ML20058K951

Requests Findings & Views on Encl Retire Nine Mile One Raising Concern About Role Played by INPO in Regulation of Nuclear Power Plants

ML20058K951
Person / Time
Site:	Nine Mile Point
Issue date:	05/08/1990
From:	Damato A SENATE
To:	NRC
Shared Package
ML17058A649	List: ML20058K925 ML20058K934 ML20058K943 ML20058K947 ML20058K951
References
NUDOCS 9008030161
Download: ML20058K951 (3)

Text

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.' perw vons too saven cuco= 0nsev Cvnacuss. New venu tuta (Ill)42 M 471 r

'2Tnifeb States Senate  :

WASHINGTON. D.C. 20510 '

May 8, 1990 i

Office of Congressional Liaison Nuclear Regulatory Commission 1717 H Street, N.W.

Washington, D.C. 20555 i

Dear Director Because of the desire of this office to be responsive to

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all inquiries and communications, your consideration of the i attached is requested, t

Your findings and views, in duplicate form, will be appreciated, u

Please reply to my Syracuse office.

Sincerely, 1

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Alfonse M. D'Amato United States Senator AMD/mt ,

Attachraent t

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i Retire Nine Mlle One e n'" 't. I. fill:og A broad based coalition of citizens concerned about the safety of the Nine Mile One Nuclear Facility Steering Committee Chris Binaxas Linda Clark Ollie Clubb Heen Daly, PhD.

Apr il 30, 1990 OMwd Fedman Cindy Gagne Chris Lynch Nornen Rdh Virginia Durkin Stamm Edward Swm, MD.

Dear Senator D ' Ama to:

Tom Walsh

+

The coalition Retire Nine Mile One has concerns about the role played by The Institute of Nuclear Power Operations in the regulation of nuclear power plants. The institute, known as INPO, was created in the af termath of the Three Mile Island accident by the nuclear industry to inspect plants and rev ie w corporate operations . INPO is a membership organization funded by the utlities. Niagara Mohawk is a member and evaluations have been made of their nuclear ope ra t io ns .

The NRC has transferred some of the monitoring of nuclear f power plants, including saf ety evaluations, to INPO and has acknowledged that they do not wish to duplicate the efforts ,

of INPO. However, INPO is not required to share their findings with the NRC and release of INPO reports to the public is prohibited. An INPO memorandum defends the groups  :

secrecy, stating that "public and/or political pressure may be brought to bear on the NRC to follow-up on INPO evaluations for the purpose of reg ula tor y action."

When the INPO reports on the Seabrook Nuclear Power Plant were recentl y obtained by citizens groups , they revealed a litany of problems never before documented and not addressed in the NRC's licensing process for Seabrook. Many of the problems affected crucial saf ety systems which the company admitted it would not address until after f ull po we r operation had begun. Recent testimony before Congress on this matter by Ralph Nader and Robert Pollard is enclosed. l l

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P.O. Box 563 University Station . Syracuse, New York 13210 l

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pg. 2 The.INP0/Seabrook situation has direct implications for people concerned about the saf ety of Nine Mile . One. For many years , INPO has produced reports about Nine Mile One.

L How can we be certain the NRC has a complete picture of the condition of Nine Mile One? How can we know that all the problems discovered at Nine Mile One have been addressed if we do not know what the INPO reports on Nine Mile One contain? -

While we recognize the right of organizations to conduct  !

confidential internal evaluations, when INPO conducts an ,

evaluation they are operating in lieu of the NRC. INPO reports should be available to the public as would the reports of the NRC. The current process endorses secrecy and eliminates public accountability.

We ask'that you request the NRC to obtain all INPO reports related to Niagara Mohawk's nuclear operations and release

-them to the public doc umen t room as would be required of NRC reports. We also request an accounting of the number of INPO reports produced related to Niagara Mohawk's nuclear operations. We hope you will insure that all in f o rm a t ion contained in reports relating to Nine Mile One be subject to restart action procedures currently in process by the NRC.

