ML20134D001
| ML20134D001 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 10/09/1996 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Mueller C UNION ELECTRIC CO. |
| References | |
| NUDOCS 9610110267 | |
| Download: ML20134D001 (14) | |
Text
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'2 NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20666-4001 l
k . . . . . p# October 9,1996 l Mr. C. W. Mueller President and Chief Executive Officer Union Electric Company l P. O. Box 149 St. Louis, MO 63166
SUBJECT:
REQUEST FOR INFORMATION PURSUANT T0 10 CFR 50.54(f) REGARDING ADEQUACY AND AVAILABILITY OF DESIGN BASES INFORMATION
Dear Mr. Mueller:
1 The purpose of this letter is to require information that will provide the U.S. Nuclear Regulatory Commission (NRC) added confidence and assurance that your plant (s) are operated and maintained within the design bases and any deviations are reconciled in a timely manner. I Backaround In the mid- to late 1980s, NRC safety system functional inspections (SSFIs) and safety systems outage modifications inspections (SS0 mis) identified concerns that design bases information was not being properly maintained and plant modifications were being made without the licensee having an understanding of the plant design bases. The NRC's findings heightened the nuclear industry's awareness of the need to improve the adequacy and availability of design documentation, and many licensees voluntarily initiated extensive efforts to improve the design bases information for their plants. To assist the industry in performing design bases improvement programs, the Nuclear Management and Resources Council (NUMARC)1 developed a guidance document, NUMARC 90-12, " Design Basis Program Guidelines." These guidelines were intended to provide a stanpard frameerk for licensee programs to improve plant design bases information. The NRC .;taff reviewed the guidelines and provided comments to NUMARC in November 1990. In emphasizing the importance of validating the facility against current design information, the staff
'NUMARC was consolidated into the Nuclear Energy Institute (NEI) on March 23, 1994.
2 As discussed in NUMARC 90-12, these programs or efforts would emphasize collation of design basis information and the supporting design information, not the identification or re-creation of the licensing basis for a plant or the regeneration of missing analyses and calculations.
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1 Mr. C. W. Mueller ! stated that the goal of any program should be to establish confidence that the existing facility is in accordance with the curre. iesign documents and that any deviations will be reconciled. The staff concluded that the NUMARC guidelines would provide worthwhile insights to utilities undertaking design reconstitution programs and that the guidelines appeared to provide sufficient flexibility for licensees to structure their programs to respond most efficiently to any unique needs and circumstances of a particular licensee. The staff requested NUMARC to consider making design reconstitution a formal NUMARC initiative and commented that design documents that support technical specification values and that are necessary to support operations or to respond to events should be regenerated if missing. NUMARC subsequently concluded that a formal initiative was not necessary because most of its umsbers were already conducting or evaluating the need to conduct design reconstitution programs, and agreed to forward the guidelines, with the NRC's comments, to its members for use on a voluntary basis. To provide more information to the industry .?n this topic and to provide an independent view of the design control issue, the staff conducted a survey of six utilities and one nuclear steam supply system vendor to determine the status of design control problems and the strengths and weaknesses of the sample utility programs. The results were published in February 1991 in NUREG-1397, "An Assessment of Design Control Practices and Design Reconstitution Programs in the Nuclear Industry." The survey observations were as follows:
- The need for a design documentation reconstitution program was directly proportional to the age of the plant.
- The general intent of the program should be to provide a central location for design bases information, with emphasis on the design intent (the "why" of the design).
- The design bases documents should be a top-level directory that defines the current plant cotfiguration.
- Reestablishment of design bases without reconstitution of the .
supporting design documents, as necessary, may not provide a i sufficient level of information for future modifications or current plant operation, or to quickly respond to operating events.
- Minor changes to the design should be tracked to support the conclusion that the changes in the aggregate do not affect the validity of existing calculations and the ability of a system to perform its design functions.
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Mr. C. W. Mueller Some common weaknesses of licensee programs identified during the survey included the following:
- Design reconstitution programs had not identified in advance the documents that are necessary to demonstrate that a structure, a system, or a component will function properly.
- The process for regenerating missing design documentation was not always proceduralized so that it could be handled in a systematic l
manner.
- Validation of the content of specific output documentation was not always thoroughly carried out.
l l In late 1991, the NRC staff evaluated whether rulemaking, guidance, or a policy statement was needed to address the issue of licensees retaining accurate design bases information. It concluded that the existing regulatory requirements for design control were adequate; however, it determined that the l publication of a policy statement addressing design bases information and l publication of a generic letter requesting licensees to describe their design l reconstitution programs would be beneficial. Additionally, the staff stated l its intention to continue to evaluate design control adequacy during its performance-based inspections such as SSFIs and SSOMIs. The staff also l expectedthattheenforcengntpolicyguidancetoprovidegreateropportunities for enforcement discretion would encourage voluntary identification of past design, engineering, and installation issues by licensees. With the Commission's approval, the staff proceeded with this approrh. In August 1992, the NRC issued a Commission policy stat- c " Availability and Adequacy of Design Bases Information at Nuclear Powe- .cs" (57 FR 35455) (Attachment 1). This policy statement stressed th- ..tance of maintaining current and accessible design documentation to ens . .nat (1) plant physical l and functional characteristics are maintained and consistent with design bases, (2) systems, structures, and components can perform their intended functions, and (3) the plant is operated in a manner consistent with the design bases. In the policy statement, the Commission recommended that all power reactor licensees assess the accessibility and adequacy of their design bases information and that they be able to show that there is sufficient documentation to conclude that the current facility configuration is . consistent with the design bases. The policy statement outlined the l I additional actions the NRC would take to keep apprised of the industry's l design reconstitution activities previously discussed. Following review by the Committee To Review Generic Requirements (CRGR) and j the Commission, a draft generic letter was issued for public comment on j March 24, 1993. The proposed generic letter requested licensees, on a 3 !r NRC would refrain from imposing civil penalties for violations up to Severity l Level II if the violations were identified and corrected as a result of i systematic voluntary initiatives. t I 1
