ML20214B783
| ML20214B783 | |
| Person / Time | |
|---|---|
| Issue date: | 02/11/1986 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8602200665 | |
| Download: ML20214B783 (81) | |
Text
..
s ,
...w -
c.y;.
,~
J. : ~,,s. a.'..
x...
~
c -
s w ,,
,sN.y . f ..>f s. , , .
..,.. . u,. w
., ..- ,e w . .
. . , . , + * , ...*m. .
. , ,'y. ;'
ay:3 h.. ..;4'&
., .> uq ry.O
...e"j. #. m
+... .
d
' UNITED STATES OF AMERICAi ~ N'I C ^ A,.'%~ <, 2<MMmn .
y , ca s . 7 <' -. s' u A.e.-
s NUCLEAR REGULATORY COMMISSION' 7' 3,.
- 3. m .y , ..s .. .
, .t ,
. 1 hum
/:my&w: .
. v. AM ,.p'p
'd,if 3. M.u, ,
. . . . .,y w
c .
.c . .:
- e. .S ;
w# , v. . $ a.D!
. t, .+.c w .. A,w -
y,e... C; In the matter of: -
~- '
~'
. .n.~. w. . . . y. @A
~;
wn.7- - w.
~ '
/
% .- .p;gi:
COMMISSION' MEETING ox , ,- . ,
R -,". - N, p ;.p,,.q: W, W
. A ;c. w. , m,M Briefing by AIF on , q - 4 W ' , '.Q Technical Specifications , b y; ..ipw.nq s . .. ,,z. 3..
Improvements .
.-- m a,p. sd s -, -_ o- ac.a . . o y., 4a (Public Meeting) - -
j .v d$. .a
- f.
,%.,j $w*. 1
^%u f./.3-
? .
.' h , .Cp-C!.sf.h,e.g.. ya m Docket No. .A:rb't;Q.
t
.. .s a _.w%.c t W uc,
?. n.~ng;M. ea .. yM
~,
s ..<~
- ~ , , ,a r
%, ,.:n. y, ::..f.m,,O . t m:'. L
,. . . - s~
,.r a
- ', , gm ;pp:'.L y.a , ,:
" ,@M
. m , , . c; ; .x .y ,
8: . y
. ,. .y A . ,a v.;, c.e. .. %, .myM
,g,
, . . c.
, ~N _ _ ,
<? %*L ',
n
, . . ? *u. . .. x.. o .c. 4b w :v. , ~ ',s'. .
7 ~,,.,.n... . . .c .,.s,., . m . . #. +. . n4r '.. . .?*.,4ivy.
.&+ *
. o^ s.cm 4-g y A . sn,'a
- .-. , .w. ., .
- . m. . -,i .,~e. s , w e. o , ,4 # e. w. p,n. n1 m ' ys., "y,..; s.o.3,99,$c .gm v
. , j,-
. ..3. .
+ e q,y y y. v._c z...
, t . . ., 3q sc r s A
. 1:
... e,
, r p.y.
. ,. . , ,? , .yjeu , D g g - ap,Q4
.'.. , , . , , . . +.. m :, ~,..C. +:in. .n e o . . . . -
.s .7.. .,s..c.
, . m, A .
y, . .,.. , a. 3 ,' ,w.n.
m g:
'.*. ,,f.,-,- ' ' 3y s
. ,, .e .;
+
.4 c* f.y 'j#ib~ gi.*Q
. >. '.(Q, ht g*:,$c
? . ', "; ', 4 %,y,w
. .~ - ;fs i w. rYu.s '
.m > J
. . ~ , - :,e c /.w. ,.,s:.v .
2+ ~,,.
14 A., y ,
, , . . . . . . . . , . s w:.w w
,. .y a- :+
.:- . .a . .
. w w.,..msu...m .4.m
. /c
,, .. ' - s .
s.',.. *
- 4. ,
--g* i '*i.?.
p..
.' *.h,i 9 MG @g, fli r h **aG.q,L ,:4.sz W e *.
c.
y .,, ~f* r- .-
~
.y y _ - y, (Location': Washington, D.-C.r ' ,'
'J- - W O,Edl
.- Date: Tuesday,(Februaryf11,.1986 ' y' . :/Pages:- ' 'l V66'. PO
...w .E, n ,. , y..
3 . s a . ..; e < ' < ,
- , N
- ...g ,,,..,,. ,, . .
- r ' y ~ s ~<r 3
, <. .. .. . ,mm. .% , ,
.]1y..,- '
. t y a ; ,.;.,
,w . ~ . s ; ,. .
- 1. b.; x ,,. s. ,
- , . ,1 a - m.;' ,. . . ,;".;,n. , , ;.r ,'.,. .m, . y,..e.
, 1 ..
.. . . .. y :, f.,e %, h$;
g
.m ...,rt -*n, , g :,-p<;
r.
. &. z, ,*
- ' . ;c-w .
,c y e, 9.) , . 7, ,+ y p;,..>.,q. .a.p y. .., f1 . s ,
..t , ', ~ *- l '
r
-,~; s.
- p~
.e . .
,p w c..y, ..
, x. .s s. %g
, . - y ,a . - . , (***
, y
.< .- g, 3 m . ,$ y f ..y *..
. . v.r n *,v'
.t.
~
'2
,c p- e m 65
.. c ,. .u, . , ~ >a ,f .,1
+ ,\w.v.
y f />
. . ~ .. m ..
-ANN RILEY & ASSOCIATES . . . ..
...._..o ,, e,.
,. . . - c. 0
. Court. Reporters r.+ . " a".. v . ~ . . . 4 .c 4
. . . .JW., '
t>l . . ,3. . ,;g.~. ,r ,
1625 I St.,'.N.W. pg*p.f.y t . .L
.- Suite 921-~ +
~
Wdw: f.* 6 Washington, D.C. 20006 .C W -
9 W ':'U.<4..ebyl.y. , . ; g 6 8602200665 860211 '
^ '(202) 293-3950 PDR PT9.7 10CFR PDR -
"o,.-/
- . . =.A. .
i
, w.:, . ,.W'.
w
. . , . . ..* y'
~i'.,~t#
.u..s . . ., A M
- 4 sMM 4, ul,d._.m. ./,
'}, ,
- *+ ,... ^ . W *4i n a 6' *e f 9 _
M, af ,'$
t D 1 SCLA I MER 2
3 4
5 0 This is an unofficial transcript of a meeting of the 7 United States Nuclear Regulatory Commission held on a 2/11/86 .
In the Commission's office at 1717 H Street, 9 N.W., Washington, D.C. The meeting was open to public 10 attendance and observation. This transcript has not been -
l 11 reviewed, corrected, or edited, and it may contain 12 inaccuracies.
13 The transcript is intended sdlely for general 14 informational purposes. As provided by 10 CFR 9.103, it is .
15 not part of the formal or informal record of decision of the 16 matters discussed. Expressions of epinion in this transcript 17 do not necessarily reflect final determination or beliefs. No 18 pleading or other paper may be filed with the Commission in l
19 any proceeding as the result of or addressed to any stafement i I
20 or argument contained herein, except as the Commission may )
i 21 authorize.
1 22 l 23 24 l
25 l
1 1 UNITED STATES OF AMERICA
,m 2 NUCLEAR REGULATORY COMMISSION' 3 ---
4 BRIEFING BY AIF ON TECHNICAL' 5 SPECIFICATIONS IMPROVEMENTS i
6 ---
7 PUBLIC MEETING 4 8 ---
}
9 Nuclear Regulatory Commission 10 Room.1130 11 1717 "H" Street, N.W.
12 Washington, D.C.
, 13 1
14 Tuesday, February 11, 1986 15
} 16 The Commission met in open session, pursuant to 17 notice, at 2:05 o' clock p.m., NUNZIO J. PALLADINO, Chairman of l
13 the Commission, presiding. .
I 19 COMMISSIONERS PRESENT:
20 NUNZIO J. PALLADINO, Chairman of the Commission 21 THOMAS M. ROBERTS, Member of the Commission 22 JAMES K. ASSELSTINE, Member of the Commission 23 FREDERICK M. BERNTHAL, Member of the Commission 24 LANDO W. ZECH, JR., Member of the Commission I i '
u_-
25 4
o
2 1 STAFF AND PRESENTERS SEATED AT COMMISSION TABLE:
. 2 S. CHILK 3 M. MALSCH 4 H. TUCKER-5 A. PASSWATER.
6 7 AUDIENCE SPEAKERS:
4 8 R. GILL 9
i 10 t
11 f
1 12 13 14 1
15 16 i !
l 17 J
18 -
i 19 20 .
21 l 22 23 24 1
25 j'
er - - , - , . - . , , - - ,,,,-~ ge .,,+.,n,,.w._.-~ -
-n.. - , , n ,, , - ..._ .,y-- w ,,,-,--, , 9w- c.n- w-- .-w---e -
-~ - .. -. - - - ..
-4
~3 l' P R O C E E D'I N G S -
2 CHAIRMAN PALLADINO: Good afternoon, ladies and
,i
! 3 gentlemen. This afternoon we are meeting'with' representatives 4 of the Atomic Industrial Forum to discuss NRC efforts for-5 improving technical specifications.
6 Plant technical specifications have evolved over 7 many years and at this time there is general staff and j 8 industry agreement that improvements should be considered. In i
i 9 December of 1984 a Technical Specification Improvement Project i
j 10 was established to reconsider the entire subject'of technical
. 11 specifications and to provide recommendations for improvement.
12 The Commission met with the staff on January 21 of h
is 13 this year to discuss this subject. By letter dated. October 8, l 14 1985 AIF provided its position regarding technical specs. In
- 15 addition, the AIF has indicated its support for the staff 16 effort.
17 In addition, it should be noted that combustion 18 Engineering, B&W, Westinghouse and General Electric Owners
- 19 Groups have indicated supported for the'AIF position. Among l 20 other things the staff recommended that the NRC proceed with
- 21 the development of a Commission policy on technical 22 specifications and to defer a decision on rulemaking to a 23 later date.
I 24 Although AIF had previously indicated a preference l a 25 for proceeding with rulemaking, it is my understanding that 1
1
)
i I
4 l
,s 1 AIF now agrees with the development of_a policy. An important 2 objective of today's meeting is to obtain enough information l 3 for the Commission to prc:eed with the development of a policy 4 if the Commission decides on this course of action.
l 5 I understand that Maury Edleman, vice president of !
1 6 Cleveland Electric Power Conpany and Chairman of the AIF !
1 7 Committee on Reactor Safety and Licensing who was to be 8 today's first speaker cannot be with us. I will therefore 9 turn the meeting over to Mr. Hal Tucker, vice president of l
10 Duke Power Company, after I ask my fellow Commissioners if 11 they have any additional opening remarks.
12 [No response.]
13 CHAIRMAN PALLADINO: All right. Hal, I will turn 14 the meeting over to you.
15 MR. TUCKER: Thank you, Chairman Palladino. Good 16 afternoon, gentlemen. My name is Hal Tucker. I am the vice 17 president of nuclear production for Duko Power Company but I 18 am here today representing the AIF policy committee on nuclear
! 19 regulation and I am also chairman of the B&W owner's group 20 executive committee.
21 I am accompanied by Alan Passwater, superintendent 22 of licensing, Union Electric and Chairman of the AIF 23 subcommittee on technical specification improvements.
24 We appreciate the opportunity to express our point 25 of view on a very inportant topic, obtaining improvements in
i
.- 1 5
1 the technical specifications.
m.
2 The industry has been interested in improving 3 technical specifications for some. time. Significant comments 4 were provided the NRC proposal in technical specifications.as i 5 described in the March 20, 1982 Federal Register. There was
- 6 considerable interaction with the NRC task group on technical 7 specifications which was established in August, 1983 '
. 8 culminating in the issuance of NUREG-1024, Technical
{ 9 Specifications Enhancing the Safety Impact.
10 The individual owners-groups and utilities have i
! 11 submitted or plan to submit requests to make improvements in 1
j 12 technical specifications. We continue to support improvements l.
13 described in our report submitted in our letter of October 8, I
14 1985 to Mr. Denton and submitted to you in Mr. Walsky's letter 15 of January 15, 1986.
- 16 Technical specification problems were identified l 17 during the industry's meeting with Mr. Denton and his staff on ,
18 March 1, 1985. These include limiting condition of operations 19 on systems that have minimal safety impact, surveillance I 20 intervals that are overly restrictive, allowable outage times l i
21 that compromise overall plant safety.and unnecessary design '
22 information and programmatic detail.
- 23 Several prcblems have been identified in NUREG-1024
, 1 24 that further support the need for improvement.
iV
- 25 Having identified several of the problems, clear
I l 6
~
1 objectives should be established for improving the technical
,m 4 s L 2 specifications. It was recognized that the purpose and scope 3 and contents of technical specifications should be redefined.
