and i 5 we will have to find out when we have got a time free. It 6 will be in the next few months, I would say. 7 MR. HULMAN: Fine. . 8 DR. SIESS: And I am not really tylng it to the 9 committee's concurrence. That comes after. But I think the 10 staff presentation should be during the comment period. I am
.11 not sure we have to have it at the last stage or something; it 12 is just for information.
13 With that in t ro duc t io n, Leon, do you want to 14 proceed? Oh, let me compliment you on the outiine that was O 15 attached. I prefer to call it a " table of contents.d It was 16 very helpf ul, and I know you did not think of the idea of 17 using an outline, but I appreciate it very much. 18 MR. BERATAN2 Thank you. 19 DR. EIESS: And that is at least a minor suggestion 20 that would be nice on some others. 21 MR. BERATAN: We got a lot of help from NRR on 22 this. We have to give them some credit. 23 The purposes of our coming here today are to keep 24 the ACRS informed. This guide has been reviewed by the ACRS r~T 25 on two previous occasions. This revised version of the V ACE-FEDERAL- REPORTERS, INc, <p02)347-3700 w -_ : -- -
r. 1558.04.2 94 l () pv 1 regulatory guide, to the best of our knowledge,. addresses 2 satisf actorily the technical issues that have been raised 3 concerning the previous versions of the draf t, both by ACRS r~s (-) 4 and by the NRR staff. 5 The major changes consist of restructuring and I 6 clarifying the guide to improve its clarity and readabilityt e' the revision of the probability levelt and changes in the 8 implementation section. , 9 After endorsement by ACRS, we propose to bring this 10 guide before the RRRC. A draft information paper has been JJ prepared as per the RRRC instruction to inform the Commission 12 of the siting implications of the proposed changes to staff 13 practice concerning the meteorological model used in assessing 14 potential accident consequences for nuclear power plants for 15 the determination of site acceptabD ity as set forth in 10 CFR 16 Part 100. 17 Background and technical discussions will be 18 delivered by Earl Markee of the hydrology and meteorology 19 branch. 20 DR. BENDER: Just as a matter of being sure what 21 you are going to te.11 us: Is what you are going to present 22 here anything different than what we have heard before, or are 23 you just going to remind us -- 24 MR. MARKEE: Part of it is a refresher, and the 25 other part is an additional clarification on how we arrived at (]) O ACE-FEDERAL. RF. PORTERS, INC. (202)347-3700
'1558.04.3 95 pv i the various probability levels. 2 DR. SIESS: How long is this going to take? 3 MR. MARKEE: Less than five minutes. 4 DR. SIESS: Very fine. 5 (Viewgraph.) 6 MR. MARKEE: First, I just wanted to review the 7 comparison between the current model or' the "old model," as it 8 is sometimes called, and the new model. 9 DR. SIESS: How about moving that machine this way 10 a little bit and using up as much of the screen as you have
.11 got, since there are some people in the back that don't have 12 advantage of the copies we've got in front of us here.
13 MR. MARKEE: As you recall, the current model or r'% 14 the old model considers a minimum exclusion area boundary in a U 15 circular f ashion for the purpose of computing diff usion 16 estimates. The old model does not consider lateral plume 17 meander, and the end product of the old model is a X/O value, 18 calculated at the five percentile level independent of 19 direc t io n . 20 The new model allows a directionally variable 21 exclusion area boundary. It allows plume meander under 22 certain meteorological and source term conditions and provides 23 a basis for calculating a directionally dependent estimate of 24 dilution, X/0. () 25 Now, with the new model you can see that we have O ACF-FEDERAL RFPORTERS, INC. (202)347-3700 ,
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1558.04.'4 96 , () pvi ! . changed ourfconcept .to a directionally dependent concept from , 2 an'overall site concept. So, at'the request of the ROC, we 3 calibrated'the old site concept with the new sector concept, ()' 4 and we did.this empirically. We took at sample of 18 . sites
- 5. for which we had good meteorological data which represented -
6 the spectrum'of conditions throughout the United States. We 7 calculated the X/O value using the old model at the five 8 pecentile level, with the same assumptions as before for each' 9 site. And we calculated the cumulative probability ; 10 distributions of X/0 by sector, allowing a variable Ji exclusion area boundary, which is .the new model. ! 12 We-then found the probability at which the old 13 model X/0 level was exceeded in each direction sector. We 14 then subjected the maximum sector probability level for each i
.( ) 15 of the 18 sites. We averaged these maximum sector probability 16 levels, and'the result was an average probability level of 17 approximately .5 percent.
18 So, in the new model we have arrived at a value of J 19 .5 percentile level for a limiting sector X/0 concept l 20 approach, calibrating this to the old model. 21 In addition, at the request of ROC, we wanted to 22 limit the X/0 value to a direction-independent approach, and 23 so we put the restriction that the accumulated frequency of 24 the maximum value at the .5 X/0 value at the .5 percentile
;{ ~ 25 level, accumulated throughout all directions, should not ACE-FEDERAlc REPORTERS, INC. (202)347-3700
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;I)' pv l' exceed five percent total for 'the sitet otherwise, if~1t did
' exc eed f ive' percent, we would utilize the fiv'e percentile
'3 value.