We hope you will share our concern that an industry group [

hes becone the industry watchdog, eliminating the public sc rutiny of nuclear plants guaranteed by law.

S i nce r el y, RETIRE NINE MILE ONE by Tom Wals h , c o- cha i r

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e EMORANDLM 0F AGREEENT BETWEEN THE INSTITUTE OF NUCLEAR POWER OPERATICES AND THE U.S. NUCLEAR REGULATORY CopMIS$10N ThismemorandumbetweentheU.S.NuclearRegulatoryCommission(NRC)andthe Institute of Nuclear Power Operations (INPO) reflects the desire for a continuing and cooperative relationship in the exchange of experience, infomation, and data related to the safety of nuclear power plants.

The NRC has statutory responsibility for licensing and regulating nuclear facilities and materials and for conducting research in support of the licensing and regulatory process, as mandated by the Atomic Energy Act of 1954, as amended, the Energy Reorganization Act of 1974, as amended, and the Nuclear Nonproliferation Act of 1978; and in accordance with the National Environmental Policy Act of 1969, as amended, and other applicable statutes.

NRC's responsibilities include protecting public health and safety, protecting the environment, protectinti and safeguarding materials and plants in the interest of national secur' ty, and assuring conformity with antitrust laws, INP0 is an organization sponsored by the nuclear utility industry whose i

mission is to promote the highest levels of safety and reliability in the ,

operation of nuclear electric generating plants. As such, NRC and INPO undertake mutual and complementary activities, as defined in appendices to this Agreement. These appendices will help ensure that the goals of both

! organzations are achieved in the most efficient and effective manner without

l. diminishing or interfering with the responsibilities and authorities of the l NRC and the goals of INP0.

l- This Memorandum is not intended to be an enforceable agreement or contract on either party, notwithstanding the occasional use of the term " agree" or the use of mandatory language such as "shall" or "will" in either the Memorandum or its appendices. In particular, insofar as this Memorandum or its l

' appendices indicate that the Commission will take or refrain from taking a particular action in discharge of its regulatory responsibilities, such an l indication is intended only to reflect the Commission's current policy

! intentions in this regard. Since this Memorandum is not legally binding, the l Cossiission may depart from its terms whenever it deems it necessary or appropriate to do so in the discharge of its regulatory responsibilities, o except that in the interests of cooperation the Cossiission will, if

! appropriate and practical, advise INP0 of any intention to depart from the terms of this Memorandum prior to doing so.

i It is intended that this Memorandum of Agreement and its companion appendices l

, complement one another. Appendices are utilized to delineate detailed and

specific areas for cooperative agreements which exist between the parties of this Agreement and which may be amended from. time to time. The appendices are not interpreted as restrictive to only those areas specified in the document, but serve as keystones of the Agreement for the exchange of information to support the common goals of both organizations.

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Memorandum of Agreement Setween INP0/NRC Page Two INP0 and the NRC agree to consult with each other with regard to the

. availability of technical information which would be useful in areas of mutual interest; and to promote and encourage a free flow of such information. In this regard, INP0 wiil provide plant specific information on a case-by-case basis consistent with the other provisions of this Agreement. Both parties I recognize the need for excluding from this Agreement fragmentary information related to work in progress and/or which has been received on a privileged basis. However, as info-mation is verified and found to be necessary or

. important to findings u g n which significant safety-related conclusions and recomendations are based, the party holding such information will take appropriate and timely steps to remove it from the fragmentary, privileged or otherwise restricted status. However, the NRC cannot provide information to l INP0 that is required by law to be withheld. Each party recognizes the need.

l on some occasions, to be able to accept and protect privileged information )

where such information could not be made available otherwise. It is 4 recognized that the parties to this Agreement may not be fully aware of the i extent of each other's knowledge and thus, this Agreement requires only the '

- parties' best efforts and a reasonable degree of care in assuring that significant safety-related information is provided in a timely manner to the other party.

