ML20033C147
| ML20033C147 | |
| Person / Time | |
|---|---|
| Issue date: | 11/18/1981 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML20033C148 | List: |
| References | |
| REF-10CFR9.7 NUDOCS 8112020733 | |
| Download: ML20033C147 (35) | |
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UNITED STATES OF ABERICA 2
NUCLEAR REGULATORY COMNISSION
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DISCUSSION OF POLICY AND PLANNING GUID ANCE 4
PUBLIC NEETING S
Nuclear Regulatory Commission Room 1130 6
1717 H Street, N.E.
Washington, D.C.
Wednesday, November 18, 1981 8
The Commission met, pursuant to notice, at 3:10 9
o' clock D.a.
10 BEFORE:
11 NUNZIO PALLADINO, Chairman 12 PETER BRADFORD, Commissioner JOHN AREARNE,. Commissioner 13 THONAS ROBERTS, Commissioner
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14 STAFF PRESENTS 15 SAN CHILK, Secretary LEONARD BICKWIT, General Counsel 16 GEORGE EYSYMONTT' FORREST REMICK 17 WILLIAH DIRCKS KEVIN CORNELL 18 19 20 21 22 23
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1 PH0CEEDINGS 2
CHAIHNAN PALLADINO:
The meeting vill please come
. ~1 3 to order.
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4 The Commission meets this afternoon to discuss the 5 Policy and Planning Guidance document which we asked the 6 Office of Policy Evaluation to prepare.
I understand that 7 in past years the Commission has evolved such a document to 8 provide guidance to the staff for budget preparation 9 purposes.
10 In addition, the document has also served as 11 management guidance on issues of major importance to the 12 Commission.
13 I strongly support the need for such a document.
14 The draf t before us reflects my initial views concerning 15 policy matters which are of particular importance.
It also 16 reflects my concern that the document be reasonably concise 17 and recognizes that not every aspect of NBC's mission will 18 be covered.
19 I would like to determine during the course of 20 this mee ting whether the current draft covers the policies 21 and plans which the Commission feels are appropriate for the 22 document.
I would also like to determine if the time that 23 it will take to review the document by individual u,
24 Commissioners will permit us to publish the final version by 25 the early part of January.
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1 I thought we might proceed as follows:
I would 2 turn the meeting over to the Director of OPE to highlight
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3 the major features of the-document, since the document was 4 prepared by OPEr then ask the Commissioners to highlight 5 their comments.
We have received comments from Commissioner 6 Ahearne and from Commissioner Bradford.
Except for about 7 three questions I find them very constructive and I would 8 have little difficulty in accomodating to them.
9 Then, I might ask the EDO for comments on the 10 document as he sees it.
So, unless there are other points 11 that ought to be covered I suggest we turn it over to OPE.
12 I would like to set a target of adjocrning by 4 13 o ' clock.
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14 MR. REMICKa Thank your Er. Chairman.
15 The OPE approached the preparation of the initial l
16 draft of the Policy and Planning Guidance document in a 17 slightly different fashion than.I believe was done 18 previously.
I as told that last year the initial draft was 19 prepared directly in conjunction with the staff and af ter 20 individual meetings with each of the Commissioners.
21 This year, as you indicated, the Chairman l
l 22 requested that we prepare a draf t based on topics which were l
23 deemed of specific interest and importance.
24 If one looks at the document we sent up, of course 25 the PPG itself is contained in Tab A, and one of the first v
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I things I would. highlight is the f act that it is being 2 entitled, " Policy and Planning Guidance" instead of " Policy
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371anning and Program Guidance."
Specifically, the draft
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--4 points out that the Executive Director of Operations would
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-- - 5 p rovide program guidance as necessary, consistent with the 6 Policy and Planning Guidance.
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There are five major topics that are oulined in
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]s the draf t, near-tern licensing problems and responses; 9 getting control requirements; streamlining the licensing
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11 steps.
Cf course, some of these have sub-topics that are 12 associated with them.
13 The PPC is more brief than last year, and this is
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14 in keeping with the Chairman's request, and it is consistent 15 with the thought of perhaps issuing this to all NRC 16 employees, keeping it as short as possible.
l 17 Under Tab B is a proposed draf t memo which would l
18 distribute the PPG to the NHC employees, and it ' includes 19 encouragement for the staff to implement the PPG in a timely 20 f ashion.
It encourages supervisors to par specific 21 attention to personnel managenevnt issues, a a encourages 22 people to use administrative support services in an l'
23 efficient manner to assist the staff in carrying out their
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24 duties.
25 Under Tab C is a proposed schedule for possible w:
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1 Commission action that would enable the documents to be 2 distributed in final form in January of 1982, and then, 3 under Tab D are the proposed major elements of a tracking a
s 4 system which would enable the staff to keep the Commission 5 briefwd on the status of some of the major elements in the 6 PPG.
7 Actually, under Tab D there are two components, 8 Attachment 2 under Tab D is a draf t from the EDO 9 recommending various items that should be tracked, and to Attachment 1 is an OPE reconnendation of major elements to 11 be tracked which include some of the recommendations of the 12 EDO but also incorporates some of the items that are 13 specifically-in the PPG.