7
- 4 - So, this is .the condition that we have put on this, 5 and this is 'not the same as that value because. this value at -
6' the- five percentile -level includes the effects of meander and 7- variable. exclusion area boundary. So, in all cases, this 8 value would be equal to or less than the old value. 9 Now, in summation, I would. Just like to -- f 10 DR. SIESS: Excuse me. That means the new method i J1 can never be less conservative than the old? ! 12 MR. MARKEE This limitation can never be less 13 conservative. 14 DR. SIESS: But it can have different exclusion O 15 boundaries than the old? 16 MR. MARK EE: That's correct. This value can be 17 higher than that. 18 Now, in summation, there are a few facts relating 19 to the new model that we have discovered from our studies. , 20 The new model provides more realistic estimates of diffusion 21 of conditions. From the studies that we have performed based l 22 on all of the sites, we do not anticipate more restrictive i l 23_ diff usion conditions with the use of the new model as compared I 24 ^ to the old model. l 25 However, we recognize that the level of detail is
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1558.04.6 98 f% (_) pv i increased in the new model, and it is going to require more 2 staff effort. Howe ver, the new model is supported by, number 3 one, experimental evidence, the evidence of plume meander, () 4 Atomic Safety and Licensing Board experience which has 5 required in several instances that we look at diffusion 6 conditions in a specific direction, and industry pre.ssure for 1 7 more realistic a.ssessment of X/O values. l l 8 Thank you. 9 DR. SIESS: Now, as I recall, in the value-impact 10 statement,.that it was a comment such as you just made, that l
.11 it would require some more staff effort, but I thought there ;
12 was also a comment that it would not cause a great deal more 4 13 Applicant effort. It says about "a man-week to modify," and 14 .in ro utine runs "about $1.00 and le ss than a man-day." O 15 MR. MARKEE2 That's correc t . 16 DR. SIESS: Have you really got something here 17 that's going to require more staff e ffort but not more 18 Applicant effort? I am skeptical. 19 MR. MARKEE The staff e ffort will be small. . 20 DR. SIESS: It is a one-time effort? 21 MR. MARKEE: No , it will be an effort on a 22 case-by-case basis. 23 DR. SIESS And the staff will have more effort on 24 a case than an Applicant wi.11? 25 MR. MARKEE: No. (]) O ACE-FETIERAl_ RFPORTERS, INC. (202)347-3700
1558.04.7 .99 () pv i DR. SIESS: Mo re increase than an Applicant will? 2 MR. MARKEE: Not necessarily at the normal le vel 3 that we anticipate, if we are looking at specific details that r 4 are going into detail. It would probably require more effort. 5 DR. SIESS: Any questions? 6 DR. BENDER: No. 7 DR. SIESS: We have had a request from Mr. Spickla, 8 of Dames & Moore, to make an cral statement. Is Mr. Spickla 9 here? 10 MR. SpICKLA Yes. J1 DR. SIESS: How long is your statement? 12 MR. SPICKLA2 About five minutes. 13 DR. SIESS: I think we would like to hear it now. 14 MR. SPICKLA2 Thank you. O 15 I am from Dames & Moore, but I am also representing 16 the AI F -~ my voice is such, I don't know if I need a 17 microphone -- I am also representing the AIF subcommittee on 18 atmospheric dispersion which is reviewing the IXXX document. 19 As an individual and also as the chairman of this 20 committee, we endorse the direction that this guide is going. i 1 21 We feel it is wise to modify and keep up with current events 22 with regard to technical de velopment and experimentation, and 23 we think this guide goes a long way in that direction. 24 We would hope that it would not be a stagnant () 25 situation but that, in the f uture, modifications would be made g (/ ACE-FEDERAL REPORTERS, INC. (202)347-3700
0558.04.8 100 Y pv 1 to this guide as new developments occur in the research field, , 2 because there is considerable.reserarch going on at the ; 3 present time in diff usion work. 4 You asked the cuestion of Earl that maybe I can 5 answer. You asked the question with regard to the added work j 6 load on an Appl.icant with regard to this new model, and since 7 I work on the other side of the table as a consultant to the 8 industry, perhaps I can comment on it better than Earl can. I 9 can't ta1k for individual Applicants, but as a consultant, the 10 activity would just mean a modification to existing programs, 11 and once the modification is made'and the program is running, 12 .it takes no more effort to run this model than it did the old 13 model. You are talking minutes on a computer. 14 DR. SIESS: The data are available, the current 15 data-gathering programs would provide all of the input? 16 MR. SPICKLA: Surely. The best meteorotogical 17 monitoring systems anywhere in the world are being done at 18 nuclear piants. It is better, I think, the data being 19 collected, and the quality of the .information is far better 20 than perhaps - Jack Vanderhoven would be upset with my 21 comment --- but I think the quality of the data is better than 22 the quality of the data being collected by our National 23 Weather Service. So, I have no question -- there is no 24 question in my mind that the data is available, so this O 25 1evei of sophisticettom or ene1xsis reetty eous no esees O ACE-FEDERAf. REPORTERS, INC. (202)347-3700
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( pv. 1 burden ~to the. Applicants. That is the only comment I wanted 2 , to make. 3' DR. SIESS: Well, thank you very much.
~
'4
- I have got some comments to make on the i 5 ' value-impact statement, which I don't usually comment on, but 6 I could not pass them up. And I have some questions about 'the 7 implementation. I don't have questions'about anything else.
8 Mike, do you have anything? l 9 DR. BENDER: No. i 10 DR. ETHERINGTON: I have a couple of minor things. JI DR. SIESS: Well, let me raise some questions about i 12 the implementation, on page 15. And I have got two or three, 13 and I think they're fairly simple. . 14 The first sentence of the second paragraph, the
.{ ) sentence involves the word " implementation" on the first line 15-16 and " active implementation" -- or " implementation date" on the 17 4first line and " active implementation date" on the third. Are 18 those the same? Is there a difference between an " active 19 . implementation date" and an " implement ation date"?
20 Let me put it differently .Are those diff erent? 21 ;Well, look, you don't have to answer the question 22 now, but I.think it should be answered at some time. 23 MR. BERATAN I don't believe there is any 24 difference.
.() 25 DR. SIESS: I don't, either.
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) pv i MR. CORNISH: I am Bob Cornish.
2 I don't believe there is any difference. Probably 3 the word " active" could be deleted. 4 DR. SIESS Well, I think " active implementation"
-5 maant " implementation as an active guide," and that is the 6 only thing you do implement, anyway.
7 MR. ANDERSON: It skips to the " active" up in the 8 previous paragraph. 9 MR. BERATAN: Why don't we just take it out? 10 DR. SIESS: No w, the next sentence, it starts on J1 line 357. I ncidenta.11y , numbering the lines helps us a great 12 . deal, and you haven't done quite all of them, but I hope you 13 will keep trying. 14 "The staff will use both the procedures used in the 15 guide and in the standard review plan. I think you need that 16 in to judge the conservatism of an Applicant's assessment of 17 diffusion conditions." 18 Now, does that mean using two procedures? You will 19 take whichever is worse, whichever is the most conservative, 20 to apply? 21 MR. bid?ATAN I think so. 22 MR. MARKEE: No, not nece ssarily. 23 MR. HULMAN: It doesn't have to be which is worse; 24 it is a basis for judging the conservatism. If there are
-( ) 25 small differences between the two, no action is warranted. If 1
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8558.04.11 103 () pv l- there are large differences -- 2 DR. SIESS: That's what I am getting at. 3 MR. HULMANs Which are we going to use? () 4 .. DR. SIESS: Yes. If there are large differences. 5 This one would still satisfy the five percent 6 dire c t io n-inde pe nden t. Both of them will satisfy that. And 7 if this comes out and allows a smaller exclusion boundary than 8 the present standard review plan, which.wi.11 you let the 9 Applicant use, and for how long will you have the dual system? 10 To me, that is fairly.important. You are putting in a new
.11 method, but you're not taking out,the old method. And it 12 doesn't quite tell me which one is going to apply.
13 MR. HULMAN: If the Applicants use the old
, 14 procedure --
k') 15 DR. SIESS: No, it doesn't say anything about what 16 the Applicant usest it says the staff will use both 17 procedures. 18 MR. HULMAN4 If the two estimates differ by about 19 25 percent, is what we have discussed. 20 DR. SIESS2 Which one would you use? 21 MR. HULMAN We would go back to the Applicant and 22 probably use the new procedure, but that isn't clear because 23 that has not happened. ( 24 DR. SIESS2 All right, let me give you -- let's (} 25 take a specific case so we can get this thing se ttled. Let's I ACF-FEDERAL. REPORTERS, INC. (202)347-3700 i
- r- E
1558.04.12 104 rn (,) pv i say an Applicant comes in with the old procedure, and you do 2 it both ways, and you check him on the old procedure,.which 3 you almost have to do, and you find that the new procedure () 4- would require -- would have a 25 percent higher concentration. 5 Is that what you mean? Not a 25 percent greater exclusion. 6 Would you then tell him he has got to either tighten up his 7 containment or release his exclusion boundary? , 8 MR. HULMAN: No. 9 DR. SIESS You would let him use the old 10 procedure?