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Mr. C. W. Mueller voluntary basis, to submit information and schedules for any design bases programs completed, planned, or being conducted, or a rationale for not implementing such a program. All but one of the commenters concluded that the generic letter was unnecessary and unwarranted. NUMARC responded that it believed the NRC's request for descriptions, schedules, and dates would have a negative impact on ongoing design efforts and that NRC's focus on schedules would undermine the licensees' ability to manage the activities. In ! SECY-93-292, " Generic Letter on the Availability and Adequacy of Design Bases ! Information," dated October 21, 1993, the staff recommended that the generic letter not be issued. The staff stated that publication of the policy statement and the proposed generic letter conveyed to the industry the Commission's concern and that publication of the generic letter would not further licensees' awareness of the importance of the activities. The staff l proposed to continue performing design-related inspections and to gather information and insights as to how well the licensees' design-related programs were being implemented. The Commission issued a staff requirements memorandum that agreed with the staff's proposal. l In response to the findings relating to the regulatory burden of team inspections identified in the 1991 Regulatory Impact Survey, during the past several years the staff has reduced its effort on specific, resource-intensive, design-related team inspections, and followed the issue of ; accurate and accessible design documentation at plants principally as an element of inspection and followup of operations-related activities. The issuance of the NUMARC guidelines and ongoing industry efforts to improve and , maintain design bases information also contributed to this decision. ' Current Problem l Over the past several months, NRC's findings during inspections and reviews have identified broad programmatic weaknesses that have resulted in design and configuration deficiencies at some plants, which could impact the operability of required equipment, raise unreviewed safety questions, or indicate discrepancies between the plant's updated final safety analysis report (UFSAR) and the as-built or as-modified plant or plant operating procedures. These inspections and reviews have also highlighted numerous instances in which timely and complete implementation of corrective action for known degraded and nonconforming conditions and for past violations of NRC requirements has not been evident. Overall, the NRC staff has found that some licensees h failed to (1) appropriately maintain or adhere to plant design bases,pve
'As described in 10 CFR 50.2, design bases is defined as, " Design bases mean that information which identifies the specific functions to be performed by a structure, system, or component of a facility, and the specific values or ranges of values chosen for controlling parameters as reference bounds for design..." The design bases of a facility, as so defined, is a subset of the licensing basis and is contained in the FSAR. Information developed to implement the design bases is contained in other documents, sone of which are docketed and some of which are retained by the licensee.
. Mr. C. W. Mueller (2) appropriately maintain or adhere to the plant licensing basis,5 (3) comply with the teps and conditions of licenses and NRC regulations, and (4) assure that UFSARs properly reflect the facilities. Attachment 2 .' provides examples of some of the deficiencies recently identified by the staff. As a consequence of this new information, the NRC believes that the industry's voluntary efforts to improve and maintain design bases information for their plants, consistent with NUMARC 90-12, the staff's coments on the industry guidelines, and the Commission policy statement, have not been effective in all cases. The magnitude and scope of the problems that the NRC staff has identified raise concerns about the presence of similar design, configuration, and operability problems and the effectiveness of quality assurance programs at other plants. Of particular concern is whether licensee programs to maintain configuration control at plants licensed to operate are sufficient to demonstrate that plant physical and functional characteristics are consistent with and are being maintained in accordance with their design bases. The extent of the licensees' failures to maintain control and to identify and correct the failures in a timely manner is of concern because of the potential impact on public health and safety should safety systems not respond to challenges from off-normal and accident conditions. It is emphasized that the NRC's position has been, and continues to be, that it is the responsibility of individual licensees to know their licensing basis, to have appropriate documentation that defines their design bases, and , to have procedures for performing the necessary assessments of plant or ' procedure changes required by NRC regulations. Attachments 3 and 4 are a . recent exchange of correspondence between J. Colvin, NEI, and Chairman S. Jackson, NRC, regarding these subjects. 5 The licensing basis for a plant originally consists of that set of infonnation upon which the Commission, in issuing an initial operating license, based its comprehensive determination that the design, construction, and proposed operation of the facility satisfied the Commission's requirements and provided reasonable assurance of adequate protection to public health and safety and common defense and security. The licensing basis evolves and is modified throughout a plant's licensing term as a result of the Commission's continuing regulatory activities, as well as the activities of the licensee. 4he FSAR is required to be included in, and is one portion of, an application for an operating license (0L) for a production or utilization facility. 10 CFR 50.34(b) describes the information which must be included in an FSAR. The FSAR is the principal document upon which the Commission bases a decision to issue an OL and is, as such, part of the licensing basis of a facility. It is also a basic document used by NRC inspectors to determine whether the facility has been constructed and is operating within the license conditions.
i Mr. C. W. Mueller l l Action l l The NRC has concluded that it requires information that can be used to verify ! compliance with the terms and conditions of your license (s) and NRC i regulations, and that the plant UFSAR(s) properly dpscribe the facilities,s as l well as to determine if other inspection activitirs or enforcement action ! should be taken. Therefore, you are required, pursuant to Section 182(a) of the Atomic Energy Act of 1954, as amended, and 13 CFR 50.54(f), to submit a response to this letter within 120 days of its receipt. Your response must be l written and signed under oath or affirmation. Please submit the original copy of your response to the NRC Document Control Desk, and send a copy to the Director, Office of Nuclear Reactor Regulation , and to the appropriate regional administrator. The following information is i required for each licensed unit: 1 (a) Description of engineering design and configuration control i processes, including those that implement 10 CFR 50.59, l 10 CFR 50.71(e), and Appendix B to 10 CFR Part 50; (b) Rationale for concluding that design bases requirements are translated into operating, maintenance, and testing procedures; l (c) Rationale for concluding that system, structure, and component configuration and performance are consistent with the design bases; (d) Processes for identification of problems and implementation of corrective actions, including actions to determine the extent of problems, action to prevent recurrence, and reporting to NRC; and 7 A number of design bases inspections are being planned, and your response will be used in the planning process, aSection VII.B.3 of the NRC Enforcement Policy addresses how old design issues ; involving past problems in engineering, design, or installation are to be l handled from an enforcement standpoint. In a related matter, the Commission ! recently approved changes that would modify this policy to encourage licensees [ to undertake voluntary initiatives to identify and correct FSAR noncompliances I by (1) the exercise of discretion to refrain from issuing civil penalties for i a two-year period where a licensee undertakes a voluntary initiative in this area and (2) the exercise of discretion to escalate the amount of civil penalties for violations associated with departures from the FSAR identified by the NRC subsequent to the two-year voluntary initiative period.
