ML021080386

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Palo Verde End-of-Cycle Meeting Summary
ML021080386
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 04/18/2002
From: Laura Smith
NRC Region 4
To: Overbeck G
Arizona Public Service Co
References
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Download: ML021080386 (24)


Text

UNITED STATES 0NUCLEAR REGULATORY COMMISSION REGION IV 811 RYAN PLAZA DRIVE, SUITE 400 ARLINGTON, TEXAS 760114064 APR 1 8 2002 Gregg R. Overbeck, Senior Vice President, Nuclear Arizona Public Service Company P.O. Box 52034 Phoenix, Arizona 85072-2034 ASSESSMENT

SUBJECT:

MEETING

SUMMARY

FOR END-OF-CYCLE PERFORMANCE

Dear Mr. Overbeck:

at the Estrella This refers to the end-of-cycle performance assessment meeting conducted on April 4, 2002. The meeting attendance Mountain Community College, Avondale, Arizona, 1 and 2.

are included as Enclosures list and a copy of the slides presented during the meeting at speech that was distributed is a copy of Chairman Meserve's January 17, 2002, the meeting.

Part 2, Title 10, Code of In accordance with Section 2.790 of the NRC's "Rules of Practice,"

available electronically for Federal Regulations, a copy of this letter and its enclosure will be Publicly Available Records public inspection in the NRC's Public Document Room or from the ADAMS is accessible from the NRC (PARS) component of NRC's document system (ADAMS).

Public Electronic Reading Web site at http://wvwi.nrc.qov/readifQg-rrn/adansn/index.htrnl (the Room).

to discuss them with Should you have any questions concerning this matter, we will be pleased you.

Sincerely, Linda Joy Smith, Chief Project Branch D Division of Reactor Projects Dockets: 50-528 50-529 50-530 Licenses: NPF-41 NPF-51 NPF-74

Arizona Public Service Company

Enclosures:

1. Attendance List
2. Licensee Presentation
3. "Nuclear Security in the Post-September 11 Environment" speech by Dr. Richard A.

Meserve, Chairman U.S. Nuclear Regulatory Commission cc:

Steve Olea Arizona Corporation Commission 1200 W. Washington Street Phoenix, Arizona 85007 Douglas K. Porter, Senior Counsel Southern California Edison Company Law Department, Generation Resources P.O. Box 800 Rosemead, California 91770 Chairman Maricopa County Board of Supervisors 301 W. Jefferson, 10th Floor Phoenix, Arizona 85003 Aubrey V. Godwin, Director Arizona Radiation Regulatory Agency 4814 South 40 Street Phoenix, Arizona 85040 Craig K. Seaman, Director Regulatory Affairs/Nuclear Assurance Palo Verde Nuclear Generating Station Mail Station 7636 P.O. Box 52034 Phoenix, Arizona 85072-2034 Hector R. Puente Vice President, Power Generation El Paso Electric Company 2702 N. Third Street, Suite 3040 Phoenix, Arizona 85004 Terry Bassham, Esq.

General Counsel El Paso Electric Company 123 W. Mills El Paso, Texas 79901

Arizona Public Service Company John W. Schumann Los Angeles Department of Water & Power Southern California Public Power Authority P.O. Box 51111, Room 1255-C Los Angeles, California 90051-0100 David Summers Public Service Company of New Mexico 414 Silver SW, #1206 Albuquerque, New Mexico 87102 Jarlath Curran Southern California Edison Company 5000 Pacific Coast Hwy. Bldg. DIN San Clemente, California 92672 Robert Henry Salt River Project 6504 East Thomas Road Scottsdale, Arizona 85251 Brian Almon Public Utility Commission William B. Travis Building P.O. Box 13326 1701 North Congress Avenue Austin, Texas 78701-3326 Michael Austin, Director Arizona Division of Emergency Management 5636 East McDowell Road Building 101 Phoenix, Arizona 85008-3495 Federal Emergency Management Agency Karen Armes, Acting Regional Director Building 105 Presidio of San Francisco San Francisco, California 94129 Mayor Ron Drake 525 North Central Avondale, Arizona 85323 Mayor Dustin Hull 100 North Apache Road Buckeye, Arizona 85326

Arizona Public Service Company Mayor Jose Delgado P.O. Box 26 El Mirage, Arizona 85335 Mayor Elaine Scruggs 5850 West Glendale Avenue Glendale, Arizona 85301 Mayor William Arnold 119 North Litchfield Road Goodyear, Arizona 85338 Mayor J. Woodson Thomas 244 West Wigwam Blvd.