.11 MR. HULMAN Yes. -
12 DR. SIESS: Now, suppose it's the other way around. 13 Say he used the new procedure, and you made it both ways, and 14 you found out the old procedure gave 25 percent higher. 15 MR. HULMAN: No. But you have not gone beyored the 16 25 percent. 17 DR. SIESS: All right, let's do the same. thing, 18 going 50. My mistake. I can't complain about being literal. 19 Suppose the old procedure gave 50 percent higher 20 co nc e n tra t io n . 21 MR. HULMAN: No. 22 DR. SIESS: You wouldn't? j 23 MR. HULMAN: Not the old procedure. , l 24 DR. SIESS: The old procedure, you could never have 25 50 percent. (]) l ACE-FEDERAL REPORTERS, INC. (202)347-3700
3558.0'4.13' 105 N) pv- 'l ' MR.-HULMAN: You could give higher. 2 DR. SIESSt. But not 50 percent? 3 MR. HULMAN* It is not the'old procedure that is () 4. the concern.
~
5 DR. SIESS2 We11, let's say the new procedure gave 6 50 percent higher than the old, and he used the old proceduret 7 you did it both ways and found out it was a 50 percent worse 8 using the new procedure. 9 MR. HULMAN: I think'we would tend to use the new i 10 procedure at that point. JI DR. SIESS: You would tend to use the more 12 conservative procedure if it is a large difference. 13 MR. HULMAN: No, I tried to clarify that 14 difference. If the new model indicates more than 25 percent O 15 worse, because we believe the new procedure is a more 16 realistic assessment -- 17 DR. SIESS: And if the new procedure gave more than 18 25 percent less, you would still buy the new procedure? 19 MR. HULMAN Correct. 20 DR. SIESS4 If it is plus or minus 25 percent, you 21 don't care? 22 MR. HULMAN: Correct. 23 DR. SIESS: I don't.think I would care at a 24 somewhat higher figure, because of more arbitrary values down 1 25- the line_than that, but that is a philosophical point. {])- RO ACF-FEDERAL REPORTERS, I fJC . (202)347-3700 I _ _ _ . . ~
3 l'558.04.14 106 L( f pv i Now, .what we rea.11y were addre.ssing in that 11.ttle 2~ discussion was the next sentences "Except in the unlikely. 3 event that direction-dependent evaluations re veal a
) 4' significant' bias.of high relative concentrations in specific 5 directions, the . staff expects the results obtained using the 6 standard method to provide acceptably conservative estimates."
7 That is what.you were saying If the new one shows , 8 exceptionally high, you would probably. use it. .This doesn't 9 say you would use it, but the term " acceptably conservative 10 estimates," what you are saying is if the new procedure is ; 1
.11 ex ceptionally higher, a significant bias, then you would not 12 think that.the standard review plan method was acceptably 13 conservative and therefore you would use the new onet right?
14 MR. HULMAN: Right.
. !} ,
DR. SIESS: 15 Oee, I think you could have said it 16 more'specifically than that. : 1 17- On page 16, the last paragraph, I am not quite sure 1 18 . what my question is. I have got the "should be" unde rl i ne d, 19 and I know .it doesn't mean "shall" here in reg guide language. 20 "Is expected to be" --Lis that what you mean? 21 MR. HULMAN Yes. 22 DR. SIESS: Now, this isn't really a part of -- 23 does this really belong in the implementation? 24- MR. HULMAN: I believe it does. It offers an 25 Applicant the option of using less deta11ed parameters than (]) KOJ ACE-FEDERAIi REPORTERS, INC. (202)347-3700 L-L L' ... .
il 558.04 '.15 107 lpv .l; :whatf one might call a full-blown analysis. 2: DR. SIESS: You will still check him? 3 'MR. HULMAN's - Yes. But if he gets home free, he is
'O 4 1es s than 150 rem.at CP time, using very conservative 5 parame ters f or -distances, for example, there is no need to do 6 a det' ailed' analysis.
7 DR. SIESS: It is a good statement for the 8 discussion or for the value . impact statement. It just did not 9 seem'quite right in the implementation. But it is not 10 substantive. JI Mike or Harold, do you.have anything? 12 DR. ETHERINGTON: I have a couple of little ones. 13 On page 4, the paragraph that begins " Calm shall be 14 . defined as average hourly. wind speeds," I find it a li.ttle O 15 difficult to talk of " hourly average speeds" when you can't 16 measure them at all. That is there below the limit of the 17 .measurementi aren't they?' Does that hourly average" 18 contribute anything? 19 DR. SIESS: If it 'is below the starting speed, how 20 do you average something? 21 DR. ETHERINGTON: Couldn't you just leave out the 22 words " hourly average"? 23 MR. MARKEEs It is going to be below the starting 24 -speed for some portion of the time, so you will know it is 25 less than, and it may be above the starting speed for the o ACE-FEDERAL REPORTERS, INC4 1202)347-3700
1558.04.16 108 k) pv 1 remainder. Then, you would get an average of zeros. 2 DR. ETHERINGTON: No, not zeros. You would have to 3 take the average, the starting speed threshold, and then when
) 4 you average it with something more, then you are already above 5 the threshold.
6 DR. SIESS: Your next sentence tells you. 7 MR. MARK EE2 This is less than threshold. 8 DR. SIESS: Read your next sentence, please. 9 "' Calm' should be assigned a wind speed equal to the van 10 anenome ter or starting speed, whichever is higher." So, that Ji is saying you don't take zero. 12 MR. MARKEE: I would have to r.eexamine that, 13 because there is an . implication there. r- 14 DR. SIESS: Yes. I could not understand. The (>) 15 first sentence said that if the average hourly speed is below 16 the starting speed, you would call it a " calm," and that 17 Scalm" should be assigned a wind speed equal to the starting 18 speed, and I did not know whether the second sentence ref erred 19 back to what you get when it doesn't start or what you use in 20 the subsequent calculations. 21 DR. ETHERINGTON: You certainly should not use 22 zero. 23 MR. MARKEE: The secono' sentence is what you use in 24 subsequent calculations. () 25 DR. SIESS: Then, Mr. Etherington's question still e A C F-F F TIF R Al. REPORTERS. INC. (20?)347-3700
1 I ,1.558.04.17 109 ) stands. You don't say "use zero." What is the starting i) pv 1 2 speed? Give us a number so we know what we're talking about. 3 MR. MARKEE: It is about three-quarters of a mile ( 4 per hour. 5 DR. SIESS: So, if it is under three-quarters, you 6 don't call it "zero"? 7 DR. ETHERINGTON: Don't you call it 8 " thr e e-q ua rt er s" ? 9 MR. MARKEE: If the average is less than 10 three-quarters. Il DR. SIESS: But to average that, you must have some 12 values that are under three-quarters. 13 MR. MARKEE: Yes. 14 DR. SIESS: The. thing only ran for 15 minutes out 15 of the hourt the other three-quarters of the hour it wasn't. 16 Let's say, if over an hour it never started, you would call it 17 "zero"? 18 MR. MARKEE Yes. That would be ca lled " calm." i 19 DR. ETHERINGTON: But is " calm" "zero"? 20 DR. SIESS: No. " Calm" is "three quarters." That 21 was the wrong question. 22 Let's say the anenometer only operates for 15 23 minutes in the hour. That meant for the other 45 minutes it 24 war below the starting speed. 25 Is that what you mean? (]}- rx ACE-FETIERAL REPORTERS, INC. (202)347-3700 ,
i ~ $558.04.'18: J10 4 ( )L py , 1 MR. MARKEE: ' Thatts right. _ And it' would be ; 2 recorded as "zero." a 3 DR. SIESS: And for 15 minutes it was two miles an i r s- -
. (_) .