i t s Mr. C. W. Mueller (e) The overall effectiveness of your current processes and programs ' in concluding that the configuration of your plant (s) is t consistent with the design bases. i In responding to items (a) through (e), indicate whether you have undertaken 7 any design review or reconstitution programs, and if not, a rationale for not i implementing such a program. If design review or reconstitution programs have i been completed or are being conducted, provide a description of the review programs, including identification of the systems, structures, and components (SSCs), and plant-level design attributes (e.g., seismic, high-energy line break, moderate-energy line break). The description should include how the program ensures the correctness and accessibility of the design bases information for your plant and that the design bases remain current. If the l program is being conducted but has not been completed, provide an ; implementation schedule for SSCs and plant-level design attribute reviews, the ' expected completion date, and method of SSC prioritization used for the , review. This request is covered by the Office of Management and Budget (OMB) clearance l number 3150-0011, which expires July 31, 1997. The reporting burden for this collection of information is estimated to average 400 hours per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to the Information and Records Management Branch (T-6 F33), U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001, and to the Desk Officer, Office of Information and Regulatory Affairs, NE0B-10202 (3150-0011), Office of Management and Budget, Washington, D.C. 20503. The NRC may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OM8 control number. In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and your response will be placed in the NRC Public Document Room (PDR), the Gelman Building, 2120 L Street, N.W., Washington, DC, and in the
-local public document room (s) for your facility or facilities.
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l Mr. C. W. Mueller If you have any questions about this matter, please contact the staff members listed below, or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager. Sincerely, l W mes M. Ta r
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xecutive D rector for Operations Docket No. STN 50-483 Attachments:
- 1. Policy Statement on Availability and Adequacy of Design Bases Information at Nuclear Power Plants
- 2. Background Information on Recently Identified Problems
- 3. Letter from J. Colvin (NEI) to Chairman S. Jackson (NRC) ,
dated 8/2/96 1
- 4. Letter from Chairman S. Jackson (NRC) to J. Colvin (NEI) i dated 8/14/96 )
l Contacts: Kristine M. Thomas, NRR l (301) 415-1362 Internet: kmt9nrc. gov Eileen M. McKenna, NRR (301) 415-2189 Internet: emmenrc. gov cc w/atts: See next page
UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT 1 cc: Professional Nuclear Mr. Neil S. Carns Consulting, Inc. President and Chief Executive Officer 19041 Raines Drive Wolf Creek Nuclear Operating Corporation Derwood, Maryland 20855 P.O. Box 411 Burlington, Kansas 66839 ' Gerald Charnoff, Esq. Thomas A. Baxter, Esq. Mr. Dan I. Bolef, President Shaw, Pittman, Potts & Trowbridge Kay Drey, Representative 2300 N. Street, N.W. Board of Directors Coalition Washington, D.C. 20037 for the Environment ) 6267 Delmar Boulevard ' Mr. H. D. Bono University City, Missouri 63130 Supervising Engineer, Site Licensing Mr. Lee Fritz Union Electric Company Presiding Commissioner Post Office Box 620 Callaway County Court House Fulton, Missouri 65251 10 East Fifth Street Fulton, Missouri 65151 U.S. NL clear Regulatory Commission Resident Inspector Office Mr. Alan C. Passwater, Manager 8201 NRC Road Licensing and Fuels Steedman, Missouri 65077-1302 Union Electric Company Post Office Box 149 Mr. G. L. Randolph, Vice President St. Louis, Missouri 63166 Nuclear Operations Union Electric Company Mr. J. V. Laux, Manager P.O. Box 620 Quality Assurance Fulton, Missouri 65251 Union Electric Company Post Office Box 620 Manager - Electric Department Fulton, Missouri 65251 Missouri Public Service Counission 301 W. High Mr. Donald F. Schnell Post Office Box 360 Senior Vice President - Nuclear Jefferson City, Missouri 65102 Union Electric Company Post Office Box 149 I Regional Administrator, Region IV St. Louis, Missouri 63166 l U.S. Nuclear Regulatory Commission Harris Tower & Pavilion 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064 , Mr. Ronald A. Kucera, Deputy Director Department of Natural Resources , P.O. Box 176 Jefferson City, Missouri 65102
l 35455 l Rules and Regulations r* ' " si>'" Vot. $7 No 154 l htonray. August to.1992 This section of the FEDERAL REGISTER Program Cuidelines." NUMARC W12. functional characteristics ere contains regulatory cocuments haeng While developing these guidelines. maintained and are consistent with the generai apphcatahty and legai ettect, most NUMARC discussed them at several design beses as required by NRC of whech are keyed to and codified '" public meetings held with the NRC.The regulation. (2) systems, structures, and the Code of Federal Regulations. which is staff has concluded the NUMARC components een perform their intended v hed under 50 tities pursuant to 44 uidelines provide a useful standard functions.and (3) the plant is operated f amework for implementing design in a manner consistent with the design The Code of Federal Regulations is sold by the Supenntendent of Documents reconstitution programs.The staff also bases.The Commission believes the Pnces of new books are listed en the agrees no single approach would enable regulatory framework already exists to utilities to best accomplish the address the need for accessible design first FEDERAL REGISTER issue of each week reconstitution task.The NUMARC bases and control of design information. guidance appeared to provide sufficient The availability of current design and flexibility for individual utilities to licensing bases will also expedite the NUCLEAR REGULATORY ..ructure their programs to respond most license renewal process. COMMISSION efficiently to their unique needs and The Commission believes as a result circumstances. of NRCinspections and licensees'self-10 CFR Part 50 The staff sent comments on the assessments, that all power reactor guidelines to NUMARC on November 9. licensees should assess the accessibility Avaltability and Adequacy of Dealgn 1990. Commission paper SECY-W365 and adequacy of their design bases Bases information at Nuclear Power informed the Commissioners in advance documentation.The results of this self-Plants; Policy Statement about the staff response to NUMARC. assessment should form the basis for a AoENev: Nuclear Regulatory The staff requested NUMARC licensee's decision whether a design Commission. consider making the design bases effort reconstitution program is necessary and Action: Policy stateme>nt. a NUMARC initiative. NUMARC the attributes to be included in the concluded they would not pursue a program.The Commission recognizes sUMM AR v: The Nuclear Regulatory formalinitiative, but would forward the the need for a design reconstitution Commission is issuing this policy guidelines to their members to use on a p:ogram to be tailored to meet the statement on availability and adequacy voluntary basis. Their reason for not unique needs of a particular utility. The of design information al nuclear power pursuing an initiative was that most of structure and content of the design plants. This policy statement describes their membars were already conducting document reconstitution program will be the Commission's expectations and or evalualmg the need to conduct design influenced by various factors. such as fuiure actions with regard to the bases reconstitution programs. the utibry's organizations! structure. the availability of design information and The Commission's eviluation of the availabahty or unavailao.lity of design emphasizes the Commission s view that status of reconstitution programs clearly documentation, and the intended users facilities should nut be modified without indicates the licenseei substantial of the documentation.The Commission a clear understandmg of the appheable investment in these programs should expects that after completing a engmeering design bases. yield positive safety benefits fcr a reconstitution program, or as a basis for EFFECTIVE D ATE: August 10.1992. majority of sites.The NRC commends concluding that such a program is FOR FURTHER INFORM ATION CONTACT: those licensees that are acting to ensure unnecessary, the licensee will have Eugene V. imbro. Office of Nuclear technically adequate and accessible current design documents and adequate Reactor Regulation. U.S. Nuclear design bases documentation is technical bases to demonstrate that the Regulatory Commission. Washington, maintained. plant physical and functional DC 20555. telephone (301) 504-2967. However. the Commission is characteristics are consistent with the c neerned some situations exist where design basis. the systems, structures,
$UPPLE MENT ARY INFORM ATION: NRC inspection findings have demc...,trated hce,nsees have no' critically examined and components can perform their intended functions and the plant is being that some licensees have not adequately their design control and configuration rnanagement processes to identify operated in a manner consistent with maintained their design bases .