4 When achieving this objective, clear and concise 5 requirements should be required to facilitate operate usage i
4 6 and understanding. The requirements should be amenable to 7 efficient maintenance and revision if required.
l i
{ 8 In addition, forced plant transient should be 2
9 avoided.
10 To facilitate this objective programs to optimize i
j 11 surveillance requirements and intervals and allowable outages i 12 time should be developed and implemented.
13 To address the problems with existing technical 14 specifications and meet the objectives described above it was 4
) 15 recommended that a joint industry /NRC plan be developed to
. 16 accomplish the following task: develop criteria for 17 determining the content of improved technical specifications, l 18 split the current technical specifications into improved f
) 19 technical specifications and residual requirements placed'in 20 other documents, review and appropriately revise the l i
j 21 administrative process for controlling the improved technical 22 specification, finalize or develop methodologies to improve 23 the surveillance and outages time.
i l 24 To support the accomplishment of these tasks, it was i i _
25 recommended that an AIF technical specifications subcommittee 1
l J
, . _ . . . - . . . . _ . , , . _ . ~ . . _ , , _ , - - . . _ . - - . . . , , , _ _ . . - - , _ ..e_.,_-, .~. __ _,,___ - . , , . , ~ , , . _ , ,
7 1 be formed to coordinate industry plans and policies and to
~
- 2 interact with the NRC. The ongoing efforts of EPRI and the 3 owners groups would continue to develop and implement 4 methodologies and have periodic interactions with the NRC. It 5 was recognized that these two efforts should proceed in 6 parallel.
7 As a result of the March 1 briefing with Mr. Denton 8 and his staff, the AIF subcommittee on technical specification 9 improvements was formed and had its first meeting on March 29, 10 1985.
11 From March 20 to October 1, there were 23-full day 12 meetings in Washington of the subcommittee or its working
( 13 group. This does not include the many meetings of the four 14 owners group to support the pilot study using the suggested i
15 draft criteria, providing input to the process and reviewing 16 the draft sections of the report.
1 17 As a result of this very intense effort, a final 18 report was transmitted to Mr. Denton on October 8. Now 19 Mr. Passwater will summarize the subcommittee's program.
20 MR. PASSWATER: Thank you, Hal. May we go to the 21 slides, please?
t 22 (SLIDE.] '
23 MR. PASSWATER: Next slide.
24 (SLIDE.]
25 MR. PASSWATER: As Mr. Tucker mentioned the O
._. ._ _ .~ __ _ . _ .
8 i
1 subcommittee on technical specification improvements was-p '
2 formed in March of 1985. That subcommittee reports to-the
,. 3 committee on reactor licensing and safety in the AIF committee l
4 structure.
5 I have been the chairman of that group since'its 6 inception last March and our purpose is to coordinate, 7 propose and promote technical specification improvements. One 8 of the things that has been a characteristic of that group is 9 that it has been very large. As that slide indicates, the
- j. :
i 10 membership has been varied and it is our opinion that we do f 11 have a fairly good representation of what the industry thinks 12 on technical specifications. ' '
!( 13 We have represented on the committee chairmen of 14 each of the four vendor owners groups, technical specification 15 subcommittees, the chairman of the nuclear power plant
! 16 standards working group, ANS-58.4, approximately 19 utilities, l
I 17 EPRI representation, four NSSS vendors, three AE firms and two l
18 consulting firms have been actively involved in the 19 subcommittee's work over the last ten months.
j 20 (SLIDE.]
i 21 MR. PASSWATER: We determined very early with the 1 22 size of that group and with the ambitious schedule that we i
23 were on last year that we needed to split the work up into i
24 four* working groups and we did that. We formed a working i
l 25 group on criteria development which we recognized early that t
a
,# , , ,_-,.w,.7 _. -.c_.,_,..m.,--.. .m._,-,-.,_ my.,_.,me,,-.-,..._.y,__.,,,,,y .,.,___,_.__ m.,.--. _ , _ _ . ,_ . , ,..-___,e -
,.,.~%.. ,ny--
.. l 9-
-l we needed to address the issue of what were the criteria for f 2 determining what should be in the tech specs and what should 3 not be in tech spacs.
i-4 Secondly, there was a working group on the i
5 administrative process. The sequence was that once we 1 6 determin9d a logical set of criteria for determining what l 7 should be in Lechnical specifications, then we needed to come i
j 8 up with a process to convert from the existing system to a new i -
3 9 system.
l
- 10 The third working group looked at regulatory changes j 11 that would be required, changes to the rules that would be i
~
12 required to implement the process and.a fourth working group
- 13 on probabilistic methodology which-is serving as the industry 1
14 focal point for various discussions with the NRC staff on use l 15 of probabilistic methodologies for determining things like 4
, 16 allowed outage times and surveillance intervals.
i
. 17 I would also like to point out that from the i 18 beginning this has been a joint effort with the NRC staff and I
19 as a matter of fact, the NRC staff has attended many of the i
i 20 gro'up meetings both at the full subcommittee level and at the 21 working group level and so the work products that came out, i
I l l
I 22 believe the staff discussed with you on January 21 the twc a
l 23 reports, the AIF report and the TSIP report, and those were 4
24 really work products.that resulted from a lot of joint effort l
l 25 between the two organizations.
i
- 10.
1 Next slide,.please.
2 (SLIDE.]
3 MR. PASSWATER: This is a graphical representation 4 of what we set out to do back in March and really what we had
! 5 to do was determine what was the logical bas'is for determining 6 what should be in technical specifications and get back to 7 what is the purpose of the technical specifications.
1
[ 8 Our focus from the beginning has been that the 9 technical specifications should be converted to something that ;
10 is more of an operator document than they are right now. I
- 11 think the opinion was pretty much that the technical 12 specifications right now represent a licensing document.
l 13 They are issued as an appendix to the operating i
4 14 license for plants and although they are required to be used
). 15 by operations people, their current format and their current i
16 content was not really usable by operators.
W 17 So one of the things that we looked at in developing 4
i 18 the criteria for splitting the technical specifications was .
19 getting back to their purpose and what they should be used 20 for. '
21 The diagram shows on the left hand side the existing .
22 situation that we have right now with the current technical 23 specifications for recent licensees. Those generally amount 24 to around between 500 and 600 pages. Then in the center it 25 shows the process that we would go through or what we would i
. _ , , _ _ . . - . . . . _ . - _ . . - . [._--.-.~_,,,.,_._,,--_-,.___,_...--
11~
1 essentially take from the existing technical specifications
- 2. and put into other documents.
3 On the right hand side would be the new system after 4 that process had been performed that would show a not set of 5 optimized technical specifications and the other requirements 6 going into other documents, for example, the FSAR, QA program 7 or something else.
8 some of the things that we looked at doing were 9 removing the non-essential LCO's and that is essentially done 10 by the criteria.
11 Along with those non-essential LcO's the i
12 surveillances that are in the technical specifications that j i 13 are associated with those LCO's wou)d also go into some other 14 document besides the technical specifications. .
15 Another example would be removing some of the 16 design information that is duplicated from the FSAR typically 17 into the technical specifications. That doesn't really need 18 to be a part of the license document.
19 COMMISSIONER ASSELSTINE: Could you give us a couple 20 of examples of that?
21 MR. PASSWATER: Design information?
22 COMMISSIONER ASSELSTINE: Yes.
23 MR. PASSWATER: One example is typically and I am 24 talking pretty much about the newer technical specifications 25 and standard technical specifications, lists of containment
. _. ._ ,_ ~ . . . . _ . . . . . _ _ _ _ . _ _ _ _ .
5 .
' 12 '
i i i penetrations, for example, electrical penetrations. There is 2 a limiting condition for operation that says if a penetration 3 has to be electrically protected.to prevent its failure in the
'4 event of an electrical failure then there are surveillance 5 requirements and limiting conditions for operation placed on 6 those. ,
j 7 Typically, what has been issued is a~ list of those i
} 8 penetrations and their associated protective devices.in the- +
l
- 9 technical specifications.
! 10 In accordance with the work that we have done, it l
j 11 was determined that really the list is also carried in the 12 FSAR and there is a process for controlling that design.
13 information once a license is issued without carrying it as l 14 some of the pages in the attachnent to the license as part of
- 15 the technical specifications.
i j 16 That is one example. There are other. lists and they i
! 17 are generally lists of containment isolation valves and so 1
! 18 forth. There were other things like removing some of the i
- 19 programmatic details from the technical specifications. The I
- 20 regulations require that administrative details be in the j 21 technical specifications, existing 10 CFR 50.36. But what it l, 22 does not determine is which of those detalis should be in and 1
23 which should be out.
24 There are a lot of things, for example, audit l
i
' l J
25 frequencies are carried in the technical specifications and if J l
0
13 1 a licensee wishes to change the audit frequency, he is 2 required to get a change to his license in' order to accomplish t
3 that. Some of those things could reside in like a QA program 4 or something that is also controlled by regulations but it 5 would not be a license document.
l 6 Can we go to the next slide, please?
7 (SLIDE.]
- 8 MR. PASSWATER
- Probably one of the first things we j 9 tackled with the subcommittee and one of the hardest things we t
] 10 tackled were development of the criteria. Back on March 1 in 1
- 11 the meeting that Mr. Tucker talked about I think everyone 12 there agreed that something, that the technical specifications i
l 13 could be improved.
14 The thing that was missing was what are the criteria j 15 by which you improve them or by which you determine what 1
16 things should be in there, so one of the early things we did 1
! 17 was look into the criteria and in conjunction with the NRC l
j 18 staff looking at what really is the purpose of the technical t
l 19 specifications and what should remain in them that makes them l
- 20 more of an operational document for the plant operators.
1 21 What we came down to were the technical a
i 22 specifications should do certain things. One is, the
[
23 technical specifications should maintain the operating 24 parameters for the plant within the design envelope for that I i 25 plant. In other words, the parameters that were used to do 1
~ '
1.-
l
.l 14- j
,, 1 the accident' analysis for that plant should be:specified
'l 2 .within the' technical specifications.
3 A second one is the technical. specifications should 4 provide the operator with.some kind of early detection of ;
5 abnormal regulation of the plant systems. I 6 A third one was the technical specifications should !
7 assure that the primary success path systems that the. operator ,
8 needs to respond to an accident or that are needed-for the 9 plant to respond to an accident, that they are available.
10 The criteria as shown on the slide then were the 11 ones that were arrived at and_those have been, of course, 12 published in our October 8 report and in the TSIP report.
( ,
13 One of the things-that we did in conjunction with 14 the NRC staff was we tested the criteria to see if they were 15 usable by assentially independent bodies on a given, set of 16 technical specifications.
17 The staff, I believe, reported to you in January 18 that they took the Wolf Creek technical specifications, . .
19 applied the criteria and they came up with a certain number of 20 limiting con,ditions for operations that would come out of the 21 technical specifications.
22 The AIF Subcommittee, actually the Festinghouse 23 Owners Group Tech Specs Subcommittee, went through the same
-~ 24 exercise with the same set of technical specifications. We 25 had a meeting with the staff on January 28 and essentially
15 1 compared notes on the results that we got using those 2 criteria.
3- Of the approximately 133 limiting conditions for 4 operations in the Wolf Creek technical specifications, after 5 about a five-hour meeting with the staff, it really came down 6 to 12 of the 133 that required some kind of resolution'between 7 the staff and ourselves. So it was a pretty good percentage, 8 or 90-percent of the LCO's that we essentially had agreement 9 on the use of the criteria as to whether or not that LCO would 10 stay in or go out of the technical specifications.
11 CMAIRMAN PALLADINO: How much did you reduce them by 12 aside from the 12 that still need work?
13 MR. PASSWATER: The numbers were about 40-percent of 14 the LCO's that came out. I don't recall the exact number.
15 CHAIRMAN PALLADINO: All right. That is good 16 enough. Thank you.
17 COMMISSIONER ASSELSTINE: You had 12 more than the 18 staff did above the 40-percent?
19 MR. PASSWATER: There were 12 that we differed on, 20 either they left it in and we took it out or vice-versa.
21 COMMISSIONER ASSELSTINE: All right.
22 MR. PASSWATER: That was after some discussion. The 23 original rough cut, there were around 30 that we disagreed on 24 but those were either based on different interpretations or 25 different understandings of the design basis accident and the
16 1 systems for that plant.
p.
2 So those that were really, that where there was some
- 3 kind of substantial difference on them were around 12.
4 COMMISSIONER BERNTHAL: It is a peripheral question, 5 I guess it is on in some sense, but I am curious. You say 6 there were 140 LCO's that you and the staff agreed on or maybe 7 that was the total. It doesn't matter. How many of those as 8 a matter of surveillance are constantly under active e
9 surveillance, that is, are instrumented, are under i
10 instrumented surveillance and how many require human i 11 surveillance?