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14 The only other comment I would make, joining me 15 today is George Eysynontt who was instrumental in assisting l
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16 in draf ting the document that you have.
17 COMNISSIONER AHEABNEs I would' like to make a 18 comment.
I have to complement you, Joe.
This is a subject 19 which has always been very dear to my heart, but I was never 20 able to get television cameras in for the Policy and 21 Training Guide.
22 (Laughter.)
23 CHAIBMAN PALLADIN0a Narbe PPG sounds like PGCE.
24 (Laughter.)
25 CHAIRMAN PALLADINO:
Do you have more?
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1 COMMISSIONER AHEABNE:
I have a couple more 2 substantive comments.
'3 3
CHAIENAN PALLADINO:
Well, we have rece ved 4 comments from Commissioner Ahearne and from Commissioner 5 Bradford.
They were fairly extensive and I think on the 6 whole very good.
I hope we can get the detailed ccmaents 7 incorporated in the draft.
8 There are a few places where the comments may be 9 deflecting, but I think that can be worked out.
But 1 to thought you might highlight what the major features of your 11 comments are.
12 COMMISSIONER AH2ABNEa All. righ t.
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13 CHAIRHAN PALLADINO:
Then I will ask Commissioner 14 Bradford and Commissioner Roberts to do the same.
15 COMEISSIONER AREABNE:
Two general comments.
One 16 which was not mentioned,. which is that I really am very glad 17 that the Chairman is very interested in this.
I think that 18 getting this kind of a document out to the staff serves an 19 extremely usef ul purpose not just in budget preparation but 20 more specifica3ly in telling the ove rall agency what it is 21 the Commission believes are important items.
22 Under the reorganization plan this is even more 23 important because one of the areas that the Commission is 24 supposed to focus on is Policy Guidance.
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1 attention to.
2 Now, the two criticisms I had - sort of general
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3 ones - in which I tried to.aake adjustments on some of the 4 comments were, first, while recognizing the value of 5 focusing on a selected set of topics and not disagreeing 6 with most of those topics as being the ones on which primary 7 emphasis should be placed, I still believe that we ought to 8 somehow get a message to the employees of the agency that in 9 spite of their area not being mentioned here does not mean to that it is not isportant.
11 I an afraid that this could be read as saying th a t 12 as far as the Commission is concerned only those areas 13 sentioned here are really-important.
Particularly since the
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14 emphasis here will be to make sure every employee gets it -
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15 and I think that is a good idea - I think it would be very 16 difficult f oc our employees in the other areas to read this 17 and not come away with the conclusion that what they are
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l 18 working in is just unimportant.
19 It would be hard to maintnin high morale, it would 20 be hard to maintain the pressure of work and keeping up with 21 that work in the absence of some kinds of words - and I have 22 tried to dra f t some.
The ones I have put in are not well 23 drafted, I recognize that, and I would encourage the OPE to
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25 put in something lik e th a t.
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1 CHAIRMAN PALLADINO:
I think that is a very 2 valuable comment.
I think Consissioner Bradford had maybe
-N 3 in a different sense' the same consent on the inclusion of 4 your items.
I think we certainly should do that.
5 COMNISSIONER AHEARNE:
The other concern I had was 6 in the emphasis on improving the way we handle regulations 7 and the licensing process.
There is a danger of getting the 8 wrong message - as at least certainly Peter recognizes, 9 there are many times that he and I have had strong 10 disagreements on steps we might take in the licensing i
11 process.
So, I have certainly been very interested in 12 saking it more effective and improving it in many ways.
13 But I think that one could get a flavor which I as
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14 sure was not intended that what we are interested in is 15 streamlining it to make it a pro forma review in order to 16 naximire the number of licenses that we can issue -
17 streamlining it to the extent that the review of safety 18 could be somehow put aside and made secondary.
19 So, I have tried to modify to some extent, just to 20 make sure that message does not coWe across because there 21 are many people in the staff who really will try very hard 22 to follow what they see is the intent tha t the Consission 23 has placed on this.
If it can be read in a direction that l
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24 is not the direction we would like it to go, then I think we l
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1 that way.
2 That was the second point.
3 CH AIRMAN P ALLADINoa I think those are both very
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4 valid comments.
I think your suggestions on how they might 5 he corrected will help OPE to make sure that we do not 6 overlook anY of these.
7 HR. REMICKs Absolutely.
I think it is extremely 8 helpful to have the written suggestions.
9 CHAIRHAN PAL 1ADINO Peter, would you like to to highlight the esserce of your comments?
11 COHNISSIONER BRADFORDs I think my concerns are 12 the same as John's.
There is not a great deal in the draft 13 PPG that I disagree with, although I would reformulate some
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14 o f it.
But there are a number of things that are not 15 included in it that I think are very important -to get in.
16 I do think that the two documents side by side, 17 last year's and this year's, do loave an unfortunate sense 18 of tilt away from the aspects of last year's document that 19 tried to keep a balance between concern about 20 over-regulation on the one hand and safety on the other.