information as required by NRC tmisije measures to ensure the plant is the design basis. regulations. Both the problems identified operstmg within the deugn bases NUMARC has developed guidance for envelope. Therefore, the Commission is the conduct of design bases during the NRC inspections and those articulating its expectations with regard reconstitution orograms. The guidance identified by licensees have prompted to design information and elaboratmg on outlines a framework to organize and ruost power reactor licensees to initiate, its planned activities to confirm the collate nuclear power plant design bases os er the past several years. design information. This information provides integrity of the as configured plant with l bases reconstitution programs. To respect to the plant design bases. the rationale for the design bases l implement a reconstitution program. consistent with the definition of design licensees seek to identify missing design Policy Statement documentation and to selectively bases contained in 10 CFR 50.2. l Posin.on NUMARC 90-12. " Design Basis Program l regenerate missing documentation as required. The Commission has concluded that Guidelmes." was issued in October 1990 in 1989. Nuclear Utilities Management maintaining current and accessible for voluntary use by NUMARC memb ?r and Resources Council. inc. [NUMARC) design documentation is important to organizations as a reference point from began developing their " Design Basis ensure that (1) the plant physical and whichlicensees would review their s .ito m rinoiniowo?. A cc.o:-i: on :o, Attachment 1
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35456 Federal Register / Vol. 57, No.154 / Monday, August 10. 1992 / Rules and Regulations existing or planned efforts to collate ensuie their validity for the life of the DEPARTMENT OF THE TREASURY supporting design information. The facility, including any renewal period. Office of Thrift Supervision Commission believes NUMARC's In order to ensure the Commission is approach provides a useful framework appraised of industry's activities. the 12 CFR Part 584 and worthwhile insights to those utilities NRC will take the following actions. undertaking design basis programs. (1)The staff willissue a generic letter 192-1951 The Commission believes a licensee requesting alllicensees to describe the programs that are in place to ensure AIN 1550- AA3s should be able to show that it has sufficient documentation, including design information is correct. accessible. Regletration, Examination and calculations or pre. operational, startup and maintained curretit.Those licensees Reporta; Statements, Applications, or surveillance test data to conclude the that are not implementing a design Reporta and Notices To Be Filed current facility configuration is reconstitution program will be requested consistent with its design bases. The to provide their rationale for not doing AotNcy: Office of Thrift Supervision. Commission further believes the design so. lf a reconstitution program is under Treasury. bases must be understood and way the schedule for implementation Actiow: Final rule. documented to support operability and completion will be requested. SuMMAny: The Office of Thrift determinations and to CFR 50 59 evaluations that may need to be made (2) The staff will prioritize NRC Supervision (OTS) is hereby amending quickly in responding to plant events. inspections of licensee's management of its regulations pertaining to holding The design bases related information design and configuration using SSFl. company reporting requirements. In should be retrievable within a type techniques based upon responses updating existing forms to reflect reasonable period of tin e. however. it is to the generic letter and other plant changes necessitated by the Financial not necessary for all design basis specific information known to the NRC. Institutions Reform. Recovery, and documentation to be organized in one Additional staff guidance will be Enforcement Act of 1989, the OTS has place. The information used solely to developed. where needed. for the design combined several forms to streamline support the development of a bases aspects of these inspections. the reporting process and ease the modification package would not need I regulatory burden on savings and loan be able to be retrieved as expeditiously (3) The NRC systematic assessment of holding companies. In particular, the licensee perf rmance (SA1.P) process reporting requirements set forth in as information needed to support an will be modified to explicitly address operability determination. Forms H-(b)3. H-[b)4. H-(b)5 and H-assessment of licensee programs t (b)10 Registration Statements are now in the event the design bases control design bases information that contained in one body of instructions for information is found technically reflect NRC inspection activity in this all Registrants. the H-{b)10. In addition. inadequate or not accessible, hcensees area and assure consistent evaluations. the H-(b)11 Annual Report and the H-shculd consider whether remedial action (b)12 Current Report have been merged is warranted. A methodology should be (4)The staff will continue t into one set of instructions requiring an developed and implemented to ensure encourage self identification of design annual filing with quarterly updates licensee resources are focused on design bases issues through apy!ication of the informing the OTS of any changes.The information regeneration in a timeframe provisions of the Commission s H-(f) Dividend Notification has been commensurate with the safety enforcement policy.The staff will. reacinded, since the requirements significance of the missing or erroneous however. pursue enforcement actions for contained in the Capital Distributions information. engineering deficiencies whose root regulation are sufficient for the OTS's cause lies in the inadequacy or monitoring and supervision purposes. The Commission also emphasizes it is unavailability of design bases arrscTive oATE: September 9.1992. very important that modifications to a information and which are identified facility be made after a thorough review during NRC inspections. Michael P. Scott. Program Manager. has been conducted and an understanding of the applicable (202) 906-5748. Supervision Policy. Paperwork Reduction Act Statement Office of Thrift Supervision.1700 C underlying design bases has been gained in order to ensure appropriate This final polic) statement does not Street. NW., Washington DC 20552. design margins are preserved. contain a new or amended information SUPPLEMENTARY INF ORM ATION: collection requirement subject to the future Actions I. Background Paperwork Reduction Act of1980(44 U.S.C. 3501 et seq.). Existing The OTS is today issuing a final rule The Commission will continue t requirements were approved by the amending its holding company reporting inspect routinely the adequacy of design Office of Management and Budget requirements.This amendment affects control program effectiveness. The approval number 3150-0011. the registration. annual, and current Commi6sion concludes that ensuring the reporting requirements. design bases and configuration of a Dated at Rockville. Maryland. this 4th day . - facility are well understood and Registration Statements of August.1992. controlled in plant documents will also As previously structured. holding ensure that those parts of the current For the Nuclear Regulatory Commission. companies were required to choose from licensing bases of most safety four separate registration statements. significance are understood and Samuel l. Chilk. These separate statements were controlled. Other aspects of the current Secretary of fbe Commission- originally deemed necessary to licensing bases. such as emergency acc e d am ge M W s M W y FR Doc 92-18895 Fded IL-7-92. 8 45 a-i) companies (i.e. companies that become preparedness and security plans. should also be appropriately czamined to *w"o coot iso * *'-" savings and loan hold;ng companies as 5-310999 0002(00x07- At'G 92-12 00 32) 4*nn NT (16101 410.02