4 hour, and for.the other 45 minutes you don't'know what it was.
}
5 MR. MARKEE: We don't know what it wast it was- - 6 . recorded as "zero" because it failed to give anLindication'. . 7' DR. ETHERINGTON: It was recorded as "zero," but [ t 8 wouldn't you compute it as "three-quarters"? i 9 MR. MARKEEs- No, we would compute that as "zero" 10 . for the averaging. We would take the indicated record to ) 11 obtain the average. l 12 DR. SIESS: So, in that case, if it was two miles 13 an hour for a quarter of an hour, you would get a 14 half-m.ile-an-hour average, which is below the three-quarters, !
.() 15- and so you would call it a " calm"?
16 MR. MARKEE: That's right. 17 DR. SIESS: If it was four miles an hour f or 15 l. 18 minutes. and nothing for 45, you would' get cae mile an hour, 19 and that would not be called a " calm"? 20 MR. MARKEE: That is correct. 21 DR. SIESS: That is clear enough, I guess. 22 And then, the next sentence refers to what you i 23 assign as " calms" when you go into the next calculation. You j i 24 assign them three-quarters.
'(]); 25- DR. ETHERINGTON: On page 6, the top line: " Le.s s
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l1558.04.19 I pv !! t' nan'one hour, i.e." -- that is, le ss than two - . 20 minutes. ; 2 DR. SIESS*- It says."substantially less." i 3 DR. . ETHERI NGTON: Yes. If it is 20 minutes, why 20 minutes"? 4f .not say *20 minutes"? Or does that mean "e.g., 5 Is it "for.' example," or is it "that is"? . 6 MR. MARKEE "That is." [ 7 DR. ETHERINGTON: Then why not just say "less than ! i 8- 20 minutes"? { 9 DR. SIESS: You define "substantially less than one 10 hour" as "20 minut'es." So, why not just say "20 minutes"? JI DR. SIESS: Why not take out "substantially less ' 12 than one hour" and just say "less than 20 minutes"? ; 13 DR. ETHERINGTON: That's what you're saying?
.14 MR. HULMAN: That is also acceptable. ;
)
15 DR. SIESS: That is exactly what you are saying. 16 You have an indefinite term, "substantially less than one 17 hour," which you have now defined. t 18 DR. ETHERINGTON: At page 9, for my own education, 19 could you tell me qualitatively why ground-relative 20 concentrations cannot be higher than those produced by 21 nonf umigating stable atmospheric conditions? And can you put 22 something on the board that would explain that? 23 MR. MARK EE2 Yes. If we take the case where we 24 have a . stack, and let's take the terrain here as rising up, t
;()- 25 and so the fumigation-condition actually puts a lid right on
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1558.04.20 312 p) (_ -pv l' it at the stack and makes this the e ff.luent. 2 Now, when we come to -- this would be the level of 3 the plume, when we get to the point here, we have had. mixing
) 4 .through'this depth, and in order to get continuity when the 5 plume comes out here and fumigates, it has already been 6 spreading at a rate of slow dispersion just .before it 7 fumigates. So, that can be represented by something that 8 comes up like this, in the shape of a plume.
9 Now, getting out to that distance, the plume has 10 already spread by this much, and if we invoke the dif fusion i l JI equation, it would say it is only -distributed through this 12 _ depth, but the diffusion has already spread it out to this 1 13 point. , 1 7- 14 DR. ETHERINGTON: Now, suppose you took a. point l (-) 15 between the stack and that rise. Then, the fumigation level I 1 i 16 would be higher than that? 17 MR. MARKEE : That's right. Here, the fumigation i 18 condition would be much higher than the spread here. i 19 DR. ETHERINGTON: Isn't that contradictory to what 20 you say here, "The ground-relative concentration for 21 fumigation conditions cannot be higher"? But in that location 22 they will be higher. 23 DR. SIESS: What does it mean, " ground level"? 24 MR. HULMAN: Show the ground-level plume growing. l () 25 MR. MARKEE: If you look at the concentration now l \ l ACE-FETIERAL REPORTERS, INC. (2n2)347-3700 l
, 4
. .! ! 3 '
1558.04.21
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i: ..Eh ' pv- 1 "as'a function of distance 1 and at.this' point, if we had 2 fumigation, we would have some level out .to some point here
'3 ' where- the terrain rose up. And as this distance shrr!nk I( ) 4 between the center line and the ground level as that' distance 5 shrunk, this value would'have to go up.
6 DR. ETHERINGTON: But I didn't want to have a hill . 7 theret I wanted a completely flat te.rrain. 8 MR. MARKEE: Then, it would continue on going on 9 out. 10 DR. ETHERINGTON2 But in fumigation, wouldn't you 11 have a higher level than the stack? 12 MR. MARKEEs That's r ight . Now, if you look at the 13 stable condition, the thing would be very near zero here and 14 come up very slowly. You probably would not see much of a O 15 plume until maybe getting out to some point out in here, and i 16 then this thing would slowly rise up from an elevated release 17 as the plume spreads down, and at some point this value could 18 actually intersect the other value. It is not too likely. 19 except at very long distances. , 20 DR. SIESS: Now, the top curve is the fumigation 21 condition, the flat curve you drew there? ; i 22 MR. MARKEE: That's right. That would be the l
. -)
23 -assumption using the f umigation formulation. I 24 DR. SIESS: And the other is the nonf umigation , t 25 . stable?' f{ [
- 1
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1558.04.22 114
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(_) pv 1 MR. MARKEE: Tha t's r ight . 2 DR. SIESS: And you said the first could not be 3 higher than the second, and you have shown it higher than the n k-) 4 second all the way out there. 5 MR. MARKEE2 The.first -- 6 DR. SIESS: Your statement says that that one 7 cannot be higher than the other. 8 DR. ETHERINGTON: That is the statement in the reg 9 guide. 10 MR. HULMAN: Let's see if I can try -- J1 DR. SIESS2 Are you still sure it's right? 12 MR. HULMAN: Yes. 13 DR. SIESS I just want to know what you're trying n 14 to prove, d 15 MR. HULMAN: Let's take Dr. Etherington's example. 16 Okay, do you want to do it? 17 MR. MARKEE: I see the problem. I have labeled 18 .this as a constant. It actually decreases because you are l 19 getting greater lateral spread. I was just looking at it f rom 1 20 the vertical point of view. That actually decreases. This 21 thing decreases as the lateral spread increases. 22 DR. SIESS Label that "F" for " fumigation." Now, 23 draw your stable condition. 24 MR. MARKEE: Okay, now, very close in, the l () 25 ground-level concentration down here without fumigation rm N.,] ACE-FEDERAL REPORTERS, INC. (202)347-3700
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15581.04;23 , 115 pv.'l. actually 'looks -- comes ' up to .some point at some distance. I 2 adon't know where'this distance is. It is probably -- usually 3 depending upon the stack height, Lit-is very long. 4 MR. HULMAN Start it at the same X value. 5 DR. ETHERINGTON: Oh, no. 6 MR. MARKEE: There is a difference in ground-level 7 concentrations. 8 MR..HULMAN2 Okay, ground-level concentrations.. Go 9 ahead. 10 DR. SIESS: Then, how do you get a ground-level j 11 concentration that is zero for fumigation? 12 DR. ETHERINGTON: You have to go out some distance 13 before this statement i s true. . 14 MR. MARKEE: That's right. And it was mainly to i 15 handle' this point with the terrain, where you are actually 16 restricting compression. l
'17 DR. ETHERINGTON: That does not come true in the 18 reg guide.