12 MR. PASSWATER: I don't know that we got a count on
( 13 that basis of the 133 that were in there.
14 COMMISSIONER BERNTHAL: Do you have a guess?
, 15 MR. PASSWATER: My guess would be that almost all of 16 those require some kind of human surveillance. There are i i
17 surveillance requirements associated with each one, with each 18 of those LCO's, the 133 LCO's, and my guess would be that !
l i 19 almost all of those would require some kind of human periodic 20 surveillance. I 21 COMMISSIONER BERNTHAL: Maybe another way to ask the 1
22 question is, are you talking about surveillance of a panel in 23 the control room only? Are you counting that in human 4
t 24 surveillance.or are we really talking about somebody having to
- 25 go out and look at an object or check sonie other thing?
)
, :, 1 17~
1 MR. PASSWATER: It is a combination of those 2 things. For example, the LCO on reactor protection system 3 might list or refers to a table that lists many reactor 4 protection system channel inputs and each of those would
~
5 require some surveillance. So really the surveillance count wouldbealot'[highernumberthanjustcountingthenumberof F -
7 LCO's because that would. count as one-LCO. That obviously 8 requires an instrumentation and contrel technician to do the 9 surveillance.
10 COMMISSIONER BERNTHAL: I am just trying to get a ,
11 feeling of the 140 conditions for operation, what fraction.of 12 those rely on a human being performing some sort of
( 13 on-the-spot surveillance of hardware that at least is not 14
- available, informat3.on not available, on a control room panel.
15 MR. PASSWATER: All right. Do you have any ideas?
16 COMMISSIollER 'BERNTHAL: Is it half? Is it
~t 17 90-percent? Is it ten percent? Does anybody know?
18 (No response.)' .
19 \
CHAIRMAN PALLADINO: Maybe there is something that 20 they can provide.
1 21 COMMISSIONER BERNTHAL: Well, we can drop it if !
22 there is no answer.
23 MR. GILL: I am Bob Gill from the Westinghouse 24 Owners Group, the B&W Owners Group, and I was chairman of the 25 criteria working group. Each LCO will have many surveillances
,.,g,,ygp-g-p--arm$'"N>"**-*"U'-# ' ' "
. T 18 1 associated with it and so you really can't directly answer 2 your question. Take an accumulator, you have to have a boron 3 level, a water level, a pressure. Each one will be handled 4 differently.
5 COMMISSIONER BERNTHAL: Fine.
6 MR. GILL: If you look at an instrument that 7 monitors it, then the operator--
8 .
COMMISSIONER BERNTHAL: Most of which are 9 instrumented.
10 MR. GILL: Most of them --
11 COMMISSIONER BERNTHAL: What I am asking is how many
, 12 of those and I don't care how you bunch them together, how l
13 many of those 140 are non-instrumented surveillances that are 14 required?
6 s 15 MR. PASSWATER: I would have to say almost all of I
( 16 them. I would say almost 90-percent.
! 17 MR. GILL: Almost all of the are instrumented.
t 18 Inspecting steam generator tubes, that is not instrumented.
19 You have to go in and do that on an outage but that is an 4
20 LCO. Appendix J leak rate testing is an LCO, integrated leak i
21 rate test, the leakage, that is not instrumented.
22 COMMISSIONER BERNTHAL: Next question is how many 23 could be instrumented but let's drop it for now. It is really 24 another issue.
25 COMMISSIONER ASSELSTINE:
s Even on the instrument t-- ,, - .-- - , _ , ._ . - ,,-
7 19 1 designs, are not there.a lot of those where somebody actually has to go out to a cabinet and do a test in order,to check 2
f
- 3 that the instruments are correctly calibrated or reading 4 properly? It is not just a matter,of going to a ial in the l 5 control room and saying, "Okay, I look at the dial. Now I ,
6 have done that surveillance."
l 7 MR. PASSWATER: Yes. For example, on a reactor 8 protection system input the pressurizer pressure channel, j 9 there is a requirement to look at those outputs in the control 10 room visually on a periodic basis. There would also be a l
11 calibration requirement and a channel check requirement in l
12 there for the same set of' instrumentation.
I 13 COMMISSIONER ASSELSTINE: That is right, which gets 14 the people out there with the jumpers.
, 15 MR. PASSWATER: That'is right.
, 16 CHAIRMAN PALLADINO: Let me suggest though in 17 response to Commissioner Bernthal that you look at this plant !
18 and see if you can make a better estimate of!the percentage-of 19 the surveillance tests that involve instruments and those that 1
20 don't and then also your estimate of the amount of human 21 . intervention a's needed.
22 COMMISSIONER ASSELSTINE: Yes.
l 23 CHAIRMAN PALLADINO: . I-think it would be. helpful.
~
24 COMMISSIONER ASSELSTINE: . Particularly with the
- 25. SNUPPS design, sortyof the state-of-the-art.
O 4
. .. . - - . . - = .-. . -
20 1 MR. PASSWATER: Back to the criteria,ithe testing 1 ( '
2 the criteria again that the staff is planning to or may have 3 already done a similar kind of. activity with a BWR plant, my i
, 4 understanding the Limerick plant and the AIF subcommittee j 5 through the resources'of the BWR Owners Group is doing the 6 same thing on the same set of tech specs and we~ plan to get 7 back together later this month to compare notes on that, too.
8 This is really not intended to come up with a new i 9 set of standard technical specifications. It is really more t
1 10 of a validity test on the criteria themselves to see if they 11 are usable by independent groups of people on a given set of 12 technical specifications.
( 13 Next slide, please.
]
14 [ SLIDE.]
i 15 MR. PASSWATER: One of the things that we stated 16 early to the staff was that we thought this process on 17 technical specification improvement would have to be voluntary i 18 for given licensees and although there is a certain amount of 19 generic Work that can be done, it will be up to each licensee 20 as to how he applies that to his given license. *l 21 However, we did intend the criteria to be applicable l o
i l
22 to the existing technical specifications either.the ones that 1
23 have existed for some time as custom'tachnical specifications '
24 or standard tech specs and could be applicable to technical
<.. 1 25 specifications that are under development for an NTOL plant i
1
,.. . - - _ _ , . . . . - . Q; _ . . . . ~ . - .. . _ . . . , . . _ . . . - - . .-,,,--m,_.-.. - --- ,,. - -
-21 1 and they could also apply to new systems or new tech specs or 2 additions to existing tech specs that are coming up in the 1
3 future.
4- Next slide, please.
I 5 (SLIDE.] ,
6 MR. PASSWATER: The process and that was really 7 graphically depicted a couple of slides ago would really j
8 result in a set of improved technical specifications that more ;
9 directly address those things that the operator needs to know 10 about the plant from a minute-to-minute / day-to-day operational 11 basis. i 12 The topics that don't Jamain in the-technical
(. 13 specifications would not vanish. They would go inte some '
14 other program like in.the FSAR if they are not already there.
15 FSAR, of course, is controlled or'those things described in 16 the FSAR are controlled by 10 CFR 50.59. It could go into a 17 QA program which is controlled by 10 CFR 50.54a or another.
18 example would be an ISI program which are currently carried.in !
~l 19 the technical specifications and those could go into an ISI l 20 program which is controlled under 10 CFR 50.55a.
21 So there are existing mechanisms for. controlling 22 those things that no longer would reside within the technical 23 specifications.
24 CHAIRMAN PALLADINO: Our emphasis up to this point 25- seems to be entirely on removing things from technical specs.
c._. _ , . . . . . . . _ . . - _ , . . ._ . . . _
. - .. -= .
9 22 1 MR. PASSWATER: Yes, sir.
,.~,
2 CHAIRMAN PALLADINO: I think that is a worthwhile 3 affort. However, some of the older plants may have some 4 important items missing. Would you contemplate supporting or 5 fixing those up consistent with a standard approach for all of 6 them? In other words, would you consider those things that 7 have to be added as well as those that have to be subtracted
~
8 recognizing that our efforts will probably result in far more 9 being subtracted than added? I am thinking of the older 10 plants that have very much shorter tech specs than the current 11 generation.
12 MR. PASSWATER* We have spent a lot'of time 13 discussing that and we discussed quite a bit with the staff 14 and as I mentioned before, it was anticipated that this 15 program once it is adopted as either a policy statement or a 16 rule change would probably come out like previous technical 17 specification programs on a voluntary basis'on-a 18 licensee-by-licensee basis and it is anticipated that for a .
19 plant with custom technical specifications if they were to opt t 20 to go with improving. technical specifications that they might 21 add some things that they don't have currently in technical 22 specifications as well as deleting some things that are in 23 there now.
24 We haven't really done a detailed look at a given 25 set of custom technical specifications but that is kind of
r 23 1 our feeling, the people who have worked with this for some 2 time.
3 COMMISSIONER ASSELSTINE: If those criteria, 4 are really the right criteria and they draw the right line at 5 what ought to be in tech specs and you have some of these 6 custom tech specs for the older plants that if you applied 7 those criteria things that are not in there now ought to be in 8 there, why should it not be mandatory? Why shouldn't they be 9 told, "Look, just as for the plants where there.is too much in 10 there, we will sweep these things out that-are not necessary 11 for those where there isn't enough, those have to be put-back 12 in.d Why should it be voluntary?
i 13 CHAIRMAN PALLADINO: I understand though this whole 14 matter and correct me if I am wrong is expected to be a 15 voluntary involvement on the part of the utilities so a 16 utility may choose'not to even change their tech specs even if 17 they are comfortable with them and I was wondering if you have 18 feel to what extent the utilities will. request technical spec 19 changes.
20 MR. TUCKER: I think your point is well made and it 21 was our intent in so designing the criteria that it could be 22 used either way. If you make it mandatory, then you change d-23 the complexity if what we are dealing ~with and that was not 24 our intent.
25 It was our intent to so set up the program that it
^
24 !
l 1 could be flexible:enough to be used either way. We recognized l 2 in the beginning when we started dealing with this that that 3 question eventually would be answered. ;
i 4 CHAIRMAN PALLADINO: Which question?
l 5 MR. TUCKER: Whether the custom should be changed or 6 not. .
4 i 7 CHAIRMAN PALLADINO: Do you have any feel for how I 8 many utilities will voluntarily change to the new tech spec 9 format especially in view of all the work? I really don't 10 have a good feel.
I 11 MR. TUCKER: At this point I can't really answer 12 that question. We have had discussions on both sides of the 13 table. I do know that there are some utilities who have 14 already made the decision but those are limited.
15 MR. PASSWATER: I guess we would have to base a 16 judgment on that on the amount of activity we have had with-
- 17 our subcommittee and the amount of activity and the amount of.
18 resources that have been expended by the four vendor-ownern .
19 groups on technical specification improvement. I get the 20 sense that there is certainly a majority of utilities in the f
21 industry that are in favor of some kind of inprovements.
22 '
As far as an exact count, we have not done any'of 23 those kinds of surveys but in our meetings on the AIF 24 subcommittee, we have been averaging between 30 and 35' people 25 coming to the meetings. So I take-that as a fairly good 4
.+,,- . _, ._, , , . - . , . . . , , _ . . , _ . _ . - ,,.,......,.,_,.._.._,,_-..,._m , . _ _ ,,,,,~..,,----.,-.r,
25 1 indication that there is a lot of interest out there.
.A.
2 COMMISSIONER ASSELSTINE: I could certainly see the 3 incentive for utilities, particularly ones with the newer 4 plants, post-TMI plants, that have very voluminous tech specs 5 to undertake voluntarily this kind of effort particularly'if 6 the outcome is going to be as the Wolf Creek review would seem 7 to indicate that you can clear out 40-percent of the LCO's and 8 associated surveillances.
j 9 It is a little more difficult to see to me the 'i 10 incentive for a utility that has an older plant with custom 11 tech specs, the incentive for that utility to come in and say, 12 " Hey, we really want to add some things, some LCO's to our 13 tech specs here." I think that is a little tougher to 14 envision, that kind of voluntary participation.
15 MR. TUCKER: There are two sides of that coin, 16 too, commissioner. A lot of the plants out there have had i 17 some pretty good safety records.
18 COMMISSIONER ASSELSTINE: Yes.
19 MR. TUCKER: If you are Onanging tech specs, you'may l
, 20 be adversely dealing with that. Again, our criteria would !
21 answer that if it is properly drafted and it will. l 22 COMMISSIONER ASSELSTINE: That's right.
23 MR. TUCKER: That is our intent.
24 CHAIRMAN PALLADINO: So you would apply the criteria 25 to measure whether something should be added or subtracted.
o
- . - - , . , - - ,,,.+--...n- - . -- - - - - , . . . +
26 1 MR. TUCKER: When the review is made, yes. It is
> 2 the intent to use criteria both for custom and standard.