Litchfield Park, Arizona 85340 Mayor John Keegan 8401 West Monroe Street Peoria, Arizona 85345 Mayor Skip Rimsza 200 West Washginton Phoenix, Arizona 85007 Mayor Joan Shafer 12425 West Bell Road Surprise, Arizona 85374 Mayor Adolfo Gamez 9555 West Van Buren Street Tolleson, Arizona 85353 Mayor Eugene Russell 12030 Clubhouse Square Youngtown, Arizona 85363

ENCLOSURE 1 ATTENDANCE LIST

Nn -----V---- MEETING ATTENDANCE I LICENSEE/FACILITY Arizona Public Service Company Palo Verde Nuclear Generating Station DATE/TIME April 4, 2002; 6:00 p.m.

Rm LOCATION Estrella Mountain Community College - S. Community NAME (PLEASE PRINT) ORGANIZATION DAVID _

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END-OF-CYCLE MEETING ATTENDANCE LICENSEE/FACILITY Arizona Public Service Company Palo Verde Nuclear Generating Station DATE/TIME April 4, 2002; 6:00 p.m.

Rm LOCATION Estrella Mountain Community College - S. Community NAME (PLEASE PRINT) ORGANIZATION

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ENCLOSURE 2 LICENSEE PRESENTATION

ASSESSMENT OF SAFETY PERFOMANCE AT PALO VERDE NUCLEAR GENERATING ANNUAL ASSESSMENT STATION MEETING Nuclear Regulatory Commission Region IV NRC PERFORMANCE GOALS

"* Maintain public safety and protect the environment

"* Enhance public confidence

"* Improve:

- Effectiveness

- Efficiency Realism of processes and decision making

"*Reduce unnecessary regulatory burden I

Palo Verde Nuclear Generating Station 2

Resident Inspectors

  • Stationed at the plant 0 2616 hours0.0303 days <br />0.727 hours <br />0.00433 weeks <br />9.95388e-4 months <br /> of oversight
  • Prompt response capability Comprehensive Oversight Progqram 3

NRC Oversight Activities Reactor OversightProcessv

"* Provide assurance plants are:

- Operating safely

- Complying with regulations

"* Based on a logical and sound framework

"*Inspections focused on key safety areas

"* Objective indicators of performance

"* Assessment program triggers regulatory actions Baseline Inspection Program Baseline Inspection Program

"* Inspection reports describe significant

"*Gathers objective evidence of plant safety findings and non-compliance

"*Conducted at all plants

"* Focuses on safety-significant: "* Inspection reports are publicly accessible

- systems

- components www.NRC.gov/reading-rmladams.html

- activities

- events 4

Event Follow-up and Reactor Oversight Process Supplemental Inspections SAFETY SIGNIFICANCE

"*Review events for significance G- very low

"* Follow-up significant inspection findings - low to moderate

-substantial

"*Determine causes of performance declines

"*Provide for graduated response

- - high Performance Indicator Performance Indicators Program

  • Performance indicator results and other assessment information available on the

"* Licensee monitors key safety parameters NRC's public web site:

"*Data supplied to NRC quarterly www.NRC.gov/NRRIOVERSIGHT/ASSESS/

PALOl/pafolchart.html

"*Performance Indicator data is publicly www.NRC.gov/NRRIOVERSIGHTIASSESSI accessible PALO2Jpalo2_chart.html www.NRC.gov/NRR/OVERSIGHT/ASSESS/

PALO3Ipalo3_chart.html 5

Performance Indicators Key Aspects of the Unplanned Scrams per 7000 critical hours Assessment Pro-gram 20/01 3Q101 40101 "*Objective review of licensee performance 0 Thresholds:

White >3.0, "*"Action Matrix" to determine agency response in three areas:

- Inspection 15 Yellow >6.0, - Management Involvement

- Regulatory Actions 20 Red >25.0 0.9 1.8 1500.9 lm~ mau2-, -F~m 251 critical hours 1.8 2184.0 0

2Q/01 2174.4 1

3OJ01 0

4Q/0t "*Plant specific assessment letters Unplanned scrams per 7000 Unplanned scrams per 7000 critical hours 20101 30101 40101 Actual scrams IActual hours Criticalscramls value Critical hours 0

2184.0 1

2174.