19 DR. SIESS: It does not say "at some distance," and 20 it doesn't say "at an elevated ground level." l 21 MR. MARKEE No. 22 DR. SIESS: So, it is not'right. 23 MR. SPICKLA: 'You ought to mention the word 24 "te rrain" in that statement, because otherwise the statement o
.]. 25 is.not true. \'
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1558.04.24 JI6
) pv 1 MR. MARKEE: That's right. In-the case of rising , 2 terrain.
3 MR. SPICKLA: In the case of rising terrain, . this n
%J 4 is true.-
5 DR. ETHERINGTON: Even then, we have to define what 6 the degree of rise or what the distance is. 7 DR. SIESS: Now, the way you' drew it the second 8 time, even with nonrising terrain, they cross at some point. 9 MR. MARKEE: That's right.. 10 DR. SIESS: Now, you're not really interested in J1 the X/0 un til you get out to some distance. Are you trying to 12 say that when you get out to the exclusion boundary -- 13 MR. MARKEE: They will cross over, and then this 14 one will come down. I 15 DR. SIESS: If that distance were always less than 16 the exclusion boundary, this would be properly qualified and a 17 -valid statement, because you're not really interested in X/0 18 inside the exclusion boundary in licensing. 19 MR. SPICKLA: With level terrain, that statem'nt e is 20 incorrect. With the normal exclusion boundary, that is not 21 true, because the fumigation case has to be a higher i 22 concentration than the same plume emi.tted at 100 meters with a 23 stable plume because the plume would not touch the ground at a 24 normal site boundary. That is why he has to add the statement 25 cabout te rrain. (]) 1 (~ l
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d558.04.25 117 () pv l' DR. SIESS: Okay, you will fix that up? 2 MR. MARKEE: Yes. 3 DR..ETHERINGTON: Then, do you have to say how much rm.
- 4 rise there should be?
5 MR. SPICKLA My suggestion is to strike the 6 sentence because it conf uses things. 7 'DR. ETHERINGTON: Then, you have a problem as to 8 what yo ur solut. ion is. 9 MR. SPICKLA Well, the next statement says that 10 you look at the X/Os from both cases and use the more Ji co ns e rva tive . - 12 DR. ETHERINGTON: Here, he was taking the less 13 conservative. 14 DR. SIEES: If we strike that sentence, I think S
- )
15 that clears it up. 16 DR. ETHERINGTON: That won't quite fix it. It very 17 -nearly will. Go to the previous page on line 1901 you have 18 AT greater thar, zero weather. AT is a little more than zero. 19 Then you're going to have a prohibitively high number for X/0. 20 DR. SIESS: Do you understand the problem? 21 MR. MARKEE : Yes. That is the problem that we 22 have. 23 .DR. ETHERI NGTO N: Maybe you can fix that'in terms 24 of your elevation. If your height is greater, if the
-() 25 elevation is greater than something, you can compare it with <~
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1558.04.26 J18
-( ) pv i this equation.
2 DR. SIESS: We.11, the terrain height, the effective 3 stack height is HS on HT, stack height minus the terrain ] () 4 height. And that is what has to be given greater than zero. i 5 MR. MARKEE: That's right. If that goes to zero, I 6 then Equation 5 comes into effect. This was the problem that 7 we were contending with. - 8 DR. SIESS: That is why you had the ground rise. 9 MR. MARKEE: That's right. 10 DR. SIESS: If the ground rises to the stack height II Equ a tion 5 goes to infinity. . 12 MR. MARKEE: Tha t's r ight . Actually, if it gets 13 too large before it gets to zero. 14 DR. ETHERINGTON: Maybe there is no problemt the O 15 only problem is in the statement that it cannot be higher 16 without qualification. 17 DR. SIESS: Well, the staff will look at it s right? 18 MR. MARKEE: Yes. 19 DR. SIESS: Okay, Harold? 20 DR. ETHERINGTON: That's all. 21 DR. SIE.SS: I just noticed a nit on page 10, line 22 2 33. You say Section C-132 gave procedures. It is not a good 23 ' idea to write as if the reader has read everything that went 24 before. It not only gave, it gives and still does -- in your 25 value-impact statement, it seems to me you have go.tten a (]) O ACF-FEllFRAl. REPORTERS, .INC. (202)347-3700
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0558.04.27 Ji9 () pv i little enthusiastic in spots. This one is in that category. 2 On page I, under the "Need," you says "Recently 3 collected experimental data have established a basis for more () 4 accurate evaluations." Well, " basis" i sn' t a '8 n eed. " It 5 might be a means for fulfilling it, but I would expect this to 6 talk about the need, and I don't even find the word "need." 7 In the last sentence on that page, you says "A
- 8 method to permit calculation of dispersion by direction is l
l 9 needed." You say it is " proposed," but you don't ever say it 10 is "needed."
.11 Frankly, I am a little. skeptical. I am not sure it 12 is needed. It might be nice.
13 MR. BERATANs It would be use f ul . 14 DR. SIESS: It is useful. It is more correct. O 15 On page 2, in C-1, it states: "The consequences of 16 potential accidents would be to determine more realistically." 17 You have made a much be tter statement elsewhere, where you say 18 that "The dispersion f actors could be determined more 19 realistically." I think I will buy that, but I don't really 20 buy that "The consequences are that much more realistic." 21 When I have got a source term that -- you've got 22 several orders of higher uncertainty in it than this stuff, 23 mostly you have confined this to the improved calculation of 1 24 dispersion coefficients and not those calculations. 1 25 MR. CORNISH: Perhaps if we said the "X/0 values." [} l i ACE-FEDERAL REPORTFRS, INC. (20?)347-3700 l' k.... . . . . . . . . . . . . . . . .
9558.04.28 120 pv DR. SIESS: That's what you said later, and I think I) 1 2 that.is more appropriate. 3
~
And then you talk about something being more () 4 accurate, in the next paragraph, and I wish you would decide 5 whether it is "more realistic" or "more accurate" or "more , 6 precise." It is "more" a lot of things, according to this, 7 and I think you are sort of overstating it. 8 And then, I get down to the end, now, on page 34 9 you've got sort of an interesting statement, beginning on the "The basis for this time estimate is the remote
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10 tenth line 11 possibility that detailed diffusion estimates of a spectrum of 12 accidents in areas would be dictated by management." 13 Do you mean you don't know what you are going to do 14 yet? O 15 MR. HULMAN: We know what we have done, and it has 16 not resulted to date in very detailed accidents in the area of 17 evaluations. There are some staff members who believe in the 18 f uture that may be nece ssary or may be dictated by management. 19 DR. SIESS: I think that when this is presented to 20 the ACRS, we might like to know how much farther this might be 21 taken by management, because I am not at all convinced that 22 additional precision in the siting process is completely 23 justified in terms of the health and saf ety to the public of 24 picking good sites. And if management is going to shove this 25 thing out to some ridiculous extreme of complexity, I wouldn't (]} C) ; ACE-FEDERAL REPORTERS, INC. (202)347-3700
$558.04.29 121 ()_ pv i be too happy, and I think the committee ought to know just how 2' far are we going with this thing. We can continue to , 3 complicate the calculations between source terms and allowable () 4 doses ad-infi,iitum -- and ad nauseum, I might add. What you 5 have donc so far is not unreasonable. 6 MR. HULMAN: Let me see if I can qualify my 7 previous statement, Dr. Siess. There are some people on the 8 staff that believe, because this model is more complicated and 9 presents more detail with respect to the meteorological 10 proportions of the Part 100-type computations, it may be
.11 necessary in the future for the other parts of the same 12 analyses to be of comparable demonstration.