BACKGROUND INFORMATION ON RECENTLY IDENTIFIED PRGBLEMS l Over the past several months, design and engineering information has been ! obtained that indicates that design bases at certain plants have not been appropriately maintained or adhered to. Specific examples follow: )
)
Millstone Units 1. 2. and 3 An NRC inspection team recently found examples in which design bases information and the Updated Final Safety Analysis Report (UFSAR) did not agree with the as-built plant, operational procedures, and maintenance practices. The team found inconsistencies that required analyses, procedure changes, and design changes to resolve. For enmple, the Millstone Unit 3 operating procedures required isolation for the turbine-driven auxiliary feedwater pump during certain plant conditions, in conf'ict with technical specification requirements for operability. The tear found that certain protective relays at Millstone Unit 3 were not set in ar.:ordance with the design bases information. This required re-analyses and resetting of certain relays. Based on the team's findings, the licensee initiated design changes to correct nonconforming conditions between the UFSAR and the as-built plant, including changes to the design of the Millstone Unit 2 reactor protection system to meet the design bases with respect to physical separation of redundant channels and changes to the design of the Millstone Unit 2 (post-loss-of-coolant accident (LOCA)) hydrogen monitors to meet the design bases for single failure vulnerabilities. Haddam Neck An NRC inspection team found examples in which the design bases information and the UFSAR did not agree with the as-built plant, operational procedures, ' and maintenance practices. The team identified a number of deficiencies in engineering calculations and analyses that were relied upon to ensure the , adequacy of the design of kay safety systems. Deficiencies were identified in l the calculations and analyses supporting the station batteries, emergency diesel generators, containment cooling system, and other key safety systems. I In some cases, the inspec6,on findings were resolved by revising the calculations and analyses. .In other cases, procedure and design changes were required to resolve the issues. For example, the team identified that the design bases calculations supporting the size of the station batteries were inconsistent with the design bases stated in the FSAR. Field measurements and design modifications were required to resolve this issue. Other issues were identified by the NRC and the licensee following the issuance of this special team inspection report that led the licensee to enter a refueling outage earlier than originally scheduled. Discrepancies included inadequate configuration management of the containment sump design and as-built conditions; a lack of detailed analysis and technical justification for the reliance on post-accident back pressure inside the containment to assure adequate net positive suction head for the residual heat removal pumps; inadequate inspection and verification of the sump as-built and material Attachment 2
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conditions; and the lack of aggressive action in response to generic' communications of industry events, which contributed to an inadequate operability determination regarding the sump screen design and mesh size. : These issues impacted the operability of the emergency core cooling systems (ECCSs) under certain postulated design basis events. t Maine Yankee j l On January 10, 1996, the NRC issued a Confirmatory Order Suspending Authority for and Limiting Power Operation and Containment Pressure and a Demand for ! Information to the Mains Yankee Atomic Power Company. The order was based, in
- part, on the NRC's determination that Maine Yankee did not apply a computer i code that was proposed to demonstrate compliance with the ECCS requirements of j 10 CFR 50.46 in a manner that conforms to the requirements of 10 CFR Part 50, '
Appendix K, nor to the conditions specified in the staff's safety evaluation i . dated January 30, 1989. Specifically, the licensee did not demonstrate that l the RELAPSYA code will reliably calculate the peak cladding temperature for all break sizes in the small-break LOCA spectrum for Maine Yankee, nor has the ! licensee submitted the justification for the code options selected and other justifications and sensitivity studies to satisfy conditions in the staff's 1 safety evaluation. In addition, the licensee assumed an initial containment pressure of 2.0 psig for calculating peak design-basis accident pressure, even though the plant's technical specifications allow a maximum operating pressure in containment of 3.0 psig. Assuming an initial containment pressure of 3.0 psig results in a calculated peak accident pressure in excess of the containment design pressure described in the UFSAR. _- Refuelina practices Survey In a survey of licensee refueling practices conducted during the spring of 1996, the NRC identified deficiencies in the management of design bases assumptions. Many plants were found to have aspects of their design bases that were only loosely proceduralized or not proceduralized at all. Typical of this kind of discrepancy was the identification of a lack of procedures for controlling the assumptions regarding hold-up time before beginning fuel transfer. The NRC found a number of instances in which other design bases assumptions were not captur'ed in procedures. In addition, it was necessary for licensees at 12 sites (23 units) to upgrade procedures to directly implement the design bases assumptions. In other cases, the licensee performed engineering analyses, documented pursuant to 10 CFR 50.59, as necessary, to ensure that the planned activities would not exceed design bases assumptions. ,
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so. e. coi.m i August 2,1996 The Honorable Shirley A. Jackson 4 Chairman U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Dear Chairman Jackson:
On July 23.1996, the Nuclear Strategic Issues Advisory Committee (NSIAC) held a special meeting to discuss industry actions for ensuring the licensing basis of nuclear plants is being maintained consistent with the regulations. The chief nuclear officers of the nuclear utilities approved an initiative to provide additional assurance and confidence that existing programs are adequate to ensure that:
. Licensees are operating their plants in conformance with their licensing basis: I
. Licensees are adequately maintaining their licensing basis:
. There are no differences between operating practices and the licensing basis that could result in a significant public health and safety concern; and
. Degraded or non-conforming conditions are captured on tracking systems and resolved in a timely manner.