The parties to the Agreement will meet periodically to exchange information and keep each other apprised of the major activities underway and planned in each area of agreement. The meetings are an effort to avoid unnecessary and unintentional duplication of activities, while providing a means to identify those areas where independent activities by another organization may be warranted.

Coordination meetings are for information exchange only. Meetings are not to be construed as requests or opportunities for (or used by the NRC for obtaining) the advice or recomendations of INPO or its personnel on policy or regulatory issues within the scope of the NRC's responsibilities. INP0 advice or recommendations to the Comission on regulatory or policy matters, if any, are to be made through established procedures of the Commission and will be considered by the Comission in the same manner as other offers of advice or recomendations made through established Commission procedures. Minutes of all coordination meetings will be placed in the NRC public document room.

These need not be verbatim transcripts of coordination meetinfis, but should include a list of the meeting participants and agenda items d'scussed at meetinfis, with brief sumaries of the discussions held by meeting partic' pants.

In addition to meetings, it is expected frequent, informal comunications will exist among the parties that will be limited to exchanging information and providing updates on the status of activities in progress or planned.

The appendices to this agreement provide for NRC access to selected INPO l

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proprietary e. gJments and information. Such documents and information provided to the NRC will be appropriately identified as Limited or Restricted l

Distribution. Consistent with previous legal decisions sanctioning the exchange of proprietary information between INPO and NRC and in the interest of improving nuclear plant safety, NRC will control distribution of INPO

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l Memorandum of Agreement Between INP0/NRC Page Three i proprietary documents and information within the agency and will exert best efforts to protect it from unauthorized disclosure. Exceptions to this policy for control of IMPO proprietary documents and information will be addressed by -

the parties to this agreement on a case-by-case basis.

This Agreement supersedes the previous Agreement dated December 18, 1985.

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Tictor all , Jr. - T5ck T. Pete E.=ecutiv rec r Operations President U.S. Nuclear R atory Comission Institute of Nuclear Power Operations Effective Date: October 20, 1988 l

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4 APPEND 1X IRSSER ONE C0 ORDINATION PLAN FOR NRC/INP0 EXCHANGE OF OPERATIONAL EXPERIENCE DATA

1. BACKGROUND i

, The purpose of this plan is to coordinate selected NRC and INPO activities related to the collection and feedback of operational experience, )

information and data related to the safety and reliability of nuclear power plants. There are several underlying assumptions, including the following:

4. NRC as the government entity has statutory responsibilities and authorities which are paramount. Nothing in this plan dilutes that responsibility and authority to take action in accordance with  ;

applicable statutes. 1 I

b. Recognizing the ability of INPO to contribute to safe and reliable operation with a resulting benefit to public health and safety, the

. following statements apply:

(1) NRC and INP0 share the comon objectives that reporting of.

operational experience information and data be efficient and that duplicative or inconsistent reporting be minimited.

(2) WRC and INP0 agree that the validity of analysis results may-depend upon the completeness and quality of input information. l (3) MRC and INP0 agree that the effectiveness of operational data feedback is dependent upon a proper understanding of the significant lessons learned from industry operating experience.

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2. OVERALL C0 ORDINATION

a. NRC and INP0 will regularly exchange, on a timely basis, the results of completed and formally documented generic analysis and event evaluation of operational data.

b. INP0 will provide the NRC with timely listinfit of the significant events that have been identified by the SEEC N screening process as significant events for analysis. Similarly, the NRC will provide INP0 in a timely manner with the results of its sitinificant event screening procedure that identifies events for en neering evaluation or a case study and for Information Notices or Bu latins.

c. Information and data obtained by the NRC from foreign sources, that do not include restrictions on further distribution, will be entered into a computerized data bank and will be made available for INPO analysis activities. Foreitin information and data obtained by IMPO that does not include restr'ctions on further dissemination will

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Appendix Number One i

Coordination Plan for NRC/INPO Exchange of Operational Experience Data Page Two j

similarly be entered into an INPO data base and will be made available for NRC analysis activities.

d. INP0 wi.11 provide the NRC access to and use of the Nuclear Plant Reliability Data System (NPRDS) operated and maintained by INP0.