0 15008.9

"*Information on NRC public web site -%i Indicator Indicator value, 1.8 1.8 0.9 Plant Safety Inspection Results Performance Summary NRC and Licensee identified inspection findings were of very low safety significance No special or supplemental inspections necessary 6

Performance Indicator Assessment Conclusion Results Licensee effectively managed:

- Reactor safety All performance indicators within the - Radiation safety Licensee Control Band - Plant security Palo Verde Nuclear Generating Station operated in a manner that protected the health and safety of the public Palo Verde Nuclear Generatinq Station Additional Focus Areas

"*NRC Responds As-Needed

"* Mandated Licensee Actions

"* Implemented Emergency Preparedness 7

Reactor Vessel Head Degradation Nuclear Industry Issues

  • Small leaks were discovered

"*Reactor Vessel Head Degradation

  • Mandated Licensee Actions

- NRC Bulletin 2001-01 "Circumferential Cracking of

"*Security at Nuclear Power Plants Reactor Pressure Vessel Head Penetration Nozzles"

  • Identified larger problem IF/° Reactor Vessel Head Degradation Reaction to September 11
  • Mandated Licensee actions

- NRC Bulletin 2002-01 "Reactor Pressure Vessel Head

  • Activated Facilities Degradation and Reactor Coolant Pressure Boundary Integrity"
  • Issued Advisories
  • Assure all plants are adequately inspected for this problem
  • Verified Implementation
  • Ensure similar degradations do not occur at other facilities 8

Reaction to September 11 Reaction to September 11

  • Ordered increase in minimum security
  • Coordinated with other agencies requirements
  • Updated advisories as terrorist threat changed
  • Reviewing security regulations considering our changed environment
  • Verified implementation Contacting the NRC Conclusions

"*Report an Emergency:

(301) 816-5100 (collect)

  • Assured Public Safety

"* Report a Safety Concern:

"* Flexible/Predictable Response (800) 695-7403 or Allegation@nrc.gov

"*General Information or questions:

"* Risk-Informed Programs www.nrc.gov Select 'What we do" for Public Affairs 9

ENCLOSURE 3 BY "NUCLEAR SECURITY IN THE POST-SEPTEMBER 11 ENVIRONMENT" SPEECH DR. RICHARD A. MESERVE, CHAIRMAN U.S. NUCLEAR REGULATORY COMMISSION

.dLUUL1SUL-UU1 Site Heb I Site Inde Contact Us [IIIIIII] Advanced Search Home > Electronic Reading Room > Document Collections > Commission Speeches > 2002 > S-02-001 OFFICE OF PUBLIC AFFAIRS Office of Public Affairs Telephone: 301/415-8200 Washington, DC 20555-001 E-mail: oDa@nrc.aov Web Site: Public Affairs Web Site No. 5-02-001 PDF Version (38 KB)".-

Nuclear Security in the Post-September 11 Environment by Dr. Richard A. Meserve, Chairman

  • ýI. Nuclear Regulatory Commission National Press Club Washington, DC January 17, 2002 Good afternoon. I am pleased to have this opportunity to address you.

I suspect that you have a strong interest in security at nuclear power plants. I hope to provide you with a summary of how the Nuclear Regulatory Commission approaches security matters, with a description of some of the actions taken in the aftermath of the September 11th attacks, and with a survey of some of the major challenges ahead.

Let me make a few general points at the outset.

First, and perhaps most important, since September 11th there have been no specific credible threats of a terrorist attack on nuclear power plants. Of course, there is information that al Qaeda considers nuclear facilities as potential terrorist targets. In light of the high general threat environment, we and our licensees have maintained our highest security posture.

Second, the physical protection at nuclear power plants is very strong. I know that there has been a lot of discussion concerning the adequacy of security in light of the sensitivity of these facilities. But let me assure you that nuclear plants are not "soft" targets. For decades, security against sabotage has been an important part of the NRC's regulatory activities and our licensees' responsibilities. The plants are among the most formidable structures in existence and they are guarded by well trained and well armed security forces. The security at nudear plants is and has always been far more substantial than that at other civilian facilities. And it has been augmented since September 11.

Third, I want to assure you that the NRC is responding to the terrorist threat in a comprehensive fashion. September 11 has served to alert America to the need for re~examination of past practices.