3 COMMISSIONER ASSELSTINE: But it would be voluntary 4 as to whether a utility would come in to say either we want to 5 delete or we want to add?
6 MR. TUCKER: That is our proposal, yes. ,
/ MR. PASSWATER: May we go to the next slide, please?
8 [ SLIDE.]
9 Moving away a little bit from the criteria, which, 10 of course, is one of our major efforts, we also identified a t-11 list of short-term or what we call short-term generic
- 12 improvements that could be made,.and I know each of the 13 owners' groups, each of the vendor owners' groups, are also
~
l _
14 looking at short-term type improvements. The ones that 15 committee has taken on are those that would really apply 16 across the board to all vendors.
17 A couple of examples are, one that we talked about 18 earlier, moving lists of components, that's really a ;
19 duplication of what's already in the FSAR.
20 Another one might be -- another one that we have got !
21 fairly good consensus that it needs to be done is to clarify :
i 22 the definition of operability that is in the existing i 23 technical specifications, and that's not a. vendor-specific 24 issue. That's really across all the vendor lines. ;
25 So in our report, we gave a list of those and gave 'I 1
._ ..~._. _. - -. _ . . , , . - _ . _ , . . . _ . . _ _ _ , ,.
27 1 some justifications or gave some proposals for resolving the i a 2 issues and gave the justifications that go along with those 3 proposals, and we are actively working on that with the 4 Technical Specification Coordination Branch.
4 5 Those are just some examples that are in that list.
6 COMMISSIONER ASSELSTINE: Where is the Q list now 7 contained, the list of s6fety-related components? Is that in-8 the tech specs, or is-that in the FSAR or both?-
9 MR. PASSWATER: , Typically in the FSAR. I don't i
10 think there is a complete Q list in the tech specs, although t
l 11 most of the items that are in the Q list are in various 12 technicaIl specifications.
13 COMMISSIONER ASSELSTINE: Okay. But the list you 14 are talking about are the kinds that you described earlier 15 that are tied to particular functions?
! 16 MR. PASSWATER: Yes. We call it -- I'think our 17 report called those, really, " design information details" more 18 than operational criteria kind of things that should be in 19 technical specifications.
20 [ Slide.]
21 We have identified, after we published our report on 22 the 1st of October, we stepped back and looked at what are 23 the things that we-need today, and I'm saying "we" very 24 broadly here, meaning industry and NRC Staff, to implement --
25 now that we-have come out-with these reports and some
1 28 l l
1 recommendations, how do we bring those to fruition? How do we j 2 accomplish these improvements that we have been talking about? l l
3 Number one, I think we need to maintain a priority l l
4 on improving technical specifications. Mr. Tucker mentioned )
5 the number of meeting days that were spent during a six-month 1
6 period last year. A lot of us were tired of going to meetings 7 at the end of that period, but I think the goal is obviously 8 there, and the benefits are there, that have kept us coming ,
9 together and working towards the implementation phase now.
10 And our understanding is that the Staff is also ;
l 11 committed to this, as evidenced by presentations they~have I
12 made to you and their recommendations in the TSIP report.
13 Number two, we encourage the implementation of the 14 criteria and the administrative process that we proposed, and 15 as you mentioned in the introductory statements, we are in 16 favor of a short-term policy statement which would allow us to 17 start doing some of these things, and we still are in favor 18 of, as we stated in our October 8th report, in the long term, 19 a rulemaking process. And we feel that the rulemaking, the 20 drafting and so forth of that, could go in parallel with the 21 existence of a policy statement, so that those two efforts 22 don't have to go in series. They could go as parallel 23 efforts.
24 Third, we feel there is a need to address short-term 25 improvements now. I gave some examples on the previous slide.
29
_ 1 And we have ongoing discussions with the Staff, as do the four 2 owners' groups, as to which of those things -- how do we !
3 prioritize those things? Which of those things should.we 4 start working on now? And again, those short-term things are 5 issues that can take place essentially today without either a 6 policy statement or a rulemaking. '
l 7 Fourth, --
8 CHAIRMAN PALLADINO: What's an example of a 9 short-term improvement?
10 MR. PASSWATER: Okay. On the previous slide -- I j 11 maybe used different terminology, but we called them !
i 12 short-term, and I used the word " generic" there, because those t
.! 13 are really ones that apply to all the owners' groups or all 14 the vendor lines. And examples were, for example, removing a
15 list of components, clarifying the definition of operability.
16 Removing duplications is another good example of 1
17 regulatory requirements. In other words, if we have -- an 18 example would be Appendix J for containment leak rate 19 testing. It's a regulation, and Licensees are required to l 20 follow that regulation. It's also duplicated in'the technical
, 21 specifications, so it's a part of their license.. There'is not 22- really need, as far as the Commission ensuring that those 23 tests are done and that the' containment leak rates are kept to
, "1 24 where they're supposed to be. It can be done with the x
- 25 existence of the rule without duplicating that in the 3
ee - --,,,,,e- ,.,,,-w- . . , . . - --.-..-,ye,,--, -,n- ., ,-..---.w,.,,.- , ,
30 ;
I 1 technical specifications. That's another example.
2 CHAIRMAN PALLADINO: But wouldn't it take an i I
3 amendment or something to --
4 MR. PASSWATER: Yes. It would take an amendment to ,
l 5 each individual license, but it wouldn't require a policy ;
6 statement or a rulemaking, in general, to accomplish that. l l
7 CHAIRMAN PALLADINO: Or a great deal of analysis. l 8 MR. PASSWATER: Yes. And I think the analysis 9 probably already exists in that case. That was required for 1
10 licensing the plant in the beginning. It's just a matter of i
11 . getting that information out of-the technical specifications.
12 COMMISSIONER ASSELSTINE: What's the concern about {
13 the definition of operability? t 14 MR. PASSWATER: The concern is that there are a lot I
15 of instances where the plant operators have questions as to !
16 whether or not a particular system is operable as required by 17 the technical specifications. And it lies in -- I'll get some 1
18 help here from Bob -- but it lies in the definition and the '
19 fact that the definition talks about support systems for a 20 given front-line system that is required to be operable. And 21 it even gets into interpretations as to, for example, if I 22 have an emergency core cooling system that has a pipe whip 23 restraint or a snubber on one of its lines that doesn't meet a 24 surveillance requirement, does that mean the whole system is 25 inoperable? Do I have to declare that system inoperable?
. '31 1 And the subcommittee's recommendation was, we could
. do something with the definition itself that would just make 3 it a. lot clearer and a lot less open to interpretation, I 4 guess.
5 COMMISSIONER ASSELSTINE: Is there a definition now, 6 or did the tech specs just say that it has to be operable?
7 MR. PASSWATER: No. There is a definition in the 8 current standard technical specifications.
9 COMMISSIONER ZECH: But you are saying it's too 10 vague? ...
11 MR. PASSWATER: It's too open to interpretation, 12 yes.
13 COMMISSIONER ZECH: And whose responsibility is it 14 to change it? It seems like that ought to be ours.
15 MR. PASSWATER: Yes. I mean, we are obviously 16 willing to help in that area. We made a recommendation for a 17 change in the October 8th report, and it's one of those things 18 on the list that, as I said, we are working with the Staff now 19 to establish priorities on.
20 We feel that one should be pretty close to the top 21 of the list to get straightened out.
1 22 COMMISSIONER ZECH: Yes. I've reviewed ity too, and 1
{
l 23 it does ssem to me that -- I would say it's probably too 24 vague, but also I think certainly you should work with the s._
25 Staff, but it seems to me that the Staff ought to try to come
_=]
l i
32 i 4
1 up with a little bit more definitive-definition of j
2 operability, and it probably would help clarify some of these l 3 things that we are talking about.
4 COMMISSIONER ASSELSTINE: What is the definition 5 that is in the tech specs now, the new tech specs for 6 operability? ,
f 7 .MR. PASSWATER: I don't know if I can quote it I
8 verbatim, but it says something like, "The system or component H 9 is considered to be operable if it meets" -- well, it's as 10 determined by meeting its surveillance requirements, and there 1
11 is also a statement in there that says, also all its 12 supporting systems have to be functional, I think is the word
( 13 that's in there.
a 14 COMMISSIONER ASSELSTINE: It doesn't sound like it's 15 a vagueness problem. It's more like it may require some 16 things that aren't necessary to assure that the system will 17 perform its function if called upon to do so in a particular 18 instance.
19 COMMISSIONER ZECH: As far as I'm concerned, it was i
20 vague to me, especially during surveillance test-intefvals, aus 21 I recall, one specific thing, and another was during or 22 regarding outage times. It could be' interpreted in different 23 ways, and that's the clarification that seems to be needed to _
24 me. There may be others, too.
25- -MR. PASSWATER: It could be more' specific, I guess
l 33 1 is the bottom line.
- - O i 2 Let's see, we were talking about -- the next slide.
i 3 (Slide.]
4 Those were -- we thought we needed to get priority 5 on those short-term improvements, and we're certainly doing
, 6 that, and I think the Staff is, too.
i j 7 Next we.are providing the resources to support a review of probablistic-based methodologies. The Staff has j 9 done that in scme cases. For example, the Westinghouse l 10 owners' Group submitted'a methodology for determining allowed 11 outage times and surveillance intervals for the reactor 12 protection system, a generic report on that, and that's been
< 13 reviewed and' approved by the Staff.
14 There are other such efforts underway right now, and 15 this bullet just emphasizes the need to keep that support 16 going, both from the industry and Staff _ sides.
17 The next one was to support the revision to the ANSI.
- 18 standard for technical specifications. We feel like that's
- 19 necessary to clean up some of the problems with standardizing 20 on how technical specifications should be written, guidelines 21 for how they are organized, and things like that that go along 22 with that ANSI standard, and we feel like that' support should 23 be provided. i l
24 I indicated earlier that we have had -- the chairman {
\
25- of that group has been an active member of the subcommittee,
- l
d 34.
- 1 essentially since the first meeting that we had. So that's --
2 we're working very closely with.that group.
3 Finally, there is a need, and the Staff agrees that 4 we need to address the approach to improving the bases for the 5 technical specifications and determine what should be in those ,
6 bases and whether they are to help the operator.or to do other 7 things that are required in the daily operation of the plant.
8 And that's really going to go a long way toward improving, for 9 example, an operator's understanding as to why he has to 10 maintain a system operable.or whatever;is -- there!s a lot of !
11 room for improvement in the bases to existing technical 12 specifications.
l I. 13 MR. TUCKER: I'd like to make it clear, as Harold is l l
14 saying, that these efforts are underway, and both parties are i
15 working on it, we and the Staff. So there is no conflict
. i 16 there as to things that we are working on. I I
17 MR. PASSWATER: I'll turn it back over to I
18 Mr. Tucker.
I 19 (Slide.]
20 MR. TUCKER: In conclusion, I would like to-stress 21 our continued support for improving the technical !
22 specifications. We are now entering what I consider to be the
, 23 most important phase of realizing the improvements, 24 implementation of the recommendations addressed in the TSIP L..
25 and AIF reports on this subject.
D. '
35 1 In summary, we make the following observations and
.m 2 recommendations:
3 We endorse the issuance of a policy statement on l l
4 improving technical specifications. We encourage its issuance l )
5 as.soon as possible and are prepared to assist where s 6 appropriate.
, 7 And having issued the policy statement and while 8 gaining the necessary confidence in the criteria through its 9 use, we recommend rulemaking go forward in parallel to
{ j 10 formalize a standard for determining what should go'into 11 technical specifications.
12 As you.have heard during-the Staff briefing on i
P 13 January 21st on this topic, they support this approach; 1 14 however, improvements that can be made now should not be 15 delayed until changes in the regulations are made.
l 16 The short-term generic improvements, including those l
17 in Appendix G of our report, can and should.be addressed now.
18 We are prepared to continue discussion on proposed
- 19 improvements with the Staff as soon as possible. These 20 suggestions do not require changes in the regulations.
21 Sufficient resources to review and approve 22 probablistic-based requests'should be provided by the NRC.
23 These reviews should not be delayed, but proceed in parallel 24 with the other suggested improvements. In addition, we should
~
! 25 continue to develop the necessary probablistic methodologies j
.-. . , - - - , . + , _ , -
w , -- , - . _ - . ,, , . . - , , . . , , , , - - , , - , - - . . - - - . ,,
36 I- 1 to support improvements-in technical specifications.
l 7
2 Existing documents, such~as FSAR procedures, QA plan l
'l 3 and others, and the' associated regulatory and administrative ;
4 controls are sufficient to safely control those areas no l 5 longer located in the technical specifications. !
6 The working relationship between the AIF 1 1
7 subcommittee and the Staff established during the evaluation 8 stage should continue during the implementation stage.
t 9 Sufficient by both the industry and the Staff to support the
- 10 activities in this phase should be provided, and we are ready 11 to do that.
