ML20196K485
| ML20196K485 | |
| Person / Time | |
|---|---|
| Issue date: | 09/28/1979 |
| From: | NRC - ADVISORY COMMITTEE ON CONSTRUCTION DURING ADJUDICATIO |
| To: | |
| References | |
| NACCA, NUDOCS 9903260374 | |
| Download: ML20196K485 (102) | |
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NUCLE AR REGUL ATO R'f COMMISSION l l
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POWER PLANT CONSTRUCTION -
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Place - Silver Spring, Maryland Date . Friday, 28 September 1979 Psgesl - 101 !
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2 NUCLEAR REGULATORY COMMISSION 3
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DURING ADJUDICATION 8
9 Room 415 4350 East-West Highway 10 Silver Spring, Maryland 11 Friday, 28 September 1979 12 The Advisory Cominittee met, pursuant to notice, at 9:35 a.m.,
h b 13 PRESENT:
14 MR. GARY MILHOLLIN, Chairman MR. BRUCE BERSON 15 MR. JOHN CHO MR. JOHN FRYE 16 MR. MYRON KARMAN MR. KARL KNIEL 17 MR. WILLIAM LOVELACE MR. DARRELL NASH 18 MR. STEVE OSTRACH MR. TED QUAY 19 MR. GEORGE SEGE 20 l
21 22 4C f 23 A .c Romnen, t . l 25 l
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i840 01 01 2 I kepDAV I MR. MILHOLLIN: The lith meeting of the committee 2 will now come to order.
3 I have just passed out a document which is the 4 sunnary I've done of the discussions at the workshop. I've
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5 prepared a summary of the interview with the memters of the
, 6 Atomic Safety and Licensing Board panel, which should be i
't finished this morning some time. It's in the typewriter 8 ~n ow. I'll distribute it to you if we receive it before the 9 meeting adjourns.
10 Are there any general comments before we begin 11 going around the teole to report on our work? Steve, I take 12 it that the Commission's meeting this morning has been 13 cancelled, on the question of suspending eff ectiveness on an
. 14 interim basis? -
'v[ 15 MR. OSTRACH: Yes. If you'd like, I could briefly 16 discu ss with the group what the matters before the II Commission are that are matters of public record.
13 MR. MILHOLLIN: I think that might be interesting 19 f or everybody.
20 MR. OSTRACH: The Commission is concerned about 21 the question of license issuance in the af termath of TMI, t
22 and that the Licensing Boards will have oefore them 23 sufficient information to assure that all the consequences
'24 of TMI are reflected in their licensing decisions. So they I
i; 23 have before them a group of options on how the Commission j
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iS4C 0102 3 kapDAV I can involve itself in the license issuance process purely to
( )' 2 ensur.e that all information about TMI is available and 3 considered.oefore the license is actually issued.
(Ps 4 One of the options before the Commission, that was s
5 proposed by the Executive Legal Director's office, is a flat
. 6 suspension of the immediate e ffectiveness rule. The
/ licensing process would continue otherwise completely as it 8 does now, except that no license would oe issued until after 9 the Commission exercised review at the end of the normal 10 process.
11 Tnere have been a variety of other, less draconian 12 suggestions, most of which involve modification in some way 13 or another to the immediate effectiveness rule, usually to 14 allow under most of the options a period of time af ter a 15 Licensing Board decision in which the Commission can take a 16 look at the record, perhaps get the parties' views on 1/ whether or not to allow that decision to become effective IS pending or during the appeal process.
19 I think it's f air to say the Commi ssion is still 20 f ar away from reaching a decision on that. There was a 21 Commission meeting on this subject on the 14 th -- I celieve 22 it was on the 14th -- where the discussion was more than a 23 bit unfocused, and the principal paper that was supposed to 24 oe discussed at the meeting today -- I'm very well k.; 23 acquainted with the author of that paper. To be charitable.
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>640 01 C3 4 kapDAV 1 the paper is very, very weak, and poorly thought out. The A
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2 options are not very convincingly discussed. Nonetheless, I l
l 3 think the group has to be aware that it's quite likely that (f' 4 the Commission's meeting next Thursday -- at lea st i t's 5 possible at the Commission's meeting next Thursday they will
$ make some interim modifications to the immediate
/ e ff ec tiveness rule. !
3 The Commission has oeen informed -- is, of course, 1
9 aware -- about our group's work. And I think that it is not l I
10 intending to pre-empt or pre-judge or brush aside our work. I 11 It's just that the f actors we're considsring are entirely 12 different f rom those that motivate the Commission. And 13 whatever the Commission does will be done in an interim 14 mode and only have effect as they have a no-confidence that 15 TMI issues have been properly integrated into the normal 16 licensing practice.
14 MR. MILHOLLIN: Steve, do you think this Thursday 13 is going to te decision day? I get that impre ssion from Il your remarks.
23 MR. OSTRACH: I think it might well be. The one 21 proolem witn reaching a decision at this time is that the 22 Chairman's oeen out of the country. When the Chairman comes 23 cack, the other commi ssioners will have had two weeks to 24 look at the paper and I wouldn't be at all surprised if they 3 23 reach a decision on Thursday. They s eem to ce making iC) .
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5840 01 04 5 r- kapDAV I decisions a little bit more quickly these days.
2 MR. KARMAN: Steve, this paper that's before the 3 Commission now is an ELD paper?
l q>*s 4 MR. OSTRACH: No, the paper that's up there now is 5 an OGC paper. What it is is an options paper that discusses
. 6 the options that have been proposed by a number of people.
7 ELD -Chairman Rosenthal, Chairman Milho111n had a suggestion.
3 MR. KARMAN - I saw that paper for a few moments 9 this morning. It came on my desk.
10 MR. OSTRACH: Tuesday or Wednesday? l i
l 11 MR. KARMAN: Just before I lef t this morning, I 14 saw that.
13 MR . MILHOLLIN: I suppose, Steve, it's fair to 14 predict that the Commission is going to decide this question 15 oefore we file our report, and we'll have to have a section !
16 in our report which discusses the possible connection 1 J
11 Detween the situation under the interim rule and what we're I 13 recommending, since interim rules around here have a way of 19 living on for years.
20 For example, the infamous Class 9 proposed --
21 MR. OSTRACH: proposed Anne x.
22 MR. MILHOLLIN: Has had a remarkaoly vigourous 23 life.
24 MR. SEGE: That never actually was borns i t never 2
h;, 25 , actua lly bec ame a rule.
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iS40 '01 05 6 kapDAV i MR. MILHOLLIN: That's right. So I suspect 2 someona's going to ask us, don't you think, what if we adop.t 3 this tomorrow, what does that mean for the period during
/ 4 which the interim arrangements are in eff ect? Wouldn't you f
5 suspect that that would be --
6 MR. OCTRACH: Yes. I think that once the group e comes up with a recommendation to the Commission, it will be 8 necessary in discussing that recommendation to say how it ,
9 meshe s with whatever the Commission comes up with. Since 10 there're ooviously two variables in the equation, a don't il think we go much further than that right now. perhaps we le can isolate some member of the group who is familiar with 13 che Commissions decision-making on the interim 14 modifications, and cooperate with that member in working on 7-y_ 15 the section you just proposed.
16 MR. MILHOLLIN: That was what I was thinking of.
17 That's why I posed the question. I assume that group member IB would agree tc do that.
19 MR. SE3E: Mr. Chairman, I'm not too pessimistic 20 aoout the possibility of an interim decision about 21 suspending immediate eff ectiveness or something of that 22 sort, lingering on without attention for a long time. There 23 will be, shortly after the Commission's decision on this 24 subje ct , there will be the reports of the presidential and 22 NRC inquiries, whien will undoubtedly motivate the h
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1840 01 06 7 kapDAV I Commission to consider what f urther action they would want
( )' d to take in connection with whatever interim decision they 3 reach now.
pd- 4 It seems to me that the likelihood of an interim -
5 decision at this time lingering on through inertia through a
. 6 very long time are relatively small. And we need not overly 4 concern ourselves with such a possioility.
~
8 MR. MILHOLLIN: Any questions about this subject?
9 (No response.)
10 MR. MILHOLLIN: The subject is not generating a 11 great deal of comment this morning. Okay.
12 Any other general matters that we might discuss 13 cefore we go around the table ?
14 MR. FRYE I don't know if Steve has brought us up O 15 to da te on the status of the study of the Appeal Panel or kxd 16 not. I'm just curious to know what was happening on that.
It MR. OSTRACH: It's on my cesk rignt now. The 13 introduction needs to be rewritten and the recommenoations 19 need to De rewritten. It's only about 45 pages long, and it 20 was definitely promised to oe in the Commission's hands oy 21 the end of April. So I'm trying to decioe whether I should
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22 wait until I get a little bit closer to April and say that I 23 came in early. The s t atus o f it is, as I've indicated 24 cefore, it's not going to recommend the abolition of the k 25 Appeal Board. It's going to recommenc minor modifications
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840 01 07 8
,kapDAV i in interlocutory appeal, primarily through referred y 2 rulings, and creation of some sort of -- some sort of 3 enhanced Licensing Board monitoring proce ss that would be 4 conducted either through the General Counsel's office or
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3 throuch the Licensing Panel's chairmar/s office.
5 At least tentatively, my preference is leaning in '
s the direction of 000. I think it would put the Licensing 3 panel chairman's office in a. difficult position to monitor 9 the work and report on the work and the proolems arising in l
10 his essentially co-equals' work. And we would hope to send l 11 it up. There isn't any particularly good reason why it 12 shouldn't go up within the next, say, two or three weeks.
13 That's been true , now, for several months.
1 14 MR. FRYE Thank you.
15 MR. OSTRACH: I note, by the way, that as we've 13 all anticipated, there is a certain overlap between the i
1e recommendations that I make and the Appeal Board study, and 13 some of the questions that ought to oe considered here. And 19 I tnink Chairman Milho111n has already suggested that I 20 volunteer to address in our report, add to our report of 21 this group a short section discussing the work of the Appeal 22 Panel study. And I expect to do that.
23 MR. MILHOLLIN: Some of the things that you're 24 c ons i de rino , iixe monitoring of lower board opinions, is j h; 25 cefore us. So it's something we have to take into account.
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840 01 08 9 kapDAV I Any other matters? Are we ready to go around the taole this
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(3 c/' 2 morning?
3 (No response.)
6P' . 4 MR. MILHOLLIN: Georga?
u 5 MR. SEGE: My head hangs in shame, Mr. Chairman, 5 because since our last meeting I was so heavily involved 7 with the completion of the study of the delegation of
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a decision-making authority within the Commisio- that I have l
9 had very little time to concentrate on the wol sf this l l
10 committee, and I am behind in my writing assignments. I )
i 11 hope to catch up in the next few days.
12 I might mention that the delegation study hs now 13 been completed, and it's in the hands of the heads of the 14 two o ffices that have the joint responsibility for it, the 7_
'q[ 15 General Counsel and the acting director of OPE. We expect 16 to submit it very shortly, perhaps in the early part of next 1, week. -
IS The report deals mostly with delegations to staff 11 and delegations to the boarcs are not treated except when 2] it's nece ssary to discuss the subject incidentally, to 21 delegations to staff offices. So the issue of greater 22 Commi ssion involvemen t in licensing adjuoication is not 23 dirs:tly touched on, but the report does maKe the point that 24 increased Commission involvement in licensing is viewed as 3 25 desiracle f rom the standpoint of tne Commission's acility g
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540 01 09 10 1
kapDAV I to make rules and to sponsor regulatory innovation when !
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\~/ d necessary, and that the need for rulemaking and the sense of 3 how rules actually work in practice, the Commi ssion would l
4 get from increased participation in licensing adjudication, l
2 coulc be helpf ul in its rulemaking function. I 1
6 And that is perhaps as close as that report gets l l
. to the subject matter of this committee. 1
- 1 3 MR. MILHOLLIN: It sounds as if it's safely
> distant f rom us, so that we don't even need a section in the l 10 report which explains its impact.
11 MR. SEGE: Well, po ssibly a one or two-sentence 12 acknowledgement of the relation might be in order. But the 13 interaction is quite limitec. There are ref erences in the 14 delegation study report to the work of this committee for DL 15 the areas this committee addresses much more intensively 15 tha7 the interrogation study addressed any of its subjects.
Il MR. MILHOLLIN: George, wnile your head is hanging 13 in sname it m!cht be time to ask you when you'il complete 19 your writing assignments. Do you tnink you could distrioute 23 some of the material next week?
21 MR. SEGE: I think so, Mr. Chairman. My 22 indic ations now are that the final review by the two office 23 heads is not going to create any suostantial amout of 24 furtner work, that the draft is likely to be approved with h 23 little or no change. If that indicat ion is correc t, I O .
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e640 01 10 11 kapDAV 1 should be aole to spend most of next week on the work of (n,/ 2 this committee, and I want to give first attention to j 1
3 completing the things that I am overdue on. !
4 l qk- MR. MILHOLLIN: I suspect it would be better for i l
5 us if you could do -- or if you and I could do the
, 5 evaluation criteria next week.
< MR. SEGE: Yes.
3 MR. MILHOLLIN: And. get tnose out to everycody
) along with the draft, the first draft of the report.
10 Tne other matters, such as the introductory 11 mat 3 rial, are really not necessary for any of us to have in 12 order to do our work next week.
13 MR. SEGE: That would be my assessment also, 1
14 Mr. Chairman. '
15 MR. MILHOLLIN: Oh, I'm sorry, week after next.
16 So, we'll work on the evaluation criteria next week and see 1e if we can come up with some kind of a formula for 19 e ve ry body .
19 MR. SEGE: The only other thing tnat is quite 20 urg3n t is a listing of the options. But in line with tne 21 conversation that we had by telephone the other day, that
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22 may involve some f urther thinking tnrough of how, if at all, 23 the/ want to regroup the options as presently conceived.
24 But I would, of course, be writing that section on tne casis
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>840 01 11 12 rn kapDAV I at the time of writing. If we elect to regroup options )
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l 3 section to update. !
4 MR. )'ILHOLLIN: Okay. Thank you, George. Steve?
/{e' 5 MR. OSTRACH: My head doesn't hang perhaps as low 6 as George said his does, and not as high as it undoubtedly 7 should. I've completed in a preliminary form the specific ,
l 3 writing assignments I think I was givin, which are section ,
I
> 1.1 of the report, which is the background of the study. I ;
10 oroke that into two subsections, 1.1.1, the establishment of 11 a group, and 1.1.2, a brief history of 10 C.:R 2.764. I 12 MR. MILHOLLIN: Excuse me, Steve, do we have that !
13 in our package?
14 MR. OSTRACH: You don't. I have a few extra l l
h 15 copies here. I seem to have not maos enougn copies to go 16 around. l 14 MR. FRYE: Could we have some made?
IS MR. OSTRACH: Go ahead. I have three here.
19 George has one.
23 '49. MILHOLLIN: While Jonn's making copies, does 21 anyone else need to have mors things copied, or more copies 24 made of things?
23 (do response.)
21 MR. OSTRACH: 1.1 a nd 1.2, I've done. Section 1.6 25 of the report, wnich is the sort of procedural section on l
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i540 01 12 13 kapDA( l puolic participation, and just how we went about getting
') 2 public participation, and a draf ted s ection 3.3, which is 3 the present system pros and cons, frankly, I recognize tnat l
4 this section is as yet inadequate. I t's muc h t oo s k e tchy , ;
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5 out I thought that it wa good to get something down on !
, 6 paper, at least to serve as the basis for other people e giving me comments while it's rewritten.
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8 dow, those are the writing assignments I have.