Under the initiative. each licensee will conduct an assessment of the programs in place to reaflirm that plants are operated in conformance with their licensing basis. The program assessment is accomplished by sampling (1) FSAR information. (2) programs in place for processing changes to procedures and the plant that may impact the FSAR, and (3) changes that may not bs governed by licensee programs. Many licensees have already commenced or recently completed similar program assessments. Differences identified through the sampling process will be evaluated to assess the overall effectiveness and adequacy of programs. Programmatic enhancements will be made if needed. The overall significance of any differences will be characterized to determine if additional sampling is warranted. Differences that represent degraded or nonconforming conditions will be captured on a tracking system and resolved in a timely manner. Each licensee will notify the NRC of any differences that are sub.iect to reporting requirements per the regulations. bl:0 ::: SV bff Attachment 3
i ' ' ' d l The Honorable Shirley A. Jackson , 1 August 2.1996 Page 2 The results of the indmdual plant assessments will be provided to NEI for compilation in an industry summary report. The summary report wt11 be pronded to the NRC for information The industry has developed a draft guidehne to assist utilities in performing the programmatic assessment. The guidehne will be Snalized subsequent to resolution of the issues discussed below Enclosure 1 prondes a copy of NEI 96 05 (Diaft) Rension D. "Guidehnes for Assessing Programs for Maintaining the Licensing Basis. ' for your information. There are a number of related issues that require a mutual agreement between the industry and the NRC before the industrv can proceed with the initiative in a consistent manner These include.
. The legal standing of the Updated Final Safety Analysis Report and the NRC s Safety Evaluation Reports.
. The scope of what constitutes the current bcensing basis. and .
. The adequacy of NSAC-125 for performing 10 CFR 50.59 safety evaluations The industry is committed to completing the initiative within six months of the resolution of these issues. Initial progress in resolving these issues was accomphshed dunng the NRC pubbe meeting also held on July 23.1996. We appreciate very much the participation of your senior staffin this meeting and the opportunity to discuss the e issues. Expedated closure on these fundamentalissues is needed to minimize cor Jusion within the NRC regions and the plants and focus our resources on addressi g the programmatic issues We look forward to a continuing dialogue with the Commisjon and NRC staff to achieve timely resolution of this matter.
Sincerely. (0q hMb
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Joe F Colun Enclosure c Comnussioner Kenneth r Rocers. NRC Commi.--toner Greta J Dieu- NRC
.\lr Jamr .1\ Tavior. NRC 4
i
- NEI 96-05 (DRAFT)
Revision D 1 3 NUCLEAR ENERGY INSTITUTE GUIDELINES FOR ASSESSING PF ) GRAMS FOR
- MAINTAINING THE LICENSING BASIS 1
4 4 i 1 JULY 25,1996 i l
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1.0 INTRODUCTION
Licensees have implemented various programs / processes over the period of their beenses for ensuring that the bcensing basis is known. is maintained current and is accurately described in the FSAR and associated referenced documents. The NRC. through a review described in SECY 94 066. determined that heensees were adequately maintaining the licensing basis of their facilities. As a result of events that have occurred over the last several months. the NRC has increased attention on bcensee compliance with the plant's beensing basis. Differences can occur due to problems in those processes / programs intended to effect changes in the license basis, missing programmatic controls to translate changed operational activities into the licensing basis, or a lack of awarenes.; oflicensing basis features. Licensees employ various programmatic mechanisms for identifying, evaluating and/or processing changes in plant activities that could affect the licensing basis or that are intended to make changes to the beensing basis These include:
. Final Safety Analysis Report (FSAID updates per 10 CFR 50.1(e)
. Safety Evaluations per 10 CFR 50.59
- Changes to Quahty Assurance. Security and Emergency Plans per 10 CFR 50.54
. License arnendments per 10 CFR 50.90
. ASME Code rehef requests per 10 CFR 50.55a
. Procedure changes (not subject to 50.59)
. Design changes (not subject to 50.59)
. Regulatory commitment changes
. Degraded or non-conforming conditions
. Configuration management changes (e.g., operator workarounds, extended operation of equipment in manual mode rather than automatic operation modes, and Technical Specification positions / interpretations) 1
i j 1 l 2.0 PJJRPOSE AND SCOPE 2.1 Purpose ; This document provides guidance for performing a self assessment of the adequacy of programmatic controls for maintaining the licensing basis in order to identify missing or incorrectly applied programmatic elements that can lead to licensing basis differences. 2.2 Scope The assessment approach consists of a data gathering phase and an evaluation phase. The data. gathering phase employs a three tiered sampling technique. The first tier involves in process sampling for the programmatic elements intended to effect a change in the licensing basis. Since programmatic elements may be missing or incorrectly applied. the next two sampling tiers involve a search for differences by sampling for potential operational changes that could be made without procedure changes. and samphng backwards by comparing selected FSAR statements with operational practices. The purpose of the data gathering phase is to identtfy a set of potential differences between the operational practices and the licensing basis. The evaluation phase determines if potential differences are valid. Valid differences are categorized in order to draw conclusions about the adequacy of particular programrnatic controls for maintaining the bcensing basis. The signtScance of the findings are used to develop recommendations for programmatic enhancements. it is recognized that many bcensees have performed safety system functional inspections (SSFIs) and other reviews that have assessed the adequacy of their programs to maintain the licensing basis of their plants and to ensure the accuracy ofinformation in the FSAR. These completed activities can be credited, as appropriate. in meeting portions of the assessment described below. The assessment methodology described below represents only one way of performing the assessment of the adequacy and effectiveness of programs for maintaining the licensing basis. Although the methodology contains a reasonable j amount of detail. it is not intended to be prescriptive. Other approaches that provide an equivalent scope of review can also meet the intent of this assessment. 2
1 3.0 ASSESSMENT METHODOLOGY 3.1 Data-Gathering Phase l The data gathering phase of the assessment employs three sampling techniques. Each sampling technique is discussed separately 3.1.1 FSAR Sampling
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. Extract the relevant FSAR sections for the system (s) being evaluated
. Highlight those FSAR statements that meet the following criteria:
0 Descriptive phrases regarding frequencies for tests, calibrations, etc.
- Con 6guration descriptions Descriptions of system operation in different modes (e.g.. normal. abnormal. accident / emergency)
- Operating limits
- Descriptive functional performance statements
- NOTE: The intent is to identify a range of FSAR statements associated with operational practices that could be changed and, in the presence of programmatic weaknesses. are not adequately reflected in the FSAR.