Additional agreements regarding NPRDS access and usage are contained in a contract between NRC and LNPO that is separate from this agreement.

e. NRC and INPO intend to have periodic informal technical discussions on generic or event-related studies in progress that are of mutual interest.

f. Prior to issuing to the industry an Information Notice or other.

completed and formally documoted analysis on a specific event at a nuclear power plant, the NRC agrees to make reasonable efforts to review available INPO SEE-IN products to determine if the Information Notice or other analysis is needed and, if so, that it is technically accurate. Similarly, INP0 agrees to make reasonable efforts to l review available NRC Information Notices or other completed analysis 1 to determine if an INP0 SEE-IN product is needed and, if so, that it l 1s technically accurate. Unless a compelling safety concern dictates l otherwise, the party identifying technical inaccuracies, if any, will give the other party reasonable advance notification of the -

naccuracies and seek resolution before formally issuing the 1 information to the industry. J fM, l Victor @tel)b. /

/ZaerT. Pate Execut19r11r for Operations U.S. Nuclear 14 tory Comission ( President Institute of Nuclaar Power Operations Effective Date: October 20, 1988 L

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i APPEN0!X IRDSER TWO ,

COORDINATION PLAN FOR NRC/INP0 APPRAISAL AND EVALUATION ACTIVITIES

1. EKEBEQ The purpose of this plan is to coordinate selected NRC and INP0 utility appraisal and evaluation activities. It is also intend:d to provide a mechanism and a basis for NRC to recognize INP0 efforts in this area.

There are several underlying assumptions, including the following:

L o INPO recognizes NRC's regulatory responsibilities and authority, o NRC recognizes INP0's efforts to promote excellence in nuclear plant operations. -

j o- NRC desires to recognize INP0 evaluation activities to the extent that these activities are effective in helping meet NRC's responsibilities as well as lessen the burden imposed on the industry by duplicative appraisal activities.

o NRC requires access to selected INP0 documents and information as well as the opportunity to observe selected IMPO activities in order to be able to give credit for INPO activities and to i thereby avoid unnecessary duplication.

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2. INP0 ACTIVITIES This section outlines current and planned INP0 evaluation activities.

a. INP0 will conduct evaluations of operating nuclear plants on a periodic basis. The interval between plant evaluations will average about 16 months.

b. INP0 will conduct evaluations or assistance visits related to corporate support of nuclear stations. This phase of INPO activities will usually be conducted coincident with (in close time proximity i

to) an evaluation of the utility's plants.

c.- INPO will prepare a written report for each evaluation. These reports will include appropriate utility responses in each area identified by INPO as needing improvement.

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1 a Appendix Number Two  ;

Coordination Plan for NRC/INP0 Appraisal and Evaluation Activities i Page Two  !

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, d. Each succeeding evaluation will include follow-up on the responses developed during the preceding evaluation. i

e. INP0 will conduct appropriate visits to Near Ters Operating License plants and their corporate organizations to assist in their 1 preparation for operation.

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3. NRC REVIEW 0F INP0 ACTIVITIES '

, a. INP0 expects its member utilities to make operating plant evaluation reports available to the NRC for review or reading. Further, INP0 will make final evaluation reports available to the NRC for review or reading by appropriate NRC management personnel at the INP0 offices in Atlanta.

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b. Current copies of, and any changes to, INPO evaluation criteria will

, be provided to NRC.

c. NRC may, on request, have a representative observe an INP0 I evaluation. INPO will obtain the necessary concurrence from the host utility. While specifyinil a maximum number to be observed is not considered necessary by e'ther party,.it is anticipated that an NRC representative may observe INP0 evaluations several times annually.