9 What I have not done, even to that level, are some of the 10 co-writing and editing assignments that I was given. In 1
11 particular, Ted Quay has provided me with section 2.3 of the j 12 report, which is the summary of public comments on the 13 que s t io nna ire . Excuse me, 2.3. And I just haven't had a 14 chance to work my input into that. John Cho and I are 15 working on a section entitled -- some thing or other from 16 outside the licensing process. I can't remember what the 17 title of it was, construction consequences of issues arising
- 13 outside the licensing process, and the Sailly case is going 19 to sort of oe the centerpiece of tnat, as a good example of l 20 what we're not considering.
21 .iR . MILHOLLIN: I think it's proceedings other 22 than direct review.
23 MR. OSTRACH: Proc eedings 'othe r tnan direct 24 revi e w.
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2; MR. MILHOLLIN: Item 3.7.
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640 01 13 14 kapDAV I '4R. OSTRACH: And we haven't done that yet. John 2 has. John has done his work. I haven't completed it as 3 yet.
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5840 02 01 15 mgcDAV I MR. MILHOLLIN: Jack has finished his draf t of
() 2 Bailly?
3 MR. CHos Yes, at least in draf t f orm.
,[' 4 MR. MILHOLLIN: Oh, okay.
5 MR. OSTRACH: That third is Bailly salient o features.
7 MR. MILHOLLIN: Fif teen pages, okay.
1 MR. QUAY:
B That's the abridged version. )
9 MR. OSTRACH: On the sections that will be 10 distributed that are being copied now that I read, Section 11 3.3 dealing with the current test and Sec tion 1.1 dealing 12 with the bac kground of the study, I would appreciate 13 co mme nts. I think both of those are very important in i
14 setting the ground from which we're proceeding, and I 15 believe every memoer of the group should have input on tnose lo sections.
Ie MR. MILHOLLIN: Excuse me , Steve, could you 13 mention those sections again?
1 ,' MR. OSTRACH: 1.1, which is the background on why :
1 23 we are here, and 1.1.2 which is the history of the present 21 rule and Section 3.3, which is the description of the ,
1 22 present system. I would really like anyone's inputs on 23 that, parti:ularly on 3.3 because I recognize tnat it's very i
24 sketchy rignt now.
k 23 Mk. MILHOLLIN: I was going to mention later tnat
840 02 02 16 m cDAV l this is a good time for us all to help with comments on each (p\
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\/ 2 section that we have. But mayoe we could do that just as we 1
3 go around the table, so each of us should ask for help from I
4 others. I notice, Steve, wnile we're on that subject that
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5 it might te a good thing for you to check the write-up for
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6 Seaorook in the charts to make sure it accords with your
/ own.
3 MR. OSTRACH: I was just going to say I was jus t 9 doing that.
10 MR. MILHOLLIN: So there are no discrepancies, out 11 there is a rather lengthy write-up of Seabrook in the state 12 charts. Is that right?
13 MR. BERSON: There is some informa tion.
14 MR. FRYE Wasn't there a special chart on h; 15 Seacr ook?
16 MR. MILHOLLIN: There is a special chart on 17 S e acr oo k. fes, le MR. BERSON: Okay. I'm not f amiliar with the is chart.
20 MR. MILHOLLIN: And I was thinking, and I recall 21 that in the final version of the chart which I just 22 received, I think, yesterday which you all put togetner tnat 23 there is an extensive write-up of the history of Seaoroo'< on 24 stays. That's what I'm thinking of, and it would ce a good 22 thing, Steva, if you could look at that.
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(-) 2 same case.
3 MR. MILHOLLIN: That's right. Ans you all could 4 look at Steve's write up to make sure tna t they're
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5 consi stent.
. 6 Excuse me, Steve, go ahead.
4 MR. OSTRACH: I'm finished.
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3 MR. MILHOLLIN: Okay. Bruce? Myron?
9 MR. KARMAN: As the Chairman indicated, I l IJ circulated to all members of the Committee on the 25th an 11 updated cocumented called " Conclusion from the Charts",
12 which you snould all have copies of oy now.
13 Did anyoocy not receive it?
14 (do response.)
15 MR. KARMAN On the 24th I sent an updated copy of 16 the write-ups of the Palo Verde and MPPSS cases. Again, 1/ hopef ully, you did all receive it. This morning Darrel IS circulated an updated copy of the accelerated treatment of 19 issues paper.
20 MR. OSTRACH: Excuse me. I have a 9/13 draf t of 21 that.
2> MR. KARMA.42 Throw it away. There's a 9/27 one.
23 MR. OSTRACH: Similarly tne August 31 draft of l '
j 24 " Conclusions f rom the Charts" ?
S c 25 MR. KARk%N: Out.
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640 02 04 18 i
( c0AV i MR. MILHOLLIN: The new " Conclusions f rom Charts
- 2 are dated wnat?
3 MR. KARMAN: 9/25.
6 MR. KARMAN: 9/24. Actually, it's dated September <
e 21, out it was really finished on the 24th.
3 MR. MILHOLLIN: It's supplants an earlier version 9 of that, dos sn't it?
10 MR. KARMAN: Yes. Actually on any of the stuff I l
11 that I've mentioned, you can discard all the previous ones.
12 A "Su mmary of Stay Operations Charts" -- it's a very short ,
1 13 accument -- that was distriouted this morning did not get 14 too oeeply involved in the operatior.s of the plants and Ted I
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15 Quay and I have circulated a document relating to Options 3 16 and 4.
14 MR. QUAY: That's Item 3./ on the list. Thr ee ,
18 tour, and five.
19 MR. KARMki: Three, four, and five. I'm sorry .
2J Yes.
21 MR. MILHOLLIN: That's also 9/28 is it?
24 MR. KARMAN Yes.
. 23 MR. MILHOLLIN: 0%ay.
24 MR. KARMAN: I tnink that's all I have, l 6m 23 Mr. Chairman.
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iB40 02 05 19 !
mgcDAV' I MR. MILHOLLIN: Tnank you. Does everyone have all i (q.
_j 4 those documents.
3 MR. QUAY: It starts out with Option 3. It 1 F l 6' 4 procaoly should oe labeled Item 3. /. ;
4 :
5 MR. OSTRACH: Now that Item 3. 7, do I take it that 6 the other cocument that we got that says Item 3.7 at the top i I has the wrong numoer - "Accelerateo Treatment of Issues?
MR. QUAY:
3 I'm sorry. I t's 3.5. My mistake. l 9 MR. OSTRACH: The one that starts out Option 3 is 10 re a ll y --
11 MR. QUAY: 3.5. !
12 MR. MILHOLLIN: Item 3.5 is " Selective 13 Effectiveness."
14 MR. QUAY: Right.
( 16 MR. MILHOLLIN: Item 3.5 of the final report.
16 MR. QUAY: That's correct.
14 MR. MILHOLLIN: John Cho?
16 MR. CHO I passed out this morning write-ups on 1/ St. Lucie-2 and Sailly. At our last meeting, I passed out a 2D craft .t St. Lucie-2, out the one I passed out tnis morning 21 is tis redraft of that earlier draft, also pa ssed out --
22 MR. MILHOLLIN: Excuse me, Jonn. So we should 23 consider now St. Lucie-2, 9/21/79 -- not the otner one. Is 24 that rignt?
h.. 23 Md. CHO Right.
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840 02 06 20 i mgc0AV i VR. MILHOLLIN: It supplants the other. Excuse J
) 2 me. I 3 MR. CHO: Okay. Also passed out was a funding (r'
s 4 discussion on St. Lucie-2. It's a separate cocument. My 5 partner on this particular project, Karl Kniel, is on 6 vacation, so he couldn't work on it, but Ted Quay prepared 4 these discussions on funding.
8 MR. QUAY: It starts out " Finding".
9 MR. OSTRACH: It oelonged with the draf t 10 St. Lucie-2.
11 MR. CHO Rignt. The Bailly discussion does not 12 incluoe any funding information. I think we had that l
13 understanding the last time -- that we decided to take 14 this. de might not get that much inf ormation, out we would 15 go ahead anyway and discuss it. l 16 MR. MILHOLLIN: Excuse me. Can I ask you a 1/ question? Does the Bailly -- if we put the two together, 18 does it dis:Uss the options somewhere?
Il MA. QUAY: S t . Lu: l e --
2J Md. MILHOLLIN: Excuse me. St. Lucie?
21 MR. QUAY: Yes. And I have concurred in tnose 22 options cased on the f unding flow.
23 MR. MILHOLLIN: The applications of the options.
24 Okay.
Q. .
2; :4R. OSTRACH: Page seven of the St. Lucie document l-l 9
5640 02 07 21 mgcDAV I has a blank next to Roman IV, and Roman IV is the separately O
g_j 2 typea sheet of paper. It fits together, and the options are 3 there.
qv 4 MR. CHO: Now I had one more task to do, and that o was to write these sections in the report on stays and
. 6 appellate procedures.
4 MR. QUAY: That's Item 3.6, John?
8 MR. MILHOLLIN: Yes.
]
> MR. QUAY: Options 6 and 7.
13 MR. CHO Right. I, too, hang my head somewhat in 11 shame because I haven't had the chance to finish that aspect 12' of my task, and I hope to do it by early next week.
13 MR. MILHOLLIN: You've started on it out haven't 14 finished it.
15 MR . CHO Yes. I'd say I'm about midway. Some of 1
16 these things take a little oit longer than one anticipates.
Ie MR. MILHOLLIN: Ye s , I think that's true.
18 Okay, I think we can assume that things aren't 19 finished yet, but things that will os comple ted next week 20 can simply ce distriouted when they're finished, and people 21 can simply plug those into the draft that I will produce ,
22 hopefully, oy the end of next week.
23 Okay?
24 .'.17. CHO : Fair enough.
'( 25 MR. MILHOLLIN: Inat's it for you, Jonn?
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2 MR. MILHOLLIN: John Frye ?
3 MR. FRYE Well, I had earlier distriouted my
/%/~' 4 writs-up of the charts I prepared and made some minor 5 revisions in that based on comments that I received from 6 you, Gary. If no one else has any other comments, I have 7 those ready to go in this form, at least for the time being.
S MR. MILHOLLIN: Excuse me, John. Are you 9 referring to --
10 MR. FRYE Write-up of the charts. I have also 11 written up what really amounts to an outline of Option 2, 12 which deals, of course, with deferring effectiveness for the 13 varying periods. That has not been distributed. generally.
14 Bill Lovela:e and I are working on that. de need to get
]
s_ 16 some more infe' tion together to put it in the form where 16 it will ce ready to distribute.
li Also, Gary and I are going to talk to Alan )
15 Rosenthal on Monday morning, and I think a lot of the i 19 questions that we have for nim will have direct bearing on j 20 what we want to say, discussing that option. So hopefully 21 that should oe ready to go out oy Tuesday or Wednescay.
~
22 4R. MILHOLLIN: Option 2 re f ers to delays f or 23 various periods of time and the costs of delays and the 24 likelihood of their adding on to the end of the process.
[, 25 MR. FRYE Basically, what I've triec to ao there
/
, - - .-. . , -e- -t
840 02 09 23 mgcDA/ I is to identify the advantages and disadvantages that are
+ - ) 2 inherent in delaying effectiveness and to conclude it with 4
3 an indication of how long we could expect the start of ,
(fs 4 construction to oe deferred under the various sub-options 5 presented.
6 Suo-option 2, that last part, of course, will, I i 7 think, ce prooably greatly influenced by what we learn from 3 Alan Rosenthal on Monday. So that is critical cefore it's
> ready to go around.
10 I've also been assigned the task of writing up 11 Rosenthal's option, which he suggested, which was reported d
12 in a report of his interview regarding any mocified stay 13 procedure coupled with a 30 day deferral of e.ffectiveness ,
4 i 14 which I hops to get out very quickly.
15 And I note this morning, I'm not sure I have yet 16 cistributed the rest of the Midland and Cherokee anc Catawoa 1/ case studies.
15 MR. MILHOLLIN: I was going to ask you aoout 19 Chero k ee. Catawce, I thougat, they were done a long tims 23 ago.
21 MR. FRYE Well, they were, and my recollection is 22 that I sent tnem to Karl Kniel, and I haven't heard from 23 him.
2* MR. QUAY: Karl is on annual, I tnink, until i.
- 2a Monday.
(:) ,
q
. l
, . - . - - . . . . . . .- - - . .~ - ... - - ._ -
540 02 10 24 mgcDAV i MR. FRYE So as soon as I get that squared away, e 2 that will, of course , come out.
3 MR. MILHOLLIN: Cherokee and Catawba are finished ks 4 as f ar as the write-up?
'r w
5 MR. FRYE So far as I know, unless Karl has some 5 thoughts and comments on it.
< MR. MILHOLLIN: This includes the options?
3 MR. FRYE Yes.
9 MR. MILHOLLIN: So we still have Midland 10 outstanding. Right?
11 MA. FRYE dell, I had written that one up too, I 12 celieve, but I don't think that's been distributed. Sill 13 and I will talk aoout that.
14 MR. MILHOLLIN: On, okay. I'm speaking now just C3 15 of the options on Midland.
16 MR. F.;YE Yes. Right.
1/ MR. MILHOLLIN: That's been written up?
13 MR. FRYE Yes.
19 MR. MILHOLLIN - Okay. So Midland is finished 23 also, except for last minute discussions.
l 21 John, I'll hang my head in shame and say that you 22 and I haven't worked on the option of making eff ectiveness 23 an issue in the licensing. de were supposed to work on l 24 that.
I 22 MR. FRYE I was going to do that with a write-up (h
1 iS40 02 !! 25 ggcDAV 1 of one of tne options suggested.
MR. MILHOLLIN: By Alan?
2
.3 MR. FRYE By Alan. So I think they fit A" 4 together. I think that would be a good way to treat them.
4 3 MR. MILHOLLIN: Okay.
6 All right. While we're on that subject, you'll e- notic e I have put quite a bit of discussion about that in my ,
S summary of the workshop, because the workshops, as I recall, 9 discussed that a lot. A lot of the discussion on more than 1
10 one panel was devoted to how that option could work. So you ;
I 11 mignt want to go oack to the transcripts and look at that.
l 12 Do you have transcripts of _ the workshop 13 discussions?
f 14 MR..FRYE Yes.
t
\_. 15 MR. MILHOLLIN: John,.do you need reactions from 16 anyone, especially as to things that you circulated or are 14 going to circulate ?
13 MR. FRYE Well, yes. I would lite to have 19 people's reactions on the write-up of the stays, which is 23 really the thing that people have now -- if they have any.
21 '42. MILHOLLIN: When you say " stays", you mean --
22 MR. FRYE: Excuse me. Not stays. The charts I
. 23 prepared on licensing decisions by appeal ocards. This also 24 includes a orief section on certification and deferral, a
( 23 brief section on what the Commission has done over the J
. _ _- - - _ - . - - - ~ --- .. . . - - ... . . ..
liS40 02 12 26 mgcDAV i years. The write-up on 3.4, which is Option 2. I think is f1 kl 2 also something that probably all the members of the ,
3 Committee will want to comment on.
4 MR. MILHOLLIN: That's the information on delays. ;
({~
5 We've been working with that and discovered that it's fairly 6 hard to present that clearly, because the problem is -- let
/ me see if I can describe what we've done. John and I were S talking about it this morning.
1 9 Okay. Here's the problem. Bill and I have talkec l
)
10 about this, too. The problem is this. We know from history 11 that there nave oeen cases in which demand delays nave 12 occurred during construction. By "aemand delay", I mean in 13 which the applicant has slipped the construction schedule or 14 simply stopped construction for a period because of a 1; re-forecast in demand. In those cases, it appears that if 15 the schedule was slipped for more than six or eight months l
- 1. and any celay in eff ectivene ss whien might nave occurrea in 13 those cases would not have af fected the date of commercial ly operation, cecause that a ate was- pos tponed anyway oec ause of 23 the r ecalculation of load demand.