12 Additionally, the Staff should work closely with_the 13 owrers groups and individual utilities, as well as the 14 suLcommittee, to develop reasonable schedules for timelir 15 reviews of existing and future' requests.
16 I think it is significant that each of the four 17 owners groups sent letters to Mr. Denton supporting the
/
18 recommendations and conclusions contained in the AIF 19 subcommittee's report. It is my understanding that copies of.
20- these were made available to you yesterday.
21 Now this concludes our remarks. Again, we 22 appreciate the opportunity to express our continued support 23 for improving the technical specifications, which we consider 24 to be very important.
25 CHAIRMAN PALLADINO: All.right. Thank you, 2
i
. . - ~ . - . . - . ...
37 1 Mr. Tucker.
g i 2 'I wonder if -- is there moie?
1 3 MR. TUCKER: That's all of our presentation.
4 CHAIRMAN PALLADINO: All right. I'd like to make a j
5 comment, and then I have three or four more remaining 6 questions.
(
7 It is certainly clear that tech specs have become so 8 voluminous that they have the potential for diverting the 9 attention of operators from the problems he may see on the
, 10 board'in trying to meet the tech specs. So I think this is an 11 effort that is probably long' overdue, and we very much.
12 appreciate the efforts of industry to cooperate with the Staff
!' 13 on this matter.
I 4
14 Now I'm going to ask you some questions that will l
- 15 make you wonder if I believe the other side, bat let me ask 4
16 them. Not all of them are in that way.
17 We talked about custom tech specs and the fact that 18 changing over to them would be voluntarily, and I asked you to 19 what extent you thought that they might make the change. But 20 how about standard tech specs?
21 If you develop standard tech specs, would you expect 1
- 22 all the utilities could use that to change over to it? What 23 motivation could we supply in a policy statement to encourage l 4
i s 24 that? l l
25 MR. TUCKER: -Let.me respond, Alan, and then you can )
i 6
t
-b
_38 1 pick up_if you need to. , -
2 I go back to my original response. I think if we 3 come up with any document that makes it mandatory, then that 4 automatically changes the complexity of what we are trying to 5 accomplish.
i 6 CHAIRMAN PALLADINO: I appreciate that. I- was 7 trying to look for, what can we offer to encourage them, or i
8 have you got any thoughts?
9 MR. TUCKER: My opinion and my conclusions were 10 drawn in discussion with other members of the-industry. If we i
11 get the criteria and by example prove it to be appropriate for 12 that kind ~of decision, then that in itself will be l
l 13 encouragement to the utilities with custom tech specs to give
(
i 14 consideration to it.
I 15 I have a real concern. I think there is concern in -
i 16 the industry, if we try to come out with-a specific standard '
17 document that says, "This is it," then that would be ;
18 discouraging in itself.
l ,
j 19 CHAIRMAN PALLADINO: I didn't follow you.
20 MR. TUCKER: A specific document that says, "This 21 must be done." If we get the criteria by which it can be 22 accomplished, then that in itself is encouraging; the otJ1er is 23 discouraging.
- 24. CHAIRMAN PALLADINO: But I would expect that if we 4
25- were dealing with some standard tech spec, you have to apply J
-+e~ r cr- -
--,++--e+e- -
em aw.w--r w -r 7, y ,- ,, -- c..,<- ,-,--~~w sw .- e -v*w----~ = = - *-
39-1 the criteria and say, "Now, look, here is all the reductions.
.-v 2- Look at the reductions tnt made that can simplify the work your.
3 operators have to do," that would probably be one of the best 4 encouragements. '
5 But if they adopt a tech spec, the standard tech 6 spec, I would expect that they would adopt it all and not try 7 to modify it for their' plant because they think that they'd 8 like to have more or less.
] 9 I don't know what your views are on that. But if i .
10 you work on a standard tech spec, and there are X number of 11 plants that can use that standard tech spec, and a certain 1
j 12 fraction o'f them say, " Yep, we'll huy it," vculd they not have i
j 13 to buy it with all the changes,.or do you envision 3
i 14 tailor-making this for each user of a standard tech spec?
15 There are some things you're going to have to 16 tailor-make, I'm sure.
! 17 MR. PASSWATER: Sure. I think that's the 18 distinction. And really it's, for any given plant -- no 19 existing plant exactly matches the standard technical 2
20 specifications. .There are always some deviations because of 21 the plant design, operating characteristics, and so forth.
22 And I think, as Mr. Tucker said, if the Commission can endorse 23 those criteria, and then a, plant could use those, and whether 24 he starts with a. standard technical specification based on the 25 criteria and tailors those for his given plant, or if he takes
,..---n, - ,n
~n+,,,..,.s . ,...r.a.-.,- nr.- , , , , , , . , - , , , , . , - - , --.+-,..,cne .~..r, ,n-- ~ ,
1 %
4o 1 the. criteria'and applies them to some other set of technical
, -~3 .
. 2 specifications and adopts th'ose for his plant, I think that's 3 really kind of a non-issue as far as.how he gets there.
4 But it's really the establishment of the criteria, 5 so there is some basis for what is contained in the technical ,
6 specifications, that are a part of that plant's license.
i
- 7. CHAIRMAN PALLADINO: Does this mean that between 8 you, industry, and the NRC, you're going to have to look at 9 every word in every line in every tech spec, including the 10 standard tech specs, or those that are trying to apply 11 standard tech specs?
e 12 It would seem to~me a very horrendous undertaking.
13 MR. TUCKER: If I may respond to that, Mr. Chairman, i 14 in reality that's where we are, to a large degree, today.
! 15 CHAIRMAN PALLADINO: Yes.
16 MR. TUCKER: What we are trying to do is establish l 1
! 17 -- if you want to call it a standard -- a standard that sets
! l 1
18 the criteria for what shall be included in tech specs and how )
4 19 you make that determination.
2
! 20 And since there is such'a difference in specific 21 plants, then that would be the standard way of determining i
22 what's in there.
I 23 CHAIRMAN PALLADINO: That may be the situation 24 today. But tech specs have been written over a. series'of 12 5 years, and if we were to go back and start to look at all of i
,-,,-;m, ,v-,,r,-err- - - , - ,----r..,w ,--w.--- , , , ..m,-r,y,.
, ,-w-, , , w,,-- .,v,,-,,,- p.,~w. r-- a - < yr,vo-,---,----
41 ;
i l- .these all at one time, I would think it would take significant j
(>
E j
2 resources. And that's what I was thinking about, and now with 1
-l 3 the projected severe cuts in our budget, despite the comments i 4 I made earlier, do you feel that this is a worthwhile effort 5 to such an extent that we ought to give it priority over other 6 things that we do?
, 7 I know that's a hard one to answer.
l 8 MR. PASSWATER: Well, we think it is definitely a
$ 9 very worthwhile effort. And as far as using the criteria to 1
10 split the technical specifications, I think the Staff 11 indicated in the example that'they did on the Wolf creek tech 12 specs, I think they said they spent about two man-months of-(- 13 their time on that. We sent about, on the industry side,.I I 14 think it was three-day meeting, and there were probably five 15 or six people involved.
16 Now these were people that obviously had a lot of 17 detailed knowledge of that plant and the FSAR and the existing 18 tech specs and worked on it.
4 19 But the criteria, once they are read by someone who 20 understands them and has a good handle on the licensing design 21 basis for a given plant, they are fairly easy to use, and it 22 doesn't require a great amount of resources to use those, i 23 CHAIRMAN PALLADINO: Well, I don't mean to imply-by
\
.2-4 my question that I still don't support the change -- I mean, s
25
~
that we shouldn't look at this -- but wa are going to have to 1
, , , , , , , . . , . , , - - . . - , ..,--.e- ,.n r- - ,- . . , - , -n.-,,,-c -.,.,,,,,.,.,--nr - . , , - - .- ~ - - .- .
i
, 42
~
1 look at many things if the budget cuts ara made.as-large as m.
2 some that we have heard about from the Gramm-Rudman-Hollings 3 viewpoint.
4 MR. TUCKER: I think in reality'we are confronted 5 with priority utilization of resources anyway. In today's 6 situation with a tech spec change, it perhaps may take more 7 resources to get that pre ess than it would under this method, 8 where there would be standard criteria for selection, and 9 there would be precedent set on specific plants that other 10 plants could use as a part of that review process by the 11 Staff with the standard criteria.
i 12 CHAIRMAN PALLADINO: Well, I think that's a question
/
(
13 that we'll have to address more internally. But the reason I 14 asked about motivations, if we can get everybody or the users j 15 of the standard ones et least to change over, I think then d
16 we'd be getting some benefits that were really worthwhile.
17 MR. TUCKER: We have done a little bit of work in s
. 18 that respect. There are a sizeable number of those already-19 identified by the individual owners groups, of things that 20 should be considered, and that would give you a format for 21 consolidating through the owners groups, then, and we can 22 identify the participants in that and perhaps reduce the
- 23 number through that process.
24 CHAIRMAN PALLADINO: Well, let me ask two more 4
25 questions, and then I will turn to my colleagues for other
. ew w -*rw- ,--.e---e-- ---4, - . ..--------.m-- ,-w + - - - - - - . . - - . . - - - - we,---%-4 + e --. . . . -..-,,w..---,,-y -y. ,gwa-.--4 -~,,1 ,
43 1 questions.
' (3 2 By reducing the number of tech specs, we will'be 2 relegating more safety decisions to Licensees, or at least it 4 would seem to me that we would be doing that.
l 5 Are there any plans for improved Licensee safety 6 review processes? For instance, will onsite safety review 7 committee evaluation criteria be made more specific?
I 8 And then it's not clear to me what role NRC will 9 have or what access we'll have to Licensee evaluations prior 10 to implementing plant modifications that may come out of such
~
]
- 11 evaluations.
1 1
12 I know I asked you more than one question there, but 13 they all have to do with improving the Licensee safety review 14 process and what role we'd play, and would they be more 15 specific.
15 MR. PASSWATER: As part of this subcommittee's 17 efforts and, as far as I know, as far'as the owners groups 1
i 18 efforts, we haven't specifically addressed any new criteria or i l
19 guidelines as far as the typical onsite review committee or J
j 20 offsite review committee reviews, safety reviews, are done. 3 21 Existing standard technical' specifications prescribe l 22 those Nhings that those groups are required to look at, and' j
23 they essentially follow the guidelines of 10 CFR 50.59. H 24 I know at least in our case with our plant, I think !
25 [
there is a concept-that once it goes out of technical '
. l i
4
,-s e . -y- ,. -- -
.e v- . *+ -e-e- --w+r, _ > + - * - - - - + +
- 44 1 specifications, it's going to have a much less strpctured-m
'- 2 review process. At least in our case, that review process for i
3 changes, whether it is in or out of the technical 4 specifications, is fairly well structured right :now, and it is
! 5 looked at on some kind.of a periodic basis by the Region, that 6 whole process of design changes under 50.59.
7 And our concept from the beginning, as far:as-the 8 subcommittee is concerned, is that we didn't really think we q 9 lost anything as far as adequacy of review in removing-10 something from the technical specifications. We were 11 obviously trying to reduce some of the administrative burden 12 associated with those things that are in there now, as.far as ,
13 changes are concerned, but we didn't think we lost anything as l
4 14 far as overall contribution to safe operation of the plant.
1
- 15 CHAIRMAN PALLADINO
- Well, I am heartened to hear j 16 that you give the same attention to the safety issues whether i
17 they are in or out of the tech specs. But I think it's 18 something that we are going to have to look'at as this thing l
19 develops. I almost said after it's all cver, but it will'ba a i t 20 long time being over.
21 Let me ask one other question: Recently there have 22 been a lot of discussions in a lot of different places about i
23 the merits or shortcomings.of testing during power operation.
24 - Now the Japanese, though, do all of their testing in i
25 their shutdown period. I think it's currently.three months or
_ ._ ._ _ J
, ~.
45 s
1 whatever.
2 Has AIF looked at the Japanese approach and formed I
- 'l 3 any opinion on it, rather than doing,all'the surveillance .
i 4 testing you would do while the plant is operating? (
5 MR. PASSWATER: The subcommittee that we have been 6 discussing today has not. We have had discussions,on whht the 7 Japanese technical specifications look like. At at least o e 8 meeting, we had a representative there who was in the group j 9 that went to Japan, and they looked at technical 10 specifications there, and there are obvious differences f
11 between what we have in the United States today versus what f
12 they have there.
- 13 But as far as looking at a different approach to 4
14 outages and testing during outages versus power operation, we 15 have not.
16 Mr. Tucker might be able to fill in with something i
17 on that.