- Compare the highlighted FSAR statements with current operational practices using iiidividuals cognizant of the operation of the system and associated engineering problems. Document the following:
0 Is the FSAR statement accurate with respect to operational practices (procedures, operating philosophy, standing orders, workarounds, etc.)? If not, identify the differences. O Is the FSAR statement clearly understood or in need of clarification? 3.1.2 Programmatic Sampling
. Select three unrelated examples of each of the following types of changes:* I 50.59 ( at least one procedure chance evaluationi 3
1 1 ,
) 50.54 (one each from QA. EP and Security) 2
- Outstanding corrective action for a matarial condition greater than one i
year old 1
- Operating procedure change not eva!uated under 50.59 i i
? FSAR change request i 0 50.90/50.55a change and associated SER (where NRC approval l
i has been received) ) 0 Regulatory commitment addition or change 0 Design change not evaluated under 50.59 l i
- NOTE: The changes selected should have been completed in sufficient ttme to have been reDected (if required)in the most recent licensing basis update of the FSAR. QA program. etc.
4
- Review the change to determine if the change should have appeared in the l
a licensing basis and. if so. if the hcensing basis accurately reDects the change. 1 For changes that are not accurately reDected in the licensing basis, detertnine the programmatic step wr missing programmatic step) that would have ensured its accurate incorporation into the licensing basis.
- Document the results of the programtnatic sampling.
3.1.3 Sampling for potential changes that may occur separate from programmatic or procedure changes
- Compile the following:
0 Workaround list 0 Operations standing orders 0 Technical Speci5 cations positions / interpretations (if any)
- Sample of documents that may show potentially routine "NA'ing" of procedure steps (e.g., last completed startup procedure recently completed system operatinc instructions. shift supervisor loc entries for deviationsi l
4 1
t . 1 . 1 i ! : List of equipment being operated in manual 2 : Old* ternporary alterations , i j '
. Old* non conformances 2 Old* tag outs
* "Old" refers to current items that should be reDected (if required) in the last FSAR update per 10 CFR 50.71(e)
. Select a sample from each of the above categories based on the number of items compiled.
. Review the item selected to determine if the item represents a change to the bcensinc basis and if so tf the licensing basis accurately reDects the change.
For changes that are not accurately reDected in the licensing basis. determine the programmatic step (or missing programmatic step) that would have ensured its accurate incorporation into the licensing basis.
. Docu:nent the results of the samphng.
3.2 Evaluation Phase At this point in the assessment, the changes to operating practices that should have been reDected in the beensing basis have been identt5ed. Those not accurately reDected in the licensing basis are ddferences that must be resolved and categorized. The evaluation phase cannot be precisely structured. However, the following broad steps should be undertaken.
. Categorize differences in accordance with the following criteria:
O Proeram/ process which should have ensured licenstng basis accuracv 0 SigntScance
- Safety signi5 cant
- Regulatory signiacant (i e. noncomphance or missed commitmenti
- Low sient5cance te.c.. the originalinformation was not required to be included in the FSAR. or the information could not have been
,5
i . rebed upon by the NRC in reachmg a safety conclusion) i [ NOTE: Section V of SDIARC 9012. " Design Basis Program Guidelines." provides guidance for assessing the safety significance of differences and for determining 'f operability and/or reporting issues j
- exist.)
" ? 50.59 was correctly / incorrectly applied i,
- Licensing basis information has always been inaccurate (i.e., there was no change m operating practice) ;
4
- Identify areas of programmatic weakness or missing programmatic controls If uncertain. pursue additional assessment investigation for the l programmatic area in question.
4
- Characterize overall significance of the 6ndings. Based on thi:,
characterization determine the need to broaden the assessment scope to !
- obtain the necessary confidence that the programs are adequate and are 1 l being effectively implemented q
!
- If applicable, generate necessary quality de6ciency documents and identifv any reportable situations.
l
- Prepare recommendations to address programmatic weaknesses.
i
- Document the results and brief appropriate management.
i 4.0 NTI REPORT
- 4.1 Purpose of Report q NEl will compile the overallindustry results to assess the composite adequacy i and effectiveness of programs designed to maintain the licensing basis of tha j
plants. The overall industry results will be reported to the NRC by NEI. s 4.2 Report Format i The report format follows the steps contained in Section 3.0 of this report. Part 1 - FSAR Samoling '
- Identify the FSAR systems reviewed under Section 31.1
* 'ndicate the number of FSAR differences identi6ed.
6.
1 . l 4 ' d Part 2 - Progranunatic Sampline Indicate the total number ofitems reviewed.
- Indicate the number ofitems where the change was not accurately reflected in the beensing basis.
Part 3 - Sampline for notential changes that mav occur separate from programmatic or orocedure changes Indicate the total number ofitems reviewed. i Indicate the number ofitems where the etiange wrs not accurately reDected in the licensing basis, if required. ? j Part 4 - Evaluation Phase s Indicate the number of differences that were characterized as being safety signtScant.