21 Is that clear so far?
2> *tR. SEGE:
. It wou;. _ sinply have oeen postponed 23 less, if the eff ectivene ss in the first place had oeen 24 aelayed some?
[ 26 '!R. MILHOLLIN:
. Yes. Ins t's ri gnt .
I
.~ _ _ _ . , . -
>840 02 13 27 mgcDAV I So that might indicate that if eff ectiveness were O
(y/ 2 postponed for some cases, it might not postpone the 3 beginning date of commercial operation. So, of course, we cr'- 4 don't know in how many cases -- or at least we haven't got w
3 the oill yet, so I'm not sure we know in how many cases that 6 would be true or has been true in the past.
t MR. QUAY: What does that get us, though? I don't l
8 know where that gets us. It's based on past history which j i
9 may not be true in the present. l 10 MR. FRYE That's the big proolem.
1 11 MR. LOVELACE: You can't plan f or it. j 1
12 MR. MILHOLLIN: There are a couple of proclems l l
13 with ascribing any significance to that. One of them is ,
14 that these things may be cyclical, and it may not happen (1) 15 again -- that there's a period of delays caused by 15 recalculation of Jemand.
]
Il MR. OSTRACH: But it's even worse than tnst, 15 because there is now way, presumaoly, of predicting at tne li time of license issuance which ones are going to be delayeo.
23 MR. QUAY: That's precisely the point.
21 MR. OSTRACH: It's as if saying tnat you Know that 22 _five out of ten people are suffering from cancer, so 23 shooting ten of them, five would have dild anyway.
24 MR. CHO I do think it's relevant, thou;n.
) 2; "R. OSTRACH: It's relevant, out your cost is O I 4-
1640 02 14 29 mgcDAV I half as mucn as you would think, because half the plants 2 would have oeen delayed anyway.
3 MR. CHO Because one conclusion would De that the
,f" 4 absence of the immediate eff ectiveness rule would os to 5 delay actual construction. But I think what you're pointing 5 out that counter to that thare may oe some other factors l
i which would indicate that the delay would not have oeen as 3 great or mayoe any delay anyway.
/ MR. FRYE It would have occurred for other 13 r e aso ns .
11 MR. MILHOLLIN: For some plants, at least in tne 12 past, the delay in coming on-line would not have been 13 affected by whether there was a celay in immediate 14 e f f ec tive ness. It would not have made any. difference.
15 DR. NASH: The decision, at the time that it's 15 made, is made on the best information that's availsole.
- 1. MR. OSTRACH: I don't think that's really what you 13 s aid. I mean, retroactively you can see that it's true, 1/ that if those plants had-started six months later, tnen they
- 2) wouldn't ha/e stopped for six months.
21 MR. MILHOLLIN: There's another point that I was 24 coming to, anc that is that the applicant, nowever, in 23 advance never plans for a atlay. And if we say tnat you 24 have to delay for six months or eight months or X period,
( 26 the applicant is going to sat the whole schedule oa k to C) ,
e
1 5840 02 15 29 mgcDAV I that period of time.
(/1 2 M3. OSTRACH: He just would have oeen that much 3 further along. Then he stopped.
4 if 5-6 I
3 9 l 10 11 l l
12 I
,' 13 i 14 s_ 15 16 14 18 19 23 21 22 1
. 23 24 h_ 26 O .
t 6 .03.I' 30 DH gsh i MR. MILHOLLIN: So if you look at tha t f a c t, then 2 the problem becomes more ' complicated. It's possible that even 3 in such a case where he slipped the schedule six months because 4 we told him he couldn't begin for six months af ter immediate 5 effectiveness, still if there's a demand delay in that o plant f or more than six months, it could be that, well, 7 let's stop talking here. I 6 What do we do in that situation?
9 MR. SEGE: The possibility of error in demand forecast 10 would not be diminished by postponing eff ectivene ss by six
.11 months. On the contrary, there would be likely to be some 12 increase in the likelihood of error because the applicant 13 would have to forecast his needs six months f urther ahead 14 than otherwise .
15 And some of them haven't been doing such a good job l I
16 even witnout the extra six months. ;
17 MR. OSTRACH: Regardless of when you start j 16 construction, wnether you start it right at the licensing !
19 board decision or six months af terward, there will be a clock 20 of time of perhaps six years in wnich the plant is under
- 21 construction, anc the probability at any time in tha t six 22 years.
23 MR. KARMAN: There will be some delay.
(
24 MR. OSTRACH: Of the applicant getting information 25 tnat, wnoops, your forecast i s too hign. You might as well I
6640.03.2 31 i'~l.g sh ! stop, is the same, regardless of when that six-year V
2 construction really begins.
3 And as George pointed out, if anything, the 7
4 prooability of forecasting error in that period is slightly 5 increased if you delay the start of construction further 6 f rom the time at which the guiding forecast was made.
. 7 I don't think that's really significant. I mean 6 they're so bad at f orecasting anyway, you can't make it much 9 Worse.
10 MR. MILHOLLIN: Let's assume that you did set it il back six months and then he starts. And then halfway through 12 the proc e ss, there's a postponement of the year in the date 13 of commercial . operation. i rs I
() 14 Wha t does that mean?
15 MR. QUAY: Just another tacked-on delay. l I
lo MR. FRYE: Just add another year to the six months.
17 MR. QUAY: In addition to the six months --
16 MR. FRYE: That would be the sort of --
IV MR. LOVELACE: Well, maybe; maybe not.
20 MR. MILHOLLIN: In that situation, if it a ppears that
. 21 the plant is going to be needed a year later than the 22 a ppli cant thought anc we assume that he started six nonths 23 later than he would have started if he could have started at )
24 the CP, then coulcn't you say that the f ac t that he startec 4"
25 later than he otherwise did is irrelevant?
( ~
. . . _ _ . . - .- . - _ . .. . - - -. _ _ - . . = . - -. ._
4 l0040.03.3 32
/~5 gsh 1 MR OSTRACH: No, because, presumably, once whatever V
2 leads to the six-month delay period is f actored into the
, 3 process, an applicant will have applied f or a license,
- 't l '
4 a ssuming tha t he coula start operation, licensing board plus 5 six months away.
l 0 And all of his projections will have been aimed at
- 7 that point. He will have applied, made his initial application l 6 presumably, maybe six months later, or waited until demand was l 9 a li ttle bit highe r.
10 He will have unoers tood tha t he was going to get 11 his license . I 12 MR. KARMAN: Just on the basis of going through l 1
13 a ppellate review. !
( 14 MR. OSTRACH: Right, of going through appellate 15 review. He will already have taken that six months into lo account in his load forecast, and therefore, he will assume !
17 t ha t once I get my approval, which is six months af ter the 16 licensing board decision, I'll work six years and then just IV m ee t that demand.
20 If once he starts work his cemand crops again, he l'
, 21 s tila has to introduce a hole into his construction scheoule.
22 MR. QUAft Tha t's correct. )
23 MR. MILHOLLIN: Once tha t occurs, though, once he i 24 puts a year on end. couldn't you say that because of the l
25 developments in aemand, that that plant would never have been i
- o, I
e
,bb40.03.4 33 f(}gsh I ready to go before the date when the applicant finally decided 2 to make it ready.
,y.
3 MR. KARMAN: But that first six months was already g
4 ginned into his f orecast.
- 5 MR. MILLHOLLIN: What I'm ge tting at is t ha t if the 6 period of postponement is greater than the period of initial
- 7 deferral, then it seems to me that it's cancelled out.
)
6 MR. SECE: Mr. Chairman, I think we need to bear in l
9 mind --
l 10 DR. NASH: You're right, but you don't know that at.
)
l
.11 the time of the decision.
12 MR. MILHOLLIN: But if you concede that t ha t's 13 true in an ex poste sense, then couldn't you say that t
r's 14 looking down the road, that that may be true in a certain t,v.J-15 percentage of cases because of what develops curing to construction?- You won't lose anything by cef erring l 17 beginning construction for six months.
16 MR. SEGE: Mr. Chairman?
I IV DR. NASH: To a large extent, it depends on our 20 trend.s in growtn and thd demand over the period of time we're
. 21 cencarned about now.
22 MR. MILHOLLIN: Tna t's right. It cepends on the
~
23 economy and it de pends on lots of f actors which nobody can 24 foresee.
'~
25 I agree.
1 rT l 's_/ ,
p
, e
.ob40.03.5 34
{}gsh 1 MR.-OSTRACH: Demand could increase.
2 MR. QUAY: And then any forecast based on that is l 3 obsolete because they're going to f all short.
\ 4 So I think that's speculative at best.
5 MR. MILHOLLIN: I'm not contending it's not 6 speculative. All I'm saying is that it is not certain that
. 7 if you delay eff ectiveness for six months or eignt months or S nine months, it's going to add on to the end of the process 9 in every case. Okay?
10 MR. SEGE: Mr. Chairman, I'd like to comment on the 11 other side of that coin, recognizing that f orecasting demand 12 is an uncertain art. We still cannot dependably proceed 1
13 on the assumption that applicants will be systematically i
( 14 overestimating the urgency of their projects.
15 We cannot count on them doing that. Many of them to have done i t in the last few years, but not all. And we 17 cannot count on that in the future.
le There has bene a wave of overestimates of urgency i
IV in the last few years. But as Ted points out, there is no 20 law of nature that it would necessarily continue in that way.
. 21 There could very well be f actors of an importance 22 comparacle to the energy crisis that has caused reductions 23 in demana forecast that might cause increases in forecasts l
l 24 of demand for nuclear energy. Increased severity of oil 25 snortage, should it occur, could be such a f actor. Extensive n-s_ .
i
. _ . . - _, .a
5640.03.6 35 (m,j gsh I use of secondary batteries in the propulsion of cars could 2 be such a f ac tor.
.,. 3 These are speculations.
4 But we're talking about a time-scale of a decade or 5 so, ar.a many things can ha ppen. And it seems to me that our o best course is to estimate the impact of options that we might 7 be proposing in terms of the impacts that would o ^ . r If -
6 utilities projec tions of demand are approximately right.
9 And then, to the extent that that can be significant, we could, 10 within the limitations of the time lef t over to us, explore 11 sensitivities in both directions.
12 If in some or many cases the utilities overestimated 13 the urgency of how might our conclusions be aff ected or, if f
.~
14 they underest.* ated the urgency, how might our conclusions 15 be a f f ec ted --
lo Because of the experience of the last f ew years, 17 there may very well be a momentum set up among demand 16 forecasters in the dir ec; ion of paring down their demand 19 f orecasts to take the past into account.
20 There is a great f allacy of econometrics that is 21 cased on the assumption that established trends will continue.
22 MR. QUAY: Gary, I might also point out that need 23 f or power is an issue that is examined by the board. So, I n 24 mean, it's something that's reached by the board.
is 25 So if there's a lot of fat in there, well, maybe the
. ~ . - - . - . .... . . - .. - -. . - - .- . . . . . . - . - . . - .
l
)
6840.03.7 36 043 gsh. I board can determine that.
U 2 MR. MILHOLLIN: That's a great vote of confidence in 3 the licensing board. I notice that it elicits a smile f rom 4 John.
5 MR. KARMAN: And no comment f rom Myron.
~
6 (Laughter.)
~
7 DR. NASH: I agree with what George was saying.
8 except tnat we don't depend solely on the applicant's need 1
9 f or power forecast. It obviously greatly influences our )
10 information.
11 But we do substantial checking on that, at the very j 12 least, and the board listens to the arguments and then j 13 reaches a decision based, to a large degree, on the ' applicant, !
{} 14 15 but on their evidence.
MR. SEGE: That is certainly a valid and important lo modification to what I said.
17 MR. MILHOLLIN: 5111 Lovelace knows more about this I 18 than any of the rest of us. Do you f eel that you would like .!
19 to comment, Bill, or do you want to wait your turn?
20 MR. LOVELACE: No, it's still my position that if you 21 impose a six-month delay in the beginning, it's gcing to 22 impa c t the end cate.
. 23 MR. MILHOLLIN: It's probably true in most cases,
,,- 24 isn't it?
t.
25 t.!R. LOVELACE: And you can be speculative on the A
L_) ,
l L , ..
5a40.03.6 37 i]gsh I aemand issue.
2 MR. FRY E I think if I may comment a bit on what
.._., 3 has gone on, the way this came up tn begin with was my 4 a ttempt to try to make some analysis of whether delaying 1
5 eff ectiveness would automatically delay the date of ,
i 6 commercial operation. I l
. 7 The tentative conclusion that I came to was that 6 aside from the fact that you might be able to identify v certain statistical trends that have occurred in the past, 10 specifically where, for one reason or another, utilities li have not begun construc tion on the date that they were 12 authorized to begin construction by NRC, for whatever 13 reason --
O 14 But aside f rom that, it was the only safe assumption f/
15 you could make, was that delaying eff ectiveness or delaying 16 the cate at which the applicant can begin construction wo"ld 17 automatically delay the date of commercial operation.
la I certainly wo.uld concede that where there is a 19 tremenonus change in the need or in the demand forecast that 20 would defer construction or hold it for a time, that it's
. 's saf e to say af ter the f act that delaying the start of 22 construction might have no eff ect on the date of commercial 23 operation.
24 Sut we're not talking about looking at tnings af ter
(
'~
25 the fact and we're not talking about looking at individual l
l l (2) I l
4
. . - . . . - . - . - ..~ . - -- . . . . - . - - - -
. s
$640.03.9 38 L(}gsh I cases. We're talking about doing something across the board.
L 2 And it seems to me that the only saf e assumption 3 across the board is that a six-months delay in the start ur' i
i
" 4 of construction is most likely to result in a six-months 5 delay of commercial operation.
6 There are lots of reasons which you could think of
. 7 why that might or mignt not be good. And one of the things 6 I was trying to do was to say that if you cause that kind of 9 delay, what are you doing? You know, what are the costs 10 in vol ved?
11 '/lell, the CB0 study came out with certain econmic' 12 costs which I would certainly think, and I think they would 13 agree, are certainly speculative., They think that the celay
( 14 in starting construction costs s8.9 million per month.
15 Well, that's a figure that you can use. That's s8.9 10 million a month that it's going to cost somebody by 17 def e rring construc tion.
Ib 'There are also possibly social costs that could be i
19 incurred if, in fact, the demand that was originally 20 estimatec turns out to be true. Or maybe even to have been
. 21 a li ttle on the sof t side if, in fact, oemand has gone up 22 fastar.
l 23 So that's something to think about, too.
. 24 There is another advantage or disadvantage that I
((;
25 allucec .to whien I think perhaps we could elaborate a little
5640.03.10 39 L
)gsh I bit more on af ter we talk to Rosenthal. And that is the fact 2 that unoer the current system, the appellate bodies have the l l
3 luxury of time. And until you get a license application at '
4 that po i n t , no one else does. The staff is under time pressure.
5 The boards are under time pre ssure.
6 But when it gets on appeal, the a ppellate reviewers I
, 7 have the luxury of time, and I think that's an advantage 6 that deserves some consideration. It gives them an v o pportunity to go through the whole thing very caref ully, 10 whien tney would lose if you put them on the critical path, 11 to a certain' extent.
12 And I think, nece ssarily, the quality of their 13 review and their decisions would have to suff er if they were 14 put on the critical pa th.
([
15 So that's something to think about.
10 MR. KARMAN Some of the interviews already held 17 with members of the appeal board would certainly indicate le that. My interview with Mike Farrar -- he certainly f elt tna t Iv they shoulc not be on the critical path because the quality 20 of their work would deteriorate.