18 MR. TUCKER: You made mention of.the industry group 19 that went to Japan. INPO put together a group that went over 20 specifically to visit Japan relative to maintenance and other 21 areas of the plant, selected individuals from the utility 22 industry that were considered to be relatively expert in i 23 specific areas, and they dealt with their counterparts on that 24 visit.
4 25 We happened to or Duke Power company happened to l
- , - . - r,- e- v e,m -n, ,-,- --,, yw-- --
, - . .. o
- 4, w
- 1 provide one of those people, so we're very much interested in im 2 what they found when their reports came.back. That l
3 information has been distributed within the industry with the 4 specific intent of that review and recommendations for review I l
i 5 developing hy that group for industry to consider.
6 CHAIRMAN PALLADINO Are the-groups looking at it?. ,
4 7 MR. TUCKER:- It has been distributed. Now each 8 utility has that available to them, and that was the intent',
9 to make that available for review.
10 I can't address specifically how each utility had 11 reviewed it, but there was'some very interesting information I 12 there and philosophy on how they conduct their business.
( 13 There's quite a bit of difference, quite a bit of difference 14 in philosophy there and this country. 4 j 15 CHAIRMAN PALLADINO: However, I think it is worth 16 looking at it in some significant depth. I don't at the j 17 moment have a suggestion how to look at it, except to exhort
- 18 industry to look at it, and I guess I can exhort'the Staff.as 19 well.
1
- 20 MR. TUCKER
- That was the intent and_ purpose,'to do 21 that, and.I can only speak, for example, for my own utility, 22 the extent to which we have looked at.it, and we have lockad !
23 at it in depth and, in fact, sent somebody to go back for a 24 second time to specifically look at things. And it was
~
25 interesting to compare plants of the same vintage as our I
I
,g, ,,, -
.,--r, ,r e 7-,.-o.y'y -,-%, g. p.,,., - - , - , - . - m ,--ay,,,---yer a, - , ,r , --,,,w-my,c.vp,,. .s--,wo.c . g e n ,e e, ,.--.p..cw 3. wy- , . ,,
t 47 .
1 plants and comparable records.
2 Now when you get'to performance records and total 3 results, there is very little difference, very little 4 difference.
5 CHAIRMAN PALLADINO: Well -- ,
6 COMMISSIONER ASSELSTINE: . For Oconee, yes.
u
- 7 MR.. TUCKER
- . Very little. difference.
8 [ Laughter.)
9 COMMISSIONER ASSELSTINE: The answer'might'be 10 different if somebody else~was sitting in that chair.
. 11 [ laughter.] >
12 CHAIRMAN PALLADINO: Well, if we were to look at 13 reportable events every night, you would be amazed at the 14 number of scrams or ESF initiation that comes 5about because:of -
t 15 some surveillance test that was run that day.,
- 16 But that doesn't say it's' wrong. -Iamjust,{
17 interested. FacedwithasignificantlydiffehentphIlosophy,
?
- 18 I think it is appropriate to ask, why1. do'they go that way when i -
19 we go this way, and what are the pros'and cons.
i 20 MR. TUCKER: I agree with you, and.I get'the same 21 concern every day when I look at those reports and see how t
22 many scrams we are experiencing in-our industry. And.I think ,
'- .)
23 what we're-talking about t-sty will-help us in improving that. i
! l 24 CHAIRMAN PALLADINO: . I.think so..
= 25 Okay, let me turn to my colleagues.
,s- ,-c* n-s.,- w pa.e.-m-,,. -.w--..w+- e ,ww.- vr +-v-w y--+w .w-,r e--*ar n ~ts*t --e-
48
-l Jim? i 2- , COMMISSIONER ASSELSTINE: Just a couple.
3 Could-you sort of walk me through how, say, an LCO 4 or surveillance requirement that would be removed under this
/
5 approach would then be-handled? Say you had an LCO for a ,
pap:icular ' system, which required to either restore the system
~
6 7 within a specified period of time or. shut down the plant and 8 repair it.
9 If that LCO were to be deleted from the tech specs, i .
i- 10 where would it appear, and how would it be treated?
- , 11 MR. PASSWATER
- That depends on the particular LCO.
- 12 We've looked at a number of examples.-
13 The things that are in there that maybe -- well, 4
14 let me take some examples. Maybe that would be the best way !
m 15 -!
to approach it. l 16 We have LCOs now, sema LCOs that are in the'
{
17 technical specifications that are strictly there so that their 18 associated surveillance can be carried in the technical 19 specification. For example, the specification on steam 20 generator tube integrity. The LCO and the action statement 21 really -- it's kind of academic -- they're-there because the 22 format of the tech spec says, to have a surveillance in there, 23 it'has to go with an LCo. And'it's really in there because of ,
24 the surveillance.
- 25 Surveillance requirements are also carried -- for
i 49 1 ' those kind of things are also carried as part of a. plant's 2 ASME code requirements that are covered.in the regulations.
3' There are obviously plant procedures that cover that, and 4 they're also described in the'-- as part of the FSAR.
5 So for that example, if.it came out of.the technical 6 specifications, it might be a requirement, if it came out of.
7 the technical specifications, to put some additional 8 statements into the FSAR that cover the associated actions and 9 specifics of the surveillance, into the FSAR, and then that 10 would be controlled under 50.59, since it's now something 11 described in the plant's SAR. And, of course, it would still 12 have the other regulatory controls over an ASME' Code type
!( 13 program.
'l 14 Some other examples that would come out are systems 5 15 that don't meet the criteria. They're no,t part of the primary.
16 success path, or they're not required -- essentially they're 17 - not something that the operator immediately needs following an 4f 18 accident, a design-basis accident.
19 Some of those systems could have the same kind of 20 controls. They would essentially go into the FSAR, and there l 21 O might be some requirements to put some programmatic things .j 22 into the FSAR that aren't there now, depending on the d 23 particular plant. In some cases, they're already in the FSAR, ,
i 4
24- and they're already controlled under 50.59, as well'as being )
1 25 in'the technical. specifications.
'. 1 1
4 u
l
- l 50 1- So there are other issues that are in1the technical A,
2 specifications that -- well, for a'given LCO, I: guess'most-of-3 those cases would, for LCOs, would-go into the FSAR from the 4 technical specifications and be controlled undar 50.59.
S COMMISSIONER ASSELSTINE: With 50.59, would that i 6 mean, then, that instead of, say, having an LCO which says you
- 7 do the surveillance or show that the equipment'is operable, 8 and if not, you have to restore it within a specified period 9 of time, this would enable you to say, "But, well, if you 10 can't do that, you can do an analysis to show that it's still 11 okay to operate." So 50.59 would give you that flexibility to 12 continue to operate the plant with that degraded condition?
13 z[' MR. PASSWATER: It would be a difference of a 14 utility doing its analysis that the plant-is okay. For 15 example, if there is some reason that they cannot do the 16 surveillance that's required to show operability of that 17 system, but maybe they have other inetications that it is
- 18 operable, and if it's in the technic.tl specifications in order 19 to meet that surveillance requirement, it would require a
! 20 license change if it can't be done in accordance with the 4
21 prescribed details that are in the technical specifications.
- 22 If it were outside the technical. specifications, 23 then it would require that the Licensee do a safety review of 24 that against the criteria in 50.59 to determine that he is not 25 increasing the probability _of an accident or increasing the I
... ..-- --. _. , ,,. ....- - - , - . _ _ . . . . ...~.m, . , . . _ , . , , - - . ._._,__,L. .. c,_ . . _ , .. , ,,... J,,
51 l consequences'of an accident or whatever, and then you can
-s, a
2 demonstratively control that -- cont'ol r that himself, rather i
3 than having to request a license change. That would be'the 4 difference.
5 COMMISSIONER'ASSELSTINE: You mentioned your 6 experience in applying 50.59 and the attitude that you all.
7 take to that.
i 8 Do you think that there is a fair degree of 9 uniformity and consistency within the industry in terms of the .
- 10 seriousness of the approach to the 50.59 process and the 11 extent to which you do full and fair'and effective analyses?'
12 Or do you think there is some variation in performance?
13 MR. PASSWATER: I would suspect-there.is some 14 var 3ation. I don't know directly, in answer to your.
15 question. I suspect there would be some variation.
.sI 16 I don't think it's a situation.where one can ignore ,
17 the requirements of 50.59 obviously. I think it is something i '
18 that is enforceable and is routinely enforced by the Regions.
.1 j 19 As far as uniformity of how the reviews.are done, 4 20 the pro'edures c for doing the reviews and so forth, I would l J
21 suspect there are some variations. But the bottom line is,
, j 22 those criteria for 50.59 would have to be addressed for making b
23 those changes from what has been reviewed in the FSAR. ,
24 COMMISSIONER ASSELSTINE: Do you have a sense for.
~
25 what difference this would make in terms of the' inspection 4
- , . , , - , -, -, .. -.__+--w, . . , . , , , , , .~.-r. . , , . . . ,, . - - , , - - - . . . , , , . . , , . - .....m.-, ,
T 52 1 burden by shifting much more over to the 50.59 process -- in O
2 essence, being able to rely on an LCO and a tech spec where 3 you all have to make the judgment that.either you need it or 4 you don't?
i 5 MR. PASSWATER: . Well, I'll have to speak, I guess, 6 from my experience. There again, those changes that the i
7 utility does now that are in the tech specs go through 8 essentially the same process, just because of our procedures, j 9 and it has to address 50.59 as well as -- of course, it's an i
10 automatic on the 50.59 -- if it involves a tech spec change, 11 it has to get prior Commission approval.
12 COMMISSIONER ASSELSTINE: Right. But now you shift-l 13 over to the second part.
14 MR. PASSWATER: Yes. That means it comes in to the 15 NRC Staff here, and they' review what we are proposing to 16 change. If it came outside the tech specs, then we would 17 still do -- our internal review process would still be the 18 same. And as far as, would that increase.the inspection .
19 burden because now the Region has more of those things to look I 20 at, I think they have -- I really-think the inspection burden 21 is the same, because that process is ongoing with those 22 changes now, how they determine what sample size they use and 23 so forth, to assure themselves that the process is. working and i . '24 that the Licensees are using --- procedures are adequate and so 25 forth. I'm not sure how they determine that.
. . - . - .. - .- _ ~, _. . -. . . _. . ., --
7 53 1 But I guess the question is, would the Region feel
~2 like they had to increase the number of things they look at at 3 the utilities, because now some of those things that were 4 coming into NRR for review are now not coming to NRR for review?
5 So that's a tough question.to answer.
6 I don't know, I guess, without knowing what their 7 criteria are for how many of those things they look'at.
8 COMMISSIONER ASSELSTINE: Okay.
9 MR.-TUCKER: .May I comment on that, please?
10 COMMISSIONER ASSELSTINE: Sure.
11 MR. TUCKER: I think it would take a period of 12 adjustment, but I don't think the burden would be increased.
r
(
13 And I'd like to point out that our main objective is to try to get the technical specifications so defined that the operator 14 15 can use them effectively and assure safe operation.
/
16 The transition of the inspection burden will take 1 17 some period of time. But after that adjustment is made, those 18 documents are just as enforceable as tech specifications. So '
19 there is a period of time of adjuctment, but I don't think-the 20 burden would be any greater. ;
21 It may be a different point you have to go to. The i
- j. I 22 burden on the industry would remain the same. We've still got !
23 to live by the regulation,-regardless of where the document 24 lies.
~
J 25 But we are trying to get the technical
_ _ _. . . . _ . . _ _ _ . _ _ . - . . _ . _ _ _ _ _ _ . . _ . . . _ . , . . . . , _ _ _ _ . . , _ , . . _ , , ~ . , , . ...l
~.% -
54 1 specifications reduced to the point where we-are'sure the 2 operator, that he has the information he needs to operate the 3 plant safely. We are not as. concerned that the requirement 4 for inspection be in that document versus another~ document.
5 Consequently, I think that the burden eventually is :
6- going to level out.
7 COMMISSIONER ASSELSTINE: ' One question on the 8 criteria. The emphasis in the .cond criteria on design-basis.
9 accidents, in the third talking about the primary success path
. 10 for mitigating a design-basis accident, to what extent does 11 one or the other or the combination of those two elements 12 reduce the capability to be able o deal with j( 13 beyond-design-basis accidents?
14 For example, would hydrogen control systems in ice 15 condenser plants be out under this? I think it would.
16 MR. PASSWATER: It would come.out, I believe, under
, 17 the criteria. '
4 18
~
1 COMMISSIONER ASSELSTINE: It strikes me that what
) 19 this does is reduce the capability to deal with the kinds'of 20 accidents that are the ones that we are all really concerned 4
i 21' about, the ones that go beyond the design basis.
-i 22 MR. PASSWATER: Again, if I take that example, the 23 hydrogen control system, if it is now in the tech-specs for an 24 ice condenser plant, and now I take it out of the tech specs 25 because it doesn't fit the criteria, it.still is described
, , - , . . . - - , . . -----,J...--,A - -*_.--,--,,m -..- , , , , ---,4--
- 55 1 in the FSAR, and its purpose.and its objective andLits q
2 operational requirements are still described in the FSAR.
3 So that is a commitment on the Licensee for that 4 plant to have its system available. He couldn't go out and i
5 remove the system tomorrow without going through that review 6 process. All it does is, it says to the operator, "This is 7 not one of the systems that fit this criteria that'are of an 8 immediate, urgent kind of need for him for those design-basis i 9 accidents in the FSAR."-
j 10 That's essentially the difference.
11 COMMISSIONER ASSELSTINE: I guess what'I'm getting 1
12 at is, to what extent would the criteria and the-approach .
13 allow the operation of plants with systems and compona.nts in a i
14 more degraded condition than is permitted now? To what extent 15 is that the likJ7 outcome of this, that we are likely to see
, 16 the plants operating with some systems and components in a i
17 more degraded condi tion than the tech specs wa0;d permit now?
18 MR. PASSWATER: Well, again, I have to go back to 19 what my experience has been. I don't think it relieves or i
20 allows any less or any more degraded operation if the process j
i 21 is carried through, as we have described it and as we have 22 defined it, than exists right now.
23 It really just removes some of those requirements s 24 into a different place from.the technical specifications, and 25 I guess that's something that no one would know until the 4
, , < , , , . , - , - , , - , - , . - - . ,- , - . - , - -._n e , v., , - - - - ---
4 .w-.-e.,..,wn----g m, .e--rv.-g ~-~ ~ ,e--,w + r~- - - . .- ~,,,wm--,-,g-> - ,-
56 1 system actually went into being and was used for awhile.
n 2 But if it is applied as inte-ded, it wouldn't result 3 in any more degraded operations from what exists right now. ,
4 COMMISSIONER ASSTLSTINE: Is it fair to say th.t a
- 5 look at the previous exper'.*ance with the 50.59 process and the 6 extent of performance under that would at least give us a clue 7 as to what es can expect to see under this approach?.
8 MR. TUCKER: I think in reality, getting to the -
l 9 direct question you have asked, there probably will be some 10 tradeoffs. There will be some that, by doing away with 4
11 certain things, we will be enhancing, to address the question 12 you are asking. Some others may move a little bit in the i 13 other direction.
t i 14 So I think if you look at the total scope, there 15 will be some tradeoffs. But I am convinced, as we have been 16 involved in this, that if it's going to be anything, it will 17 be an improvement overall, not a degradation of safety at all.
i 18 COMMISSIONER ASSELSTINE: I certainly thing you are 19 right in terms of improving the operator's ability to j l
20 understand what they are responsible for and what is going on 21 in the plant. I agree with that.
22 I guess what I'm trying to get some sense for is how 23 much of a tradeoff there is involved in'this, how much would 24 be shifted over to this new process, and to what extent the 25 new process would give --
a a d. ...L . - _ __A_4 = 4 57 1 MR. TUCKER: Well, in reality, we are not shifting s
2 it over to a new process. The process has been'in place and
- 3 been tested. Your custom plants now use_that. So the system 4 is well tried.
1 5 It's a matter that more will be in-that process than 6 is currently in it, because what comes out of the tech specs 7 would be in some other document requiring that process.
8 But I think they have proven that the use of that is 9 there.
10 COMMISSIONER ASSELSTINE: Okay. Thanks. That's 11 all.
12 COMMISSIONER BERNTHAL: I don't really have any t' 13 questions. I would just say that this is perhaps from the
]
14 standpoint r,f outsider, maybe even insiders, one of the more 15 arcane subjects that this commission has been asked Eo deal-16 with.
17 But in many respects, as you will understand better 18 than anyone at this table, those of you with direct operating 19 experience, it's one of the more important things that has 20 been undertaken. It may not be high-profile, but it mey have 21 more to do with safe operation of plants than many other 22 things that we are considering..
i 23 And on the'othe~ hand, there are probably a few 24 things that are going to require the kind of input that only 25 you and the industry, with operating experience, and our Staff
. _ , _ - - _ - - _ _ _ . _ _ - _ . ~ . _ - _ . _ _ _ _ . - _ . _ _ . _ _ - _ . _
~
58 d
1- can provide us-on the commission with. And I appreciate.that. 1 2 Nobody at this table, with the possible exception, I-t 3 guess, of Lando Zech, on a rather smaller-scale plant [ has.the
.4 kind of direct _ experience that you do with operations. So 'I t
5 would urge you to press on with it.
4
- 6 Let me explain for a moment the concern that I have 7 about limiting conditions of operation and this cuestion of 8 instrumentation and instrumentability, and I'll just toss the
.i 9 comment out for what it's worth. -
10 I'm always troubled by circumstances where we hear, ,
J 11 for example, that some plant has been operating in violation 12 of tech specs, quote / unquote, and the tech spec turns out to 13 be something like maybe a door left open on containment or
- 14 some similar thing, or it might even be something to do with i
, 15 steam generator tech specs..
1
- 16 I have yet to be convinced that most of the things f 17 that I have been able to see cannot be instrumented, so that 18 it's virtually impossible to proceed'with the plant running d
19 for a week in violation of this or that tech spec.
20 Now I am sure you could name one or two things, but 21 my concern is that when this process is over with, that we try 22 and move toward plants where we are fully instrumented, so i
23 that we know, as nearly an is possible, whenever any of those
- j. 24 elements fall outside of the limiting conditions of 25 operations, and we don't have to wait'for the next refueling-i i
l
-_- . _ _ _ .._ -. . . . . ~ . - . . . . _ _ _ .
[. 59 1 outage or whatever it might be to test that.
.m, 2 That's simply a broad ~ philosophy-that I have that 3 does not. reflect, of course, the day-to-day operating-4 experience that some of you have. But-that was the reason-for 5 the earlier question, and I am, therefore, particularly 6 interested in having the answers to the questions that the.
7 Chairman then later articulated.
8 That's all that I have to say.
I 9 CHAIRMAN PALLADINO: Okay, thank you.
10 Mr. Zech?
I 11 COMMISSIONER ZECH: Could you elaborate just a
- 12 little bit on why you think a rule is required? I thought 13 that was interesting that you came up with'that 14 recommendation. I would appreciate your thoughts on that.
If. MR. PASSWATER: I think the feeling of the 16 subcommittee was that there would be less tendency for the 17 criteria and a determination of what goes into technical i 18 specifications to slip back into the process that we're in i 19 right nov if they were in a rule rather than --
!. 20 COMMISSIONER ZECH: .A more formal basis would be l
21 appropriate is what you're saying, I guess.
22 MR. PASSWATER: Would add some' stability'to 23 determining how tech specs are derived. j 1
24 MR. TUCKER: That's the main consideration,
, 25 stability, once we get it set.
- i l
1 l
. .- .- - . . . _ - .. .~ .... _ - .-. . _
60 1 COMMISSIONER ZECH: Right. I undetstand that.
q 2 I think you have answered the question on 50.59 4
l 3 enough, but I will-say that I have, in my -r eview, too, and our .
4 Staff, the I&E folks, havn recently come up with several 4 5 reviews that indicate that the 50.59 reviews sometimes could 6 be improved upon, and it's my understanding that sometimes the 7 answers are, you know, yes and no and that kind of thing.
And I would be interested to make sure that perhaps
~
8 9 this process will result in an~ analysis that would be more
- 10 meaningful in order to, you know, justify the changes that 11 might take place.
1
! 12 So I think the 50.59 process itself should be looked
['
13 at very carefully if we're going to go to this,-perhaps i
14 improve that review process.
, 15 I will make that as a comment. I know you've
, 16 addressed it, but I would hope that that would be an outcome I
{ 17 of what we're doing.
a 4
18 I thinN frankly, I agree that this is a very 19 commendable undertaking. I think the industry, as well as our 20 Staff, is to be commended for addressing this very difficult j 21 area, but I can assure you from an operator's-standpoint, it's 22 perhaps one of the most important things that we're doing, and 23 I know your operators feel that way, and I sensed at the
, 24 minute that you do, too.
25 But, you know, as a full-time operator on one of
,wv,- - , , - , , s, , , - + - -,,,.-,-y ,-g- - , - -- , , - - - e, rn - .,,e- .-w- --- ,. ,,-,--~,,,g n n,--r-,,-,,-vg . , - - w< ~ -
.e e . m a, .--m ~~-sm+- e
7 ;
61 l
1 those smaller plants that Mr.-Bernthal referred to, --
--3.
l 2 (Laughter.)
3 COMMISSIONER-BERNTHAL: Everything is relative.
4 COMMISSIONER ZECH: But anyway, the operators do, 5 indeed, need some assistance in tech' specs, and I was 6 extremely impressed by seeing the more recent tech specs, how 7 . voluminous they are, and I can assure you that from an 8 operator's standpoint, if they're that voluminous , he.is -
9 simply overwhelmed by the detail, and certainly not very 10 useful in the current form, and discipline is need, and 11 prioritizing is needed, so the things you are addressing, I 12 think, are extremely appropriate and will, indeed, contribute 13 to safer operation of our plants.
14 There is no question about the operator's l 15 standpoint. I think that's real, and that's something to be
! 16 recognized.
I 17 I think that I agree with your short-term 18 conclusions and our longer-range conclusions, I think, I would 19 certainly generally agree with. I think there's one question 20 that I saw, and I don't know that we've address 6d it in great 21 detail here today, but concerning the supplemental
} 22 specifications and whether or not a document is needed or not.
23 I understand that it's ycur view that it probably is 24 not needed and the Staff's view, they think it would be 25 appropriate. That probably should be addressed between from i
w.-,,-yw,w y, -yr.---m .- w. *-9gy,,,%g.-a ,. ,..e- r --w -y.A=wsu.g ,%r we-*-.,:-s.&&w.g , gs yy9-. . . - - - w-y.w-97,7-9-g- ' ,w---mmm.cw-gpyvg e y.,- 9ww9 .- uw, 9.i+ e
, 62 1 the Staff's standpoint and from your standpoinu.
2 I would assume, although I think you stated in your 3 recommendations that you do not need to establish this 4 document, I would submit that perhaps it might be appropriate 5 from the Staff's standpoint to establish it, and I can 6 understand that it would be useful.
7 You may want to comment briefly on that. If you 8 don't, well, I'll move along. But it seems to me that that's 9 something that was not quite completed as far as your-10 negotiations are concerned.
11 But my point is that it seems to me that there i 12 might be some usefulness for a document that would gather 13 together these supplemental specifications, and rather than 14 have them in so many different places.
15 I will pass on that for now, but that was my 16 conclusion, that the Staff may be absolutely correct in the 17 approach they are taken, and if you have completely different 18 views, if you care to acdress it, why go ahead.
19 MR. PASSWATE2: The term " supplemental 20 specifications" was used in the proposed 1982 rule, and there
- 21 were some very specific characteristics of those and some 22 regulatory controls on how those were used. And I think it --
23 well, I know it was our viewpoint that if supplemental 24 specifications means that definition that was in the proposed I
25 rule, then administratively it is almost a worse situation j
I
, . , -,,-.--.--p .---
~
63L 1 than we have right now with technical specifications.
2 And that's why we have avoided the use el
~3 supplemental specifications and talked about -- I think.the' 4 term we used was " Licensee controlled documents" and called 5 those -- in the slides here, I've listed some examples of 6 those Licensee controlled documents: the FSAR, the QA plan, 7 and so forth that exist today. Regulations exist that control 8 those and control Licensees as to how they can make changes to 9 those documents.
10 Our feeling was, there was not a need to set up 11 another set of documents called supplemental specifications.
12 It would be duplicative of what already exists today.
13 COMMISSIONER ZECH: I understand. But I say, I 14 think that's something that still has to be addressed, and I'm 15 sure it will be.
16 The only comment I have is really a request, I 17 guess, Mr. Chairman, is that we should, besides thanking these 18 people and all the other who have devoted all this time to 19 this very important effort, we should ask our Staff to come up 20 with some recommendations regarding the conclusions that we've 21 been presented and review those very carefully, and I think we 22 should, and I thank you very much for your presentation.
23 CHAIRMAN PALLADINO: Well, I would like to express 24 our appreciation for the cooperative approach that the i
( 25 industry has taken, particularly AIF, in working on improved t
1
, _ _ . _ . . . . , ~ , . _ - - - - - - . . . . . . _ . , . , _ .----,.~,,..,_..__.,.,.,_..-..--........-.._,...,m
._--._,_-_.,,.,-,-.._-,m._._-_--.
