ML20147J116
| ML20147J116 | |
| Person / Time | |
|---|---|
| Issue date: | 12/11/1978 |
| From: | Gilinsky V, Hendrie J, Kennedy R NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML20147J123 | List: |
| References | |
| REF-10CFR9.7 NUDOCS 7812270470 | |
| Download: ML20147J116 (55) | |
Text
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A ilk l "ssa NUCLE AR REG UL ATO RY COMMISSIO N-
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N-IN THE MATTER OF:
PUBLIC ICUTING DISCUSSION OF SECY-78-616 - REPORTING THE PROGRESS OF RESOLUTION OF " UNRESOLVED SAFETY ISSUES" IN THE dRC ANJUAL REPORT
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Place - Washington, D. C.
Date.
Monday,11 December 197 8 Pages 1-55 w nen.:
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DISCL. AIMER This is. an unofficial transcript of a meeti'ng of the Unf tad States Nuclear Regulatory Commission held on 11 Decenber 1978 in the Commission's offices at 1717 H Street, N. W., Washington, D. C.
The meeting was open t.
public attendance and observation.
Th'is transcript has not been reviewed, corrected, or edited, and it may contain inaccuracies.
. The transcript is intended solely for general informa'tfonal purposes.
As provided by 10 CFR 9.103, it is not part of the formal or informal record of decision of the matters discussed.
Expressions of opinion in this transcript do not necessarily reflect final de'tarminations or beliefs.
No pleading or other paper may be filed with the Commission in any proceeding as the result of or addressed to any statement or arg*.! ment contained herein, except as the Commission may authorize.
4 6
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2 CR1781 i UNITED STATES OF AMERICA l
ERC:mp DICT 2
NUCLEAR REGULATORY COMMISSION t
i 3I I
PUBLIC MEETING 4
DISCUSSION OF SECY-78-616 - REPORTING THE j
5 i
PROGRCSS OF RESOLUTION OF " UNRESOLVED SAFETY 6
ISSUES" IN THE NRC ANNUAL REPORT 7
i 8
9 Room 1130 1717 H Street, N. W.
l 10 Washington, D. C.
11 Monday, 11 December 1978 12 The Commission met, pursuant to notice, at 1:40 p.m.
I 13 BEFORE-14 DR. JOSEPH M. HENDRIE, Chairman 15 VICTOR GILINSKY, Commissioner 16 RICHARD T.
KENNEDY, Commissioner 17 PETER A. BRADFO RD, Commissioner 18 JOHN F. AHEARNE, Commissioner 4
19 PRESENT:
20 Messrs. Aycock, Case, Denton, Gossick, Kenneke, Stello and Murphy.
21 l
22 23 24
-Federal Reporters, Inc.
25
3 CR 1781
~
j Reel 1 CP 1-1 PROCEEDINGS 2
CHAIRMAN HENDRIE:
Okay, why don't we start?
l 3
The Commission meets this afternoon, first on a 4
discussion of the unresolved safety issues chapter, draft chapter, 5
for the Annual Report -- programs on it.
What is proposed, and 6
so on, j
7 Lee, I see; Howell Denton, Ed Case are here -- and 8
Mike Aycock.
9 Go ahead.
10 MR. GOSSICK:
Howell, do you want to go ahead and.
11 introduce the subject?
12 MR. DENTON:
Mike has spaarheaded the effort on looking 13 up the 133 issues that we have previously identified, the Congress' 14 have identified, which ones are truly unresolved safety issues 15 in our estimation.
And he has a presentation today.on working 16 through the process by which we culled the list down to the list 17 we proposed.
18 So, Mike, why don't you go ahead?
19 MR. AYCOCK:
Yes.
If I could have the first slide.
^
20 (Slide.)
21 In the way of background, I think we should look at 22 the Section 210, which is now the Energy Reorganization Act.
As 23 you recall, the Act was amended in December of last year to 24 include a new section, 210, which required the Commission
. eeJederal Reporters, Inc.
25 develop a plan for specification and analysis of unresolved I
i I
i
4 CP 2 1
safety issues relating to nuclear reactors and that they shall 2
take such action as may be necessary to implement corrective 3
measures with respect to such issues, and that such plans shall 4
be admitted before January 1, 1978.
5 The plan was submitted in the form of NUREG-0410 in a 6
report to Congress that also requires that progress reports be 7
included in the Annual Report of the Commission thereafter.
8 Next slide, please.
9 (Slide.)
L 10 At the outset, we would like to point out that the i
11 terminology selected by the Congress -- that is, unresolved
)
i 12 safety issues -- is one that the staff would say these issues t
13 are not unresolved in the licensing sense.
That is, the staff i
I 14 has determined that licensing and operation of individual l
l plantscancontinuependinggenericresolutionoftheseissues.l 15 16 In this regard, we have made filings to date on two 17 CP proceedings -- construction permit proceedings.
i 18 MR. CASE:
And those filings were in response to an 19 Appeal Board decision, ALLub'444, 20 CCNMISSIONER GILINSKY: Well, if you say "pending" resolution I
21 MR. CASE:
It is pending a generic resolution, but not 22 necessarily pending a resolution on that particular plant.
Any
{
23 particular plant, a solution which the staff believes to be 24 acceptable for that plant is developed.
And in response to A.-Lab i
Am FMero Recturt, Inc, 25 444, it is discussed in that particular proceeding, the reasons i
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5 CP 3 1
why we think this particular interim resolution is acceptable, 2
pending the generic resolution.
3l And we have recently started to file these in each 4
case because of the Appeal Board decision.
And it is an 5
evolutionary process to get all the material together.
And I 6
think it is fair to say, at least in our view, in each case we 7
do.more and are more explicit and more detailed concerning the 8
unresolved safety questions in these filings.
9 MR. DENTON:
Since we had not proposed to discuss the 10 merits of these individual cases because of the pending 11 proceedings, but in any case, even in my view at least, if the 12 Commission today approves the list for us to discuss with 13 Congress, it doesn't mean that we are relieved from discussing 14 categories B's, C's, and D's in individual proceedings.
And we i
15 are prepared to continue to discuss case by case whatever I
16 issues develop in a proceeding.
17 And that what we have done in the examples cited.
And i
18 in the future, we will start discussing the ones that we 19 eventually all agree on in the safety evaluation reports 20 themselves on a case-by-case basis and how they apply to that 21 particular plant.
22 COMMISSIONER AHEARNE:
Who came up with the term 23
" unresolved safety issues"?
24 MR. CASE:
Congress itself.
It was in the Act, and I j
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l 25 suppose it is fair to say it is language which we and the l
l
6 CP 4 1
Commissioners had used in discussions, perhaps not --
l 2
COMMISSIONER AHEARNE:
All right.
3 MR. CASE:
-- recognizing the implications that the 4
unresolved has, at least the public implications, without an 5
explanation.
6 CCREISSIONER GILINSKY: Well, we have had lists like this 7
around for some time.
8 MR. CASE:
Yes.
9 MR. DENTON:
So that when they culled that --
10 MR. CASE:
I am not really blaming the Congress.
11 COMMISSIONER AHEARNE:
So when the Congress asked for 12 unresolved safety issues, it wasn't a lot of head-scratching on 13 the part of the Commission staff:
"Now, what do they possibly 14 mean?"
It was an understood term, with in some sense a list 15 that went with it.
16 MR. CASE:
Yes, yes.
17 Now, a lot of people had a lot of different lists; so 18 there is a lot of culling down to get it to one list.
And this 19 represents the latest culling.
,/
2(
CCtNISSIONER GTLTNSKY: Well, let me ask you, Tcm: you are 21 saying that the problem is solved in some way or other in each 22 individual case --
23 MR. CASE:
Or not applicable.
24 COMMISSIONER GILINSKY:
Or not applicable.
Ase federet Reporters, Inc.
25 MR. CASE:
Or whatever, yes.
l
7 CP 5 1
CCM4ISSIONER GILINSKY:
Why aren't these solutions satisfactory.
2 solutions to the generic problem?
3 MR. CASE:
Well, in some cases, they are procedural 4
solutions, pending a more longer-term design change.
5 CCNMISSIONER GILINSKY:
You maan like operator frequency -
6 MR. CASE:
Something like that.
7 MR. DENTON:
Well, another one would be Atlas, which 8
we think does have -- various plants of different susceptibility 9
to that event.