, 21 "R. OSTRACH: Our interview, at least, I believe it 22 was, with Commissioner Ahearne, he pointed out that t he r e 's 23 a curious definition that use s critical path only to 24 oescribe situations that are impediments to construction and 25 not reviews tnet take place wnile construction is going anead.
L
() ,
. - _ - . _ - . _ - _ . _ _ _ _ _ . ~ . . _ . . _ _ - _ . _ _ . . _ _ . _ _ . _
lo340.03.ll 40 l
l }gsh 1 The appeal panel members might well feel more 2 relaxed about adjudicating while the plant was under 3 construction then they would if construction was halted V^
j 4 pending adjudication.
l 1
5 But that's just because tnat's their perception.
- o I can imagin
- individuals who f eel under great pre ssure
. 7 knowing that while they were deciding whether or not 6 construction should begin, that construction was day-by-day y leaping ahead.
10 I've .been in situations where I have listened to l
11 decision-makers hurrying up their decision because they 12 knew that as every day went by, more work was being done 13 and they were very af raid that if they didn't decide fast, (f 14 it woula be too late.
15 So it's not necessarily true.
16 MR. FRYE I t's a valid poin t. But I think you also 17 have to observe that in the current set-up, that the aopeal l 16 boara has got authority to stop construction any time that.it IV f eels tha t i t snould be stopped.
20 MR. OSTRACH: True.
l , 21 MR. QUAft Tney've used that authority, to some l
- 22 extent, too.
1 23 MR. FRYE: Yes, I think they have, to a certain 24 fs~ extent.
- 25 '4 R . 00AY
- If tney thought it was really urgent, then b'
f
\_)\ ;
l l
'6640.03.12 41 I'dgsh 1 they acted.
V 2 MR. CHO And I think the appeal board is generally 3 aware of what goes on. I think they know which issues are 4 important, which critical., which could aff ect ongoing things.
5 You know, and wnich issues are not so critical.
6 MR. KARMAN: They're just not sitting back on
. .7 everything. I agree.
5 MR. FRYE I didn't mean to imply that.
v MR. CHO So whether we're on the critical path or 10 not, I think they sort of self-impose, you know, that kind of 11 impression.
12 MR. MILHOLLIN: So even under the present system, 13 they don't have the luxury of time and everything.
) 14 MR. FRY E: My impression is that they feel that 15 they have run into a problem that they could well be aff ected to by delay in construction.
17 They're very quick to confront it with appropriate >
~
16 a c ti on.
19 MR. OSTRACH: I don't know if this is the appropriate 20 time to mention our ciscussion there about whether a
, 21 six-montn delay nece ssarily delays operation. I'c like it if 22 some of our tecnnical members could either answer for me or
' l 23 snow me where it already has been answered. ]
24 Tne question of if we impose or recommend a system i 1
26 whereby all licensing decisions will become ef f ective six 4
I
l l 6o40.03.13 42 t{}gsh I months af ter, f airly clearly about six months after the 2 initial decision, wny wouldn't utility companies in 1985 3 or sometning, looking forward and seeing that they're going
(
4 to need a nuclear power plant in 11 years, just simply a pply 5 six months earlfer for it, begin the process six months 6 earlier.
. 7 MR. OJAY: Okay. They probably would, Steve.
I 6 MR. OSTRACH : If t ha t's so -- '
9 MR. CJA.Y: But anything you tack onto it, you're 10 9etting into your load forecasting.
11 MR. OSTRACH I understand that. One obvious factor 12 is that starting six months earlier means you've started with 13 that much worse ir4 formation about the need in the future.
(x)-a 14 But other than that, why would they be --
15 MR. QUAY: That's probably it.
16 MR. LOV.El. ACE: You're adding more dollars to the 17 cost.
16 MR. OSTRACH: Why are you adoing more dollars to IV the cost?
20 MR. LOVELACE: Time is money.
, 21 MR. OSTRACH: What time?
22 MR. LOVELACE: The six months earlier tnat they 23 start. Insteac of having a lO-year project, you've got a.
( 24 10-l/2 year project.
U'
, 25 "R. SEGE ' T ha t increase in cost, though, would be
t ..
i
,5640.03.14 43 I
Q( p gsh I relatively snall because actual construction with the j 2 commitments of large amounts of money would not start 3 earlier. It's only the planning and analysis and application 0, [~.
4 pre paration work that would start earlier.
5 That would have its costs and there would be a cost o i m pa c t. But it would not be as great as if construction
. 7 startec.
6 MR. OSTRACH: You retain your licensing manager 9 f or an extra six months.
10 MR. LOVELACE: Your prof essional staf f, your people 11 working on the PSAR, the ECS.
12 MR. OSTRACH: All of those people are going to get 13 six months more salary.
() 14 MR. SEGE: No, I don't think they would get six 15 months more salary because they'd really be doing the work 16 six months earlier.
17 And it's the earlier spending of the money that 16 would increEse the cost of the pl an t.
19 MR. MILHOLLIN: Interest on the money you have to 20 spend earlier to get through the licensing process six
. 21 montns earlier. Just ne interest on that amount, s100 22 cillion times 10 percent.
l 23 MR. OSTRACH: It almost sounds as if I'm hearing 24 now that we don't want to spend the money early in the 25 proce ss when many otner times I've heard spending money, you've i
2 C:)
1
de40.03'.15 44 LG gsh I cot to spend the money as soon as we can because seconds'
.V 2 worth of celay hurts us.
3 I'm not claiming that these things are nece ssarily ih 4 conflicting because I recognize that I'm economically naive.
5 But is it done, Ted? Have you got charts?
6
. 7 d
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l
- 1 CR 6840 45 i HOFFMAN l t-4 mte 1 1 MR. QUAY: I think Ted has done quite a bit with l
2 generic cash flow and initial commitment. To give you some l
3 idea of what kind of money is committed to the project at the d
N 4 time of CP issuance, the way he's shown it here it's close to ,
l 5 10 percent. Essentially, you're talking about interest on 6 10 percent, and depending on contractual commitments.
7 MR. OSTRACH: Interest on 10 percent for an extra 8 six months.
I 9 MR. QUAY: Plus you might have to add onto that your 10 maintaining supervisory personnel. Your AE just doesn't sit 11 still. He's got a project team committed to that. So that's !
12 an additional expense. l
( 13 MR. MILHOLLIN: Whatever that cost is --
14 MR. OSTRACH: Okay, I just hope that we take account 15 of the f act that -- well, we've said this before. I'm just 16 restating it -- that a fairly predictable delay after a licens-17 ing board decision could be taken account of in planning and 18 might significantly reduce the cost of it.
l 19 MR. QUAY: I won't dispute that fact. I think that i
20 clearly comes out in several of the submittals. They would
{
21 much prefer a predictable delay, rather than starting and !
{, 22 being forced to stop right in the middle. j 23 MR. OSTRACH: And even starting and being subjected
- 24 to a threat of stop. I geoerm nooners, Inc.
25 MR. QUAY: Several of them have stated they could
. .* 46 mts 2 1 plan around it. However, they clearly state that if there's D
V 2 any change in load demand and the need for power generation 3 within a certain period of time, that six months might rule if~
4 4 it out.
5 MR. FRYE: That's just the point I wanted to ask you 6 all to talk about, aside from the economic question. Let me 7 start again. I guess I personally, at this stage, don't view 8 the economic cost as being very important. I would view things 9 being important would be any increased uncertainty that you 10 would be injecting into the process in light of the fac: that 11 the utility is in the position of having such tremendously 12 long lead time already.
( 13 And I would love to hear you comment on that, as 14 to whether you think that's a factor.
15 MR. QUAY: I don't think there's any specific time 16 frame which would prohibit nuclear. I daink it's based generally 17 on the utility and how well it can forecast the demands and 18 when it meets its load.
19 MR. FRYE: Whether it's nuclear or not, I just wonder j 1
20 whether injecting more time, expanding the lead times, injects j
~ i 21 uncertainty which is difficult for you to deal with, regardlessi i
(u. 22 of the type of capacity he's got.
l i 23 MR. LOVELACE: That's the problem right now.
24 MR. QUAY: I think we're seeing that. Obviously, l lhenimmorws.ix. l
[ 25 it's difficult now because they just are not ordering nuclear ,'
I' 1
I
{ .
E ._ .o
_m -._ ._ . _ _ . . .. ._m.._ . _ _ _ _ _ _ _ . . _ . _ _ _ _ _ -
47 t- . -
l mt3 3 l 1 plants.
-h% 2 MR. FRYE: What are they doing with the coal plants?
3 Are they ordering them?
q..
- 4 MR. QUAY:
They're ordering some. I don't know.
5 Maybe Bill.would know.
6 MR. LOVELACE: I don't know.
I' 7 MR. QUAY: I think Bob Shannon told Gary and myself 8 that lead time on coal, you're talking six to seven years.
9 MR. OSTRACH: That's lead time from when to when?
10 MR.-QUAY: From start to on line, 11 MR. MILHOLLIN: The decision to go with coal. Like 12 if you're sitting here now. I mean, what we've been told is
( 13 you'need power eight years from now of X amount, you go coal.
14 You don't go nuclear because you can't get it in that time l 15 frame.
16 MR. FRYE: That's certainly an advantage that coal 17 has over nuclear. You can wait longer before making your 18 decision.
19 MR. OSTRACH: Coal is six to seven and nuclear is --
l 20 what are people saying? l 21 MR. LOVELACE: 12 years.
1, 22 MR. QUAY Duke Power said 14.
s ,
23 MR. MILHOLLIN: 10 to 12.
24 MR. OSTRACH: In retrospect -- this might be amusing
()mminmorws.tx. .
25 or painful -- but I've been reading hearings before the JCAE -- l 7
l l
48 mto 4 1 MR. MILHOLLIN: The JCAE?
2 MR. QUAY: Joint Committee on Atomic Energy.
3 MR. OSTRACH: Actually, they were hearings which r;. .
,d 4 led up to the pressure on the Commission to introduce the 5 immediate effectiveness rule. And there was great unhappiness 6 about the Commission's licensing delays, because it took the 7 Commission sometimes up to 18 months and averaged a year between 8 application and issuance of a CP. And JCAE put a lot of pres-9 sure on the Commission, saying that this is a real disadvantage, 10 because if someone wanted a coal plant they would decide today 11 and begin work tomorrow, whereas with a nuclear plant, had they 12 spent a year and sometimes as much as 18 months before they A
(j 13 could begin in getting the licensing approval, before they 14 could begin construction.
15 The JCAE announced that they were horrified and they 16 hoped to get licensing times down to between six to nine months 17 in the near future.
18 MR. QUAY: So we're going to add that six to nine-19 month delay.
20 MR. SEGE: What's the punch line? Did they succeed? I
~
21 MR. OSTRACH: The amusing part is that the facility, 22 the proposed facility that was the subject of anger because 23 it was taking a long time to get a license,-was the variously prs 24 referred to Mulholland or Beverly Hills nuclear power plant i L ew i nworwes. ine. I, 25 they were going to build right next to downtown Los Angeles, ,
i l \
49 m k o 5 **
I ' virtually, which in fact never did get built. That was the l
2 l one the Joint Committee was outraged that the Commission was i
~3
! squandering time when they could have built it with coal by
((
b 4 now.
5 MR. MILHOLLIN: I've interviewed I guess three people 6
on the planning question and they all said that if a fixed 7
period were tacked on, they'd come in that much earlier, b
8 because they start with the date when they need the power and 9
they figure all the increments in the schedule backwards. So 10 if you add on six months, then they figure, well, I've got to II come in six months earlier.
I2 Also, what I was told was.timt, for nuclear now, the
() 13 load forecasting is so spongy out at ten years that they said, 14 well, look, six months more is not going to make any signifi-15 cant difference. Our confidence is not within six months as 16 to what our demand is going to be.
17 MR. FRYE: I think that's perfectly evident.
18 MR. MILHOLLIN: So it's not a qualitative difference.
19 It's some kind of quantitative difference. i 20 MR. CHO: I suppose that type of. approach would be 21 okay in today's climate. But assuming that there is a develop-t 22 ment which suddenly forecasts a rapid increase in demand --
23 for example, the possibility of electric motor vehicles by 24 mid '85, then the point that you made about working back and i jlgeem neomri. w. ,
25 starting sooner can't be done, because you just don't have any l i.
50 m'ta 6
1 i
j I time.
, en 2
MR. MILHOLLIN: Then you have to use some other 3
i means of generation than nuclear.
IF- ,
4 4 l'
MR. CHO: Certainly, if you're talking, if that 5
occurs within the 10 to 12-year time frame. But as soon as, 6 you know, it's 11 years, then --
l 7 MR. MILHOLLIN; Ted, correct me if I'm wrong. The 8
impression I get is that when the utility sits down and makes 9
this decision, they say, well, I'm going to need a certain 10 amount of peaking capacity, a certain amount of baseload Il capacity, and I'm going to need it at different times, and they 12 make some sort of a soup out of that, and they say, well, I'm
() I3 going to need that, maybe a nuclear plant and maybe one or Id two other types of plants or something. Is that correct?
15 So it also depends upon what kind of capacity that 16 they think they're going to need, whether they think they're 17 going to need a baseload plant.
18 MR. FRYE: Well, sure. All we're talking about here 19 is baseload generation.
20 MR. OSTRACH: Also, most utilities, I'm told -- ;
i 21 MR. MILHOLLIN: I I guess it's going to depend on i
22 4.
s -
whether they think they need baseload and when they think !,
23 l they need baseload. As they need baseload, they're going to ,
24 need it 13 or 14 years from now, and nuclear still appeals jggen i neo,wrs. im:.
25
! to them economically, and then t.2eytre going to go nuclear.
9
1 l
i 51 m t o 7
l
! I MR. MILHOLLIN: But they may not go nuclear because 2 of storage of wastes or TMI or local opposition or hundreds 3 of other things.
4 MR. FRYE: There are hundreds of other things to S take into account: whether they get long-term coal supply 6 contracts, the sites that have coal versus nuclear.
7 MR. KARMAN: You've got certain utilities who, 8 until very recently, had committed themselves almost totally 9 to nuclear. Look at Commonwealth Edison out in the Midwestern 10 area. They were going.only nuclear. I can't say that's so Il now, but there was a time, until within the last year or two, l 12 that they weren't even considering anything else. ,
(} 13 MR. MILHOLLIN: John, has this discussion helped you Id any? !
1 IS MR. FRYE: Well, I think we've certainly focused 16 really on the uncertainties. , '
r 17 MR. SEGE: Mr. Chairman, I'd like to return to the 18 issue of whether a six-month additional delay can be important >
l l9 when the period is already so long that utilities feel highly I l
i 20 uncertain about their ability to forecast -- if a utility is 21 so uncertain about its forecasting abilities 12 years ahead, !
22
({ that they say that they cannot estimate how much greater the l 1
23 I likelihood of error will be if-six additional months were ;
24 added to the period, that doesn't mean that that six months !
i
( ) ewe moorws. 25 w.
does not increase the likelihood of error.
52 m'to 8 **
1 MR. MILHOLLIN: I'm not suggesting that.
2 MR. SEGE: Intuition would say that the likelihood 1
3 of error would increase even though, because of the substantial !
'I 1
4 I likelihood of error in both cases, they are not able to
~
5 , estimate what that likelihood would be.
6 MR. MILHOLLIN: Okay. I would agree with that. I'm
. 7 just pus ~tng around my unproofed summary of interviews with I
B members of the Atomic Safety and Licensing Board Panel. I 9 MR. QUAY: Unless I'm wrong, there are only like i I
10 five copies.
Il MR. MILHOLLIN: Are there only five copies? I'm 12 sorry, I didn't count them before I passed them out.