21 As I indicated in my meno, there are a couple that 22 I feel pretty strongly about.
But I certainly do not have a 23 problem with strengthening the concerns regarding
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24 over-regulation as long as we keep the righ t balance.
25 CHAIRMAN PALLADIN0s I certainly agree that we v
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I have to keep a reasonable balance.
As a matter of fact, 2 when I read it I sort of felt it may have leaned over
('s 3 backwards more than we should have in stressing the easing 4 in the regulatory process and not enough emphasis on the 5 saf ety aspect.
6 So, I think these corrections are quite in keeping 7 with both the past practice and what we ought to do.
a COREISSIONER AHEARNE:
I would like to make two i
9 o th er commen ts if I. co uld.
One, I certainly agree with 10 dropping the programming side.
We have always had 11 difficulty trying to get there, and I think under the 12 reorganization plan the programming side is much more 13 appropriately lef t out of a document that is a Commission
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14 document.
15 The second, I do not, for arself see - I do not 16 have great concern if it does not track too exactly the 17 previous year's version, even though 'I have liked the i
18 previous year's version.
But there is basically a change in i
19 leadership of the agency and it does not therefore make ne 1
20 too upset that a naw document coming out with a new set of 21 leaders is going to be different from last year's.
i 22 COMMISSIONER BRADFORD:
I agree with that, both 23 because of changes in personnel and also because l
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24 circumstances themselves change, particular policies become l
, 25 programs.
One hopes, even, that from time to time things l
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1 get resolved.
2 CONNISSIONEH AHEABNE:
Not on the time scale of an 3 individual Commissioner.
-3 4
COHHISSIONER BRADFORD:
That is probably right.
5 (Laughter.)
6 CONHISSIONER BRADFORD:
But at the same time there 7 are some more general themes that have been in the 8 proceeding, a couple of iterations that I would not drop 9 without making sure that we knew what was meant by dropping 10 them, and also just. exactly what was taking their place.
11 CH AIBH AN P ALLADIN0 s I presume OPE has copies of 12 rour detailed recommenda tions.
13 HR. HEHICKs Yes.
14 CHAIRHAN PALLADIN0s And.on the insertions.
If 15 ther have any questions, I think, they can work that out.
16 HR. REHICK4 I would assume tha t the Commission
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17 supports the concept of 2A-2C, which it seems to me the most 18 appropriate thing to have in.
19 COMMISSIONEH AHEARNE:
Yes.
20 CHAIHHAN PALLADINO:
I do have three questions 21 that were raised in reading the comments, but I thought I 22 would defer them and give Commissioner Roberts a chance kand 23 the EDO a chance to comment.
([j 24 COHHISSIONER ROBERTSs I have no specific l
25 comments.
But the lack of any specific comments does not l
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ALDERSON REPORTING CCMPANY,INC.
400 VIRGINIA AVE S.W WASHINGTON, D.C. 20024 (202) 554-2345
12 1 indicate in any var my lack of interest or the importance 2 that I attach to this.
But I have no specific comments.
3 CHAIRHAN PALLADIN04 Bill, have you had a chance x
4 to look at the document?
5 HR. DIRCKS4 We have gone over it and in general 6 ve do not have any major problems.
We have some questions 7 of interpretation of, say, the rule of, for example, th e 8 Generic Bequirements Review Committee.
But I think we can 9 straighten that out in providing detailed language.
10 COMMISSIONER BRADFORD:
Bill, doe s "we" in this 11 one include the EDO, the staff in general?
12 HR. DIRCKS:
Yes.
13 CONHISSIONER BRADFORD How broid is that?
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14 HR. DIRCKSs The office directors have seen it, 15 but we have ' ot gone over it in detail with the office n
16 directors.
We have gotten some prelliinary comments back 17 f rom th em.
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18 We have, for example, in the vaste management area 19 Jack Martin 's vied, and I think we have some comments on 20 dates leaving us some flexibility on dates.
21 COBEISSIONER AHEARNE:
Do you intend to get 22 detailed comments from the office directors?
23 HR. DIRCKS:
I do not know how much more detail we
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24 need.
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John Davis has done the ALDERSON REPORTING COMPANY,INC, fBR
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'T 1 same.
So, I think we have a good basis for getting comments 2 back.
The detailed programming we can work out as we go
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3 into. that system.
4 I think our questions are on interpretation of 5 some of the broader headings.
The role of project managers, 6 I think is, we have project managers and we would like to 7 make-sure that we have something similar to what the 8 Commission may be intending in its write-up.
9 We do want to do something about dates to make to sure that we do not have. too much of a discontinuity with 11 the on-going programs and we can adjust them to the main 12 areas.
13 We do have some questions on the new m
14 organizational element, the Generic Committee versus the 15 role of the new deputy, versus responsibility of myself.
We 16 can give tht to OPE and we will work closely with them.
17 We will try to at the same time gear up to think 18 ho w we can convert this into programming.
tg COEMISSIONER BRADFORD:
Do I understand correctly 20 that your consents are not in this draf t?
21 MB. DIRCKSt The comments that they have in our 22 d ra f t, I think, basically are mine and Kevin's.
We did not 23 go down very much farther at this iteration.