Where NRC Regional personnel participate as observers, they would not normally accompany an INPO team on an evaluation in their own Region.

d. INPO will brief personnel of the NRC Division of Reactor Inspection '

and Safeguards, Office of Nuclear Reactor Regulation (NRR) periodically on all aspects of INP0's evaluation and assistance program.

e. NRC review of INP0 evaluation activities will be coordinated by the NRC Offica of the Executive Director for Operations. Since INP0 has I its own system for obtaining member corrective action, NRC's role in pursuing correction of INP0 evaluation findings will primarily l

involve only those potentially significant safety problems for which l NRC has no other reasonable alternative in meeting its legislated

'- responsibilities. Any other NRC follow-up enforcement action would

be in accordance with paragraph 4.c. below.

4. NRC RECOGNITION OF THE INP0 EVALUATION PR' 0 GPAM

a. Subject to the continued development and success of the INPO program as outlined above and NRC's ability to effectively review the program, NRC intends to recognize INPO evaluations and, in those i

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. . i Appendix Number Two Coordination Plan for NRC/INPO Appraisal and Evaluation Activities Page Three areas deemed appropriate, to minimize NRC-sponsored evaluations or ,

appraisals that duplicate INPO evaluations.

b. NRC and INP0 will coordinate NRC inspections (involving two or more inspectors)andIMPOevaluationstominimizetheimpactonthe utility involved.. Where feasible, NRC and INP0 will coordinate event  :

related or other emergent on-site activities such as NRC augmented i inspectionteams(AITs),incidentinvestigationteams(IITs). l diagnostic evaluation teams (OETs) and INP0 event investigations, although each party recognizes.that it may not be possible to coordinate all of these efforts. -

c. The NRC will apply the established Connission enforcement policy for licensee identified non-compliances to those non-compliances identified by utilities as a result of IMP 0 evaluations.

,ff jfL ,p M h.J 1 51ctor/5te71o M . Pate Execut W Di for Operations U.S. Nuclear latory Commission (President Institute of Nuclest Power Operations i

f Effective Date: October 20, 1988 i

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APPENDIX NWSER THREE {

l C0 ORDINATION PLAN FOR NRC/INP0 TRAINING-REl.ATED ACTIVITIES

1. SACKGROUND l The purpose of this plan is to coordinate selected NRC and INP0 activities I related to nuclear power industry training. It is also intended to I provide a mechanism and a basis for information sharing and NRC .

1 recognition of INPO efforts in this arca.

There are several underlying assumptions: l o INPO recognizes NRC's regulatory responsibility and authority.

o NRC and INPO share the goal of improving and r.aintaining the quality of nuclear utility training.

o NRC recognizes the industry's initiative and commitment to INPO programs that promote high quality training through development  ;

of integrated training and qualification systems, including 1 accredittition of key training programs. ]

o NRC recognizes INPO accreditation and associated training evaluation activities (see also Appendix 2. " Coordination Plan for NRC/INPO Appraisal and Evaluation Activities") as an acceptable means of self-improvement in training. Such l recognition encourages industry initiative and reduces duplicate l program review and appraisal activities. 1 o INPO recognizes that the NRC requires access to selected INPO documents and information, as well as the opportunity to observe I selected INP0 activities related to training and accreditation, in order to ensure that the NRC meets its obligations to the public and the Congress, o Coordination of NRC and INP0 training-related activities and sharing of information will increase overall effectiveness as well as lessen the burden imposed on the industry by duplication of activities.

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Appendix Number Three Coordination Plan for NRC/INPO Training-Related Activities Page Two i

2. OVERALL COORDINATION In order to promote overall coordination of MRC and INP0 training-related activities, the following actions will be taken

a. NRC/INP0 Coordination meetings will be held periodically with representatives from NRC's Division of Licensee Performance and  :

Quality Evaluation (NRR) and INP0's Training and Education Group. At  ;

these meetings, information on ongoing projects and plans will be exchanged. Written reports of progress and results may be exchanged.

b. INPO will provide the NRC with access to selected INPO documents and information, and will provide updated copies of the INP0 training guidelines and Training System Development Manual. INPO will also provide the NRC, on a case-by-case basis, with access to the job and task analysis data stored in the IMPO computer data base.

c. Coordination regarding accreditation of training programs is covered by Attachment 1.