13 MR. QUAY: Do you want me to see that all the others 14 get it?
15 MR. MILHOLLIN: Yes. Would you just take it?
16 MR. QUAY: I can do that right now.
I 17 MR. MILHOLLIN: I can't proof this, j 18 MR. CHO: On the subject of interviews, Mr. Chairman, i
19 I don't recall receiving copies of the interviews of I j
20 Commissioner Gilinsky.
- 21 MR. MILHOLLIN: Okay. I was going to come to that.
- (> 22 MR. KARMAN: I have not seen that.
l 23 MR. MILHOLLIN: Wait'll Steve comes back. Steve 2d was in charge of passing this out.
( }ews muoners, ine.
25 '
Steve tells me over the phone that we now have .
I I
p
, 53 mto 9 1
received back from all Commissioners except Kennedy their 2
So they have been to the Commissioners, interview notes.
3 were revised, and have come back and are available and should I o f'
% 4 be distributed. I don't know when. They will be this after- l l
5 noon.
6 MR. SEGE: There's still one question on one possible 7 correction on Commissioner Kennedy's interview. That is still l 8 in limbo. l 9 MR. MILHOLLIN: I haven't seen Commissioner Kennedy's l 10 note.
Il MR. SEGE: I have it.
12 But there is still one question -- I don't mean 13 Commissioner Kennedy; Commissioner Gilinsky.
14 MR. MILHOLLIN: Not Commissioner Kennedy, but 15 Commissioner Gilinsky.
16 MR. SEGE: I'm talking about the possible correction 17 is in Commissioner Gilinsky's, and he wanted to think some I
l 18 more about the phrasing of a particular statement. There may l
l 19 be a further correction. So that has not been distributed.
[
20 It will be held until W hear from Commissioner Gilinsky on 21 that statement.
22 MR. MILHOLLIN: Have we received Commissioner
!( {
c .
l 23 Kennedy's written responses?
24 MR. SEGE:
i I have not.
kww m oonws, Inc.
l ,
25 MR. MILHOLLIN: Okay. So we have at least almost '
i s
.mte 10 54
1 final word from all Commissioners except Kennedy. And as soon l
O 2 as Steve comes back, I'll ask him to distribute those. I 3 thought they had been distributed.
if'
% 4 MR. QUAY: Do you want to take a short break.
5 MR. CHO: I have received the interview reports 6 from Chairman Hendrie, Bradford, and --
7 MR. SEGE: And those of Commissioner Ahearne.
8 MR. CHO: Ahearne, yes.
9 MR. MILHOLLIN: So the only one that you haven't 10 received is Gilinsky.
Il MR. CHO: The two that we just discussed, Kennedy 12 and Gilinsky.
13 MR. MILHOLLIN: Okay. I misunderstood. Good. I 14 haven't received them yet.
15 Shall we just continue to go around the table.
16 John, do you know where Steve is?
17 MR. FRYE: No, I don't. He apparently had some 18 correction to be made in something he had. j 19 I MR. MILHOLLIN: John, do you have anything else that
~
I 20 you'd like to talk about?
21 MR. KARMAN: May I interrupt for a moment? I seem
- (. 22 to have only Bradford's interview. i l
23 MR. QUAY: I saw the Ahearne interview. I know that l
i-l 24 was distributed. !
m wer necon m ,Inc.
I 25 MR. CHO: And Chairman Hendrie's. #
l*
l
l
.y , 55 mto 11 i l
1 DR. NASE: And Bradford.
! ..O l 2 MR. MILHOLLIN: Well, Myron, if after checking you 3 still don't have it, call Steve.
4 MR. QUAY: I think I know what the difficulty is.
5 I.think those were passed out at the last meeting or something, 6 maybe the meeting that you weren't here.
7 MR. BERSON: I would presume that. I gather -- I 8 don't recall seeing thocs, either.
l 9 )R. MILHOLLIN: Okay. Why don't you call Steve.
10 MR. QUAY: And I might mention this, Gary: I'll see 11 that Carl Neal gets the packet of material distributed today.
12 I think we've been doing that consistently.
13 MR. MILHOLLIN: All right, yes. That's a good point.
14 So you'll take responsibilities to see that Carl gets it.,
15 MR. QUAY: Yes, to see that. Carl gets this packet.
16 MR. MILHOLLIN: Okay. John, are you finished?
17 MR. FRYE: I'd just like to give you my thoughts in i
18 light of the discussion we've just had, on where to go with l
19 dealing with Option 2.
If anybody has any different ideas, j 20 certainly I'm open to them. But it would seem to me that ,
i 21 perhaps to keep the same sort of approach I started with, to .
( 22 point out that there is great uncertainty in any attempts to i I
23 relate delays at the start of construction to delay in the l
24 start of commercial operations; and simply to try to perhaps i
- l. Os. eemi meoon.n. inc. l l 25 point out -- and whether this would be a problem -- there are
, , 56 mts 12 1 lots of factors which we don't have any particular ability to
() 2 forseast or foresee at this point.
I 3 MR. CHO: Excuse me, John. On that point, though,
[
4 I think it would be worthwhile mentioning some of these 5 factors that we have discussed.
6 MR. FRYE: Oh, yes, right. I fully agree with that,
, j 7 MR. QUAY: Especially the appeal board treatment.
8 MR. FRYE: Basically, to catalogue the advantages 9 and disadvantages and to try, to the extent that we can, which 10 I think would be very limited, to point out any statistical 11 trends that we can from past cases, and try to come up with 12 some sort of prediction based on our interview with
() 13 Al Rosenthal of how long we could reasonably anticipate that 14 effectiveness would be deferred under each of the various 15 sub-options.
10 MR. MILHOLLIN: How long would it take the appeal 17 board to do the various things which are mentioned?
18 John, I assume that you're going to make some 19 kind of a rough prediction about how many dollars it would 20 cost per month of delay based on the CBO thing.
~
21 MR. FRYE: I don't know any other figure to use 22 than the CBO figure.
(
23 MR. QUAY: That depends on the section of the country and a whole mess of factors.
O .'24 23 MR. MILHOLLIN: We might also indicate what u
. - , . - - . . - - . . . - - - - - - - - - - - - - - ~ ~ ^ ^ ~ --
"T L
57 l
? Nto-15 l i
i 1 assumptions are included in that figure.
2 MR. FRYE: I would think the place to put that would 3 be in Section 2, where that sort of' thing is discussed, and (7'
4 4 we can pull it out at various places where we refer back to 5 the discussions.
-6 MR. MILHOLLIN: Yes, because there are so many 7 assumptions in that number that it's very unreliable and.
8 probably < .ite a bit too low, given the developments of the i
~
9 last coupl years. Of course, it's conceivable that the 10 bottom could fall out of the oil market and then the number 11 will be too high.
12 (Laughter.)
(J 13 MR. QUAY: And the lights would go out.
14 MR. MILHOLLIN: Or the interest rate.could suddenly 15 fall to four percent per year.
- 16 MR. FRYE: They made assumptions of what, an interest 1-7 rate of 10 percent and the inflation rate of 7 percent. And 18 they also assumed that crude oil would reach the price of 19 what, roughly $28,-roughly, by 1980. And I'm not sure, but 20 it's pretty close to that right now.
21 MR. MILHOLLIN:. Those were the good old days, back 22 two years ago.
l 23 MR. FRYE: That's all I have.
i
! 24 MR. MILHOLLIN: Go ahead, Daryl.
().eannnewan.In i 23 DR. NASH: Myron mentioned the three items that I
.v _. _ - , - -
.
- 58 mta 14 I worked on during the last meeting. One was the 3.7 accelerated A
kJ 2 treatment of issues, a draft of that. Then the drafts of the ,
1 3 cases, Palo Verde and WPPSS 3 and 5.
(f -
4 I might mention, with regard to these two case 1
5 studies, I put in information which I couldn't find directly l 6 in my responses from the applicants, which was the cost of
~ 1 7 replacement power, assuming that the plant was needed at the a time it was stated to be needed, when the decision was made. l 9 So that appears in these two case write-ups, which brings up 10 the point, I think, that we need to, in our work from here 11 on, be sure that we're consistent in our treatment of cost 12 estimates or other issues, so that the case write-up doesn't
( 13 depend on who happened to write it up. But it should be done 14 consistently across the cases.
15 I take it that the questions that were sent out to 16 the applicants, that asked them directly what would be the 17 cost of replacement power, so therefore at least the two that 18 I had, they didn't include that.
19 MR. MILHOLLIN: I was going to ask you whether, in 20 your writeup, you tried to evaluate the applicant's figures.
21 I take it that in some cases there weren't any figures. Did 22 you just use the applicant's figures where the applicant gave 23 you figures?
7.
24 DR. NASH: In the one ca s e , Palo Verde, they supplied
[ Q oere noso,wri, inc.
25 a cost per kilowatt-hour, but the figure didn't make any l l
l'
., , 59 mts 15 I
sense from any information I had, from the assumptions they
.O 2 appeared to derive that. So I used some other sources to 3 derive that.
.n 4 4 In the case of WPPSS, they didn't supply any figures.
, 6- 4 5 So again I used other sources.
l l 6 l
7 l 8 9
10 l 11 12 i
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14 15 l 16 l
17 18 19 20 21
( 22 l 23 i
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- bwerei menerwes. inc. ,
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t l
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>a40 05 0'l 60 l mgcDAV 1 atner than that, the processes which appear in 2 there, there is no real evaluation done.
({} We're taking 3 essentially figures as the applicants supplied them.
l 4 I might mention with regard to the problem that
(( x l
o John Frye just brought up, we're hoping during the month of
$ Octooer to complete a study looking at the impact of e different schedules in. bringing on a nuclear power plant.
3 :
.or example, we're looking at various options in terms of
) what would ce there makeup, whether it would be low cost 10 coal, high cost coal, oil, and then looking at diff erent 11 growth scenarios, and assuming they made a decision casec on 12 one set of circumstances anc then looking at what the costs 13 would be if tho,se circumstances cic not come to pass -- say, la a higher growth rate or a lower growth rate. This may os of
() 13 some value, and it has -- as was mentioned, the CSD study, 15 there's no way to avoid making a suostantial number of -
1e assumptions when you do a study of this kind. You nave 13 troucle reaching general conclusions, I think, cecause it's 19 very tightly controlled oy the set of assumptions that JD you're making. You're forced into a large number of 21 assumptions. '
22 . .R . FRY 3: I will certainly take all the nelp I 23 :an get.
!* 24 :.G . MILHOLLIN: That's a gooc point. Anytning
([ 23 else, Darrel?
9 4
I s 1 840 05 02 61 '
mgcDAV I DR. NASH: No. 1
() 2 MR. MILHOLLIN: Bill?
3 MR. LOVELACE: Mell, I've been mostly working with 4
j{~ John on Option 2. Me passed out tne delays during a construction of the 13 intensive study cases which we're
. 6 including. !
4 MR. MILHOLLIN: Excuse me. Is that a separate 3 document, Bi ll ? I'm looking through my stuff here.
9 MR. LOVELACE: Yes. It's entitleo " Delays 13 Suosecuent to Construction." i 11 MR. MILHOLLIN: Can we write your name on the top 12 and a date tnen? It would os 9/28/79. You managed to get 13 through the 19 cases.
14 MR. LOVELACE: The 13 cases.
l
-)
f ..
s_ 15 MR. MILHOLLIN: The 13 cas es. An3 these are 15 celeys subsequent to construction authorization?
17 MR. LOVELACE: Right. In other words, it's delays 13 that occurred either ef ter LWA or CP issuance.
11 'u.
MILHOLLIN: Are these delays in construction 23 or un til co1struction oegins.
21 MR. LOVELACE: In construction.
2a YR. OSTRACH: On that chart , why did you list 23 3eacrook, for example, at the very top? A delay cefore 24 issuance of the C??
If 26 MR. LOVELACE: That's a good question. I con't l
m 4
t e 840 05 03 62
- mgcDAV I know. On page one --
() 2 MR. MILHOLLIN: This is on page two, you're 3 talking about, Steve?
q7 4 MR. OSTRACH: Yes.
. s 3 MR. LOVELACE: They should not be there. The
. 6 asterisk on Harris and Midland, I started out using some of 4 the responses in the letter. They didn't Jibe with the
~
S' information that I had.
j 9 MR. MILHOLLIN: So how should we consider it now 10 in its final form, Bill?
i 4
11 MR. LOVELACE: Well strike out the asterisk delay i
12 in Midland, the asterisk delay in Harris, and the asterisk l
13 aela/ in Seacrook. l 14 MR. MILHOLLIN: You mean just strike out the ,
s l s2 15 asterisk?
13 1R. LOVELACE: No, strike out the item.
Il MR. MILHOLLIN: So we strike out the numoer of 13 curation of delays as well?
Iv 11. NASH: Then I guess tne total aown here would 23 change?
21 MR. LOVELACE: Yes, the tot als on the bottom would 22 change.
23 43. MILHOLLIN: O'< a y .
24 M7. LOVELACE: Midland will ce 24 months. 12 4 25 montas on ell the Harris units.
c BMi ---
63 iB40 05 04 -
l mgc0AV i MR. MILHOLLIN: Seaorook, I would subtract 187 l l
l n(_/ 2 MR. LOVELACE: Right. Now, I'm assuming that in :
! 3 our discussion you want me to do this for considersoly more l
4 cases, characterize the delays and the amounts of delays.
[{^ -
I 5 MR. MILHOLLIN: According to our discussion, we l l
6 were thinking perhaps it would be useful to know -- I guess
']
, we snould go back a step. The CB0 figures that we started 3 witn simply expressed delay as a percentage of total delay 9 in all the plants. CB0 took the total months of delays 10 during construction for X number of reactors, added up tne i
11 montns, and then they took the number of months caused oy l 12 certain types of celays and categories, added up those 13 montns, divided and got a percentage. The cifficulty with 14 those figures is we don't know now many plants were affected 15 by each category of delay.
l$ You could nave had three plants which had very le long delays for some reason, and that would cause tnat type 13 of delay to be a large percentage of the total delay. But li it may only have a ff ected one or two plants.
23 So we were talking aoout this in connection with 21 the e ffort to predict whether a deferral of construction 22 woul; ado on to very many plants in getting the data for 23 :aamercial operation. If we concluce tnat tais is a very 24 speculative thing anyway, mayce it's not worth it to go 25 through the cases to see in which cases what kind of delay k_
, em
( - p e
64
'.840 05 05 mgcDAV i occurred, for example, to see in how many cases there were
(} 2 cemand delays.
3 dnat do you all think aoout that? Do you
'r 4 understand the proolem?
4 5 MR. CHO We'll be talking about delays in t .
6 construction.
< MR. MILHOLLIN: Yes, delays in construction. So
- S even on that point, I suspect to be meaningful, to craw
> anything meaningful from any particular delay, you'd have to 10 know what.that delay entailed.
11 MR. KARMAN Are you restricting it only to demano 12 delays or other delays?
13 MR. LOVELACE: All delays.
14 MR . CHO For example, in Bailly, there was a ex
! (,J . 15 delay in dewatering activities, but not in construction, so l
16 I think it would oe misleading to say that there is a delay 1e of so many months, cecause nat delay may not have nad a IS r3al impact on the construction schedule because it was only 19 on one aspect of the problem.
l 23 MR. MILHOLLIN: I guess wnat I was concerned 21 aoout, for example, was knowing in how many cases 22 nistcrically a def erral of ceginning construction would not 23 have affected the beginning of commercial operation. To do 24 that, you heve to 90 through all the cases and see what the I 25 delays were and see whether in those cases those celays 1
O
. . - . . --- . . . . _ . - - ~ . - . - - . . . . . . . - . - . . - . - .-- ---.
l 1 s
.840 05 06 65 mgcDAV 1 would have meant that a deferral on beginning construction r')
(_/ 2 would not have made any diff erence. Now that's a ver.y 3 ambitious e ffort, and it may not be . worth it.