13 DR. SIESS: That is a very good argument that I can 14 turn the other way.
-O 15 MR. HULMAN Yes. And I have argued the same way.
16 DR. SIESS: And if somebody wants to define source 17 terms more realistically or more accurately or more correctly, 18 to use the various words I have seen here, this might be ; 19 worthwhile. But I suspect if you went very far in that 20 dire c t ion , the kind of differences you would get here, you 1 21 could forget about it. But we are jnterested in source terms, 22 as you know, and we are interested in this whole accident 23 calculation for siting, and that kind of open-ended statement 24 that says, "I think there are some people on the committee who 25
-() are going to feel maybe this is going a little too far now in
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1558.04.30 122 () pv 1 view of what we know and how arbitrary the 300 rem is and if 2 it is going to get a lot more complicated," I think the 3 committee would like to get some comments in. And you ought ( 4 to have a basis for it. So keep that in mind when you're 5 . making a presentation. 6 MR. CORNISH The reason for putting this in was 7 the fact that we wanted to bring out in the open that if, 8 indeed, people wanted to go through much more detailed 9 calculations, that there was a possibility. 10 DR. SIESS: I think it is great that you said it, end#4 11 On page 7, what is a " default analysis"? 12 13
, 14 15 16 17 i
18 19 20 21 22 23 24 25' (]) k. ACE-FFDERAl. REPORTERS, TNC. (202)347-3700
BS58.05.1 123
! MR. HULMAN At one time there was an assumption
(])h 2 of'the same meteorology for every sector. 3 DR. SIESS: I just never heard the term that on () 4 page 8, at the end of the top paragraph, when you talk about 5 the other variations, you mention the likelihood of a release. 6 And I would like to see added "of the assumed magnitude." 7 That is not only. the likelihood of a release, but 8 the likelihood of 1.3 or 1.4 magnitude release. 9 MR HULMAN: Even though the word " include" is in 10 there, I think you are right. J1 DR. SIESS: And up at the top of that paragraph, it 12 says "the proposed model off ers the opportunity to inform the 13 public of the relative diff usion risks around the nuclear 14 power plant site." A
\I 15 Do you really believe that?
16 MR. HULMAN This points out the differences in 17 diffusion conditions around a site. 18 DR. SIESS: Do you think anybody can understand what 19 it means? 20 MR. HULMAN: Yes, I think so. I think that somebody 21 residing on one side of a reactor site, as opposed to another 22 side of the site, can see significant differences by the 23 use of this model. 24 DR. SIE SS: They can certainly decide which fence yy b 25 post to stand next to. O ACE-FEDFRAL REPORTERS, INC. (202)347-3700 _. ~ 4 . r ~~.'
8558.05.2 124
\
(s\h- 1 MR. HULMAN: Or not to stand next to. i 2 DR. SIESS: But when you get out any further than 1 3 that, is there a difference at LPCs? 4 MR. HULMAN: There is a difference at LPCs. 5 DR. SIESS: Where can the public get that information? 6 They can't get it out of an SER. Can they get it out of an 7 SAR? > 8 MR. HULMAN: Yes, they can get it out of an SAR. 9 They tend to display this information. If we, for example, 10 display by sector 5/10ths X/O value, that gives people 11 living in the area a relative, a feeling for the relative 12 risk given an accident of how bad it can be. 13 DR. BENDER: I hate to get involved in this 14 ergument. Are you really inf erring that people. who are living 15 at the site boundary are going to look at this thing? i 16 DR. SIESS: I can see some advantage to it from the 17 point of view of people that are doing emergency planning. 18 But for people that are living there -- 19 MR. PORSE: I t i s g ood PR . 20 DR. SIESS: I don't say it won't happen, but I don't 21 think it is of great value to anybody to kno;; that. 22 MR. HULMAN: I think displaying the relative risks, 23 if I don't define the term risk," but if I say the relative 24 diffusion conditions that one might expect around the () 25 boundary to the residents in the vicinity of a plant. I think
.O ACF.-FFTIERAL REPORTERS , TNC. (202)347-3700
1558.05.3 125 O
\,sh 1 I .have contributed to public understanding of this.
2 DR. SIESS: The risk involves probability. 3 Probability is involved here in direction. Of course, the 4 larger Improbability is in the. occurrence of the accident in 5 the first place, and that makes it a little hard for them to 6 evaluate the risk because I think if they question the 7 probability of the accident, there is more uncertainty 8 on that probability than there is dif ference in the 9 diffusion characteristics in different directions. 10 So I think it is a little misleading. I mean if
.11 you tell them that it is 10 to the minus 7 probability on 12 the accident, divided by 10 to the 2, that is a much bigger 13- fac tor _ than the second independence. ~T 14 On page J !, you've got a statement that the (J 15 disadvantages ar.e not implemented in changing the licensing 16 staff open to criticism for showing improvements in state of 17 the art.
18 Do you have in mind any particular people who are 19 going to be criticizing? 20 MR. HULMAN: We already have been criticized. 21 DR.-SIESS: Then I like the last sentence there 22 about the justification. That will justify anything. W e.11, 23 as'a value impact statement, it is not bad. 24 You mention on page 19, the overall siting policy () 25 and practice revision study currently under review by the O ACE-FFTtFRAL REPORTERS, INC. (202)347-3700
0558.05.4 126 p office of standards- development in cooperation with NMMR, (_,h I 2 NRR, and RES. 3' What is the status of that? I) -4 - MR. BERATAN: It is underway. 5 MR. HULMAN The task force has been established 6 within NRR. 7 DR. SIESS: That takes care of the next couple of 8 yects. 9 MR. HULMAN: No. Let's see, it was established in 10 October with a 6-month length. That makes it about March. ) J1 Preliminary information .is supposed to be available, 12 I. understand in January. 13 DR. SIESS: What is the scope of that. Does that 14 includ crack code, an Appendix A seismic? Seismic is part of it. But that has
~
15 MR. BERATAN 16 been separated out from it. 17 MR. HULMAN: It goes to existing practice with 18 recommendations to what the future changes in policy practice 19 should be. It is pr.imarily at the direction of the commission 20 to discuss present policy and practice. 21 It may discuss crack code. 22 DR. SIESS: Any comments, Mike?
]
23 DR. BENDERJ No. 24 DR. SIESS: Harold? l 25 ' DR. ETHERI NGTON: No. (]) l n U. ACE-FEDERAL REPORTERS, INC. (202)347-3700 l
l 1558.05.5 127 DR. SIESS: Any objection to this going out for ( )h ! 2 comment ? 1 3 (No response.) l () 4 - DR. SIESS: We've got one other item lef t on the 5 agenda, and that is an old friend, Regulatory Guide 1.104, 6 draft 3, revision 1. 7 " Single failure proof, overhead crane handling 8 systems for nuclear power plants." 9 MR. PORSE The guide has been revised to include 10 the changes suggested in the meeting of October 4. A typo,
.11 though, has sneaked in on page 2,.where we say, "the 12 capability in the first conments for saf ety shutdown."