. i Indicate the number of differences that were characterized as being i
] regulatory sign 16 cant. Indicate the number of differences where 50.59 was incorrectly applied. l . Indicate the number of differences where the licensing basis information has always been inaccurate. Provide a brief summary of the programmatic de5ciencies identined, if any. Indicate whether the assessment scope is being broadened based on the l identtBed differences. Describe any departures from the methodology of this guideline. . 5.0 DEFINITIONS q 5.1 Regulatory Commitment NEI " Guideline for Managing NRC Commitments." endorsed by NRC in SECY 95-300, defmes a regulatory commitment as follows: i "Reculatorv Commitment means an explicit statement to take a spectSc action agreed to or volunteered by a licensee that has been submitted in writing on the docket to the Commission." 5.2 Licensing Basis 10 CFR Part 54 defines the curren: " licensing basis as follows 7
" Current licensing basis o i.Biis the set of NRC requirements applicable to a speciSc plant and a licensee's written commitments for ensuring compliance with and operation within applicable NRC requirements and the plant specific design basis (including all modincations and additions to such commitments over the life of the licensel that are docketed and in effect. The CLB includes the NRC requirements contained in 10 CFR parts 2.19. 20. 21. 30, 40, 50. 51, 5 4, 55. 70. 72. 73. and 100 and appendices thereto: orders: license conditions: exemptions: and technical speci5 cations. It also includes the plant specine design basis information deSned in 10 CFR 50.2 as documented in the most recent Snal safety analysis report (FSAR) as required by 10 CFR 50.71 and the licensee's commitments remaining in effect that were made in docketed licensing correspondence such as licensee responses to NRC bulletins, generic letters, and enforcement actions, as well as licensee commitments documented in NRC safety evaluations or licensee event reports.
NOTE: Responses to NRC bulletins. generic letters and licensee event , reports contain some commitments that are outside the scope of the CLB in that they are not necessary to ensure compliance with applicable NRC requirements (e.g., rules. regulations licenses and ordersi or to maintain !' the plant.spectfic desien basis. l 1
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NUCLEAR REGULATORY COMMISSION wasmscToN o e resss.oooi g . g k * .s... August 14, 1996 CH AIR M AN i Mr. Joe F. Colvin i President and Chief Executive Officer Nuclear Energy Institute
- Suite 400 1776 1 Street, N.W.
Washington, D.C. 20006-3708
Dear Mr. Colvin:
I am responding to your letter of August 2, 1996, concerning industry actions for assessing programs in place to reaffirm that nuclear power plants are operated in conformance with their licensing basis. Your letter also identified three issues that, in your view, require mutual agreement between the industry and the Nuclear Regulatory Commission (NRC) before the industry would proceed with the initiative: (1) the legal standing of the Updated Final Safety Analysis Report (FSAR) and the NRC's Safety Evaluation Reports; (2) the scope of what constitutes the current licensing basis; and (3) the adequacy of NSAC-125, " Guidelines for 10 CFR 50.59 Safety Evaluations," for ! performing 10 CFR 50.59 evaluations. 4 We believe that resolution of the issues you identified is not a prerequisite to reviewing, on a retrospective basis, whether existing programs are
- sufficient to ensure that licensees know their licensing bases, whether i
licensing bases have been properly maintained, and whether licensing bases are accurately described in each facility's updated FSAR or other documents. The significant issues recently identified by licensee reviews and NRC staff inspections relate to failures to address degraded and nonconforming conditions properly, failures to perform reviews required by 10 CFR 50.59 before making changes to facilities, and f ailures to update f acility Final In our view, Safety Analysis Reports in accordance with 10 CFR 50.71(e). industry initiatives can proceed notwithstanding that ongoing NRC activities under the 10 CFR 50.59 Action Plan will consider, in a broad sense, issues such as those you raise. Existing regulations and guidance are sufficient to conduct a retrospective review for conformance to existing regulatory requirements. These include: (1) NRC regulations 10 CFR 50.2, 50.34, 50.54, 50.59, 50.71(e), 50.72, 50.73 and Appendix B; (2) NRC's policy statement - Availability and Adequacy of Design Bases Information at Nuclear Power Plants, 57 FR 35455 August 10, 1992 (3) " Design Bases Program Guidelines," NUMARC 90-12 and NRC letter dated November 9, 1990: and (4) Generic Letter 91-18, "Information To Licensees Regarding Two NRC Inspection Manual Sections On Resolution Of Degraded And Nonconforming Conditions And Operability." Attachment 4
'l&&:::C3?"- W
1 . i ! The staff 1s cor.cerned, however, that the proposed initiative may not be of i sufficient scope and depth to identify tha types of design and operability j problems recently identified at several operating plants. Specifically, it is not sufficient to perform a process / procedural based review. An in-depth l' vertical slice review of actual design basis documentation and comparison of
- "as built" and "as operated" safety systems is more appropriate.
1 for example, reviews similar to safety system functional inspections j (Inspection Procedure 93801, " Safety System functional Inspections"), may be used to evaluate a licensee's program effectiveness to maintain the licensing l and design bases. These reviews should include: (1) an in-depth review of selected systems' design and design basis since issuance of the facility 1 operating license: (2) risk- and safety-based criteria for selection of systems for review; and, (3) a method to ensure that licensee problem ; ! identification and corrective action on the selected systems are ;
- representative and consistent with other systems. The in-depth review should i i exa ine: (1) engineering design and configuration control; (2) verification of j i as-built and as-modified conditions: (3) translation of the design bases recuirements into operating procedures. maintenance, and testing; (4) j l
l verification of system performance through review of test records and ocservations of selected testing: (5) proposed and implemented corrective l l actions for licensee-1dentified design deficiencies; and, (6) modifications j 3 ade tc the syste s since initial licensing. a In snori, the NRC position has been, and 15. that it 15 the responsibility of individual licensees to know their licensing basis, to have appropriate ! docu*entation that defines their design basis, and to have procedures for < performing the necessary assessments of plant or procedure changes required by NRC regulations. Until such time that any regulation changes are made as a result of NRC action plan activ1 ties, we will continue inspection and 2 oversight activities related to the design basis to ensure compliance with ' existing regulations. Sincerely, i - Shirley Ann Jackson i M t J
Distribution for 50.54(f) letter to utility CE0s dated: October 9, 1996 Docket File PUBLIC J. Taylor EDO Rdg File F. Miraglia/A. Thadani R. Zimmerman DRPW/DRPE/DRPM Directors DRPW/DRPE/DRPM Deputy Directors J. Lieberman J. Goldberg W. Dean G. Tracy B. McCabe J. Mitchell D. Matthews E. McKenna K. Thomas F. Akstulewicz OGC ACRS OPA DRPW/DRPE PDs i NRR PMs ! NRR LAs PD Rdg File R.W. Cooper, RI l E. Merschoff, RII W.L. Axelson, RIII J. Dyer, RIV K. Perkins, RIV/WCFD}}