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. Pate JPictor SUll . or Operations President Executive Vire Institute of Nuclear Power Operations U.S. Nuclear R 14 tory Connission Effective Date: October 20, 1988 l

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~NRC/INPO Coordination Plan Attachment 1 '

Appendix Three Page one  ;

ACCREDITATION OF TRAINING PROGRAMS ,

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1. SKKralLID The purpose of this plan is to provide for coordination of selected NRC and INPO activities related to the accreditation of performance-based training profirams. This plan also provides for continued industry initiattve w'th NRC monitoring in this area and serves as a basis for NRC  ;

recognition'of INP0's efforts. This coordination plan is consistent with ,

the Comission Policy Statement on Training and Qualification of Neclear Power Plant Personnel. In carrying out this plan INPO recognizes NRC's responsibility and authoritj. ,

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2. INP0 ACTIVITIES This section outlines current and planned INP0 activities related to the accreditation of performance-based programs for the training and '

qualification of nuclear power plant personnel. The INP0 point of coordination for the implementation of this plan is the Group Vice President Training and Education.

a. INPO will continue to manage the accreditation of utility training programs including:

o self-evaluations by member utilities, with assistance from the INPO staff; o on-site reviews of training and qualification programs by teams of INPO and utility personnel; o preparation of a report for each accreditation team visit; o follow-up on recomendations developed during the accreditation process; o awarding, deferring or placing on probation of accreditation by the National Nuclear Accrediting Board; and o reviewing accreditation of utility trainin(I profframs approximately every four years (accreditat'on w'11 be renewed, continued in a probationary status, or withdrawn).

b. INPO will continue to conduct periodic performance-oriented evaluations of training and qualification programs as part of its i operating plant evaluations and as follow-up to accreditation.

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t NRC/INPO Coordination Plan Attachment 1 :

Appendix Three Page Two  !

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c. INPO will provide updated copies of the accreditation procedures and criteria document as it is revised. This document will be made  :

publicly available. i

d. INP0 will review and consider NRC recomendations regarding INP0- l managed training-related programs, documents, and criteria. j

e. INPO will provide periodic detailed briefings on accreditation to '

appropriate NRC management personnel, including review of the activities described in 2.a above and documentation of industrywide ,

accreditation status.

f. INPO intends to brief the Comission periodically on program status.

3. NRC ACTIVITIES -

This section outlines the NRC's continuing efforts to monitor INPO activities as part of NRC's assessment of the effectiveness of industry's training and qualification program improvements; The NRC point of coordination for implementation of this plan is the Director Division of Licensee Performance and Quality Evaluation. HRR.

a. NRC will not issue documents that duplicate INP0 training documents and will not refer to INPO documents as a means of satisfy 5g NRC requirements so as to avoid " codifying" or the appearance of

" codifying" INPO documents. 4

b. NRC will assess the effectiveness of industry's training and qualification program improvements as follows:

o- conduct operator licensing exams; l

o conduct operator requalification exams, consistent with g

Commission policy and 10 CFR Part 55;

{ o conduct reviews of a sample of utility training programs to ensure use of performanc.w-based training principles; o monitor plant and industry trends and events involving personnel errors; o continue evaluation of industrywide ttW og and qualification program effectiveness; and o conduct performance-oriented training inspections to assess the level of knowledge and qualifications of plant personnel.