13 It should be safely shutdown. 1 14 DR. BENDER: Where is that? O 15 MR. PORSEs on page 2 in the first comment on the . l 16 right-hand side, at the end of that. 17 DR. BENDER: Okay, yes, I've got it. 1 18 MR. PORSEs However, we have one announcement that 19 should possibly be made now. At the RRRC meeting on 20 November 21, the committee decided that.this document should 21 not be issued as a regulatory guide, but as a new reg report. 22 That means, of course, that the format will be 23 changed slightly, but otherwise, the substance of the 24 document will be retained. f' 25 DR. ETHERINGTON: Will it also mean the subcommittee O ACE-FETIERAL REPORTERS, INC. (202)347-3700
0558.05.6 128 ()h l~ would not review it? 2 MR. PORSE: Yes. 3 DR. SIESS: We could always comment on it. But I () 4 think that there would be not much to say. I think that is 5 a good decision, and I think it takes it out of our province 6 now. 7 But I would like to thank the' staff for this 8 material they provided at the back of this on the 9 implementation, which was at our request last month, which 10 I think is very interesting and helpful in understanding the
.11 implementation. -
12 I must admit I did not understand the categories j 13 very we ll, and in Table 1, I . think as you do that, you l 14 probably won't put that in a new reg. O 15 MR. PORSE No. 16 DR. SIESS: The operating plants in Categories 3 and 17 4, I could not figure those out, but that is beside the 18 point. 19 MR. ANDERSON: If the committee has any suggestions 20 that they thought should be carried into the new reg, I 21 believe we would like to hear them. 22 DR. SIESS: I think we gave you an awful lot of 23 suggestions that got incorporated into various places. And 24 I don't know how the new reg fits into the regulatory process, 25 but this does seem to have a very limited app 1f cation. And it ({} , I ACE-FEDERAL REPORTERS, INC. (202)347-3700 l __ ___-._m. _ - _ _ _
e558.05.7 129 l T k','J h I will be very helpful to people who are trying to backfit or [ 2 design single f411ure-proof cranes. 3 Gentlemen, that is all the matters you brought up. 1 ' (~')
\' 4 I had previously mentioned to the committee that we will 5 inform the committee of the changes made in the Appendix H, 6 which I don't think gives us any problem.
7 MR. ANDERSON: I should point out as f ar as the 8 Appendix H is concerned, that is now going out for public 9 comment and so you will see it again.- 10 DR. SIESS: Yes, we wi.11 see it again. But since ! .11 the committee approved a particular thing, and I think it 12 was fort. ally in a letter, we probably need to make them l 13 cognizant of it. But we can probably do it by a memo or f 14 something. 15 .s there any other business? 16 (No response.) 17 DR. SIESS: Thank you all, gentlemen. The meeting 18 is adjourned. 19 (Whereupon, at 12:35 p.m., the hearing adjourned.) 20 21 22 23 24 () 25 l I d () ACE-FEDERAL REPORTERS, INC. (202)347-3700 l
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UNITED STATES
- 8 g NUCLEAR REGULATORY COMMisslON
- WASHINGTON, D. C. 20555 ,
5 .gA, M'Oj - K.fff % ,,.. , NOV 2 1978 .
~
O - MEMORANDUM FOR: Raymond F. Fraley, Executive Director, ACRSr FROM: Guy A. Arlotto, Director, Division of Engineering Standards, Office of Standards Development 4 DRAFT 1, PROPOSED REGULATORY GUIDE 1.XXX (RS 810-5),
SUBJECT:
" QUALIFICATION OF QUALITY ASSURANCE PROGRAM AUDIT PERSONNEL l
! FOR NUCLEAR POWER PLANTS"
! Enclosed for initial review by the ACRS Regulatory Activities Subcommittee are fifteen copies of proposed Regulatory Guide 1.XXX (RS 810-5), "Quali-fication of Quality Assurance Program Audit Personnel for Nuclear Power Plants, " Draft 1 dated September 27, 1978. Also enclosed are fifteen
. copies of (a) ANSI /ASME Nd5.2.23-1978, " Qualification of Quality Assurance )
-' - Program Audit Personnel for Nuclear Power Plants," which is endorsed by l
~l 'the proposed Regulatory Guide and (b) the value-impact assessment for the proposed guide.
Since the draft guide is preliminary, additional staff effo'rts including review ead reso utio" or pub'ic comme"ts win be "ecessery Prior to O implementation of a regulatory position. ACRS Subcommittee comments and recommendations are requested on the proposed regulator position.
~
l Guy A. Arlotto, Director Division of Engineering Standards Office of Standards Development
Enclosures:
(15 each)
- 1. Draft 1, Regulatory Guide 1.XXX (RS 810,5) dated September 27, 1978
- 2. ANSI /ASME N45.2.23-1978
- 3. Value-Impact Assessment dated August 2S, 1978 An wsogy#'CE* 2 D
, REACTOR s4pggg
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. PROJECTS E1Wty MRAL MLECTRtc COMPANY 17s CURTNER AVE., SAN JOSE, CAUFORNIA G5125 i MC 682, .(408) .925-5040 MFN 427 Q- -
December 5, 1978 1 Advisory Comittee on Reactor Safeguards . U. S. Nuclear Regulatory Comission Washington, D.C. 20555 etention: G. G.. RuittRhreiht -
~
Gencte' men: , SUDJECT: DRAFT 1, PROPOSED REdULATORY GdIDE 1.xxx (RSS10-5),
" QUALIFICATION OF QUALITY ASSURANCE PROGRAM AUDIT PERSONNEL FOR NUCLEAR F0WER PLANTS." DATED 9/27/78 General Electric is pleased to coment on the subject guide. GE cermants?
q deal with the credit /pointcount system and the validation of examination - criteria. O The subject regulatory guide fully endorses ANSI /ASME N45.2.23-1978 With the exception of Section 1.5 of the standard. GE recconends that Section 2.3.1. " Education and Experience;" Section 2.3.5, " Examination;" Section 3.3.. "Requalification" (portion dealing with reexamination in accordance with paragraph 2.3.5); and Section 4.2, " Qualification Examination," of ANSI /ASME N45.2.23-1978 be identified in the regulatory guide as.non-mandatory guidance. The basis for this recomendation is . the following. CREDIT /POINTCOUl1T SYSTc7 Section 2.3.1 requires that a credit /pointcount system be used for qualifying lead auditors. Such a concept is counter-product.ive and deprives nunagement' of the selection prerogative. The point score system is en academic exercise which does not realistically evaluate a lead auditor's qualifications. . For en example, a young Rhodes scholar with , a PhD in. nuclear engineering, with sei>eral courses i_n QA; one year in pressure vessel design, and a member of a supplier evaluation team which had performed one audit, could not become a lead auditor until he had perticipated in four more QA audits. Yet a person with an Associate O deeree in arts. with five zeers exnerience es en inspector end eueitor in n non-nuclear industry, has enough credits to imediately become a j lead auditor. JO 4 - a l> 1{ .
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G E N ER A L [fj E LECTRIC: l (~) G. R. Quittschreiber H' Page 2
; December 5,1978 . s.