And in the cases to date, we have gone through 10 the A's and B's and discussed the applicability of each issue ta 11 that individual plant.
12 COf4ISSICNER GILINSKY: Are these individual solutions interim 13 solutions on the part of the --
14 In other words, are they solutions like the example 15 you just gave, which would not be acceptable over the long run 16 or --
17 MR. DENTON:
Sometimes.
18 MR. CASE:
Sometimes yes and sometimes no.
l l
19 One of the things you do over this longer-term period j l
20 of study is determine whether, for instance, the interim 21 solution is acceptable as a long-term solution or perhaps even 22 something less than the interim solution might be acceptable for 23 the long term.
24 MR. DENTON:
One, for example, is BWR pipe cracking - ;
(c..F e.r.: Reporters. inc. i 25 that is on our list.
And that is the one where we find we have ;
i l
i i
8 CP 6 1
a test for looking at it, and I expect recommendations back in 2
January.
3 So we are saying that, based on what we now know, l
4 there is no need for immediate action while awaiting results of 5
the task force before deciding what new action might be 6
appropriate.
7 But they are ones that, if we don't do any more on, 8
we would have difficulty with.
9 MR. CASE:
In each individual case, the acceptah lity 10 of the issue for that plant or what has been done is looked 11 into by the adjudicatory process for that plant, including the 12 Board's and Appeal Boarf's.
13 CC6EISSIONER GILINSKY:
But do you tend to put the same fix on?"
14 MR. CASE:
Yes, to the extent that one can.
Yes.
j 15 Even in the same interim fix.
16 CCtEISSIONER GILINSKY:
Yes.
But that is not considered a 17 satisfactory solution for the generic --
18 MR. CASE:
Until the study is done.
As I say, it may 19 turn out to be the satisfactory solution.
20 COtEISSIONER AHEARNE:
I think you also said in scme cases that j 21 solution might turn out to be more than --
22 MR. CASE:
Yes.
23 MR. DENTON:
This become a little clearer if we get 24 into tha tubstance of it, m FMwo Rworuts, Inc.
25 MR. AYCOCK:
Yes, let's go to the next slide.
1
9 CP 7 1
(Slide.)
2 As I indicated earlier, we filed the report last 3
January; and NUREG-0410, which describes the NRR programe for 4
resolution of generic issues and identified 133 generic taaks 5
subdivided into priority categories A, B,
C, and D.
6 You also note that in the transmittal letter to the 7
Congress that our program was considerably broader than we 8
believed the unresolved safety issues plan requested by the 9
new Section 210.
10 CCtNISSIONER AHEARNE: A reader of that transmittal last year, 11 would they have come away with the conclusion that there were 12 133 safety issues that were unresolved?
i 13 Did we attempt at that time to --
14 CHAIRMAN HENDRIE:
No, you wouldn't, because I got my 15 hands on it and made it clear in both the transmittal letter and 16 introduction of the report that it was a report which covered a 17 good many issues beside " unresolved safety issues," including 18 all kinds of things that were of interest to the staff for a 19 variety of reasons and were legitimately on an action plan 20 scheduled to the agency.
But for reasons best known to the 21 staff, they had gone ahead and packaged this whole thing.
22 But I think the transmission was quite clear that this 23 considerably exceeded what would be the intent of the subject.
24 And we anticipated at that time, in fact, winnowing it down.
%e Federse Reporters, Inc.
25 MR. AYCOCK:
In fact, I believe it said specifically I
10 CP 8 1
that it may be more useful in later years or next year to report 2
on only those issues that are the " unresolved safety issues."
3 CCtNISSIONER AHEARNE:
I would just ecmnent that in May and 4
June of this year, the staff who are recipients of that report 3
were asking me what did I think about the 133 safety issues that 6
were still unresolved; so that at least to some extent, that 7
communication wasn't complete.
j 8
MR. DENTON:
What did you tell them?
9 CHAIRMAN HENDRIE:
All you. asked was whether the 1
10 transmission made it perfectly clear that there were more than 1
11 safety issues.
And the answer to that is yes.
12 Whether or not certain human skulls, you know, there 13 is a channel that hasn't registered that information or is 14 willing to register; it is quite another question.
15 MR. AYCOCK:
The other types of issues include 16 environmental issues, issues for improving the licensing process i
l 17 itself or possibly consideration of relaxing certain requirements.'
18 The next slide.
19 (Slide.)
20 With regard to those tasks that were reported last 21 year, first of all we want to look at the number of issues 22 resolved.
23 We reported in NUREG-0410 that we estimated that we 24 would complete seven category-A tasks, I believe, in FY
'78.
In Ace FederJ Ceoorters, Inc.
25 actuality, we completed four.
We have two more, if you will l
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t
11 t
CP 9 1
note in the footnote there, that are essentially complete with 2
final documentation needed to be wrapped up and management 3
review of recommendations and so on.
4 And two Category B tasks were also completed.
5 And you might ask, "Why are we working on Category B 6
tasks?"
The reason they were completed is that they were under-7 way when the program was initiated, and they were essentially 8
complete when we assigned them to Category B.
9 COMISSI(EER BRADERD: What are you using for a definition of 10
" completed or resolved"?
11 MR. CASE:
This means the solution is adopted by 12 management, but it hasn't necessarily been implemented by 13 management, but it hasn't necessarily been implemented on each 14 applicable plant.
However, the Section 210 plan doesn't stop at 15 that point.
It wants to know the plans and the schedule for 16 implementation.
17 Am I correct?
In the Section 210 reg.
18 MR. AYCOCK:
It goes beyond this point.
19 MR. CASE:
It goes beyond this.
20 CCtNISSIONER BRADMRD:
So there is a difference between what 21 we would consider completed and what Section 210 would consider 22 implemented.
23 MR. CASE:
Yes, but we recognize the difference; and 24 we do implement these things, obviously.
i bw FC1eral Reporters, Inc.
25 MR. AYCOCK:
The Annual Report, proposed Annual l
l
12 CP 10 1
Report, sections do discuss our efforts regarding implementation 2
of these things.
3 MP. DENTON:
Mike, I think a fair distinction would be.
4 by " completed" we mean the development of the technical positioq 5
approved by R C and this sort of thing.
And that implementation 6
follows after that.
7 CObMISSIONER KENNEDY: And what form will it take - a a
modification of the regulations, reg guide, or what?
9 MR. CASE:
Probably more likely a modification of 10 their license.
11 COMMISSIONER KENNEDY:
Modification of the license?
12 MR. CASE:
Or it could be a reg guide.
Even on that, 13 the eventual implementation is a change in their license, a 14 change in tech specs, change in design.
15 CCIEISSIONER KENNEDY: And at what point does the question of' 16 back-fitting get addressed?
17 MR. DENTON:
It gets addressed through the R C methods.
18 COMMISSIONER KENNEDY:
So when you say " completed,"
19 decisions have been reached as to whether back-fitting is 20 necessary, desirable, or unnecessary.
21 MR. CASE:
Hopefully.
22 COMMISSIONER KENNEDY:
What does that mean?
23 CHAIRMAN HENDRIE:
It is nominally part of the task 24 for the completion of the management review with completion of I.Fw c coomn. ix.
+
25 the task action planned to know where you are going to implement I
i i
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13 CP 11 1
it and how, if there is any difference across the reg plans, if 1
1 2
you didi.
3 COMMISSIONER KENNEDY:
That's what I ar asking.
l 4
MR. DENTON:
Well, the R C recommendation, as you 5
recall, put items in the categories as to how they were to be 6
applied.
And that was done without public input.
And the recen t 1
7 letter to AIF says they will have an input into the process in 8
the future.
And we have asked that all sorts of things coming 9
to R C now do a much better job of spelling out how it will be 10 implemented.
11 The ones that we did complete, I don't remember how 12 they broke out as to how they applied.
1 13 MR. AYCOCK:
Well, an example would be tasked A-31, 14 which was on RHR shutdown requirements.
That was marked 15
" complete" following R C approval of position and development I
l 1
16 of the implementation schedule.
And in fact, a draft reg guide 17 was issued which incorporated that decision.
18 CHAIRMAN HENDRIE:
What about back-fitting 19 considerations?
Have they been considered?
20 MR. AYCOCK:
It included back-fitting.
21 COMMISSIONER KENNEDY:
Do you remember, Roger, the 22 details?
23 VOICE:
Yes, there was a requirement for new 24 plants, another requirement for old plants; the Rash Committee Am#ederal Reporters, Inc.
25 approval of the -- this was in the reg guide.
l
l 14 CP 12 1
CHAIRMAN HENDRIE:
Consideration of the implementation 1
2 where, if it differs from group to group, what those differences 3
are ought to be part of the so-called resolution of an issue.
I i
4 Otherwise, youdon'tknowwhereandhowtoapplythem.!
5 COMMISSIONER KENNEDY:
When you say " completed," that 6
decision has been taken --
7 MR. CASE:
Yes.
8 COMMISSIONER KENNEDY:
-- and implementation will 9
affect whatever that decision has been, whether or not you have 10 R C.
11 MR. CASE:
That's right.
12 COMMISSIONER BRADFORD:
What kind of time do you 13 expect to see between the time an issue is resolved and the time 14 that the resolution is implemented for all plants to which the 15 issue had applied originally?
16 MR. DENTON:
It would vary with how many plants it 17 applied to, and this sort of thing.
Maybe we can get an i
18 example --
I 19 MR. CASE:
I think it would be typically years, as 20 distinguished from months -- several years.
21 MR. DENTON:
Let me ask this too:
have we had any 22 experience?
1 23 MR. STELLO:
Of course, it depends on how complex the i
i 24 solution is and how much equipment you might have to modify, l
$wFMwet Qwonm, Inc.
l 25 what you need to do in the plant.
l l
15 - 16 CP 13 1
I think a good example is fire protection.
We have 2
been about that task now for a couple of years.
There is an 3
awful lot of hardware that needs to be designed, purchased, andI I
4 installed.
And hopefully by the end of next year, we will have 5
had that task completed.
6 We have been on that one now for about three years.
7 COMMISSIONER BRADFORD:
The task will be completed, 8
but it won't be implemented.
MR. STEL'LO:
I mean completed -- all the hardware will 9
10 be in, fully implemented.
11 COMMISSIONER BRADFORD:
That's different from the 12 word " complete" as it appears on this chart.
13 MR. DENTON:
Yes.
14 MR. STELLO:
' Fully implemented" perhaps is a better 15 description.
16 COMMISSIONER BRADFURD:
What would it have been 17 resolved and completed?
18 MR. CASE:
When did the branch technical position l
19 on fire?
20 MR. STELLO:
The branch technical position 951 must be 21 close to three years, two and one-half years.
I think about l
22 two and one-half to three years.
l CRAIRMAN HENDRIE:
It was the fire, it was Browns 23 l
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24 Ferry plus what? nine months?
l toFederco Reporters, Inc.
25 MR. STELLO:
About a year after the fire.
l l
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17 CP 15 1
CHAIRMAN HENDRIE:
The Haneler force had to go through 2
the whole thing.
3 MR. STELLO:
We adopted a branch technical position Then we began l 4
which was the management solution to the problem.
5 to implement it on the individual plants thereafter.
6 COMMISSIONER BRADFORD:
So from that point in time --
7 and fire protection would have been taken off the unresolved 8
safety issues table, if there had been such a thing.
9 MR. STELLO:
It would have been taken off the 10 unresolved safety issue at the time the branch technical 3
11 position was approved by the R C, which had the solution for the 12 new plants in it, and the solution for the old plants.
At that 13 time, it became a matter of implementation.
14 And Roger Maxin's division and mine began the actual 15 implementation of the recommendations in the branch technical 16 positions.
They were applied to each of the plants.
And now 17 the plants are starting to install the hardware to meet those j
l I
18 objectives.
l l
19 MR. DENTON:
But as Mike said, for our report to 20 Congress on these issues, we wjlf include implementation plan.
I 21 I assume we will keep it going until it is fully implemented.
22 MR. AYCOCK:
There is a discussion of what implementa-23 tion is ongoing or has gone on in the last year -- in the report, i
l 24 the draft report, Enclosure (1) of the Commission paper.
&*FMwd Repomn, Inc.
l 25 CHAIRMAN HENDRIE:
Why don't you seize the several l
l l
3
18 CP 16 1
seconds of silence and plunge ahead to the next slide or 2
complete that one?
1 3
MR. CASE:
I just have to point out the manpower one, !
I i
4 where some months ago we said that 50 man-years, and the record I 5
shows we expended 48, 6
COMMISSIONER AHEARNE:
We have got that record tuned 1
7 to very well.
8 COMMISSIONER KENNEDY:
That is an innovation, I< assure 9
you.
10 CHAIRMAN HENDRIE:
What the record shows very clearly 11 is that there are two people who, if they had just worked a 12 year out there, would have done three generic safety issues.
13 MR. CASE:
I just* calculated this last Friday.
And 14 that is the way it came out after we got Commissioner Kennedy's 15 memorandum.
16 MR. AYCOCK:
If we can go to the next slide --
17 (Slide. )
18 With regard to the process that the staff used to 19 identify unresolved safety issues, the objective was to identify 20 those generic issues that posed substantive questions about the 21 adequacy of current safety requirements or plant designs.
l 22 The review or the decisions were made by NRR's 23 technical activities steering committee, which is chairmed by l
24 Mr. Case; and the members are the four NRR divison directors.
i>Fewel Emom,s. Inc.
25 And they received input from the technical staff in making these l
l l
19 CP 17 1
judgments.
I 2
MR. CASE:
Whose chairman is Mike Aycock.
l i
3 MR. AYCOCK:
They have an advisory group, yes.
4 MR. CASE:
With members from each of.the divisions 5
involved, technical assistance from es.;; division involved.
And 6
I must say right here now:
it is that input that helped us do 7
this job in a relatively short time and I think a rather 8
effective way.
9 MR. AYCOCK:
The first step was:
develop a definition 10 or a set of criteria for use in screening the generic issues and l
11 utilized a considerable amount of information which I will 12 detail a little more later, including task action plans and the 13 risk-based evaluation that is enclosed as Enclosure (3) to the 14 Commission paper.
15 And they reviewed all of those generic issues that 16 could potentially qualify as unresolved safety issues in a step !
17 wise procedure.
18 If we can go to the next slide.
l 19 COMMISSIONER BRADFORD:
Hold that one just a second.
20 Didn't you already have a definition of sorts when you l
21 were looking for generic issues that posed substantive 22 questions about the adequacy of current safety requirements?
l 23 Why wasn't that for all practical purposes your working 24 definition?
l Sa Federal Reporters, Irn.
25 MR. CASE:
I think he just coined that for this slide, i
20 CP 18-I but I don't know.
2 MR. AYCOCK:
We tried to characterize our view of what 3
we thought that Congress' interests were.
Andinordertohave!
i 4
a working definition, I believe you need something a little more 5 l definitive anyway.
6 COMMISSIONER AHEARNE:
Could I ask you, you were 7
saying that -- I'm confused on the role of the response to 8
Congress versus the role of trying to concentrate on what other 9
important issues you have been working on.
10 I would assume that in theory they -- they are somewha b 11 synonymous; but I thought that this procedure that you are about 12 to describe going through was narrowed down to focus on which 13 were the truly critical issues and how much resources had to be 14 expended.
15 MR. CASE:
Right.
16 First, the Congress's view is just safety.
So one 17 would exclude all the other important issues, like environmental
--~
18 don' t necessarily involve safety.
19 Then, among the safety issues, the most important are 20 the most significant.
That was the logic that was used.
And 21 let me try to answer your question.
We could have used the 22 definition of whatever the substantive safety issues or what 23 have you that could have been used.
24 The next slide has the definition.
Perhaps if we movei h Federal Reporters, Inc.
25 to that.
l 21 CP 19 1
There is some logic to it, but I must admit you could 2
have used another definition.
One of its bigger attributes is l
3 that a lot of people agreed to it and used it for this process..
4 I think that is its biggest plus.
5 MR. AYCOCK:
If we can move to the next slide.
I 6
(Slide.)
7 The definition used by the steering committee was:
8 "An unresolved safety issue is a matter affecting 9
several nuclear power plants for which it is likely that actions 10 will be taken to (1) compensate for a possible major reduction II in the degree of protection of the public health and safety, or 12 (2) provide a potentially significant decrease in risk to the 13 public health and safety."
14 MR. CASE:
Now, let me say a few words about that 15 definition.
16 As a matter of fact, in several nuclear power plants, 17 you need something like that because it is generic.
So you need 18 some words like that for a definition.
I9 It is important to know that it only applies to things 20 where it is likely that actions will be taken.
In other words,l 21 that is a judgmental step.
I 22 COMMISSIONER AHEARNE:
Are you saying it is likely l
23 that actions will have to be taken?
l 24 MR. DENTON:
Yes.
Ameews neoonus, inc.
25 MR. CASE:
Excuse me.
Not necessarily.
Because it i
22 CP 20 1
covers for the first --
2 CHAIRMAN HENDRIE:
For category
'I yes.
3 MR. CASE:
For category I, yes.
For category II, which 4
involves the potential risk reduction, you could be taking some I
5 risk reduction actions because of the cost-benefit ratio l
6 primarily, rather than you thought the risk was too high.
7 If you saw a way of getting a significant decrease in I
i l
8 risk for a few dollars, I think there would be general agreement l
9 that should be done, regardless of whether you particularly l
10 thought it was required or not.
11 COMMISSIONER KENNEDY:
Is it conceivable you could 12 have an unresolved safety -- thst's true.
The issue wouldn't I
i 13 take any action.
l i
14 MR. DENTON:
We would have one in a category.
I i
15 COMMISSIONER KENNEDY:
Then it wouldn't be an f
i 16 unresolved safety issue any more.
By definition, it is something i
17 else.
l t
18 CHAIRMAN HENDRIE:
Once you decided what --
19 COMMISSIONER KENNEDY:
Once you decided, you are not 20 going to take any action.
It is not an unresolved safety issue.!
l 21 MR. DENTON:
That's right; it is resolved.
l i
22 COMMISSIONER KENNEDY:
What is it?
You know, if you 23 use a definition like that, if you think for a second, just 24 logic -- if you use a definition like that, all you have to do l
OFederd Reporters, Inc.
25 to eliminate all your unresolved safety issues is decide you
. - -~
23 CP 21 1
are not going to take any action.
Then, you have no unresolved
-2 safety issues.
3 MC. CASE:
Then, there is no need for the staff to be 4
studying it.
That's true.
5 COMMISSIONER KENNEDY:
That is a fascinating brand of 6
logic.
7 COMMISSIONER AHEARNE:
So you see two separate types 8
of issues.
MR. CASE:
Yes.
That.is important.
One, I categorize 9
r 10 more as looking back; the other is looking forward.
11 COMMISSIONER AHEARNE:
On the first category, that is 12 something that you would end up requiring action?
13 MR. CASE:
Yes.
14 COMMISSIONER AHEARNE:
That's right?
15 MR. CASE:
Yes.
16 COMMISSIONER AHEARNE:
And the second one is one that l
17 the cost-benefit comes into place, i
i l
18 MR. CASE:
Or it could be required, too.
I have to l
l 19 say that.
20 In other words, we might find out'something we never 21 knew before that would make us feel that you have to do 22 something, you are required to dc something, across the board to 23
' decrease the ri sk.
There is some risk that was unbeknown to us, 24 at the time we issued a number of licenses, w..r.oima Roomn. im,
25 COMMISSIONER BRADFORD:
That would become a category I.
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MR. CASE:
Well, it could.
It could, B,
'y I,
2 the major reduction in the degree of protection to tl
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3 health and safety, those are the words of Ar't to be used in the id Belt 14 abnormal occurrence criteria.
6 7
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We tried to use words that are used in other places RC t#2 mcc 1 2
and have a meeting associated with them already.
That war ne 3
of the objectives.
I I
4 COMMISSIONER AHEARNE:
Try to help me understand.
1 5
I am not that familiar with the words of art tPat you have in 6
other places, so that I am having dif ficulty seeing a 7
distinction, if you have concluded that you might have to 8
take an action to provide a potentially significant decrease 9
in risk.
10 It would sound like, if you didn' t take the action,
11 then you would conclude that there has been a major reduction 12 in the degree of protection.
13 MR. CASE:
Possible.
One of the problems, 14 Commissioner Ahearne, and we went through this, in identifying 15 things we thought should be on the list, some peciple would say i
16 they are on there because of number two.
Other people would I
17 say they are on there because of number one.
'Jhey would agree l 18 i
i 19 COMMISSIONER AHEARNE:
I am having some difficulty 20 understanding the difference between one and two.
21 MR. CASE:
To some people there is a difference, a 22 sharp difference.
To others there is not such a difference.
23 I guess that is my answer.
I i
24 But they wound up both agreeing that such and such m-FWwd Amorters, tm:.
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25 topic ought to be one.
l l
26 pmcc 2 1
COMMISSIONER AHEARNE:
Is there a distinction in the 2
minds of people who see a sharp distinction from, as you 3
started to say in the beginning, that there is one category of i
4 actions that you could see being required to be taken because 5
they would be a requirement to provide the adequate safety 6
measure?
7 And the second category being one where you now do 8
the cost benefit?
And you conclude that for those, for the 9
costs that would be involved, then it would be reasonable to 10 take that action?
1 11 MR. CASE:
Yes, for those who see a sharp distinction, 12 is that true?
l 13 COMMISSIONER AHEARNE:
Yes.
14 MR. CASE:
Yes.
15 I think I see a sharp distinction, although some of I
16 the others don't.
17 COMMISSIONER AHEARNE:
But is your distinction 18 based upon those?
19 MR. CASE:
Yes.
20 COMMISSIONER GILINSKY:
Let me ask you, suppose 21 somebody raises a question -- an issue was really the question 22
-- and you don't kncw what in the world we are going to do 23 about it, but it sounds important.
Isn't that an unresolved j
l 24 safety issue?
l 6Federes Reporters, Inc.
25 MR. CASE:
No, I don' t think so.
Not in what we l
l 1
I
27 pmcc 3 I
have tried to draft here.
2 I think there ought to be some resources to study.
3 COMMISSIONER KENNEDY:
Not unless you have decided 4
to do something about it.
l 5
MR. CASE:
But unless there is a relatively broad 6
consensus that out of this study we are going to do something, 7
then it doesn't rise to the test of unresolved safety 8
questions.
9 COMMISSIONER BRADFORD:
But at that point dcn't you 10 think you have left behind a concern that the Congress had in 11 mind when they used the terms?
12 MR. CASE:
I don' t believe so, but that is --
13 COMMISSIONER BRADFORD:
The Congress, you think, 14 only wanted issues on which they knew we were going to be 15 taking action.
i 16 MR. CASE:
It doesn't say, no.
It says likely.
It 17 has some qualifiers in there, but what it tries, frankly, one I
18 of the things that I don't think should rise to the occasion 19 is just one person's thought that this is a problem.
The way 20 this is constructed, it would have to be a broader consensus 21 than that.
22 COMMISSIONER KENNEDY:
Let me put it another way.
23 Why wouldn't it be correct to say an unresolved safety issue 24 is a matter affecting several nuclear plants, for which it is 4..re..i ceormn. ine.
25 likely that action will be required to one or two?
j
28 pmcc 4 1
MR. CASE:
You could say that.
2 COMMISSIONER KENNEDY:
That's different.
I i
3 You know, if it is required, obviously it is going i
4 to be taken, but this doesn' t go to that.
This says we just l
l 5
decide whether we are going to do it or not, and that 6
automatically makes it an unresolved safety issue.
7 If you look at an action and say that is something 8
you have got to do something about, then it is an unresolved 9
safety issue.
10 MR. CASE:
Depending on what you mean by actions, in 11 order to get something done in a plant, the staff has to take 12 some action; i.e., you have to write an order or write a 13 something or other to get it done.
And the licensee has to 14 take some action to do it.
And it includes both of those.
l 15 The action will be taken and includes both those l
16 s te ps.
We take some action to require them to take some other l 17 actions.
l 18 COMMISSIONER KENNEDY:
I understand what it means.
I l
19 MR. DENTON:
This is the one :that the group actually l l
20 used in making their separation.
No doubt it could be worded 21 differently and still meet as a result of these same risks.
22 COMMISSIONER KENNEDY:
I wish I knew what it meant, i
l 23 so I would know what it was they decided.
i 24 MR. DENTON:
But we deliberately didn't pick only b Fww3 Geonm, W.
i 25 those where we are 100 percent sure what we are requiring.
I i
29 pmcc 5 1
You can't decide that well.
So there are some on there tha 2
may not require action once a thing is fully understood.
l
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3 COMMISSIONER AHEARNE:
I think there is a second I
I 4
question, though, Harold, based upon Ed's point that, at least I
i S
in the minds of some people, to see a distinction between one i
6 and two, and there are then, I assume, some issues on the 7
list put on there by some people who, A,
saw such a distinc-8 tion and, B, thought they were category two.
9 COMMISSIONER BRADFORD:
Which are those?
10 COMMISSIONER AHEARNE:
Category two is a cost benefit 11 argument, and that is a different character, I think, at least 12 in the minds of -- certainly in my mind.
And I think that was 13 the point that Al had been making in the paper that he wrote.
14 And if there are that character to some of these I
i 15 items, I think it would be important to make that a little 16 clearer.
17 MR. DENTON:
Maybe in the presentation can you l
l 18 separate out which ones were one and which ones were two?
I 19 MR. CASE:
There is not complete agreement on that.
20 CHAIRMAN HENDRIE:
John, let me make a comment, and 21 then I would suggest you might like to get on here a few more 22 slides.
23 This two part definition is there.
One of the 24 reasons it's there is that the prescription or what is the Sm Fewd Reorwn. inc. !
l 25 required level of safety by virtue of the Atomic Energy Act
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l i
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30 pmcc 6 1
the Commission's regulations and various staff positions in 2
many areas is not all that precisely defined.
3 There is, in fact, a bit of a fuzz to it.
And 4
people who might disagree on wuether a particular improvement 5
in safety was in fact required to meet that legal standard or 6
whether the improvement is actually somewhat in excess of the 7
legal standard but still a great buy, and hence in the public 8
interest, these definitions allow both of those people to agree g 9
both people to agree on the things where that is the case.
)
10 And I expect that is part of the reason that you 11 evolved that two horned standard.
12 MR. CASE:
That's right.
13 CHAIRMAN HENDRIE:
And it also, as you mentioned, 14 has a certain amount of forward looking -- backward looking, to i
15 it.
I i
16 MR. CASE:
Yes.
l 1
17 CHAIRMAN HENDRIE:
That is, if there is a perfectly i
18 well defined level required by law today that provides some l
l 19 level of safety for our nuclear facilities, are we in fact 20 constrained never to do better than that for future 21 installations?
22 And I think many people would read the fairly 23 general mandates of the Atomic Energy Act as not to so limit 24 the thing.
So this again has to be --
Sm Feem Repomn. W.
j 25 CHAIRMAN AHEARNE:
Joe, but the difficulty, I think, I
i
31 pmcc 7 I
which you have focused on, I think Ed has pointed out, some 2
discussion has pointed out, we have here a definition whose 3l virtue seems to be that people can interpret it, the people whot i
4 work with it can interpret it several ways and, there fo re,
5 enable various items to be included in its list, each feeling 6
comfortable that it is there but perhaps for different 7
reasons.
8 I think that that is their definition.
9 CHAIRMAN HENDRIE:
Let me point out the reason you 10 I have a Section 210 now in the Energy Reorganization Act is II because the staff evolved as a consensus position that there 12 were a number of items that they proposed to treat generically; 13 that is, rather than settle it.all on plant A, it was going to 14 be treated generically, and that list of items became known 15 over a period of some years as generic safety issues or 16 unresolved safety issues in some people's minds, and the term 17 got picked up.
18 What the Congress did was say, "Make a report on 19 these things and tell us what you can do about it. "
20 Now, what they identified was a body of items which 21 the staff had in fact agreed upon as a list of generic issues 22 they wanted to work on on that basis.
23 So I think it is not totally inconsistent as the i
24 origin of the 210 position.
The consensus of the staff to come, a.vano nworms. Inc.
25 back to that staff consensus for --
i
32
.pmcc 8 1
MR. CASE:
If anything, this errs on the side of 2
putting more on the list than less.
3 COMMISSIONER AHEARNE :
I am not concerned with that.
4 MR. CASE:
If it errs, it errs in the right 5
direction.
6 QOMMISSIONER AREARNE:
I am not in any way concerned 7
about the list being too big.
The definition, I think, is 8
sufficiently fuzzy that certainly I had difficulty understand-9 ing it, and I think, going out to the public or trying to 10 I work with it, it is difficult to work with, and you can move on.
11 MR. AYCOCK:
I move on to the next slide.
12 (Slide.)
13 The next slide simply provides a list of the types 14 of information used by the Steering Committee and its staff 15 in reviewing the issues.
The task action plans for the 16 category A tasks, the set of problem descriptions for B, C and 17 D tasks, we have no approved task action plans for lower 18 category tasks at this time.
l 19 The draft risk based evaluation of the generic 20 issues provided in Enclosure 3 to the Commission paper.
We 21 also had an NRR staff review of that particular evaluation.
l 22 The NRR groupings of generic issues into eight groups 23 by type of activity.
That was provided in Appendix A to 24.
And also we used the list of abnormal occurrences '
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25 related to power reactors reported to Congress to date.
j
33 pmcc 9 1
MR. CASE:
Because of that language tie-in that I 2
discussed.
MR. AYCOCK:
On the next slide --
l 3l t
4 (Slide.)
l 5
MR. DENTON:
Probably we should mention too the 6
key actors of this all had copies of the lowest committee 7
report in their hands at the time of making the selection.
8 CHAIRMAN HENDRIE:
Well-stelned copies.
9 MR. AYCOCK:
The next slide provides a list of those 10 issues selected as unresolved safety issues for reporting to 11 Congress.
These are described in the proposed annual report 12 sections, Enclosure 1.
13 I might note that we briefed the ACRS Subcommittee 14 on Ge.neric Activities last week on the Commission paper.
They i
15 indicated at that time they probably would like to talk to us l
16 again in January, but in fact they put that of f to some later 17 time because their schedule was too crowded in January.
i IS COMMISSIONER KENNEDY:
You did speak of the staff l
19 review of draft risk based evaluation, which is an Enclosure 20 3,
21 Table 2 of the enclosure refers to PWR accident 22 perspectives and iodine for other reasons, the basis for 23 the table being PWR design in the reactor safety study.
I 24 CHAIRMAN HENDRIE:
Do they have a page, Dick?
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25 COMMISSIONER KENNEDY:
Yes.
It is ll-A of the j
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Could you just clarify for me what that-implies?
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MR. DENTON:
Yes.
We have a research representative.
4 COMMISSIONER KENNEDY:
Tell me what the basis for i
5 the table is.
6 MR. DENTON:
Joe Murphy, Research.
7 MR. MURPHY:
Basically this is a product of the 8
probability of occurrence times the number of curica of 1
9 iodine released.
10 COMMISSIONER KENNEDY:
These data are right out of 11 the reactor safety standards or what?
12 MR. MURPHY :
The first six items are the PWR release 13 categories one through six, and then number 12 is PWR release 14 category 7.
Those numbers derive directly from the safety 15 study.
They are normalized, so that they are 100 percent when !
l 16 added together.
17 These other items were treated in the same way and i
18 normalized back to the values of the safety study.
I 19 COMMISSIONER KENNEDY:
Thank you.
20 The fact that you had the Lewis study in year 21 hands when you did this, a well-summed copy, as I get it, what 22 effect did that have on this table 7 l
t r
23 MR. CASE:
It was on the use of the table that it had j
24 an effect.
Those who used it, including those members of the i
W Fewet Qgomrs, Inc.
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25 Steering Committee, took into account the Lewis Committee.
l I
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35 pmcc 11 1
COMMISSIONER KENNEDY:
How?
2 MR. CASE:
Well, we agreed with the Lewis Committee 3
thoughts what the range of uncertainties ware in the absolute 4
numbers given in the RSS study.
We were aware of and agreed 5
with their observations of the points.
6 We used this information in aiding our judgntent on 7
things rather than as the only basis for judgment.
8 CHAIRMAN HENDRIE:
You also recognize that this 9
table which is now normalized in a way that what is significant 10 are relative positions and things of the table, which is Il entirely consistent with the committee's Lewis group 12 recommendation.
13 How Lewis would say is look at items 1 and 2, where 14 you get nine percent on Cat 1, PWR Cat 1, and 9.7 on 2 and 15 don't make a great deal of that difference, because it is I
16 getting down to the point.where the precision of the results l'7 wouldn't justify drawing any strong distinctions between the l
18 two.
1 19 But if you want to compare PWR Cat 2 at 81 percent 20 to RCS main pump seizure, my God, about three times to the 21 minus eight on a relative basis.
22 So I think it is not an inconsistent proposition.
23 This is just on an iodine release basis, and one could form a l
24 table like this of the same group of --
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25 COMMISSIONER KENNEDY:
This was nothing but an f
l
36 pmcc 12 1
illustration.
2 CHAIRMAN HENDRIE :
-- issues on the basis of what 3
whole body doses in the near term, total doses over the long 4
term.
5 This one is simply on an iodine release basis, 6
which has occasional'ly been used for these comparative purposes 7
I know a farmer and his group for years used an iodine release 8
as a measure, not to reflect everything that went on in an 9
accident, but as a useful way to characterize the severity of 10 1 various --
11 COMMISSIONER AHEARNE:
Since the issue has been 12 brought up, Enclosure 3 is described as a preliminary draft.
13 Did you get a final report?
14 MR. CASE:
No, it has not become final yet because 15 the interaction between the staffs has not yet taken place.
I 16 It would be helpful and needed before the thing were made f
17 final.
i 18 COMMISSIONER AHEARNE:
I wonder if I could ask Mr.
l l
19 Murphy a question.
20 In the consideration I notice that,in addition to 21 the point that Commissioner Kennedy raised, there are several 22 of these descriptions of the various problems that were 23 examined that give absolute values of probabilities of 24 occurrence in addition to just relative.
Qa Fews Reorters, ltw,
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25 Are you examining that, or what did you have in mind? i i
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Or in your view is the preliminary draft the final?
I 2
MR. MURPHY:
Well, I think right now I don't l
l 3
expect things to change.
But we are going to look over the l
l 4
considerations that we are hearing from NRR on their review l
5 of the documents.
6 In order to make relative comparisons you have to 7
have absolute numbers.
The strength of the report, though --
8 and it should only be used in terms of the relative 9
comparisons.
I think we have made that fairly explicit in 10 the earlier parts of that document.
11 As I say, we don' t expect any change at the moment, 12 but we are going to continue our dialog with NRR.
13 COMMISSIONER AHEARNE:
Do you have some reasonable j
14 confidence in the absolute values?
i 15 MR. MURPHY:
In many areas the analyses that were l
16 done are bounding in nature, and therefore the absolute i
17 values do not represent realistic numbers, and they were not j
i 18 meant to.
We tried to preserve som ething close to the same i
i 19 degree of conservatism as we went through, so the relative 20 comparisons have some meaning.
21 But I would question against the use of the absolute >
l I
l 22
- values, j
l 23 MR. AYCOCK:
If we can move to the next slide.--
i i
l 24 (Slide.)
l n Faswet Cwmmn, lx.
25
-- I would like to go through the procedure of steps that were i
i
38 pmcc 14 1
used to consider those issues that might qualify as 2
unresolved safety issues.
3 In step one we considered those issues that appeared 4
in NRR groups 1, 2 or 3, and those groupings, I guess the 5
definitions of those groupings are provided on pages six and 6
seven of Enclosure 2.
7 Perhaps I could get backup slide number 2 8
(Slide.)
9 These are the definitions of the first six groups.
Ne used i
10 groups 1, 2 and 3 because we felt that these were the groups 11 that included those issues which potentially could result in 12 the staff upgrading its requirements, safety requiremenus.
13 The other' issues, the other groups, as you note 14 from the definitions, group 4 would be relaxing requirements.
15 Group 5, develop and maintaining, improving staff capability 1
16 to perform audit calculations, improving guidance.
Seven has 17 to do with environmental reviews and so on.
I 18 If we can go back to the previous slide --
19 (Slide.)
20
-- we use those issues that appear in groups 1, 2 and 3 and l
21 also appeared in the draft risk report categories 1 or 2; that 22 is, they're categories of potentially high risk significance l
23 and potentially low risk significance.
We didn't give any I
i 24 significance to the two groups.
W.Fewd Quemn, Inc.
j 25 I think we considered anything in those two I
i i
i
39 i
pmcc 15 1
categories as being potentially risk significant.
2 Result that taking this cross cut of issues provided 3
us with the most likely candidates for unresolved safety I
4 issues, compared each issue against the definition or the l
5 crite ria.
And as we note on the next slide --
6 (Slide.)
7
-.this graphic, that 11 of the category A issues, or the 15 8
category A issues considered in this step, were determined to 9
qualify.
There were four category B issues considered in this 10 step.
One was determined to qualify.
It was previously 11 Task B-57, station backout.
As a result of this review of 12 unresolved safety issues and its assignment to the group of 13 unresolved safety, issues, it was elevated to a category A 14 issue, A-44.
I 15 And part of one category C issue was determined to 16 qualify.
It was Task C-3 regarding insulation usage and l
l i
17 containment.
It had to do with,that particular part of the 18 task had to do with some potential for blockage.
Go to the 19 next slide.
I 20 (Slide.)
21 Step two --
22 MR. CASE:
First I would like to say one could make l
23 an argument, we could have stopped there.
We had taken those 24 from our groupings that were most significant to safety and
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25 those from the research grouping of highest risk potential and !
i i
40 pmec 16 1
looked at those, and one could have said, well, that's good 2
enough.
3 We went beyond that, as Mike will indicate, to make i
4 sure that we had picked up any that might have been on the 5
fringe in between that step and the research step.
6 MR. AYCOCK:
That 's correct.
7 In step two there were 51 additional issues that l
8 appeared in our groups 1, 2 or 3 that were not determined to 9
be potentially risk significant in the draft risk base 10 1 report that were considered in step two.
11 These, it was unlikely, we felt, they would qualify, 12 principally because of the draft report characterization, but 13 nonetheless we considered them.
14 It is noted on the next slide --
15 (Slide.)
16
-- of the 12 category A issues considered in this step, three 17 were determined to qualify.
And one category B issue,
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18 previously issuc B-14, on vortex suppression requirements was l
l 19 conbined with the category C issue considered in the previous 20 step in the task of emergency sump reliability.
21 (Slide.)
22 And step three considered the remaining five issues I
23 that were classified as potentially risk significant in the l
24 draft report that were not considered in step one.
Again, we ha Feewet Reorwrs, lm.
l 25 felt these were unlikely to qualify because they appeared in the!
l
41 pmcc 17 1
lower groupings of NRR groupings of the issues by activity 2
type.
3, And it is noted in the next slide --
4 (Slide.)
5
-- two issues, two category A issues were determined to qualify 6
in this step.
7 COMMISSIONER AHEARNE:
Which were they?
8 MR. AYCOCK:
They were Task A-24, which is on 9
environmental qualification of safety related electrical 10 e quipment.
11 I think principally because the original plan for 12 resolution was such that it.was.to simply review vendor 13 programs that we would request on a generic basis, so we can 14 apply the solution case by case.
It was more of an audit 15 type review.
That task was subsequently, it was assigned i
16 therefore to group 5 in the NRR groupings.
17 Subsequently that task was expanded to include 18 additional things which we believed caused it to qualify.
l 19 That is the development of an interim position on how in fact 20 do you meet the positions of IEEE 323, 1974.
i 21 MR. CASE:
It is a fair way to say our paperwork 22 didn't catch up with the way the task was going.
The direction 23 of the task and its scope moved faster than the paperwork l
24 describing that particular task.
l ww Focersi Qoporters, Inc.
l 25 The effort in this area to a large part was driven I
42 pmec 18 1
by our work on the Union for Concerned Scientists' petition
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)
2 on electrical vectors and our paperwork didn't catch up with 3
the pace of the work.
But here it did catch up, and we 4
considered it to be an unresolved safety issue.
5 COMMISSIONER AHEARNE :
It sounds almost like it was 6
shifting up into other categories.
7 MR. CASE:
Yes, all the time.
8 CHAIRMAN HENDRIE:
What was the other one?
9 MR. AYCOCK:
The other one was task A-40 on seismic 10 design criteria.
11 CHAIRMAN HENDRIE:
Okay.
12 MR. AYCOCK:
In the final step --
13 (Slide.)
14
-- because of the use of the terminology or.:use of terminology 15 similar to that used in the abnormal occurrence criteria --
l l
16 COMMISSIONER AHEARNE:
I'm sorry, as the Chairman 17 in his question triggered something, why wouldn't seismic I
18 design criteria have fallen into group 2 or group 3?
i 19 MR. AYCOCK:
Let me try to give you the rationale.
20 Seismic design criteria, I believe, was initially based in l
21 group 4, which was "he group for consideration of relaxing 22 certain requirements.
I 4
23 (Slide.)
24 Paragraph A-40 is a task principally looking at our l
hwFMwal Reomn, lm,
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l 25 developing the tools necessary for the staff to re-review l
43 l
1 seismic design of operating plants.
That is looking at 1 pmcc 19 2
quantifying conservatisms in the design and so on.
In that 3
sense, it might allow the staff to accept something less than 4
provided by current requirements, if you were to review old 5
plants to current requirements.
6 So in that sense it would be possibly relaxing.
7 The Steering Committee felt that it was likely that some 8
actions were going to be necessary at some plants too --
9 MR. CASE:
Existing old plants.
10 l MR. AYCOCK:
Existing old plants, to upgrade the i
11 seismic design.
12 COMMISSIONER AHEARNE:
It shifted from relaxing to 13 upgrading and shifted --
14 MR. AYCOCK:
Yes.
15 COMMISSIONER AHEARNE:
Okay.
l 16 MR. AYCOCK:
In step four --
j 17 (Slide.)
i 18
-- we reviewed those events reported to Congress as abnormal l'
19 occurrences in the past.
Five generic issues resulting from 20 previously reported abnormal occurrences had already been 21 identified as unresolved safety issues.
22 MR. CASE:
By these previous steps.
23 MR. AYCOCK:
An example would be steam generator to i
24 integrity.
One generic issue related to a recent abnormal m-FewW Reorwrs, lm.
l 25 occurrence report --
f l
44 pmcc 20 1
COMMISSIONER AHEARNE:
The pipe cracking.
2 MR. AYCOCK:
The pipe cracking in oiling water f
3 reactors -- was determined to meet the definition.
It was i
4 also made a generic issue and assigned to category A at the i
5 same time, o
6 The other generic cases either don't require long 7
term study or compensating actions have been or are already 8
being taken.
I believe that's all I have as far as the 9
presentation is concerned.
10 MR. CASE:
The point I would like to make is we 11 went through a rather systematic, deliberate procedure for 12 coming up with these issues which is more than the definition,
13 but it is in support of the definition.
14 And I think it was a logical way to do it, and 15 because of the deliberate nature of that process, coming back 16 to something we said earlier, you should recognize that for I
i 17 each thing that is labeled an unresolved safety issue, we have !
l 18 to testify at adjudicatory hearings why it is, why does the i
19 staff think it is, what is its program for resolving it, why l
20 is it all right to license in the meantime?
21 And through this process we have developed a 1
22 consensus on those questions and stand prepared to talk about I
1 23 these at the various adjudicatory hearings.
s i
24 COMMISSIONER AHEARNE:
The impression I get from the D F W wel R m o m n.l s i
I 25 comment you made earlier, Mike, about the ACRS is that they h
45 pmcc 21 I
have not completed or may not go through a detailed review of 2
your culling.
Is that correct?
3 MR. CASE:
Either one or the other.
i They have a list of their own of generic issues, and l 4
5 there is a lot of correspondence between the two lists.
But 6
they didn't choose, nor did we, to try to combine them on a 7
common list.
We just handled them separately.
8 As a matter of fact, in each hearing we talk about 9
these various issues, what the status is and why -- or why it 10 doesn't apply to this plant and why, when we think one could II license in the meantime, and the same way for our issues.
12 COMMISSIONER AHEARNE:
You would not expect any time 13 in the near future or perhaps at all to get a letter from the 14 ACRS saying, "Yes, we have reviewed your process.
We believe i
15 that the 14 that you have chosen are the high priority items."?
16 MR. CASE:
No.
l 17 MR. DENTON:
I had thought we would be able to get 18 this to them in time to reach such a list, but we just didn't l
19 make it.
And we ran up against the need for the yearly i
I 20 report.
Maybe next year we will be able to come to that kind of 21 a resolution.
22 We had in hand their grouping from, I guess, about 23 mid-summer that gave us a report.
Their report also includes 24 items which are researches on going a lot.
OFuwsnoorms. w.
l 25 COMMISSIONER AHEARNE:
Is there any advantage to f
i
46 i pmcc 22 1
either explicitly asking them or some group to review this to 2
try to get an advisory opinion concerning it?
3 MR. DENTON:
I anticipate we will be getting advice l
t 4
from them in February on this; that is, their views on the 5
list.
6 COMMISSIONER AHEARNE:
I thought Mike had said the 7
meeting had been postponed from January, 8
MR. DENTON:
The January meeting has been postponed, end t#2 9
but I think eventually we will get together on it.
10 11 12 13 14 15 l
l 16 17 i
18 19 20 21 22 6
f 23 i
24 WD Federd Rooorms, Inc.
25 i
l i
i
47 781.03.1 gsh I
I guess the reason I didn't see it as crucial is 2
this is not a rule-making defining of these as the only 3
issue.
That's why I pref aced my earlier comments, I sti11 4
anticipate having to address anything on.the list for us to 5
determine are applicable.
6 It would be maybe convenient next year sometime to see if 7
we.could get a list that ACRS agreed with.
One thing we do 8
want to do is start numbering them all sequentially, the 9
As and Bs and is and 2s -- Just list all the issues and we 10 can talk about their relative priorities.
COMMI.SSIONER AHEARNE:
In what way are the rescuces l
12 that you have to place on these issues going to be reduced.if 13 we agree to a reduction to essentially 14 high priority items?
14 MR. DENTON:
The resources now are spreed over the 15 As and Bs, mainly concentrated in the As.
If you approve 16 this, they will be redirected to go into the As as much as l
l 17 possible.
I think the 51 man-years or so that we budgeted l
18 in '79 for this activity will enable us to work on this 19 entire list and a little bit on other ones, but not a lot.
20 And we will attempt to use dollars in place of manpower on 21 the ones that are in the lower priority list.
22 COMMISSIONER AHEARNE:
You are saying as f ar as 23 the NRR manpower that is allocated to the items, that that 24 is going to stay relatively the same, even if we accept the 25 reduction in the high priority items.
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48 f81.03.2 gsh 1
MR. DENTON8 Yes.
2 MR. AHEARNE: And if we don't, it just means it will 3
spread the same number of people over the items.
4 I guess one comment I have to make is that not having had 5
the opportunity or not having taken the opportunity to go 6
through last year's reports, I did come into this exercise 7
with the idea in mind there were roughly 133 items of 8
contention.
Starting to read through the material that has 9
been coming up over the last month, I recognize that it has 10 been culled down.
JI I am, though, not myself satisfied with the explanation, 12 the written explanation of the culling process that brings 13 you down to 14, because to some extent, you started with. this 1
)
14 list of category A items which were identified as either being 15 high priority with regard to the safety issues or the 16 licensing process.
And then, the category 1, which are high i
17 probability of risk.
18 I would have expected, at least, a more lengthy explanation 19 and maybe it was because it was assumed that it had been i
20 done last year of going from the 1.33 down to that matrix, j
21 two pieces.
And then a more full explanation of why 22 every one of those items that was going to be dropped wasn't 23 on it.
Because I think that, frankly, in many people's minds, 24 there really are 133. And to suddenly turn around and say, 25 "Oh, no, it's 14," that is an ord.er of magnitude.
)
i l
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And to make that a believable step is going to have to take 2
some very careful explanation, because it is going to be very 3
hard to believe.
4 MR. DENTON:
Some of them that are on the list will 5
probably continue to be worked on it. things --
6 CO MMISSIONER.AHEARNE:
No.
You are saying that he 7
is.the high priority set --
8 MR. DENTON:
Yes.
9 COMMISSIONER AHEARNE:
-- which means that the 10 others must be lower priority.
And it is that step which will
.11 have to be explained more carefully.