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24 COMMISSIONER BRADFORD:
Your comments are 25 reflected, though, in the draft we have seen.
ALDERSON REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W, WASHINGTON. D.C. 20024 (202) 554-2345
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HR. DIHCKS:
Yes.
2 CONHISSIONER BRADFORD:
Yours and Kevin's, but not 3 the office directors '.
4 ER. DIRCKS:
Not the office directors'.
5 NH..CORNELLs There is also a fair amount of 6 language in here that was not in the earlier draf t. that we 7 did comment on.
8 MR. DIHCKS:
There have been changes, yes.
9 MR. COHNELLa We saw an earlier draft comment and 10 this is a new one and we have not commented on this one.
11 COMMISSIONER AREARNEa Do you expect the schedule 12 that OPE proposed would have an OPE redraf t by November 25 13 that would require the basis of comments?
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14 MH. DIHCKSt Oh, sure.
We would be able to do 15 tha t.
16 CHAIRMAN PALLADIN0s Yes, I was hoping we all 17 could try to adhere to the schedule.
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18 MH. DIHCKS:
I think the best way we can handle it 19 is if we just sit down with George and Forrest and work it 20 out directly.
We have our. comments.
A lot of it may be 21 interpretation of what did you mean here and how can we 22 adjust the language to make sure that we know what is meant, 23 cla rity.
24 CHAIRMAN PALLADIN0s With respect to the comments
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25 tha t I. received there were three topics I would like to ALDERSON REPORTING COMPANY,INC.
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15 1 discuss for just a few minutes.
2 One had to do with - I guess it is page 3 - where gm 3 a suggestion was made that we cross out reference to Clinch 4 Hiver Breeder licensing.
Since that is an item that has 5 been talked. about a great deal, both by the Executive 6 B ranch, by DOE and by the Congress, it seems to me that some 7 newntion of it would be appropriate.
8 Now, whether or not the thrust given on page 3 is 9 the right one, but crossing it out entirely would give me a 10 little bit of a problem.
11 COHNISSIONER AHEARNE I would not object to 12 keeping it in in some. modification.
I would first make it a 13 separate item.
It links here directly to the operating 14 plants, to the rest of them, it is essentially an equal 15 level.
I did nit have a chance to think of any better way, 18 but I would not object to including it with some 17 modifica tion.
18 COMMISSIONER BH ADFORD:
Let's see, at least a 19 couple of Commissioners have now requested a separate 20 briefing on Clinch River.
I guess.we have not scheduled it 21 y et.
22 I do not mind having some mention of it in the 23 document somewhere, but my inclination would be to keep it 24 pretty neutral.
Until we have had that briefing, I guess I 25 do not have a good feel for just what the resource a
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1 implications of a. commitment to have the NRC in no way delay 2 the Clinch River licensing are.
Whether, for example, that 3 entails a commitment to delay the licensing of plants that
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4 are ready to operate; or if it entails a commitment to delay 5 some other programs; or whether that is a commitment we can 6 fulfill with our existing resources is important to know.
7 CHAIENAN PA1LADINO:
Well, the word a " unnecessarily" delay, but there may be more.
9 COHNISSIONER BRADFORD:
I think that will be read 10 to mean unnecessarily within the confines of that 11 proceeding.
Unless we say more it would not be read to mean 12 unnecessarily relative to other activities.
13 CHAIBRAN PAL 1ADIN06 He will try to work something 14 up with regard to this.
15 My second question, I think, relates to siting 16 policy on page 15.
I think both Commissioner Bradford and 17 Commissioner Ahearne raised questions about the statement 18 that says, "Further, siting regulations should take account 19 of engineered safety features."
20 CONHISSIONER AHEABNfi Hine was more a question.
21 The question was with respect to whether that was an 22 explicit policy that was in disagreement with the 23 authorizing language which told us to develop it.
This was
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24 the bill that was passed.
25 CHAIRMAN PAllADINO:
Is it 19807 1
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CONHISSIONER AHEARNE:
FY '80 Authorization Act.
2 COMMISSIONER BRADFORD4 Yours is a pretty firmly em.
3 stated question, John.
4 (Laughter.)
5 COHNISSIONER AHEARNE:
Yes.
It says the 6 regulations promulgated pursuant to.this section.
That is 7 the one that tells us to develop siting criteria.
It says, 8 "It shall specify demographic criteria for facility siting" 9 and goes on, "without regard to any design engineering or 10 other differences."
11 CHAIBHAN PALLADIN0s Peter, I think you have a 12 comment. that says that you do not think we should take this 13 into account.
14 COHNISSIONER BRADFORD:
Well, John's question is a 15 good one.
Part of my concern was that I had a recollection 16 which I did not bother to look up, that there was a l
17 statutory problem.
18 Beyond that, though, I think we vill ultimately 19 vant a siting policy that for new reactors really is that, a 20 siting policy, irrespective of improved fea tures within the 21 plant, at least ones that I know anything about, unless 22 somebody is talking about something like undergrounding l
23 which really simply says that there won't be any release.
24 So, with regard to some of the older plants I am s
25 sure judgments about engineering featurec will have to be s
ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554-2345
18 1
1 made.
But I would be inclined to shy away from having a 2 siting policy that varied a great deal with the kind of 3 equipment that was in the plant.
m 4
CHAIRMAN PALLADINot I have a little problem with 5 both of these comments because even in the siting rule that 8 was under development now there vere assumptions, specific 7 assumptions, made about the engineered safety features that 8 vere going to be in the plant.
9 COMMISSIONER BRADFORDs Can you give me an 10 example, Joe?
11 CHAIRHAN PALLADINO Oh, yes, they presumed 12 containment; they presumed CCS.
13 COHNISSIONER BRADFORD a Well, of course.
14 CHAIRHAN PALLADIN04 Well, if you postulate you 15 are not going to have then, then you can ha rdly site any of 18 these plants anyway.
17 As a matte of fact, they postulate the current 18 best data.
l 19 COHHISSIONER BRADFORD Yes.
I did not mean to 20 take issue with tha t.
Wha t I had in mind, what was worrying 21 se was the notion that perhaps vented containments or core 22 catchers would become a basis for siting closer to large 23 population centers, and that plants that had those features a
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24 would be allowed to be sited in more densely populated areas.
25 There might come a time when - and of course when we ALDERSON REPORTING COMPANY,INC,
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'N 1 ve are talking about new plants we are obviously talking 2 about sometime in the future - but there may come a time m,
3 when we are confortable in the sense that we know enough
- 4. about how those features would work to permit some 5 relaxation of siting criteria.
But I do not think we are 6 there yet.
7 CHAIRHAN PALLADIN0s The siting rule would have 8 some statement about exotic safeguards.
My incliuation is 9 that if. ve a re unwilling to talk about safeguards, then the 10 siting rule that is under development now is not a proper 11 one either.
We are going backwards, we. are going to the 12 place where reactors did not' have cooling systems, emergency 13 cooling systems; did not have back-up residual heat renewal 14 systems; did not have containment.
15 If we are going that f ar back, and that is what I 16 get when I hear the statement "no engineered safety 17 features."
18 COHEISSIONER BRADFORD:
That is not what I had in 19 mind.
20 CH AIRM AN P ALLADINO:
That is what I an afraid some 21 people are actually thinking of.
The other thing they do l
22 not want to do is so discourage improvements in the systems 23 we have that we stagnate.
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24 CONHISSIONER BR ADFORD:
I see what you are saying.
25 CHAIRMAN PALLADIN0s So, I am not pushing for ALDERSON REPORTING COMPANY,INC.
1 400 vtRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
20
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1 gradiose schemes to improve safeguards yet, I would hate to 2 see us discourage innovation or f ail to take advantage of
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3 the f act that the siting rules that we are now working on do 4 better on engineered safety features.
5 COHHISSIONER BRADFORD Yes.
6 CHAIRHAN PALLADINO:
Now, if you are willing for 7 us. to try to construct something in that framework --
8 COMMISSIONER BRADFORDa Sure.
Wi thin the confines 9 of the statute.
10 CHAIBHAN PALLADIN04 I had trouble with the 11 statute, too becaue I do not think ther intended what ther 12 finally came out with.
13 COHEISSIONER AHEARNEt I am not sure, and the
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- 14. reason I am not sure is that a lot of the arguments you just 15 made were ones that I know I and some others made at the 16 time the statute was being put together.
17 CHAIRHAN PALLADINO Well, then maybe you know 18 what they meant.
19 COMMISSIONER AHEARNE:
Now, whether they went 20 ahead without listening to what we were sayings or went 21 ahead, listened, ' understood and then decided we were wrong, 22 tha t I do not know.
23 I agree with the points you just made.
I was 24 nerely raising the question that before we issue, "Here is
._s 25 NRC policy," we ought to at least address, are we saying ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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1 that our policy is to go against something that is in the 2 statute.
3 CHAIRMAN PALLADINO:
That is a good point.
I 4 think we have to watch how we say tha t.
5 (Laughte.)
6 CHAIRHAN PALLADINO:
We might also want some 7 advice f ren. legal counsel as to the continuing effect of 8 that authorization bill.
9 CONHISSIONER AHEARNEs That's right.
10 HR. BICKWIT4 Our advice on these matters has been 11 that you are not bound to the authorization bill of the 12 previous year as a strictly legal matter.
13 CHAIRMAN PALLADINO:
This does ont mean we want to 14 ignore it.
15 HR. BICKWITs That is right.
16 CHAIRHAN FALLADINO:
Because it does have a 17 concept in there where they are trying to emphasire 18 demographics as a primary feature, and that I could 19 understand.
What I had difficulty with, both in the 20 implimentation of that and what I believe is-behind it is 21 that one should not consider engineered safeguards at all.
22 That was my impression.
23 COMMISSIONER AHEARNEa I believe that the part of
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24 the debate in the past which now has been compressed into a 25 few sentences.
Part of that debate is whether you can take ALDERSON REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
22
'T 1 a site which you.would reject on the grounds of any of the 2 other criteria - Ravenswood, for example - and say, "No, we 3 are going to accept it because we will come up with some 4 unique plant-specific provisions."
It was that concern, I 5 know, that originated the drive to eliminata it.
6 CHAIRMAN PALLADINOs Yes, that I can understand.
7 COHHISSIONER AHEARNEs The other strong effort to a eliminate it came from within the NRC.
Bill, you recall, 9 the NRC staff that was working on siting criteria eventually 10 came up with a proposal to eliminate all connection between 11 the engineering design and the site.
The reason they did' 12 that was not because they disagreed with the philosophy you 13 just said, Joe.
The reason they did that is, they concluded
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14 that it was just too hard a probles to resolve in a 15 rulemaking, how you would do 'the connection.
16 So, after five years of effort they decided to 17 chuck it and proposed a separation.
18 CHAIRNAN PALLADIN0s Yes,.but the separation is
- 19. sort of artificial.
20 COHNISSIONER AHEARNEa Of course.
21 CHAIRHAN PALLADINO:
It just says, "We are ' going /
22 to accept the status quo of engineered safety features ands
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23 are now going to look at demographics."
24 I say that already admits 'to engineered safety e
25 f ea tures.
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COMEISTIONER AHEARME Oh, yes.
2 CHAIRHAN PALLADINO Once you have admitted it, it
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3 is a little bit like prostitution, how far do you want to 4 go, I mean, what is your price?
5 (Laughter.)
6 CHAIRHAN PALLADIN0s But I agree, it has to be 7 handled delicately.
But I do not want to leave it out 8 because I think it is one of the points that could lead us 9 to an erroneous conclusion.
to COHHISSIONER AHEARNEa Yes, I would endorse 11 including it,. but I think expanding it a bit.
12 CHAIRHAN PALLADIN0s All right.
13 COHEISSIONER AHEARNE:
I would also want to make 14 sure Forrest talks to Len and see if he can perhaps word
- 15. that in some var that does not make it look so obvious that 16 ve 'have decided to use the legal rationale that one yea r 's 17 authorization language does not connect any of the others.
l 18 Hany authorizing committee members, while they mar l
19 agree with that legally, will take some offense to that.
20 COHEISSIONER BRADFORD4 Well, alsc, they will i
21 simp 17 re-enact it again.
22 COHHISSIONER AHEARNE:
They may not be able to.
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24 course, is a rule that is developed in response to a
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3 be some vague carry-over, even if it is not specific.
4 CHAIHHAN PALLADIN0a That is why I said, I just do 5 not. think we ought to be entirely indifferent to that.
6 COMHISSIONEL AHEARNEs Yes.
7 CHAIRHAN PALLADINO:
But I would like to clar ify a
8 it a little bit.
9 COHNISSIONER AHEARNEt Right.
10 CHAIRHAN PALLADINO:
Now, there are a number of 11 questions tht I think are addressed either to Remick or the 12 EDO.
For example, it raised the question on NBC reviewing 13 the Three Nile Island plant within three months.
I think
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14 that came from Bernie Schneider.
Your question here was --
15 COHHISSIONER AHEARNE:
My question was, is that 16 realistic that we will be review and decide on the merits of 17 the plan t within three months.
That is not a question to 18 you, it is on page 13, down near the bottom.
19 CHAIRNAE PALLADINO Abou. ' he sixth line.
20 HR. DIRCKS:
I guess the reaction was, the 21 technical review can be done, but, say, any public comment 22 review and any reviews by the Commission, I quess, would 23 have to be factored in our comments.
24 CONNISSIONER AHEARNE:
But this says the NBC.
s 25 HR. DIRCKS4 Yes.
The technical review, I think ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
25 1 can be done.
2 COHNISSIONER AHEARNE:
As we know on this issue, 3 that has not necessarily been the limiting factor.
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4 HR. DIRCKSs That is why we are going to feed 5 these date problems back in.
6 COHHISSIONER AHEARNE:
Right.
7 CHAIRHAN PALLADINOs I picked tha t up as typical 8 of some of the date problems.
9 CONNISSIONER AHEARNEs Yes.
10 CHAIRMAN PALLADINO:
But there is one that I think 11 has some policy implications and I think we ought to talk 12 about that for a few minutes.
That is on page 11 on the 13 storage and disposal of nuclear vaste.
14 Now, there we talk both about the vsste confidence 15 --
18 COHNISSIONER AHEARNEs Item 1, the vaste 17 confidence for planning guidance, I was merely saying that l
l 18 ve vill complete in the proposed rulemaking.
l 19 CHAIRHAN PALLADIN0s But down in this paragraph 20 your suggestion would be with No.
1.
21 CONHISSIONER AHEARNE:
Correct.
l I
22 CHAIRHAN PALLADINO:
At the bottom we say, "A t
23 permanent repository site vill be selected andf a license 24 application to obtain construction authorizT. tion vill be 25 submitted to the NRC as early as mid-FY 85. "
t ALDERSON REPORTING COMPANY,INC, 400 VIRGIN!A AVE. S.W. WASHINGTON. O.C. 20024 (202) 554-2345
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COHNISSIONER AHEARNE:
I did not touch that.
2 CHAIRHAN PALLADIN0s Nov ve come to the sentence 3 that follows.
" Duration of the NRC review and hearing 4 process should permit a decision on. the issuing a 5 construction authorization by January" - I think it was 1988.
6 Now the question is, should we have it that way or 7 within four years receiving the license application from 8 DOE, and what the implications are.
9 COHRISSIONER AHEAENE What I did was try to go 10 back through information_that I received, that the 11 Commission has received from NHSS and also some of the 12 testimony NHSS has given on what are the stages that they 13 have to go through once they received a license 14 application.
That includes developing their review, putting 15 out the SER and then going to the hearing.
That time frame 16 is about four years.
17 Now, I did not want to pin a date.
So, there are 18 really two issues here, one is vehat date and the other is 19 the length of the time.
I did not want to put a date in 20 because the date that we complete is going to be driven 21 inexorably by the date that DOE comes in.
22 I believe that although there are some bills that 23 have been going around saying ' 85, DOE, I b elieve, is is 24 telling some people in the Congress that th ey cannot meet 25 that.
,ALDERSON REPORTING COMPANY,INC,
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27 1
So, I do not want to get us in a situation that we 2 are in all too of ten. for example, with EPA.
We get a fixed 3 calendar date independ -nt of tre date that is really driving 4 us.
He are readier in situations where we are up front of 5 EPA on things that. ve really logically should have waited 6 for EPA.
But they just did not move.
7 In ths particular Case we clearly have to wait for 8 the application to come in in order for our process to go.
9 So, the first thing is, I think we ought to say whatever the to time is there, it ought to be so much time of receiving othe 11 license.
12 CH AIENAN P AL1ADINO:
I would have no problem with 13 that.
The reason I recall there are several policy
(
14 questions is, I think one of the bills - and I hesitate to 15 try to remember which nusber it was - had two years and nine 16 months in there, and we did comment that that was rather 17 tigh t.
I was really raising it to ask the question of 18 whether or not we shou.3d be trying to meet a target that 19 Congress says in a lav which has not passed yet, or whether 20 ve should be putting in there what we really mean.
21 CORRISSIONER AHEARNE:
My understanding of the l
22 message we gave to the Congress was, it would be very 23 tight.
Certainly, we would do our best to meet it.
If 24 there is a lav ve vill always do our best to meet it.
25 But I think for planning guidance what we are l
ALDERSoN REPORTING COMPANY,INC.
400 VIRGINIA AVE, S.W, WASHINGTON, D.C. 20024 (202) 554-2345
28 1 telling the. sta*'
t do we realistically expect them to 2 dc.
We ought t
ng them what we really, 3 realistica!.ly, e4 them to be able to do.
4 Hy best cotisate, at least from what I have reen 5 is, unless we want 11 the Planning Guidance to assume the e interim licensing for the repository, and if that is the 7 assumption, it should be explicit.
8 But without that assumption I do not think they 9 can make the two and-a-half years.
to CHAIHEAN PALLADINO:
I was going to ask two 11 questions.
One, see if the EDO thinks this is about the 12 right times and two, whether the Commissic7 would 13 countenance putting in there a statement that if 14 congressional action takes place that we would have to 15 re-examine our capabilities versus the schedules shown in 16 whatever legislation is passed.
17 This is another way of keeping the options open.
18 CONHISSIONER AHEARNE:
I guess I would have no 19 problem with a statement - whether it is here or a general 20 statement - that as Vic has often said, we of course are 21 going to try our best to obey the law.
22 CHAIREAN PALLADIN0s That is the sentence I wanted.
23 COHNISSIONER HOBERTS:
Hight.
By concerr. is that l
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24 we ought to recognize and the staff ought to recognize that 25 ve recognize what is a realistic schedule.
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1 CHAIRNAN PALLADINO:
We have told them they time 2 they had and it was not long enough.
3 COMMISSIONER AHEABNE:
That is right.
This is nov
{%
4 speaking to the staff, "How do you plan?"
I think it harms 5 us and it harms the effectiveness of the staff's work if we 6 in speaking to staff tell them to do somthing which is 7 really unrealistic - they know it is unrealistic and we know 8 it is unrealistic.
9 So, I would put in the kind of first point I made, 10 of course we will do our best to try to obey the law, 11 whatever the law onds up saying.
12 HR. BENICK:
Jack Martin has expressed concern 13 with this very thing that you are talking about.
He is very 14 auch concerned about the two years and nine months as not 15 being ad equate.
16 COHNISSIONER AHEARNEa I as positive the only way 17 ve can make a two-year nine-month schedule is if we have 18 interia licensing legislation which says that we will issue to the permit before the hearing is over.
20 HR. DIRCKSs And the other point. we keep 21 stressing, I think we mentioned it to Congress too, it 22 really depends on the quality and acceptability of the DOE 23 submission.
If it is a poor submission, hastily put 24 together to meet a date, that really will then extend our 25 process out considerably.
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CHAIRHAN PALLADINO:
Well, does the four years 2 seen reasonable to you?
3 CORHISSIONER AHEARNE:
I put that together from
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4 the information I had.
You have to go back and check 5
HR. DIRCKS:
I think we also try to condition it 6 on a satisf actor 7 or acceptable DOE submission.
7 COHHISSIONER AHEARNE:
Yes, that is a good point.
8 COHHISSIONER AHEABNE:
What about the change from 9 five to three sites. for purposes of characterization?
Last 10 year's PPG said five.
11 CHAIRHAN PALLADINO:
Inciden tally, it was 12 suggested we take all this history out.
This, I think, is a 13 history based on the recent --
i 14 COMMISSIONER AHEARNE I think Peter's point 15 probably, if I couli rephrase it differently, is that the 16 rule that we put out requires --
17 COHEISSIONER BRADFORD:
I do not recall whether 18 the rule requires a particular number of sites to be 19 characterized.
20 COHNISSIONER AHEARNE4" Did the rule say three, or 21 five?
22 HR. DIRCKS4 Three to five, I think.
It had a 23 range in there, more than three.
24 CONNISSIONER AHEARNE Hore than three?
26 HR. DIRCKS:
No, between three and five.
I think ALDERSON REPORTING COMPANY. INC.
400_VIRGINtA AVE., S.W., WASHINGTON D.C. 20024 (202) 554 2345
31 1 it was a range.
2 CONNISSIONER AHEARNE:
I am not sure.
I know I 3 pushed hard for three, Peter pushed hard for five, and he d
4 von.
5 HR. DIRCKS You.mean in the guidance.
,6 CONNISSIONER AHEARNE:
I thought in the rule, 7 also.
It ought to certainly follow the rule.
8 COMMISSIONER BRADFORD:
The part of the rule I 9 remember is the three sites business -- what I said about 10 sites to has characterized I don't recall.
But I wondered 11 why, since last years PPG said five, I wondered why were 12 were going to from five to three this time.
13 HR. CORNELLs The last budget we put together, the 7-14 FY 63 budget, the assumption was there in terms of budgeting 15 resources processing three sites.
When we put the '83 16 budget together there was a three site assumption in that, 17 and I suspect that is what that number means.
18 CHAIBHAN PALLADINO:
Why don't we ask OP to look I
19 a t the rule if there is something that changed.
20 COHHISSIONER BR ADFORD:
Ies.
21 COMMISSIONER AHEARNEs It may be that '85 is the 22 tim e.
23 COHHISSIONER BR ADFORD :
Haybe that is what it is.
l 24 I assume that the t'ive. appeared in the first place beca use 25 that was what DOE was at that time proposing to do.
If we 1
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
s' 32 1get just the three now, does that mean that DOE has slipped 2 two, eliminated two ?
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CONNISSIONER AHEABNE:
Well, cert ainly' as time 4 goes on --
5 CO.fMISSIONER AHEARNE As it gets closer to
'85.
6 CONNISSIONER AHEABNEs As it gets closer to '85 it 7 is less likely that there vill be more than three sites 8 characterized..
9 CHAIRNAN PALLADINO:
I think that is what DOE is to plannning.
11 NE. DIHCKS:
I think this is in the legislation, 12 too, the two or three bills that are kicking around up there.
13 CHAIRNAN PALLADIN0s I do think even though it was
('
14 suggested we cross all that out since it is not policy, I 15 think the basis on which we are proceeding should be 18 included.
17 CONNISSIONER AREABNE:
This has nothing to do with 18 the vaste management.
What I crossed out was on vaste j
19 confidence procedure.
This whole section is on the vaste 20 confidence.
21 MH. BENICK:
And you did re-introduce waste 22 confidence as Item 1 in the Planning Guidance.
23 CONNISSIONER AHEARNE:
Right because it did not 24 seem to me that the history of the waste confidence 25 proceeding was a valid part of policy, whereas the Planning
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33 1 Guidance would be that we - are going to finish it.
That was 2 my intent.
3 CHAIRHAN PALLADIN0s Any other points on the PPG 7 4
All righ t, thank you very much.
We look forward 5 to the redraft.
6 COMMISSIONER BRADFORD:
I as sure you have been 7 just through the first and last televised PPG meeting.
8 (Laughter.)
9 CHAIRHAN PALLADINO.
I have a feeling that it is to going to appean in connection with a different subject.
11 Thank you, we vill stand adjourned.
12 (Hhereupon, a t 3:55 p.m.
the meeting of the 13 Consission adjourned.)
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14 15 16 17 18 19 20 21 22 23 24 25 v
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MUCLEAR REGULATORY CO.*CIISSION This is Oc certify that the attached proceedings before the
^
COMMISSION MEETING in the =atter ef:
PUBLIC MEETING - DISCUSSION OF POLICY AND PLANNING GUIDANCE Date of ?receeding:
November 18, 1981 Docket Nu='cer:
Place of ?roceeding:
Washincton, D.
C.
were held as herein appears, and that this is the criginal transcript therecf for the file of the Cc==ission.
M.
E.
Hansen Official Reporter (Typed) r h!!4$24 Official Reper:er (Sigr.ature) iV
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