The use of a credit /pointcount system for qualification of lead auditors l (~) has been deleted in the latest draft of ANSI /ASME NQA-1, draft 4, revision 0, October 1978, " Quality Assurance Program Requirements for Nuclear Power Plants." This latest draft has been approved by the ASME
- Nuclear Quality Assurance Main Ccemittee and forwarded to the Nuclear Codes and Standards Conmittee.
7 VALIDATION OF EXAMINATION CRITERIA , , ~ ;, i . i
. Sections 2.3.5, 3.3 and 4.2 address examination and reexamination of ! lead auditors for the purpose of qualifying such personnel to lead- ! audits. Utilization of the examination criteria identified in Section j 3.2.5 (and referenced in Sections 3.3 and 4.2) would require validation i as prescribed in CFR Title 41, Chapter 60, Part 60-3. As stated in Section 60-3.4, evidence of a test's validity should consist of empirica.la data demonstrating that the test is predictive of or significantly correlated with important elements of work behavior which comprise or are relevant to the job or jobs for which candidates are being evaluated.
Because of the difficulty of validation, it is doubtful that each validation attempt would be successful, and users of the standard would be in the position of having to violato the standard or the Federal .6 Regulation. r q
! General Electric would be pleased to provide any further information and
.to actively interact with the NRC on this subject. Robert J. Murillo of my staff (408) 925-3406,may be contacted in this respect.
s , , . n . .-
-Very truly yours,-
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m '... Glenn G.' Sherwood, Matlager Safety and Licensing Operation GGS:bp/1131-32 . ,
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o% ***** / . SEP 2 y y. . ( .. c) .. . . MEMORANDuti FOR: Raymond F. Fraley, Executive Diiector, ACRSI FROM: G. A. Arlotto, Director, Division of Engineering Standards, Office of Standards Development
SUBJECT:
DRAFT 1, REGULATORY GUIDE 1,8, " PERSONNEL SELECTION AND TRAINING," REVISION 2 - Enclosed for the use of the Subcommittee on Regulatory Activities are fif-teen copies of Draft 1 of proposed Regulatory Guide 1.8, "Personnei Selec, tion and Training," dated September 22, 1978. The guide endorses with certain exceptions ANSI /ANS 3.1-1977, " Selection and Training of Nuclear Power Plant Personne'l." Revision.1-R of the guide, which endorses the , 1971 version of the standard, was published in May 1977, , l
-j i Since the draft guide is preliminary, additional staff efforts including review and resolution of public comments will be necessary prior to imple-mentation of a regulatory position. ACRS Subcommittee comments and recom- l
(] mendations are requested on the proposed regulatory position. W Guy A Arlotto, Di ector l ,' Division of Engineering Standards i Office of Standards Development l l
Enclosures:
(15 each)
- l i
- 1. Draft 1, R.G. 1.8, Rev. 2 dated September 22, 1978
- 2. ANSI /ANS 3.1-1977
- 3. Value Impact Statement
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- RECtlyED i ADYlSORY c0MMITTtt oN
! REAc10R sAFtcyARDs U.S. W, GRT 201978 PM
;9tutdtklNI UI NO 1
MEMORANDUM FOR: Raymond F. Fraley, Executive Director Advisory Committee on Reactor Safeguards FROM: Guy A. Arlotto, Director, Division of Engineering
! Standards, Office of Standards Development e
SUBJECT:
DRAFT 1, REGULATORY GUIDE, " SAFETY RELATED PERMANENT DEWATEP,ING SYSTEMS" Enclosed for'the use of the Subcommittee on Regulatory Activities are R fifteen copies of Draft 1 of the proposed Regulatory Guide, " Safety p\ Related Permanent Dewatering Systems," dated 9/9/78, and its associated preliminary Value/ Impact Statement. Since the draft guide is preliminary, additional staff efforts including review and resolution of pub ic comments will be necessary 1 prior to implementation of a regulato position. ACRS Subcommittee' { comments and recommendations are re sted on he proposed regulatory 4 position. Gu A. I lotto, Director Div 'sion of Engineering Standards
, Off ce of Standards Development i
Enclosures:
- 1. Draf t 1 Reg. Guide (9/9/78)
- 2. Preliminary Value/ Impact Statement I
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** NOV 0 91978 O
V - MEMORADNUM FOR: Raymond F. Fraley, Executive Director f Advisory Committee on Reactor Safeguards ; f FROM: Karl R. Goller, Director Division of Siting, Health and Safeguards Standards, SD < 4
SUBJECT:
DRAFT REGULATORY GUIDE, " ATMOSPHERIC DISPERSION MODELS
! FOR POTENTIAL ACCIDENT CONSEQUENCE ASSESSMENTS AT NUCLEAR Q
I POWER PLANTS" Enclosed for review by the ACRS Regulatory Guide Subcommittee are fifteen copies of draft Regulatory Guide " Atmospheric Dispersion Models for Potential Accident Consequence Assessments at Nuclear Power Plants," dated October 26, 1978, and the accompanying Value/ Impact Assessment. - The ACRS Regulatory Guide Subcommittee reviewea a previous dr' aft of this guide, dated September 13, 1977, during the Subcomittee's meeting on Q. l November 2,1977, and a subsequent revision of the guide, dated June 12, 1978, was reviewed during the Subcommittee's meeting on July 5,1978. Discussion at the July 5 meeting revealed that there were still unresolved concerns among the NRR staff regarding the guide. The Subcommittee recom-mended resolution of these concerns before progressing further. Since that
~
meeti.ng, the NRR staff concerns have been resolved and the resulting changes have been incorporated into the enclosed revision of the guide. This revision involves a major reorganization of the guide and a change in the probability level at which atmospheric relative concentration values are selected for use in design basis accident evaluations (Section C.2.1 of theguide). Additional review of this draft regulatory guide by the Regulatory Guide Subcommittee is considered appropriate before the guide is issued for public comment. _ This draft guide should be considered only as a preliminary document and not necessarily reflecting an NRC Regulatory Position. Citing of this l I - (% )a' . c
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# UNITED STATES
[yg 4,3'{
- NUCLEAR REGULATORY COMM!sSION g j WASHINGTON, D. C. 20555
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F) r MEMORANDUM FOR: Raymond F. Fraley, Executive Director, ACRS
- FROM: Guy A. Arlotto, Director, DES, SD
SUBJECT:
DRAFT 3, REVISION 1, PROPOSED R.G. 1.104,
; " SINGLE-FAILURE-PROOF OVERHEAD CRANE HANDLING
. SYSTEMS FOR NUCLEAR POWER PLANTS" l
Enclosed for use of the Subcommittee on Regulatory Activities a're 15 copies of Draft 3, Revision 1, of the proposed Regulatory Guide 1.104, " Single-Failure-Proof Overhead Crane Handling Systems for Nuclear Power Plants," dated October 1978. Also enclosed is Appendix A, " Implementation" to the Value-Impact Statement for-warded on August 29, 1978. The revision to the guide reflects comments received at the Sub-committee meeting on October 4,1978. ACRS concurrence in the regulatory position is requested. s 3 Gu3 A. Arlotto, Director 4 Ditision of Engineering Standards Office of Standards Development
Enclosures:
As Stated CONTACT: L. Porse 443-5997 cc: Public Document Room l l C (h / re-, < >-}}