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NRC/INPO Coordination Plan Attachment 1 t Appendix Three '

.- Page Three

c. NRC will monitor INPO activities in training and accreditation as follows:

o receive periodic briefings and/or reports from INP0 and review a '

sample of applicable INPO documents; o nominate individuals who are not on the NRC staff to serve as members of the National Nuclear Accrediting Board with full voting privilegest o have an NRC staff member attend and observe selected National Nuclear Accrediting Board meetings with the INPO staff and/or the utility representatives; l

o on request and with concurrence of the utility, have NRC 1 employees observe INPO accreditation team site visits for the J purpose of monitoring the effectiveness of the accreditation j process. Since accreditation teams are relatively small in '

sire, it is anticipateo the NRC would typically send only one 3

ooserver on any visit. However, in certain circumstances, it i may be appropriate to send more than one. INP0 will obtain the '

necessary concurrence from the host utility. While specifying a maximum number to be observed is not considered necessary by '

either party, it is anticipated that NRC employees would observe approximately 20 percent of INPO accreditation team visits; and o accompany INPO on selected operating plant evaluations (see Appendix 2). ,

d. NRC will continue to provide INPO copies of NRC's performance-oriented inspection program, including applicable inspection guidelines.

e. NRC will coordinate any team inspections with INPO accreditation team visits and evaluations so as to minimize the impact on the utility involved. On request and with concurrence of the utility, an INPO employee may occasionally observe an NRC inspection in this area.

f. . Since INP0 has its own system for obtaining member corrective action, NRC's role in pursuing corrective action of INP0-identified training and qualification recomendations will involve only significant safety problems for which NRC has no other reasonable alternative in meeting its legislated responsibilities. The NRC intends to exercise discretion in enforcement matters related to traininfi as described in the Commission Policy Statement on Training and Qual' fication of Nuclear Power Plant Personnel.

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APPENDIX N SER FOUR COORDINATION PLAN

- FOR INM/INDU$TRY PARTICIPATION IN i NRC INCIDENT INVESTIGATION TE#ts h

1. The purpose of this plan is to establish guidance for INPO or other i

industry representatives involvement with NRC Incident Investigation Teams  ;

i (IITs). It is also intended to minimize duplication of event investigation efforts to reduce the impact on the affected utility and to .

promote dissemination of accurate operating experience information to the ,

industry.

2. NRC and INPO recognize the importance of NRC's incident investigation activities in identifying significant operational experience

• information. Participation by industry representatives on an IIT should result in a more complete and thorough understanding of the factors

contributing to the incident and acttons needed to prevent recurrence. In carrying out this plan INPO recognizes NRC's responsibility and authority.

3. In view of these considerations, INPO and NRC agree on the following: -

4. INPO or other industry representatives' participation on an !!T will be coordinated between the Director of the Office for Analysis and Evaluation of Operational Data (AE00) for the NRC and the Vice President for Government Relations, INP0. A request for participation by an industry representative can be initiated by either party to this agreement.

b. NRC will provide INPO with a reasonable number of copies of the current Incident Investigation Manual and any other procedures which apply to the operation of an IIT.

c. NRC will notify INP0 promptly when an IIT is being aci.ivated and provide all necessary information to enable INP0 to facilitate industry participation. ,

d. INP0 will serve as the central point of contact for coordination of all issues and procedures regarding industry participation on IITs.

e. INPO will recommend industry participants to the NRC.

Appendix Number Four Coordination Plan for-Incident Investigation Activities 1

Page Two i

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INP0 will request each industry nominee to sign a statement regarding proprietary compensation.

information, conflicts of interest, and waiver of In addition, each industry nominee will be requested 1 to comply with the. procedures established for the operation of !!Ts, which include procedures for handling differences in professional .

opinion and the release of investigation information. This signed statement will be provided to the NRC as part of the nomination process.

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g. INPO will provide assistance in coordinating with the affected utility to obtain site access for the industry representative (s).

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h. INPO will work with the affected utility and the !!T so that the Significant Event Report eventunderinvestigation(byan!!Tisfactuallycorrect.SER), To this if any, bei; i- end, INPO will request that the affected utility coordinate a review of the draft SER with the !!T and provide connents to INP0.

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frctor SteQlg/ Jr V

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Executive Direc for Operations residen U.S. Nuclear Re latory Commission Institute of Nuclear Power Operations Effective Date: October 20, 1988 l

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