12 MR. DENTON That true, we haven't documented. And 13 you would just, I guess, have to weigh the need f or that 14 against using the same resources of. the group moving on the 15 top uf the list, f(
16 It depends on how carefully you document.
17 COMMISSIONER AHEARNE:
Harold, it almos.t sounds like 18 you are saying we accept.your calling, because if we don't 19 accept it, you can't afford to spend the time.
20 '
MR. DENTON: No, not at all.
It just takes a little 21 bit of time. We recognize, I guess, we could have (ocumented 22 better the reasons that we didn't.
It took much longer to 23 get.this far than we thought.
24 We could certainly go back and document the reasons and 25 rationale that was discussed in the group as to why they didn't ACE-FEDERAL REPORTERS, INC. (202)347-3700
50 981.03.4 gsh I
take any of the As or the i s and 2s, the ones that had been 2
rejected, and find out why they did so.
3 We have difficulty doing it on the schedule we are on, but 4
we could do it.
5 Maybe Mike can address how difficult a task it would be.
6 MR. CASE:
Let me speak for him.
It. would be quite 7
difficult to meet the deadline of the Congress for this report 8
COMMISSIONER AHEARNE: I guess when you say, 9
" documents," and I say explain, I guess what I am having 10 dif fleulty -- I am not t ',1c'J to say that you need voluminous J1 documentation.
12 What I am assuming is that if a task which was one of the 13 Category A, Category 1 items is not going to be included, 14 that there must be in someone's head resident the understanding 15 as to why.
16 MR. CASE: There are only 4, I believe is the right 17 number, Mike. C9ta"ory A, Group I, 2, 3, high research.
18 L. s.sSIONER AHEARNE:
I am talking about A and 1, 19 the sum of those 2.
20 MR. CASES But you see, it could have been an A 21 and an. environmental Lssue.
/
22 COMMISSIONER AHEARNE: Fine.
But I belie ve it has 23 got to be explained lf we are going to be -- if. this going in 24 with a much reduced list is going to be gree ted with anything 25 other than great skepticism and disbelief and cynical ACE-FEDERAL REPORTERS, INC. (202)347-3700
\\
s 51 l
81.03.5 gsh I
rec e pt io n.
2 MP. AYCOCKJ Are you saying, though, that our 3
Category A and also apoeared in the draft risk based 4
evaluation as potentially a --
5 COWWISSIONER AHEARNE: Category A or --
1 6
MR. AYCOCKJ Category A or.
I understand.
7 COMMISSIONER.AHEARNE:
It is just a personal 8
belief.
9 MR. CASE:
So I don't know how many there are.
10 There were some number like 40 As and --
11 MR. AYCOCK:
Well, we can get them out of here.
12 COMMISSIONER AHEARNE:
That is just my own personal l
1.3
, reaction.
14 CHAIRMAN HENDRIE: As or what?
15 COWWISSIONER AHEARNE:
As or 1s.
One of the 16 dominant themes --
17 CHAIRMAN HENDRIE: As and Is?
18 COMMLSSIONER AHEARNE: That's right. I'm not saying 19 Harold ought to be pu.tting hls resources on it.
But I am 20 saying if we are going to accept a reduction to 14, where we 21 have got a list somewhere of the number of As that perhaps 22 it was a bad set of categorization.
23 CHAIRMAN HENDRIE: I think it is more like 19, but 24 a comparable list.
25 COMMISSIONER AHEARNE:
I think that we ought to be ACE-FEDERAL REPORTERS, INC. (202)347-3700
781.03.6 52 gsh I
able to write down in a clear fashion why those are not items.
2 MR. CASE It is no.t clear to me -- As and i s or 3
As or Is?
4 COMMISSIONER AHEARNE2 Well, it is not the union's, 5
the inte rse c tion, in other words.
If it were an A --
6 MR. DENTON2 Any A or any one, which doesn't get on 7
the list.
8 COMMLSSIONER AHEARNE:
Correct.
9 MR. KENNEKE: We have the explanation for the As 10 and 1s.
J1 COMMISSIONER AHEARNE2 An explanation.
.2 MR. DENTON If it doesn't need to be in the annual 13 report, we could sure do it early by the time anyone gets 14 around to the questioning..
If it has got to be in there, 15 we will have to make a major perturbatlon to document it.
'l 16 COMMISSIONER.AHEARNE:
You might keep some more 17 on the list.
18 MR. DENTON: But I think the sta.ff did discuss them.
19 They really. don't.think they need the high effort.
It is just 20 the question of how long it will take to remember what the --
21 because they weren't documented at the time.
22 I assume they weren't documented.
23 MR. AYCOCK: No.
24 CHAIRMAN HENDRIE: I think it wou.1d be helpf ul to have 25 some di.scussion on a sort of rung, work one's way down the ACE-FEDERAL REPORTERS, INC. (202)347-3700
53 981.03.7 gsh I
previous list and$ note what the disposition was and why.
2 And we might be able to schedule that.
3 MR. DENTON:
I assume I can add that we could even 4
t od ay, if necessary, go through the list. And you are just not 5
organized.
6 MR. CASE 2 See, we didn't organ ize it that way.
If 7
you just want to Look at the As and is, we can give you a 8
clear story of why we don't think there any any unresolved 9
safety questions.
10 Part of the story will be they are not saf ety issuest it J1 1s an evironmental issue. Or if it is a safety issue, it is 12 confirming rather than we think there is anything likely to 13 come of it.
14 The research, but even though it is likely that some action 15 will be taken, the risk potential is low, i.e.,
it is not a 16 major reduction in --
17 COMMISSIONER AHEARNE:
Ed, I'm not saying you can't 18 do it.
I'm just saying I haven't seen it. And I think it is 19 necessary if it is going to be believed --
20 MR. CASE: What we attempted to do is to it by class.
21 I am reacting to we didn't do it. We did it by class.
22 COMMISSIONER AREARNE:
Oh, no.
23 MR. CASES We said everything that is not in 24 groups 1, 2, and 3, never mind the f act that it is an A, by 25 definition, is not an unresolved.saf ety issue.
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COMMISSIodER AHEARNE:
But unfortunately, you have 2
already crossed a couple that really should have been in 3
1, 2, or 3.
4 MR. CASEJ But it is because of changed circumstances, 5
changed Information.
6 COMMISSIONER AHEARNE2 Fine. Thac's one of the 7
reasons why --
8 MR. CASES You don't do this continuouslyt you do 9
it periodically.
And it is that period of time you ought to 10 review all the information yeu have -- move some up, move JI some down. That's what we did.
12 C'HAIRMAN HENDRIE I don't want to do it this 13 af ternoon, as we have two othe*.- items to get to.
But what
)
i 14 do you.think of some further discussion which would allow 15 a point-by-point working through these things and questions 16 can be raised at appropriate times?
17 COMMISSIONER AHEARNE: Well, I would certainly like 18 to do it when it is convenient. And if everybody else isn't 19 interested, that's all right.
20 COMMISSIONER BRADFORD: I think we need it as well.
21 OPE has pointed out several --
22 CHAIRMAN HENDRIE: That would also allow discussion 23 in the context of that kind of report, particular items OPE 24 has raised.
25 And it seems to me that that. would be the way to get out ACE-FEDERAL REPORTERS, INC. (202)347-3700
55 781.03.9 gsh I
of it.
2 Sam, when can we schedule that?
3 MR. CHALKS I will have to look.
4 CHAIRMAN HENDRIE: How f ast can you be ready?
5 MR. CASES If you are talking ora.11y, we are ready 6
any time.
If you are ta,1 king writing, that will take --
7 CHAIRMAN HENDRIE:
Orally is fine.
8 MR. CASE: I have all my tr. cops here ready right 9
now.
Are you people ready?
10 '
CHAIRMAN HENDRIE: No. de are going to talk about J1 something else, not unrelated totally.
12 MR. DENTON:
I would like to suggest, then, that if 13 you want to do it immediately, let us do it through slides 14 and handouts and data at the meetlng, rather than trying to 15 prepare a paper.
16 COMMISSIONER AHEARNE: Oh, yes, fine, fine.
17 CHAIRMAN HENDRIE: Sam, let's see how soon.
- Okay, 18 why don't we then turn to subject 2 for this af ternoon.
19 (Whereupon, at 2:55 p.m.,
the meet ing was adjourned. )
4 20 21 22 23 24 25 ACE-FEDERAL REPORTERS, INC. (202)347-3700