As a result, the NRC is undertaking a top-to-bottom review of our security program to ensure that we have the right protections in place for the long term.

I. The Existing Security System.

Let me start by providing you with a more detailed description of our security requirements.

Each licensee has a responsibility to defend its nuclear power plant, subject to regulatory scrutiny by the NRC. Under our existing regulatory system, we require that our licensees demonstrate a high assurance that they can defend their facilities against a so-called "design-basis threat." Although the details of that threat are classified, it basically involves a 03/1512002 2:55 P?,

Npeecn - buui - lNuciear Security in the flost-September I1I Environment http://www.nrc.gov/reading-rmidoc-collectionslcommissionlspeechesl2Oo2stIr.,si commando attack by several skilled attackers, armed with automatic weapons, with hand-carried explosives and incapacitating agents, and with assistance by 'an insider, the use of a 4-wheel drive vehicle, and a vehicle bomb. Our licensees defend against such a threat by the establishment of a fenced perimeter (usually a double fence topped with-concertina wire),

intrusion detection devices, layers of access barriers, heavily armed and carefully trained guard forces, armored defensive positions, and a comprehensive defensive strategy. The adequacy of the defenses is subject to detailed inspection by the NRC, including periodic force-on-force exercises designed to probe for weaknesses so that corrections car,'be made.

The design basis threat does not Include an aircraft attack. In the aftermath of Septýr7*ber 11, many have asked about the consequences if a large airliner, fully loaded with jet fuel, had crashed into a nuclear power plant. We had to say candidly that we were not sure. We know that reactor containments are extremely robust, typically being constructed with two to five feet of reinforced concrete with an interior steel lining. The plants benefit from redundant and diverse safety equipment so that if any active component were unavailable, there is another means to satisfy its function. The operators are trained to respond to unusual events. And carefully designed emergency plans are in place. Nuclear power plants are certainly far more capable to respond to an aircraft attack than other civilian facilities. But the NRC has never previously had reason to perform a detailed engineering analysis of the consequences of a deliberate attack by a large airliner. We are performing those analyses now.

I am sometimes asked whether a terrorist might be able to gain employment at a nuclear plant. Let me describe some of the regulatory requirements that bear .ýis issue. At the time of employment, every potential employee who will have at-t3tisy equipment is required to pass various background - including examination of past employment, references, credit history, and an'F13BI criminal record check, as well as to undergo psychological testing. During the course of employment, each employee is also subject to fitness-for-duty requirements, which include random drug and alcohol testing. Behavioral monitoring of employees is also required so as to ensure that any aberrant actions receive appropriate attention. Of course, access to the plants is controlled and there are portal detectors for metals and explosives. We are examining whether these requirements should be supplemented in the course of our top-to-bottom review.

II. Response to the September 11 Events Let me turn now to the events on September 11 and the NRC's subsequent actions.

Shortly after the second crash into the World Trade Center, the NRC activated its Headquarters Emergency Operations Center and the parallel Incident Response Centers in each of NRC's four regional offices. We immediately called for our major licensees to go to the highest level of security, which we have maintained since that time and augmented as circumstances warranted. This heightened security stance generally includes, among other resources, increased patrols, augmented security forces and weapons, additional security posts, heightened coordination with law enforcement and military authorities, and additional limitations on access of personnel and vehicles to the site.

The NRC's safeguards analysts have worked continually with the intelligence and law enforcement agencies to assess the general threat environment, as well as information about specific targets. In order to assess whether terrorists may have been conducting surveillance of nuclear facilities, we, with assistance from Federal, State and local law enforcement, have carefully examined unusual incidents, such as fly-overs, threats, or the possible probing of defenses. NRC investigators have also examined incidents over the past two years that might have seemed innocent or odd at the time, but that in retrospect might suggest a pattern that should be referred to the FBI for follow-up.

As you might expect, there have been extensive interactions with other governmental agencies. We have worked closely with the new Office of Homeland Security, the FBI, the Federal Emergency Management Agency, the Federal Aviation Administration, the military, and the Department of Energy, among others. And I have communicated with the governors of 40 states so as to ensure that any state defensive assets (National Guard or state police) are used as needed to augment our licensees' defensive strategies.

III. Fundamental Challenges 2 of 5 03115/2002 2:55 P?

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ýpee* n - vviJ - I*iU * .L;uatIIcu J-l i Let me turn now to some longer-term challenges. The Commission has not yet had the opportunity to complete its consideration of some of these issues, so these comments should be seen as my own.