64 1- tech specs. I think it's a i tremendous undertaking, but one
-s 2 that is very worthwhile despite some questions that I may have ,
3 raised that would give you a different viewpoint.
l 4 Now I. noticed that the Staff in SECY-86-10 informed 5 the Commission of the-recommendations of the Technical 6 Specification Improvement Project and the planned Staff i
- 7 actions in response to these recommendations. And then in the 8 back, on of the initial tasks will be the preparation of a 9 Commission policy statement.
10 I think, even though this is an information paper, 11 that if the Commission was prepared to support the Staff or 12 encourage the Staff to go off in that direction, I think.it 13 would be a worthwhile move.
f I don't know if the Commission is 14 ready for that.
15 COMMISSIONER ZECH: My only thought is, from the ;
{
16 presentation we have heard today, I would like to. hear from 17 the Staff to see if there is anything new or anything they 18 would like to add or change.
19 CHAIRMAN PALLADINO: We can do that.
20 COMMISSIONER'ZECH: And with that, I think we are 21 ready to move along.
22 COMMISSIONER ROBERTS: Can we get that in writing?
23 COMMISSIONER ASSELSTINE: Yes, I think that would be 24 useful.
25 CHAIRMAN PALLADINO: Well, why don't I ask SECY to f
, , - - - e,. --,vn,,---._-~ y y , .g.m--g, ,,.m ,,.,-,n,-,- y on,.,.,.,- , , - ,,-- - - + ,,,w,4p,,~,,,,,,-,,n.---,,,_,~,en -
.,-,,y.-- -.,,,-,,.,.,,,.w,y-,g,m,p--
.~ . .
65 i 1 see if there~is support after the meeting on encouraging the 2 development of a policy on this matter. I, for one, am 3 prepared to give them that encouragement ~now.
4 COMMISSIONER ZECH: I agree. That's fine. But I ?
! 5 think we should hear the Staff, just as a last --
6 COMMISSIONER ASSELSTINE: I think Lando's suggestion 7 is good.
8 CHAIRMAN PALLADINO: Yes. I wasn't excluding that.
9 MR. TUCKER: We would encourage your moving as i 10 expeditiously as you could. We are very anxious to get this, i
j 11 as you are, too.
t
~
12 CHAIRMAN PALLADINO: The point I want to make, if 13 the Commission was reluctant to go in the direction of a I 14 policy statement, they had ought to speak up.
- 15 COMMISSIONER ZECH
- No, I have no reluctance at j 16 all. I just want to make sure that the Staff from today's 17 briefing doesn't have anything additional, and I am ready to
[
18 move out as soon as I hear that they are satisfied.
19 COMMISSIONER ASSELSTINE: I think I have a couple of 1
l 20 questions that I could address to the Staff in writing.
21- CHAIRMAN PALLADINO: Well, let me ask SECY to see 4
l 22 how the Commissioners feel on the subject of going ahead with i
- 23 a policy statement.
3 24 Anything more to come before us?
)
25 (No response.]
a l
~66~
l CHAIRMAN PALLADINO: Well, thank you very much,
'J 2 gentlemen. It was a very worthwhile briefing.
3 We stand adjourned.
4 [Whereupon, at 3:32 o' clock, p.m., the commission 5 meeting was adjourned.]
6 7
8 9
i 10 11 12 13 s
14 15 16 17 ,
18 19 -
~
20 21 l
22 ,
23 24 25 l
1 CERTIF1CATE OF OFFICIAL REPORTER 2
S 4
5 ,
This is to cartify that the attached proceedings 6 before the United States Nuclear Regulatory Commission in the
- 7 matter of
- COMMISSION MEETING L
8 9 Name of Proceeding: Briefing by AIF on Technical Specifica-i tions Improvements (Public Meeting) 10 11 Occket No.
12 P1 ace: Wa'shington, D. C.
j 13 Date: Tuesday, February 11, 1986 ,
14 15 were held as herein .sppears and that this is the original 16 transcript thereof for the file of the United States Nuclear 17 Regulatory Commission.
18 /
/ .
,/
' /
19 (Signature) N d- : ( ^
- ~~/
~
(Typed Nanie ofjReporter) Suzanne gYoung 21 i .;
22 23 Ann Riley & Associates. Ltd.
24 25
)
l
- l
- 2/11/86 SCHEDULING NOTES i
TITLE: BRIEFING BY AIF ON TECHNICAL SPECIFICATION IMPROVEMENTS SCHEDULED: 2:00 P.M., TUESDAY, FEBRUARY 11, 1986 (OPEN)
DURATION: APPROX l-1/2 HRS SPEAKERS: - HAL TUCKER, VICE PRESIDENT DUKE POWER COMPANY j - ALAN PASSWATER, SUPERINTENDENT FOR LICENSING UNION ELECTRIC COMPANY AND CHAIRMAN, AIF SUBCOMMITTEE ON TECHNICAL SPECIFICATIONS 4
4 e
e I
- e v., - g , - - n-. - -mm e --
I i i i
[
i I
BRIEFING OF THE COMMISSIONERS i '
i BY 1
l l
THE AIF SUBCOMMITTEE ON TECHNICAL t SPECIFICATION IMPROVEMENTS OF THE
! COMMITTEE ON REACTOR LICENSING & SAFETY j
l '
l l
TUESDAY, FEBRUARY 11,1986 1
1 e
i !
I I
TECHNICAL SPECIFICATION i
IMPROVEMENTS SUBCOMMITTEE i
i l
- REPORTS 10 THE COMMITTEE ON REACTOR LICENSING AND SAFETY
- CHAIRMAN: ALAN PASSWATER, SUPERINTENDENT OF . 'l LICENSING, UNION ELECTRIC COMPANY l
e PURPOSE: COORDINATE, PROPOSE AND PROMOTE TECHNICAL SPECIFICATION IMPROVEMENTS l -
l
- MEMBERSHIP: REPRESENTATIVES FROM:
CHAIRMAN OF EACH OF THE FOUR VENDOR OWNERS GROUPS TECHNICAL SPECIFICATION SUBCOMMITTEES l
CHAIRMAN, NUCLEAR POWER PLANT STANDARDS WORKING GROUP, ANS-58.4 NINETEEN UTILITIES EPRI '
FOUR VENDORS
- THREE ARCHITECT ENGINEERING FIRMS TWO CONSULTING FIRMS l
1
i l
i i
ESTABLISHED WORKING GROUPS -
i t
!
- WORKING GROUP ON CRITERIA DEVEl.OPMENT '
l
- WORKING GROUP ON THE ADMINISTRATIVE PROCESS e WORKING GROUP ON REGULATORY CHANGES i
- WORKING GROUP ON PROBABILISTIC METHODOLOGY l
l l
l i
PLAN TO REFORM NRC REQ.UIREMENTS
, RELATED TO THE TECHNICAL i
SPECIFICATIONS .
OLD SYSTEM NEW SYSTEM ,
l h l l
}
' l l l l
- REMO VE NON-ESSENTIAL -
I '
l LCO'S '
l l i
++ g g e ADDITIONAL EMOVE SURVEILLANCE - * # O e g l gfg'y*g g#fgp"ygg
'+ l l INTERVALS f
+
i : REMOVE DESIGN INFORMATIONm I I 1 .
(LISTS etcJ l l
! *4 b 0
- g l e OPTIMlZATION OF 4- - REMOVE PROGRAMMATIC y ALLOHi4BLE OUTAGE i 'DeTAuS , / 1 I TIMES
. IMPLEMENT OTHER I l
i ' SHOR T-TERM l l e CONSOllDATE/S!MPLI 1 IMPRO VEMENTS g LIMITING CONDITIONS 1* / g l l FOR OPERATION l l 8 I
l l
. I I i i !
. DEVELOP ADMINISTRATIVE CONTROLS n l l
' FOR NEW SYSTEM ';
. I REVISE REGULATORY .l I
- REQUIREMENTS
'} l NRC LICENSEE APPROMel IMPLEMENTATION
.s . ..
t l .
l CRITERIA et e AN INSTALLED. SYSTEM THAT IS USED TO DETECT,
, BY MONITORS IN THE CONTROL ROOM, A SIGNIFICANT ABNORMAL DEGRADATION OF THE l REACTOR COOLANT PRESSURE BOUNDARY; OR
!l e A PROCESS VARIABLE THAT IS AN INITIAL l
CONDITION OF THE DESIGN BASIS ACCIDENT; OR i
e A STRUCTURE, SYSTEM, OR COMPONENT THAT IS PART'OF THE PRIMARY SUCCESS PATH OF A SAFETY
- SEQUENCg ANALYSIS ~ AND FUNCTIONS OR ACTUATES TO MITIGATE A DESIGN BASIS ACCIDENT.
j C ..
I
' '~
j -
i i
i j ;
I I
APPLICABILITY i
CAN BE APPLIED TO:
l e EXISTING TECHNICAL SPECIFICATIONS, CUSTOM i OR STANDARD l
e TECHNICAL SPECIFICATIONS UNDER DEVELOPMENT (NTOL) e PROPOSED FUTURE CHANGES TO EXISTING OR NEW TECH SPECS i
l -
i
~
l THE PROCESS i
l
- IMPROVED TECHNICAL SPECIFICATIONS .
t
- FOR THOSE TOPICS NO LONGER IN TECH SPECS:
- FSAR (10CFR50.59)
- QA PLAN (10CFR 50.54a) l
- ISI/IST (10CFR 50.55a)
I l
i i
l' 2/10/86 i
i ..
i i .
i SHORT TERM GENERIC IMPROVEMENTS -
t t
- REMOVE LISTS OF COMPONENTS l
- REMOVE DUPLICATIONS OF REGULATORY l REQUIREMENTS i
! t
- i
!
- CLARIFY DEFINITION OF OPERABILITY l
i e ADDRESS NEED FOR FIRE PROTECTION '
l REQUIREMENTS IN THE TECHNICAL SPECIFICATIONS i
i
- ADDRESS SHUTDOWN MARGIN REQUIREMENTS l
l
- OTHER l
i 2/10/34 i
i i
- T SKS TO SUPPORT IMPLEMENTATION PHASE
- MAINTAIN PRIORITY ON IMPROVING TECHNICAL SPECIFICATIONS i l
- ENCOURAGE IMPLEMENTATION OF CRITERIA AND -
ADMINISTRATIVE PROCESS
- POLICY STATEMENT (SHORT TERM) ,
l - RULEMAKING (LONG TERM) l e ADDRESS SHORT TERM IMPROVEMENTS l
- SUPPORT PROBABILISTIC BASED METHODOLOGIES i
l
- SUPPORT REVISION TO ANSI /ANS 58.4 i
j e ADDRESS APPROACH TO IMPROVING THE BASES
'll10/86
~
CONCLUSIONS
l
- PROCEED WITH RULEMAKING IN PARALLEL l
!
- IMPLEMENT THE SUGGESTED SHORT TERM IMPROVEMENTS NOW '
- CONTINUE TO SUPPORT THE USE OF PROBABILISTIC '
I METHODOLOGIES TO IMPROVE TECHNICAL
- SPECIFICATIONS
- RECOGNIZE EXISTING DOCUMENTS AS ADEQUATE j FOR NON-TECH SPEC ITEMS
- CONTINUE THE WORKING RELATIONSHIP TO GAIN
.THE MAXIMUM IMPROVEMENTS l
l
- PROVIDE SUFFICIENT RESOURCES TO SUPPORT ;
i IMPLEMENTATION PHASE :
! 2/10/88
4 I h h(h h hh h h k h TRANSVIITAL 'IO: Documer.t Control Desk, 016 Phillips 9/35
-':E ADVANCED 00PY 'IO: / / 'Ihe Public Docuraent Rocm 3
3 mTs: 34sleo j g cc: C&R N FBOM: SECY OPS BRANCH ta .
papers)
Attached are copies of a Comnission meeting transcript (s) and related meeting '
doctment(s) . They are being forwarded for entry on the Daily Accession List and placment in the Public Ibcument FDcm. No other distribution is requested or requ.tred. Existing DCS identification nunbers are listed on the individual documents wherever kn an.
Meeting
Title:
h t d A A hw lh l E 0 0 YtCM tea _.l <Pect(5A b t J a i
tl%:oe oU e mN S t
Meeting Date: Open Closed DCS Copies (1 of each checked)
Iten
Description:
Copies
- Advanced original May Duplicate
'Ib PDR , Document be Dup
- g* ~
- 1. TRANSCRIPT 1. 1
.. hhen checked, DCS should send a ,
copy of this transcript to the ,
LPDR for: ,
M1u) C acaphs
- s > <
- 2. (EoG touk.cse.eks o h M \ l r 9.c4 [hdscd 6ocu(ufes -
T y ~<_ M s" *
- 3. ,
- 4. ,
- < l i
(PDR ic advanced one copy of each document, ,
- Verify if in DCS, and !
two of each SIrY paper.)
- Change to "PDR Available." h 3 1 menenwawawawawawawawawmenems