4 MR. CHO: I'm sugge sting that unless you actually 4'(-
5 go through the whole thing, the information you get may not
. 6 be reliaole enough to draw conclusions from.
4 MR. MILHOLLIN: That's right.
3 MR. FRYE To give you a little background, when I
/ originally wrote out the 324, I included the chart which 13 said in the following cases, the . f ollowing celays occ urred 11 in construction. Then I put in a paragraph that said in so 12 many of these cases the. Committee f eels that the delay in 13 construction would not have -- or I don't know how to put I -; - this, because it gets a little complex -- but the delay in 16 the authorization at the beginning of construction would 16 nave had no eff ect on the date of commercial operation 11 oecause this delay was encountered in the course of 13 construction. ,
19 In so many other cases, we couldn't make any 2- c onne c tion, and in so many cases, the delay that occurrec in 21 construction would have added to any delay that was put in 22 the front of the process.
23 And I think what Gary is trying to say now is, is 24 that d wortnwhile exercise? My own conclusio'n that I came 4 25 to when I went back over it is that, no, it's not.
- CE) ,
l i
.. e i840 05 07 66 mgcDAV i MR. MILHOLLIN: Ex cuse me, John?
() 2 MR. FRYE It's not a worthwhile exercise.
3 VR. MILHOLLIN: It's not worth the effort to find 4 out?
{"
5 MR. FRYE It's not worth the effort. I don't
, 6 think we could really come up with anything.
7 MR. OSTRACH: I must say I agree. It seems to me
~
5 that your assumption is somewhat artificial because if you 9 make one change in historical f act -- was there a six month 10 delay af ter a licensing boarc decision -- why don't you make 11 the other assumption which was that the planners would nave 12 known aoout that and would have, as we said oefore, applied 13 f or their license six months earlier. They still would have 14 ceen aiming at the same time. If they had know there was
( ).. 15 going to be a six month delay, they would presumably have 16 arranged to have gotten their licensing ocard decision six Ia months earlier than they did, so they woulc have started 19 construction when they hoped to. Whereupon, they would nave 19 gone a year down the roso, run into the same surprise -- I i
2] mean the target date in the ALA3 is the day they could start l
21 their bulldozers running. l 22 If they know that six months af ter the licensing 23 boaro decision, taey'll start the process six months earlier 24 and try to nit that same date. If they nit that same date, 23 tnen a year later wnen the cottom fell out of their demand, l
4 o
t r 5840 05 08 l mgcDAV I they still would have had to suspend construction.
2 I must say that it seems to me that we're going to 3 find that delaying e f f ectivene ss, at least a predictable
(
i f/~ 4 delay of eff ectiveness, won't really change the date a plant w.
5 can come into operation. It should be, as the responses 6 have indicated, just changed planning to either deter people e from going nuclear, or if they go nuclear, just have them j l
3 submit tneir applications six months or a year earlier. !
/ Tneir target dates are wnen they can start 13 construction, when they meet operation, and you know, !
I 11 they'll just build the amount of time necessary to romp over !
12 those things at the front end. !
13 MR. MILHOLLIN: I take it, then, for a series of i
_ 14 diff e rent reaso.ns, we've kind of concluded that it wouldn't St 15 oe worth the effort. l 16 MR. LOVELACES Good. I conclude that, too.
1/ MR. MILHOLLIN: I'm sure that Bill won't put up 13 any opposition.
IV MR. QUAY: Really, I concur in tha t, too. I. con't 2] know what we'd get from this past history if things change 21 in the present and future.
~
22 MR. MILMOLLIN: Ogay. Gre a t. All right.
4 23 Tnat one was resolved f avorably, wasn't Bill?
24 (Laughter.)
I 25 MR. LOVELACE: Yes.
l
[ ,
i I
.. -- .. - _ . ~ . - - . . -_- - _- .- . _ - . _ - -. _.- - -
I
, l 68 840 05 09 mgcDAV i MR. FRYE On a related point, let me bounce this 2 off of you, which I think I referred to earlier. If you can 1
3 say that in so many cases, the utility did not begin (f~ 4 construction until so many months af ter receiving NRC 3 authorization to oegin, we could draw some statistical
- 6 information. Utilities have in the past deferred their 7 ceginning of construction for so many months, af ter being 3 authorizad to go ahead by NRC. Do you think that would be 9 worthwhile?
10 MR. LOVELACE: That's the next paper, but it f alls l
Il right in line. I don't know what Gary had in mind. I 12 MR. QUAY: Is this the same sort of discussion, I l
13 think, for the last one? There are unforeseen factors. I 14 MR. MILHOLLIN: Excuse me, Ted. Let's identify
\t/ 15 this one for purposes of discussion. It's a study of 15 elapsed time for construction authorization to start work, 1/ so it would be a -- -
13 MR. LOVELACE: 9/28/79.
11 VR. QUAY: Let me ask this. Is there any way you 23 can discriminate this type of delay from change in load 21 f orecasts and other perturbing f actors that are unforeseen 22 at the time they forecastec them?
23 MR. ? RYE I thin'< it focuses on something that 24 may be a little easier to understand, in that we know tnat
([. 23 in many instances now, the utility may oe held up because l
l a
~ _
l
- e 840 05 10 69 l
l mgcDAV i of some other regulatory proc eeding, something of that i O)
(_ 2 nature now. If we found that in general utilities were 3 being held up six months af ter NRC authorizes their
(,7 4 construction to go ahead, I think --
s 5 MR. QUAY: Okay. You're saying because of other
. 5 proceedings.
1 MR. FRYE Because of other proceedings.
~
8 MR. QUAY: If we can definitively separate that
> type of information out, it might be useful.
10 MR. FRYE In other words, why should we keep our 11 immeciate ef f ectiveness rule , if in fact it doesn't make any 12 difference?
13 MR. QUAY: Several public comments pointed that 14 out, John, and they can't see us making our decision O
N1 15 immediately eff ective when the other permits that are being 16 sought that still haven't been issued.
17 MR. FRYE: of course, to the extent that the 13 utility is delayed oy some other f actor other than NRC, it's 19 as if the immediate effectiveness rule didn't exist anywey.
20 MR. MILHOLLIN: I have a comment on this 21 s uc je ct . I interviewed Saul Burstein last week. He said 22 that he thought there was going to De, that in the state 23 utility commisions there was a move on now to discourage --
24 MR. KARMAN: You might indicate to some of the
(, 25 memoers wno Saul 5urstein is.
8 -
1 iS40 05 11 70 m cDAV i MR. MILHOLLIN: He's a Vice president at Wisconsin A- 2 Electric Power Company. He said, while in (disconsin it's 3 clear the State Public Service Commission is discouraging
,1r ' 4 utilities from making any kind of expenditures bef ore they s
6 get all their permits, utilities, from what he told me, are l l
6 going to give in and go along with that. l 4 Now one of the things he told me was that before 3 the utility can oegin construction on a site , they need l 9 construction drawings and they need to do a certain amount 10 of engineering work to plan how the construction's going to 11 happan. And if they adopt the policy of not making any 1
12 financial expenses for that until they get their permit, l 1
13 what's going to happen is that they're not going to be able 14 to start work right after the CP is issued, because they 15 won't have the engineering done which will ce necessary to I 15 do the construction, because they won't take the risk of 1/ paying for that engineering cefore they get the CP.
13 MR. QUAY: I don't know how the hell they're goin; 19 to get their CP without engineering.
23 MR. OSTRACH: They can't get their CP without that 21 engin ee ring.
22 MR. MILHOLLIN: I'm talking aoout 23 construction engineering.
24 MR. QUAY: There's also design engineering.
(_ 25 MR. MILHOLLIN: I'm not talking aoout the design O ,
k
s s liS40 05 12 71 mgcDAV i of the plant. I'm talking about the engineering which is 7
e 2 necessary to figure out where the hole is going to os dug 3 and how you're going to dig it, what equipment you're going 4 to use.
ff~
w 5 MR. QUAY: I don't see how you can do that without 6 coing design work. I don't see how they can separate ths s two. !
8 MR . MILHOLL .N Maybe I was misinf ormed as to l
9 that. You mean that information is necessary for the Cp?
10 MR. QUAY: Yeah. l I
11 MR. OSTRACH: A lot of money has to be spent in '
12 very detailed engineering dasign work to get a CP. J l
13 MR . MILHOLLIN: Yes, I realize that. !
MR. OSTRACH: And if the state is serious about !
()
14 15 restricting expenditures prior to permits, there will be no
'($_.. )
l$ permits. Ine NRC -- to get a OP from the NRO, you have to 1/ have spent an awful lot of money.
IS MR. MILHOLLIN: At least in Wisconsin the theory 19 is tnat the expenses- should oe limited to tne expenses which 23 are necessary to get permits.
21 MR. QUAY: Okay.
24 MR. MILHOLL Ii4: Se yond the expenses necessary to l i
23 get oermits, we're not going to let you spend anything.
24 MR. QUAY: Construction sequence and things of i
25 that type.
[.
l
() ,
t -
840 05 13 72 mgc0AV i MR. MILHOLLIN: There are expenses for engineering 2 that have to ce gotten before construction begins which are 3 not necessary to get the CP. ,
'/ ' 4 MR. KARMAN: What you're saying is, in effect, is u
6 once they get the CP, cefore the state will issue their 6 permit, additional expenses will have to be spent.
/ MR . MILHOLLIN: The information he gave me -- and 5 pernaps this is not correct --
9 MR. KARMAN: There's a cart with a horse missing IJ somewhere.
11 MR. MILHOLLIN: Tae information he gave me was 12 that they're not now going to commit the money necessary to 13 do engineering construction, which they'd have to have to 14 cegin construction, cefore they get the permit, so there's
(}y, k_ 15 going to be a necessary period of gap af ter the CP, else 16 the/'re not going to be able to do anything oecause they ll won't commit that money until they get the CP because of the 13 pressure on them oy the state.
1/ MR. QUAY: Then they don't get tneir construction 2] contract and they don't mobilize prior to pursuing the C? ?
21 MR. FRYE They don't buy the reactor components.
22 MR. MILHOLLIN: Apparently that's also true. But 23 f or o ur purposes, I guess, the most relevant thing is how 24 much they're going to spend getting ready to construct, and 20 apparently that's going to oe limited by the pressure from (b.
O ,
73
-840 05 14 l mgcDAV I the s tates. This may be true in other jurisdictions as
() 2 well.
3 MR. OSTRACH: Did he carry the analysis one ste p l
- 4 further and say what hs thought his view of the ultimate 4
5 effec t of tne state policy is? Just naively, it strikes me
. 6 tnat the upshot of this approach is penny-wise and e pound-f oolish.
3 MR. MILHOLLIN: It's possicle.
9 MR. OSTRACH: But he didn't say that?
10- MR. MILHOLLIN: We didn't get to that point. de 11 onl/ had an hour interview, and I was trying to limit it to 12 things whien were necessary for us. But the impre ssion I 13 got was that they were going to be slowed down in oeginning 14 construccion because of these restraints.
n k.4d 15 MR. OSTRACH: Is that just nuclear, by the way.
16 MR. MILHOLLIN: It sounds like across the coard.
/ 1, Oh, sure, the state doesn't segregate nuclear. They're E 13 concerned aoout expenses for any kind of utility.
19 MR. QUAY: You're going to be importing a lot of 23 energy.
21 DR. NASH: They're hoping Illinois doesn't do the 22 s ame thing.
23 MR. MILHOLLIN: So for wnst tnat's worth then, 24 that variaole will add to the confusion.
25
, ([ .
I CE) -
l l .
l l 1 s 1
l 840.06.1 74 DH gsh i Bill, I'm sorry. I kind of broke in on your
() 2 discussion nere. . Bill, I had a question about this oefore 3 we go on. You have 17 cases here. You looked at a total (7- 4 of 40 cases.
n l 6 MR. LOVELACE: I looked at everything that receivec l ,
6 a CP or LWA f rom 1974 through January of 1979.
e MR. MILHOLLIN: O ka y .
i .
l 3 MR. OSTRACH: Bill, I have a question about the 9 charti in pa rticular, about Surry, North Anna 3 and 4, and l 10 Limerick.
1 11 I notice on the chart that you have site work for i 12 Limerick starting 11 months oefore they got their CP, anc 13 for dortn Anna 3 and 4 ceginning two years cefore they got l
14 their CP. And neitner one did they get an LWA. l
)
-4 16 Could you tell me how are they working on the site?
16 What authority did they have?
Ie MR. LOVELACE: I assume tnat they are the older l 13 generation. Well, I know tnat they're the older generation.
1/ MR. KARMAN: Procaoly exemptions. l 23 MR. OSTRACH: >73, we were allowing this?
21 MR. KARMAN: '73 we were issuing exemptions. I think
~
22 the last one we issued was possibly Syron and Breidwood ana 23 Harris back in '74 24 MR. LOVELACE: Harris, I believe, was the last.
26 MR. KARMAN: Just aoout tnat time, and tnen the LMA l
(}
1
1 e iS40.06.2 75 uH. gsh I. matters came into eff ect.
/"g
(_/ 2 MR. QUAY . Were these exemptions precursors of the 3 LWA, or very much similar to them?
er 4 MR. KARMAN The basic idea was the same.
%l j p MR. LOVELACE: But Limerick was actually started, 6 I think, well, they started and then they stopped about two
/ years and tnen they restarted again in '73.
l 3 MR. OSTRACH: So it would nave been started before i 9 you had the site work started here.
10 DR. NASH: You might say that there is some 11 presumption that a license will be issued.
12 MR. OSTRACH: I notice that you have Bailly and NS l 13 on site work started. l 14 MR. LOVELACE: To my knowledge, they're not doing
\y_ 15 any extensive site work. It's strictly drilling.
15 MR. OSTRACH: So you would s ay, in othe r words, that 1s Bailly coulo be viewed as a case where there's oeen five la years ?
19 MR. LOVELAC ' Essentially going on other than 20 testing the soil.
21 MR. MILHOLLIN: NS means --
- l 24 MR. LOV ELAC E: Not Schedulsd. !
23 MR. CHO: How aoout excavation wor,:7 Do you consider l
24 that to be 6ct construction?
( 23 MR. LOVELACE: Yeah. Sailly hasn't done any extensive l 1
d ,
s e 840.06.3 76 DH gsh I excavation.
() 2 MR. FRYE They had excavated down to the water 3 table.
,{ - 4 MR . CHO: That was the issue of dewatering, at least 6 af ter the issuance of a construction permit.
. 6 MR. LOVELACE: I blew that they kept on driving
/ pilas, out I didn't know that they had done any ext 3ns.es 8 exc av ation.
9 MR. QUAY: You mean that they were putting in long 10 pilings when they assumed that they were going to be short, il right?
12 MR. MILHOLLIN: So this one's sort of uncertain.
13 Bailly? '
14 VR. LOVELACE: Bailly, p 15 MR. KARMAN: We might have an update on this chart.
(,L 16 I know that Tyrone has been cancelled.
17 MR. LOVELACE: Of ficially?
19 MR. KARM AN: Yes.
19 MR. MILHOLLIN: Yes , that one's dear 20 MR. LOVELACE: Just put an asterisk oy it.
21 MR. KARMAN: Right.
~
22 MR. QUAY: Elapsed ties will go to infinity. !
23 MR. OSTRACHi Are Nortn Anna 3 and 4 still alive?
24 MR. LOVELACE: Just not seneduled, but they're
( 26 still alive.
, -s
~
t e i840.06.4 77 DH gsh 1 MR. OSTRACH: Are they constructing them?
() 2 MR. LOVELACE: No. They're about 3 or 4 percent 3 complete, respectively, whatever that means.
4 MR. MILHOLLIN: Bill, do you have any other things? !
5 MR. LOVELACE: I might add that this might raise
, 6 some questions. One might ask now why some start immediately i and why the other ones were delayed six months or greater, 8 nine months or greater before they started.
9 MR. MILHOLLIN: Why don't we give Bill our comments 10 on this sin:e a lot of us seem to know about particular l l
plants. If we see something in here which doesn't accord 12 with our own particular knowledge --
13 MR. OSTRACH: Some of the comments, they'd be 14 explanations. Like the reason that Sterling hasn't started O
% ,/ 15 is cecause they don't have a permit from the State of New is York. '
1 il MR. LOVELACE: That's what I say. A lot of these . I IS I guess deserve explanations which I didn't get into. I got 19 most of the information, but I didn't know exactly what you 20 wanted with it.
21 MR. MILHOLLIN: Okay.
22 1R. S EGE: Nould there be merit in adding an 23 additional :olumn for comments where special remarks of the 24 sort that nave been orought up in the last f ew minutes coula I
'( . 23 De no ted?
I
__ _ _. _ _ - . _ _ _ _ ~ . _ _ _ _ . . . - - . _ . - __ _ _
t -
>840.06.5 78 DH gsh 1 MR. LOVELACE: Sure.
() 2 MR. QUAY: Causes like state certification.
3 MR. MILHOLLIN: That might ce good just to put another r/- 4 column in tnere, columns.
(1 5 MR. QUAY: Just terse comments, load projection --
I
. 6 MR. OSTRACH: State permits. load projections,
, financial constraints.
S MR. MILHOLLIN: John, do you think that that would
/ be helpful to you to have an extra coJ umn?
13 MR. FRYE Yes, I think it would be very helpful.
11 MR. MILHOLLIN: You can plug this into your 12 discussion then, right?
13 MR. FRYE Right.
14 MR. MILHOLLIN: Okay, s,) is MR. OSTRACH: I think that's a very useful chart, j 15 cy the way. !
Ie '/A. MILHOLLIN Yes, I agree.
13 MR. LOVELACE: Then the other thing that I've oeen
- 1) working on is the financisi aspects that go into Section 2, 23 the dollars, percentage of total. cost and so on.
21 You look at that stuff and you're talking apples and 22 oranges, at least in my opinion.
23 . Mow the responses that we got, the applicant 24 responses, some of them you know what's included in the 1 22 dolla rs, some of them you con't know what's included, c
l t .
s >
'i840.06.6 79 DH gsh I 'G. MILHOLLIN: Dollars for what, Bill?
O (l' 2 MR. LOVELACE: What we spend.
3 MR. MILHOLLIN: I see.
4 MR. QUAY: Some of them tell you, a lot of them don't.
f"..
k 5 MR. MILHOLLIN: You're speaking now about the effort 6 of breaking it out according to site specific.
7 MR. LOVELACE: Plus the fact that you don't know 3 what's included in the dollars. Site specific will say 9 what's includedt others will exclude things.
10 MR. MILHOLLIN: Are you going to be able to?
l 11 MR. LOVELACE: I wanted to discuss this with John 12 anc prooably maybe you today.
13 MR. MILHOLLIN: tie can discuss it together.
14 MR. CH3: It seemec that in our report, some whe re
\$ 15 prominently we ought to put the caveat in that wherever we l
i 16 rely on these figures, we can point that out if they came j 14 from the applicant. And we can explain it more to the effect l
13 that if we have not independently analyzed it, we should 19 also say thet.
23 I think the report on its f ace ought to make clear 21 the casis for our various information and as s umptions .
22 M2. SEGE: And also that dif f erent applicants' bases 23 may differ f rom each other. Ana sometimes the casis has not 24 ceen completely defined.
'[ 23 M2. MILHOLLIN: Bill and I were talking earlier about n
(_/ ,
- - . . . . . . - - . . . - - . - - _ . - . - . - . . - . ~ . -- .. . . . , . . _ __ _ - _.
i e
>S40.06.7 90
' DH gsh I the difficulty of trying .tx) assign percentages to site A
(_)' 2 specific information or make some sense out of the numbers.
3 Maybe the three of us could get together and work on that.
r' . 4 Ma. QUAY: Just some general wording maybe to start
%L 3 out that particular section. Case studies.
$ I think it's true in all cases.
7 MR. LOV ELACE: Do you have the proolem, too, do you 3 inflate the dollars that they actually start out to today's 9 dollars before you take the percent?
i 10 MR. MILHPLLIN: That's another difficulty. It's ;
l 11 hard to compare the dollars over diff erent periods of time )
12 because they're different dollars.
13 MR. QUAY: Some of them have done that, some of them 14 haven't. Some of them are today's costs, some yesterday's.
15 MR. MILHOLLIN: If you're talking aoout percentage 15 of tne total cost of the plant, then it depends on when that il date will be because of inflation. j 13 It's just very difficult to know what you're talking 19 a oout at all.
23 Some of tne plants have doubled in their estimatec 21 total projec t cost.
~
22 So that halves the percentage of expenditures, for 23 examcle.
24 '4R. LOVELACE: I know one nat's increassa 273 25 percent.
e
i e 5840.06.8 81 i i
DH gsh 1 MR. MILHOLLIN: Is that at Midland? I
(_f >
MR. LOVELACE: No. !
3 MR. QUAY: That's infinity. i MR. MILHOLLIN: Okay.
} 4 So you've been working on tne l 5 effort to break out some of the stuff for site specific oill?
., 6 MR. LOVELACE: Yes. i 1
, MR. MILHOLLIN: Okay. !
8 MR. LOVELACE: Until I got to the point I didn't 9 know where to go, so I quit. And this was yesterday. 1 l
10 And that's about it. l 11 VR. MILH9LLIN: Okay. thank you. red?
12 MR. QUAY: Okay. George -- an administrative l
13 aspect George nas checked with Kre ss. They indicated that I 1
14 thef w. '.c nave little di fficulty with us. But the contact 15 has been made with Kre ss. But the contact has been made, i
16 so he shoulan't hang his head as low as he wanted to.
1/ MR. SE35: I might add to that thing that the largest i 13 of the Kress units, which is in the Philips Building, has been 19 designated cs the place where the principal work of this 20 commi ttee wi ll os done .
.(R. OSTRACH: iio , George.
21 Where the principal
~
22 typing will oe done, i
23 ( *. aught e r. )
24 MR. SEGE: I stand correctea, Mr. Cnairman. But the
( 25 supervisor of Kress Typing 5ervice also offered that if there l
e
i e
>840.06.9 82 DH gsh i should os extensive craf t typing help that committee members D
kI 2 need and there is a satellite Kress service in that old 3- builoing, they would be welcome to use that service.
r 4 MR. OSTRACH: Where are cheir satellites Kre ss? Is (L-5 there one down at H Street?
6 MR. SEGE: No. I think that's the only place where e there isn't.
9 3 MR. QUAY: Nicholson Lane, mayce.
9 MR. SEGE: In the oank building.
10 MR. KARMAN: We've never utilized it, to my 11 knowledge , so I really don't know.
12 MR. MILHOLLIN: Ted, do you have anything else?
13 MR. QUAY: Yes, a couple of the plants -- I don't l
- 14 s ee much prospect in ge tting Sailly. It's oeen extremely
\ 3.' 15 difficult. They said that they were coming in with something, l I
'16 but I don't see much prospect of us getting anything. I 1, M2. MILHOLLIN: Thsse are the people that never 13 answer the phone ?
Is 'R . QUAY: That's right.
. Pe rry was promised wi hin 23 a week and a half of the last meeting. I haven't enec keo up 21 on tn at. Steve tells me that they haven't come in with their 22 report.
23' I will check up on Perry again.
24 'W . MILHOLLIN: While we're on Sailly, John, do we 2; need it or don't we?
f_
) ~
. . l
1 h /
liB40.06.10 83 l l DH gsh 1 MR. CHO dell, it depends on the kinc of conclusions
() 2 we draw from it. If you want to generalize and to hypothesize, 3 you con't need it. If you want to have a firmer set of l l
4
]^
w.
conclusions, then I think you ought to have some of that. {
5 MR. OSTRACH: At least for what I think John and 1
i
, 6 I are supposed to oe using Bailly 4, which is just as an i
7 illustrative case of perturbations from outside the normal l 1
1 S licensing process. ;
) I don't mean financial data. We're just using it l 13 as a series of events. )
11 As' f ar as that goes, we don't need the financial I 12 data for Section 3.7, or whatever I'm working on. 3.10.
13 ,
'G . MILHOLLIN: It's 3.7.
l l
14 MR. OSTRACH: It's 3.10 now. It used to be 3.7. It's
( 15 now 3.10. I 16 l.4 R . Q U A Y : Further, the Seacrook write-up is 1, completeJ. I draf ted a section on f unding flow for St. Lucie.
15 Unfortunately, Johr. cid not receive that until the meeting 19 this morning. There might ce some comments on that, some 23 changes.
21 I will ask Karn Neal to look it over also since ne
~
22 had original responsicility f or it.
1 23 Inis Section 2.3, puolic inputs. '
24 'G.
. MILHOLL IN: While we're on St. Lucie, I guess I
'l 25 asked eerlier, you naven't, I take it, done the acclication of l 1
i 1
3 9
i
t e
'iB40.06.11 84
- DH gsh I the options for St. Lucie?
O)
(_ 4 MR. QUAY: Yes, it's done, and I concur in that.
3 But there might ce some minor changes in the funoing flow (l?
4 for clarity or other reasons editorial in nature.
x 3 MR. MILHOLLIN: In the documents that we have tnis
, 6 morning, we have a draf t of St. Lucie 2, which is John
/ Cho's.
3 MR. QUAY: That's everything, minus the section 9 for funding flow and environmental impact.
la MR. MILHOLLIN And we have that separately, right?
11 MR. QUAY: That's co rrect.
12 Section 2.3 Steve has to look over. He referred to 13 that earlier. Okay?
14 -
The Section 3.5, Myron referr d to that earlier.
() 15 You have that. The other thing that I've got is a 3.9. To 15 what extent can the costs of postponement be avoided by 1/ utility planning? Ihat's joint between you and me.
13 MR. MILHOLL I.N I have a couple of more interviews 11 wita people in Wisconsin, one of whom is Saul Burstsin, whom l 23 I ment-ioned. The other is William Kuypers, wno's an executive 21 at another utility in Wisconsin.
2: I nave coth of those finished and cack to the 23 interviewees anc they're going to advise me and seno them 2? osc'c to me. As soon as I get them cack, I'll send tnem to you.
(
~
23 I can't enink that their conclusions are too different f rom s_/ ,
6 e a640.06.12 85 DH gsh i the conclusions of the interview Ted and I conducted.
(f) 2 MR. QUAY: With Shannon?
3 MR. MILH3LLIN: With Mr. Shannon. I guess to sum 4 it up is that procaoly wnat will happen, the utilities will Q'
3 come in earlier with their applications. The incremental l
. 6 diff erence in difficulty of f orecasting will be quantitative e .rather than qualitative sin:e it's already so spongy, as I l s said oefore.
9 I think those are the two main things which '
I 13 r eme m oe r. [here are other subsidiary points, out they tend i 1
Il to di ffer from one interview to the next, and it would oe '
l 12 ratne r complicated. And I don't reme moer tnem.
13 MR. QUAY: I think the one proolem they orought up, i l
14 that it is far better to delay start rather than to get celayed !
15 right in the middle of construction. That was very la empnatically pointed out. l ll MR. MILHOLLIN: Also, the people I interviewed said 13 that they would pref er a fixed delay af ter the CP rather than 1
19 a celay whi:n woulo cepend on the speed of review. l l
2J If that were possiole.. l l
21 12. KARMAN Set a limit?
~
22 MR, "ILHOLLIN: Set a limit, you '<now, X-numoer of 23 months, ratner than saying until certain reviews are 24 comaleted, cecause that coesn't help them schedule at all. l
'[ 23 v.d . QUAY: They're just striving for predictacility. 1 l
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840.06.13 86 DH gsh 1 MR. MILHOLLIN: They're striving for predictaoility.
(f 2 i4R. OSTRACH: That's not anything. You could say that 3 if fou haven't -- if nothing has happened within 6 months 4 af t3r tne licensing ooard decision, you can oegin. But I 6(
- s 6 i
l s' don't - think that that would give them ade qua te predictaoility. !
$ They will still be sitting there by their desks 4 on the night of tne 6th month to see if, in fact, the d -commission nas extended it for another montn, or if the 9 ;ppeal board decision which they have been rushing to get out 10 Jerks their permit.
11 Tnat gives them a deadline, perhaps in their 12 uncertainty. But it doesn't give tnem a predictacle date to 13 oegin construction. ,
14 MR. QUAY: They've got some f eel as to what's going la on, though.
15 MR. OSTRACH: I think they'd have a lot less i l
1/ confidence aoout appellate review tnan they do aoout the l 15 licensing ocard decisions. I really do.
1 19 I think tnat right now they look ahead at when
- 2) the licensing board decisions come cown. They a ssume that 1 21 they know taey've won the case in the licensing ooard oecause 22 thef feel if tne licensing ocard haa'proolems, there woulo j 23 have oeen adoitional hearings.
24 I think they would be a lot le ss sanguine aoout
( 2; having, you know, ou11 dozer operators sitting at the switen C) ,
9 4
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iS40.06.14 87 DH gsh I at midnight on the night of the appeal board decision than
( )' 2 they would ce with respect to a licensing board decision.
3- I just don't think that a deadline by which an
/> 4 appellate decision comes out will give them very much 4 .
3 in tne way of predictability.
1
, 6 Maybe so.
/ MR. CHO On the other hand, theoretically, you have 3 a rule that construction can begin six months after the 9 initial decision. There you do have the predictacility j 10 suoject, of course, to the same kind of risk that is pres ent j l
11 now. That issue may arise -that causes reversal on appeal, or 12 something.
V i 13 I think there's diff erent ways of concluding and 1 i 14 havs some degree of predictsoility. -
15 13 le IS I
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(_/ pDAV 1 MR. SEGE: It seems to me there are two separate 2 f actors that militate against the view that Steve expressed 3 about whe ther six months would really give de pendability.
P.
- 4 If the appli: ants observe that no Licensing Board decisions 5 have been ultimately reversed in subsequent review and from 6 tha t they judge that it's f airly dependable, that they will
. 7 ultimately prevail in review af ter a f avorable Licensing 8 Board decision, then they just have to wait for the 9 six-month clock to have done its ticking and they can start 10 wi.th reasonable confidence that their construction work will
.11 not be wasted. There is one aspect of it.
12 MR. QUAY: And know precisely when they're going 13 to start, too.
14 MR. SEGE: precisely. Another aspect is this (f if 15 as a result of Three Mile Island and other f actors their
. 16 estimate of the predictability of Licensing Board decisions 17 not being ultimately reversed is now less certain than it 18 had b een in t he pa st, they may still f eel that in a 19 six-month period af ter which they are allowed to start 20 construction, that that will put pressure on the reviewers 21 to com'plete their review within that time and that they 22 would benefit from that schedule consideration by the 23 reviewers. .
et 24 MR. OSTRACH: There's a third f actor that argues 25 against my position, that I thought George was going to
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$840 07 02
'apDAV I mention, which is that particularly in light. of TMI, but (O
2 also in light of the Commisison's expressed interest in
,, 3 increasing its role in adjudication, it is conceivable that 4 future applicants may be less confident of relying upon a 5 Licensing Board decision and may view a Licansing Board 6 decision as not as useful a predictive event as they have in
, 7 the pa s t, and therefore realizing that a Connission decision 8 is be tter than a Licensing Board decision because at least 9 it isn't going to be reviewed by the Commission.
10 They might find that getting a Commission decision 11 is a more satisf actory, predictable step on which to go 12 forward. So there is that f actor. There is that element 13 of, you know, predictability, that at least you know this
(} 14 15 decision won't be reviewed within the agency, and therefore, in that instance it is a more useful thing to base our 16 actions on.
17 MR. MILHOLLIN: While George was talking it 16 occurred to me that maybe there could be a provision which 19 would make it very difficult for the system to stop 20 construction once tha t clock had ticked. That would
. 21 increase the likelihood of being able to rely on the 22 period. It just occurred to me.
23 MR. SEGE: From wha t the utilities have been
,f 24 saying, they might view with f avor such a result.
25 MR. MILHOLLIN: It would make it very hard to hold
() ,
9
90 6840 07 03 pDAV 1 up construction af ter the period had run, or some kind of 2 . stay rule, or some thing. I'm just thinking out loud now.
- g. - 3 MR. FDYE In other words, if you're going to hold s
4 it up, you would be forced to do it before the period was 5 over, as opposed to af ter.
6 MR. MILHOLLIN: Of course, Steve's point is that
. 7 that could ha ppen on the evening of the deadline.
8 MR. OSTRACH: Could and will.
9 MR. MILHOLLIN: The Commi ssion puts out the se 10 orders giving itself more time.
11 MR. FRYE I think Steve's raised a point that we
[ 12 prooably need to think about in that the Commission has 13 illustrated i ts desire to be more involved in the r h 14 adjudicatory process. Instead of simply saying that the 15 Appeal Board will have six months to conduct its review, 16 af ter which time the construc tion could go ahead, it might 17 not be as predictible or as certain a date for the utility 18 as it would have been in the past.
19 MR. MILHOLLIN: When we interviewed Commissioner i 20 Ahearne, he expressed the view that if we were going to have
. 21 the se periods, there should be an additional one f or the 7
22 Co mmi ssion , that we had X number f or the Appeal Board and Y 23 number for the Commission.
,f
< 24 MR. QUAY: But he was tal. king about fixed periods.
e s
(. 25 MR. MILHOLLIN: He was talking about fixed period, t
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$840 07 04 k'
-7pDAV 1 yes.
l 2 MR. OSTRACH: A fixed period is only fixed as o'ng !
g ,, 3 as the fixee doesn't have the power to entend it. Once the 'l
'l- 4 fixes has the power to extend it, it's not of much use.
)
5 MR. QUAY: And the fixes, being the Commission, !
6 ha s the power to extend it. l 1
, 7 MR. CHO You mean the fixer?
8 MR. OSTRACH: I meant fixee, because the fixes is 9 the body presumably bound by the fixed period.
1 10 MR. MILHOLLIN: We're the fixors. !
L 11 MR. OSTRACH: I've written enough Commissio, !
12 orders. Both as fixor we will issue it on such and such a l 13 date, and as fixee, when, a month later, as we rush to that ;
(' 14 15 date, we were bound by-it and then became a fixer again, extending our time. There's a certein amount of anguish j
16 every time we do it but we're strong. We saye ourselves.
17 MR. SEGE: of course, to the extent that an 18 (,plicant f eels that he must recognize the possibility of 19 reversal of a Licensing Board, he could voluntarily delay 20 construction.
. 21 MR. FRYC Ye s, he could. And I think that sort 22 of leads us, in a way, back to the su gge s tion , the t-in 23 suggestions that the Licensing Board make a finding as to 24 whether its decision should be eff ective and Alan 25 Rosenthal's suggestion that in certain circumstances that I
() .
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- 6. <
92 6840 07 05
(])apDAV I the stay standards be relaxed. Where a stay was obtained, 2
let the A.ppeal Board decide the issues that gave rise to the g) 3 stay f.irst. It interrelates, you know, you may come to the d ) 4 point where the board decides that there is a substantial 5 issue here, the Licensing Board decides that there is a 6 substantial issue and appeals ought to be resolved before 7 construction is allowed to proceed.
8 The Appeal Board reviews that and perhaps even the 9 Commission. reviews that, just on the issue of whether 10 construction ought to be allowed to go ahead before the case
.11 goes through the appellate process.
12 MR. MILHOLLIN: That parallels one of the options 13 you have before the Commission now for the TMI thing.
14 MR. OSTRACH: To ge t back to a point George has 15 made, thinking like that would be very destructive. It l 16 would be very harmful to the applicant's posi. tion if it 17 became understood that one reason why an applicant is not 18 going aheed with construction is that the a pplicant himself i 19 believes the Licensing Board decision is shaky. That would 20 really harm the applicant's position before the Appeal Board 21 or the Commi ssion on review. My expectation is, if an 22 appellate body realizes that the prevailing party itself 23 doe sn't have much confidence in the decision, the appellate 24 body usually doesn't have much confidence in the decision.
25 If I were an applicant, I would be tempted to say, B
a 4
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'5840 07 06 1 I've got to start constructon. If I don't start
}mpDAV 2 construction, people will say I expect to get reversed. And 3 I think that's self-fulfilling. l 1
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. \
4 MR. MILHOLLIN: I think you're making a deception l
5 t ha t the decider is very strongly influenced by the opinion 6 of the parties before him as to their case. I'm not sure,
. 7 at least my experience, sitting on the one case I am on, is l
8 that I'm really not too influenced by whether the parties i
)
9 think tnat their points are strong or not. I am influenced 10 by whether I think they're strong. l 1
11 MR. KARMAN: Steve's point would be a valid point 12 if you could show a . history of reversals. But other than ;
, 13 t ha t -
14 MR. MILHOLLIN:
( }' or a history of the board's really 15 deciding the case on the substantive points made by the I
- 16 parties in their brief s. The parties' briefs usually don't 17 answer all the questions and whether the party believes 4
18 strongly in his position or not, I'm not sure tha t's 19 critical.
4 20 MR. OSTRACH: I didn't say it was critical, and no 21 doubt different adjudicators place, subconsciously, 22 different weight to the strength of the party's convictions.
- 23 MR. MILHOLLIN
- I think your point is valid up to e 24 a certain extent. I certainly can see that.
,J.
25 MR. FRYE: I do think , though, that some of the
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94 6840 07.07
I utilities may have said that they f eel that they can make a
'%)9pDAV 2 judgment as to whether something is likely to be upheld.
3 MR. OSTRACH: They do say that.
4 MR. QUAY: That's correct.
5 MR. OSTRACH: They say they're willing to bear the 6 risk.
. 7 MR. QUAY: I think WPPSS made that point.
8 MR. MILHOLLIN: Well, by way of succeeding 9 activities, perhaps the first thing to do would be for us to 10 sit down on Monday and go through all the things we've JI received caref ully with the object of ge tting back to the 12 authors' comments we have. I am thinking now of the views I 13 circulated to you.
() 14 ,
Thinking just of my own as an example, you all --
15 some of you -- were chairs in the workshop and it could be 16 that my recollection or summary of the views is not the one 17 tha t you have on certain points. I'm sure this i s true --
18 prooably -- of other write-ups, so why don't we try to do 19 that first, since if additional work has to be done on any 20 of these sections, it would be nice to know about it 21 quickly. Agr eed?
22 MR. CHO: Yes. At this point, though, I would 23 suggest we focus mainly on accuracy, because if we go much 4 24 beyond that I think we'll be wasting time. All the various L
25 sections interrelate so much that until we see the big l
s
L e 95 5840 07 08 l r'~ 1 picture -- what I mean by big picture, the entire package --
(_;) .oGAV 2 we'd be wasting a lot of effort by focusing on a narrow part 3 of it, because other parts may take a completely diff erent k.['. . 4 view, and ultimately, we may be persuaded that the other 5 view is better. And I know in my own case of stays, it 6 depends so much on how we end up with the immediate
. 7 eff ectiveness rule, and how we change that approach. So, 8 whatever conclusions I express in my draf t will necessarily 9 have to be very, very tenta tive.
10 MR. MILHOLLIN: Sure. I am not suggesting that we 11 start trying to do an editing job. I am just suggesting 12 that if you see something in somebody's write-up which 13 doesn't jive with your own recollection as to 'the
( 14 substantive accuracy, it would be a good tning to let the 15 person know.
16 :1. CHO: I'm talking not only about yours, but to 17 all the submi ssions. I was going to say that we ought to 18 emphasize the point that you're making, check for accuracy.
19 MR. MILHOLLIN: Beyond that. I was hoping to throw 20 it open for suggestions as to how we might proceed. What I 21 plan to do is take all this and lock myself up over the 22 weekend here in Washington, and get out a draf t procably by 23 Tuesday, so that eact, person could have a complete draf t.
r 24 And I assume that by the end of next week the missing e
25 portions could be just supplied by the authors as they're m
l %? t I
- .. -, . . . - . - - - . . - . . . .~ . - . - . . - _ _ - _ - _ _ _ _
L .s 96 6840'07 09
/^'ppDAV 1 finished, so that by the latest, the beginning of the week
-) ,
2 af ter next, which is the week before we have our meeting to
,_ 3 draw conclusions, everybody would have a draf t with all l b[,
4 sections.
1 5 MR. OSTRACH: The w.eek after next is the week we '
o have our mee ting.
. 7 MR. MILHOLLIN: Is the week?
8 MR. KARMAN: That's the week of October 8th.
9 MR. MILHOLLIN: At the latest, by Monday, October 10 8th, everybody has a complete package of everything.
11 MR. QUAY: October 9th.
12 MR. MILHOLLIN: Excuse me. October 9th. Some 13 people have vacations on October the 8th, but by October the
( I4 9th, everybody will have everything. And probably most of 15 it quite a bit before then.
l 16 MR. OSTRACH: I think tha t John's point is well l 17 taken. At that point we can begin saying, you know, section 18 8.7 is written -- is too long compared to the way -- that 19 type of thing. In fact, now that I look at it, it's really 20 done in section 7.1 be tte r.
l 21 MR. MILHOLLIN: Yes. !
22 MR. QUAY: I think we've got 90 percent 23 participation on the 8th.
,~ 24 MR . OSTR ACH : On the ro11 day aspect of the 8th. l 2
25 MR. MILHOLLIN: Yes, all these federal holidays.
I g !
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i
97 5840 07 17
('7pDAV I Well, so, I'll go through this stuf f over the yJ.
2 weekend and try to get back to you. If I have any problems 3 with any of it --
4 MR. KARMAN Call me on Tuesday, not Monday.
5 (Laughter.)
6 MR. MILHOLLIN: I won't be able to call anybody on
, 7 Monday. Some peo ple I won't be able to call this Monday and l 8 I won't be able to call anybody a week from this Monday.
9 Are there any other suggestions about how the time next week l 10 might be used ef f ectively by the group? I am going to be I
11 working and trying to get the draf t out. What about you l l
12 all? Some of you have things which are hanging over, that j 13 have to be finished. Some ,of you wil be busy doing those.
()[ 14 MR. OSTRACH: We should of course start doing what 15 we're going to be doing the next week, which is thinking 16 about recommendations and conclusions. Obviously , that 17 won' t be as easy to do withou t the draf t, but to the extent 18 we h' ave time it woulon't hurt to start thinking about what 19 we've learned to date.
20 MR. NASH: It might be easier.
21 (Laughter.)
22 MR. OSTRACH: Decisions first, facts later.
23 MR. SEGE: We have some idea of the content of the 24 draft, anyway. And we've discussed some of the steps so 25 that what you're suggesting is not necessarily rendereo too 1
-h
6 4 98 5840 07 11 i
i /~' 1 difficult.
()apDAV 2 MR. MILHOLLIN: We have all the raw materials of l 3 the draf t. We have everybody's wri te-up so f ar. Well, do 4
, you think it would be profitable to set some . kind of a 5 tentative schedule for circulating proposed recommendations 6 on that? Is it too early to do that? Do you think it's too
. 7 early to do that? Or would that be a good thing to do now?
8 How do you feel about tha t?
9 MR. NASH: What's the value of delaying it?
10 Estaolishing the schedule , it seems like it would be a good 11 iaea to have something to work toward.
12 MR. FRYE Does this need to be mandatory?
13 Perhaps there are those of us who f eel that we have some 14 f( )- tentative conclusions. Tro se who f eel they want to wait, 15 let them vait.
16 kR. MILHOLLIN: All right. It would be useful to 17 have whatever tentative conclusions we can come up with 18 before we meet, on the 10th, it seems to me, since that'll 19 give us something to f ocus on when we discuss what the 20 conclusions should be.
- 21 MR. SEGE: It could be quite manageable to go 22 along the lines that John suggested rather than having 11 23 different complete sets of recommendations f or the group to
^
24 consider. We had not nece ssarily complete sets of l
l .25 recommendations f rom people who f eel that they are ready l
l
,- - . ~- . - . - . . - - - - - - - - - - . - - -- ------
s' s I 99 l
5840 07 12 I (ppDAV I to f ormulate at least part of the recommendations, so that
' L/ .
2 we would be in a position - a pre tty f air starting point.
- 3 MR. MILHOLLIN
- People could focus on recommending 4 things which they know most about. Darrel, for example,.
5 maybe he f eels now that he's ready to make some kind of a 6 tentative recommendation on the work he's been doing with l
, 7 respect to early site review and so forth, which would be I 8 useful to everybody. I am just using him as an example.
9 Don't f eel picked on.
10 So shall.we leave it that way, then? What about a 11 date for these items? We're meeting on the 10th.
l 12 MR. QUAY: Which items are you talking about? j 13 MR. MILHOLLIN: The sugge sted recommendations
( I4 which would be voluntary.
15 MR. CHO: Could you have it by the end of this 16 coming week, then, so it could be made part of the package?
17 MR. MILHOLLIN: Okay. Is that agreeable, by 18 Friday? People could just put them in the mail.
19 MR. OSTRACH: By Friday.
20 MR. MILHOLLIN: Of next week.
21 MR. OSTRAQi: That guarantee s, then , that the 22 draft will not be circulated until Tuesday, the 9th.
23 MR. MILHOLLIN: No, these would be inde pendent of j g; 24 the draft.
25 MR. OSTRACH: I'm sorry. I thought you said they 0 ,
{ 4 100 6840 07 13 gggspDAV 1
would be circulated with the draf t. Okay.
2 MR. MILHOLLIN: We could try putting those in the !
77_, 3 mail on Friday. They would arrive, then, on Tuesday, I !
4 su ppo se . And people could have them to think about for one 5 day before we meet. Okay.
6 NR. QUAY: Do you want to set some other dates on 7 the due . stuff ?
8 MR. MILHOLLIN: Would it help you if I set dates i
\
9 on the due stuff for the things that are still outstanding? l l
10 I a ssume that it all has to be done by next week or it won't 11 be part of the grist for our mill following that. So, for 12 ourstanoing things, I assume we should have them done by 13 Friday of next week. Is that agreeable, George?
(% w 14 MR. SEGE: Yes.
15 MR. MILHOLLIN: I a srume everyone will try to do 16 them as quickly a s possible. So, proposed recommenda tions 17 would go in the mail on Friday -- what date is that?
18 MR. QUAY: Friday's the 5th. Monday's the 8th.
19 MR. MILHOLLIN: Yes. And the things which are 20 outstanding can simply be done as early next week as 21 po ssible . I'll be, I guess, working probably here. Well, I 22 can talk about that with George. So if you want to reach me 23 on Tuesday you can reach me either here or down in the
,a 24 General Counsel's office. I'll be at one or the other
)
25 places. If , when you come in on Tuesday, you have an
e p 101
- 5840 07 14 1
pDAV 1 irresistable desire to talk to me, you can reach me at one 2 or the other places. So 3re we finished? The meeting will g 3 adjourn.
V 4 (Whereupon, at 11255 a.m., the meeting was 5 adjourned.)
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