A. The Need for a Comprehensive Security Strategy I shall first discuss the context for examining the security of nuclear plants.

As you know, there have been numerous discussions about the potential vulnerability of nuclear power plants to terrorist attack. Some argue that the only acceptable response to the risk is to shut down the Nation's reactors. Others contend we can continue with nuclear power - which provides about 20 percent of the Nation's electricity -- so long as appropriate security measures are in place.

The crimes of September 11 were designed to shock the American people in part by the very fact that they involved such large and imposing targets. In the effort to ensure that no such horror ever occurs again, there is a danger of drawing the wrong lesson from the attacks: of blaming the victim, so to speak. The destruction of a skyscraper does not suggest it was a mistake to build skyscrapers, any more than the dissemination of anthrax spores through the mails proves that it is an error to operate a postal service. If we allow the threats of terrorists to determine what we build and what we operate, we would be headed into the past -- back to an era without suspension bridges, harbor tunnels, stadiums, or hydroelectric dams, let alone skyscrapers, liquid natural gas terminals, chemical factories, or nuclear power plants.

The problem is not the terrorists' targets, but the terrorists themselves. It is they who need to be eliminated, not the creations of a modern industrial society. It is thus my view that a strategy of risk avoidance -- the elimination of the threat by the elimination of potential targets -- does not reflect a sound response. Rather, the evaluation of the terrorist threat to infrastructure, including nuclear plants, should include a careful and realistic examination of risks and benefits and the development of appropriate defenses in light of those risks and benefits.

September 11 has made clear that our society must increase the vigilance with which we defend ourselves from terrorist attack. But the reality is that, as a society, we do not have infinite funds to spend for this purpose. Accordingly, we must allocate our defensive resources in a fashion that serves to minimize the total risk. As a result, any policy regarding the defense of nuclear facilities should be integrated in the overall response to the threat to infrastructure of all kinds.

Clearly this is not a task that the NRC can undertake alone. We have sought, and will continue to seek, appropriate security at facilities subject to our jurisdiction. We look forward to working with the Office of Homeland Security and others to ensure that our strategy is coordinated with the Nation's overall defensive posture. I see this as a great challenge, however, because the task is large and the defense of infrastructure involves government at all levels.

B. Public and Private Roles.

The second policy issue that I would like to discuss relates to public and private roles in the defense against terrorism. This is an issue that the events of September 11 have brought clearly to the fore.

As I have explained, the NRC licensees must defend nuclear power plants against the "design-basis threat." September 11 obviously revealed a type of attack -- a suicidal assault using a large commercial aircraft -- that has not been part of the NRC's planning (or that of any other agency with similar responsibilities). Moreover, the event has demanded that the NRC and its licensees reevaluate the scope of potential assaults of all types.

There are limits, however, as to what should be expected from a private guard force, even as assisted by local law enforcement. For example, if it were determined that 3 of 5 03/15/2002 2:55 Pr

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nuclear plants should be defended against aircraft attack, I cannot conceive that the NRC would expect licensees or local law enforcement to acquire and bperate anti-aircraft weaponry. Rather, this obligation would be one for the military. Similarly, there might be other types of attacks which should properly involve governmental response because of the size of the assumed attacking force or the equipment that must be employed in defense. As a result, in its development of policy, the NRC must be prepared to differentiate the defensive obligation that is borne by licensees from that which must be undertaken by the government.

As part of the top-to-bottom review that I mentioned earlier, the NRC is examining the new threat environment in coordination with various other agencies of Government.

There may also have to be an additional discussion with the military, the States, and local law enforcement about the provision of governmental assets at appropriate times. I do not expect that defining the appropriate boundary between the public and private sector in the defense of nuclear facilities will be easy.

C. The Balance Between Security and Openness.

The third issue relates to the balance between security and openness. The NRC has sought to achieve public confidence through a variety of means, but perhaps the most effective tool has been a policy of transparency. We recognize that decisions made behind closed doors may be viewed with suspicion. We have therefore sought to assure open decision processes that would enable the public to be fully informed of the issues before us. We cannot aspire to a world in which all will be satisfied by our decisions, but we have hoped that all would see that our decisions were reached through fair processes.

September 11 has made clear that we need to rethink just how open we can and should be with respect to physical security issues. In this process we must give due regard to two vital but competing interests. The first is the public's right to know, a right that is grounded in law and that is one of the most cherished principles of our democracy. The other is the need to keep sensitive information away from those whose purpose is to destroy that democracy. We are striving to strike an appropriate balance between openness and security.

D. Achieving ProgressIn Other Agency Business.

The final challenge I would like to mention is the need to accomplish security reform at a time of major transition in the energy sector.

Over the past year or two, we have seen a quiet Renaissance in the nuclear business.

The nuclear generating companies have become "leaner and meaner": more effidently run, with far fewer outages and greater reliability. In the past decade, the average capacity factor, which is a measure of plant utilization, has jumped from 70 percent to nearly 90 percent. Not surprisingly, as the electrical production of the average plant has increased, the cost of the electricity has declined. As a result, the production cost of electricity from nuclear plants is less than that from its principal competitors -- coal and natural gas. And nuclear is not burdened with the emissions constraints and concerns about global warming that attend fossil fuels.

Most importantly, by all objective measures, the safety performance of nuclear plants has improved in parallel with economic performance. The NRC tracks "significant events"

-- safety system failures, unanticipated plant responses, degradation of key systems or components, and operator errors. The number of significant events has declined 99 percent in 15 years. It is not an accident that safety performance and improved economic performance should be linked to each other: both are furthered by preventive maintenance, better training of operators, and the fostering of a safety culture.

Just a few years ago, some pundits claimed that restructuring in the electricity business would lead to the premature shutdown of nuclear plants. But, as a result of this strong economic and safety performance, we are instead seeing interest among our licensees in expanding their activities. Generating companies are seeking the renewal of the licenses of existing plants so as to allow operation beyond the initial 40-year license term. And some are even contemplating new plant construction.

4 of 5 03/15/2002 2:55 P?

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New construction offers the promise of improvements in both safety and in economics.

But new construction presents a significant challenge for many reasons, including that new construction might involve designs that are completely different from existing facilities. For example, there are discussions of reactors that are cooled by helium, rather than water. We have started to prepare for the possibility of new applications so as to ensure that we have the appropriate regulatory and analytical tools in place.

I mention these developments because, even before September 11, the NRC was an agency that was confronting significant challenges. Fortunately, we have used the past quarter century to good advantage, improving our processes and preparing to accommodate technological and economic developments. If society decides to expand reliance on the nuclear option, the NRC is prepared to perform its role of protecting public health and safety.

Conclusion Let me note in conclusion that we live in very uncertain times and it is difficult at this juncture to predict how the security and other challenges I have mentioned will be finally resolved. I hope that I have left you with the awareness that the NRC takes its obligations very seriously.

Thank you for allowing me to join you. I would be happy to respond to questions.

5 of 5 03115/2002 2:55 PI*

Arizona Public Service Company Electronic distribution by RIV:

Regional Administrator (EWM)

DRP Director (KEB)

DRS Director (ATH)

Senior Resident Inspector (JHM2)

Branch Chief, DRP/D (LJS)

Senior Project Engineer, DRP/D (JAC)

Staff Chief, DRP/TSS (PHH)

RITS Coordinator (NBH)

B. Henderson, PAO (BWH)

W. A. Maier, RSLO (WAM)

C. J. Gordon (CJG)

DRS Branch Chiefs (GMG, ATG, CSM)

W. D. Travers, EDO (WDT)

C. A. Carpenter, Chief, NRR/DIPM/IIPB (CAC)

R. K. Frahm, PPR Program Manager, NRR/DIPM/IIPB (RKF)

R. W. Borchardt, Associate Dir. for Inspection and Programs (RWB1)

B. W. Sheron, Associate Dir. for Project Licensing and Technical Analysis (BWS)

J. Shea, Chief, Regional Operations Staff, OEDO (JWS1)

L. W. Bamett, Acting NRR Project Director (LWB)

R. Gramm, Chief, Section 1, NRR/DLPM (RAG)

J. Donohew, NRR Project Manager (JND)

RidsNrrDipmlipb S:\DRP\DRPDIR\EOC 2002\Summaries\PV 04-04-02 EOC MS.wpd

_____*...*_..*._________________/RA_04/LJ.m.th.bh7/02..................:::::::::::::::::::::::.

LJSmith;tbh IRAI 04/17/02 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax