ML20149M034

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Weekly Info Rept for Wk Ending 961129
ML20149M034
Person / Time
Issue date: 12/04/1996
From: Blaha J
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:
References
SECY-96-246, SECY-96-246-R, WIR-961129, NUDOCS 9612110194
Download: ML20149M034 (15)


Text

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2 December 4. 1996 SECY 96-246 f_or:

The Commissioners q

From:

James L. Blaha, Assistant for Operations, Office of the EDO Subiect:

WEEKLY INFORMATION REPORT - WEEK ENDING NOVEMBER 29, 1996 Contents Enclosure Nuclear Reactor Regulation A*

Nuclear Material Safety and Safeguards B

Nuclear Regulatory Research C

Analysis and Evaluation of Operational Data D

r General Counsel E*

Administration F

Information Resources Management G*

Controller H*

Personnel I

Small Business & Civil Rights J*

Enforcement K*

State Programs L*

Public Affairs M

International Programs N*

Office of the Secretary 0*

Region I P

Region II P

Region III P*

Region IV P

Executive Director for Operations Q*

Congressional Affairs R*

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  • No input this week.

D Carl F. Dolinka for James L. Blaha j

100150 Assistant for Operations, OED0

Contact:

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l UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20665 INFORMATION REPORT December 4. 1996 SECY 96-246 For:

The Commissioners From:

James L. Blaha, Assistant for Operations, Office of the ED0 Subiect:

WEEKLY INFORMATION REPORT - WEEK ENDING NOVEMBER 29, 1996 Contents Enclosure Nuclear Reactor Regulation A*

Nuclear Material Safety and Safeguards B

Nuclear Regulatory Research C

Analysis and Evaluation of Operational Data D

General Counsel E*

Administration F

Information Resources Management G*

Controller H*

Personnel I

Small Business & Civil Rights J*

Enforcement K*

State Programs L*

i Public Affairs M

International Programs N*

Office of the Secretary 0*

Region I P

Region II P

Region III P*

Region IV P

Executive Director for Operations Q*

Congressional Affairs R*

  • No input this week.

/

JJames L. Blaha e

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Assistant for Operations, OED0

Contact:

SECY NOTE:

TO BE MADE PUBLICLY AVAILABLE 55 5

5 WORKING DAYS FROM THE DATE OF THIS PAPER.

IN

Office of Nuclear Material Safety and Safeguards Items of Interest Week Ending November 29, 1996 Conference of Radiation Control Proaram Directors SR-6 Subcommittee On November 18-20, 1996, a representative of the Division of Industrial and Medical Nuclear Safety participated in a meeting of the Conference of Radiation Control Program Directors SR-6 Subcommittee. The meeting focused on modifications to the Part G (Medical Use) of the Suggested State Regulations.

In particular, the committee addressed changes to the suggested regulations resulting from the Nuclear Regulatory Commission's " Quality Management and Misadministrations Rule" and the " Preparation, Transfer for Commercial Distribution, and Use of Byproduct Material for Medical Use" regulations.

As part of this meeting, our representative provided the committee with an overview of the Strategic Assessment Decision Setting Initiatives Papers Numbers 7 and 12 dealing with Materials / Medical Oversight and Risk-Informed, i

Performance-Based Regulation, respectively. In addition, a representative from the American College of Nuclear Physicians / Society of Nuclear Medicine also provided these organization's general reactions to the Papers.

Meetina with Department of Enerav. Uranium Mill Tailinas Remedial Action Pro.iect Office On November 19, 1996, staff of the Division of Waste Management, Uranium Recovery Branch, met with representatives of the Department of Energy (DOE),

Uranium Mill Tailings Remedial Action (UMTRA) Project, to discuss the status of activities related to the remediation of Title I mill tailings sites and issues related to the transfer of Title 11 sites to DOE. The meeting included DOE representatives of the Grand Junction and Albuquerque UMTRA Project Offices and DOE Headquarters.

Items of discussion included the status of the Nuclear Regulatory Commission's review of DOE submittals, 00E completion schedules, generic issues related to the disposal of material from UMTRA vicinity properties, and the potential for placement of Title 11 material at Title I sites.

Participants also discussed DOE's plans for leaving the Grand Junction Cheney disposal cell open to accept tailings from vicinity propertie; after DOE's authority expires under the Uranium Mill Tailings Radiation Control Act. The next management meeting is planned for late Spring 1997.

Nuclear Materials Manaaement and Safeauards System Users Meetina 4

During the period of November 19-20, 1996, Fuel Cycle Safety and Safeguards i

1 (FCSS) staff attended the annual Nuclear Materials Management and Safeguards System (NMMSS) Users Meeting in Atlanta, Georgia. The NMMSS Users Meetirg provides an opportunity for policymakers, the NMMSS contractor, and the nuclear industry to learn firsthand about U.S. nonproliferation initiatives and the critical role NMMSS plays in support of these initiatives.

i Presentations were designed to heighten awareness concerning Department of Energy, U.S. Enrichment Corporation, and Nuclear Regulatory Commission i

accountability and safeguards activities. An FCSS staff member made a presentation on obligation exchanges and tracking nuclear material pursuant to ENCLOSURE B NOVEMBER 29, 1996

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1 Agreements for Cooperation.

Interactive discussion groups allowed attendees

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to address such specific issues as licensee and International Atomic Energy Agency reporting, electronic data transmission, material safeguards, and reconciling transit data involving foreign shipments.

Following the Users Meeting, FCSS staff participated in the semiannual NMMSS 1

Steering Committee Meeting on November 21, 1996, where issues related to the effective and efficient operation of the NMMSS were discussed.

Safeauards Bilateral Meetinas Safeguards bilateral discussions were held with Australia on November 17, 1996, and with Japan on November 19-20, 1996, in Tokyo, Japan. A tour of completed facilities at the Rokkasho Reprocessing Plant was conducted on November 18, 1996.

Representatives from the State Department, Arms Control and Disarmament Agency, Department of Energy, and Nuclear Regulatory Commission participated in the meetings.

The meeting with Australia involved discussion of U.S. and Australian comments on the draft protocol for.

implementation of the Part 2 measures of the International Atomic Energy Agency's (IAEA) Programme 93+2.

Australia's comments were in general agreement with those of the U.S. and served to refine the U.S. comments on several issues.

The bilateral meetings with Japan were to review the implementation of the U.S.-Japan Agreement and to keep Japan apprised of U.S. safeguards activities that could impact Japan. Topics discussed included:

IAEA safeguards implementation, safeguards assistance to former Soviet Union countries, IAEA i

Member State Support Program cooperation, Programme 93+2, and safeguards for plutenium facilities and nuclear wastes, j

During discussions involving Programme 93+2, Part 2 draft protocol, Japan indicated a desire for universal implementation of the verification measures and prefers to withhold acceptance of certain measures until after the Nuclear Weapon States have committed to acceptance of the protocol measures. Japan also had concerns with the protocol language with respect to access to facilities (primarily to private property) and the impacts of the measures on its industries.

Tours were conducted of the spent fuel receiving and storage building and of the vitrified waste storage building at the Rokkasho Reprocessing Plant. The spent fuel receiving building is nearing completion and should be commissioned in 1997.

Twenty-eight canisters of vitrified high activity waste have been received from France and are being stored at Rokkasho. Additional vitrified waste is scheduled to be received during 1997. Separate storage facilities will exist for vitrified waste generated at Rokkasho and received from France and Great Britain.

Physical Protection Bilateral Consultations During the week of November 18-22, 1996, the International Safeguards Section participated in physical protection bilateral consultations in Belgium and Sweden.

This was a cooperative effort with the Department of Energy designed NOVEMBER 29, 1996 ENCLOSURE B j

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to exchange technical information on physical protection with countries possessing U.S.-origin nuclear materials.

Staff Visit to Hanford Tank Waste Remediation System Representatives of the Tank Waste Remediation System (TWRS) Section in the Division of Fuel Cycle Safety and Safeguards visited the Hanford Site on November 20-21, 1996, to meet with the Department of Energy (DOE) Regulatory Unit that has oversight responsibility for the DOE privatization contractors that will be performing waste solidification pilot demonstrations under the TWRS project. The meetings were held to discuss the draft Memorandum of Understanding between DOE and the Nucleae Regulatory Commission, as well as to discuss the working relationship, organizational matters, schedules and distribution of documents. A tour of the tank farm areas was also conducted, with emphasis on the new transfer line under construction and the tanks and waste materials to be involved in the pilot demonstration effort.

Meetina with VECTRA to Discuss Concerns with Their Quality Assurance oroaram On November 26, 1996, the Director, Office of Nuclear Material Safety and Safeguards and the Spent Fuel Project Office staff conducted a management meeting with the President of VECTRA and members of his staff.

The purpose of the meeting was to discuss recent inspection findings, concerns with the J

quality assurance program and design control for fabrication of NUHOMS system components. The meeting was initiated by the Nuclear Regulatory Commission i

because the agency has identified several recent concerns with VECTRA's ability to ensure that safety analysis report nonconformances are promptly identified, corrected and prevented from recurring. The meeting was also attended by several reactor plant licensees who use the NUH0MS system, and by several members of the press.

Acceptance of Arkansas Nuclear One Response to Nuclear Reaulatory Commission.

Bulletin 96-04 The Spent Fuel Project Office staff, with technical assistance from the Office of Nuclear Reactor Regulation, has completed its review of Arkansas Nuclear One's (ANO) response to Nuclear Regulatory Commission Bulletin 96-04,

" Chemical, Galvanic, or Other Reactions in Spent Fuel Storage and Transportation Casks." AN0 plans to use the VSC-24 cask, the same cask design involved in the hydrogen ignition event at Point Beach Nuclear Plant on May 28, 1996. A Confirmatory Action Letter prevents AN0 from loading a cask until the staff has reviewed and accepted AN0's response to the bulletin and verified the corrective actions taken in response to the bulletin.

Based on its review of AN0's response, the staff has concluded that ANO has i

satisfied the requested actions and required responses to the bulletin. The procedure changes discussed in AN0's response adequately resolve the concern of preventing a hydrogen ignition and boron depletion during loading or unloading of existing VS?-24 casks. NRC inspectors have reviewed the loading and unloading procedures at ANO and verified that the procedure changes have been implemented. ANO has also adequately addressed the effects of any identified reactions or their products.

The staff has found that AN0's NOVEMBER 29, 1996 ENCLOSURE B

l response provides the necessary level of confidence that the casks will safely store spent fuel over the 20-year period of the certificate.

Therefore, the staff has recommended that ANO be permitted to load the existing VSC-24 casks.

Although the staff finds the use of existing VSC-24 casks, coated with Carbo Zinc 11 or its various grades acceptable, the staff believes that it is prudent to discontinue fabrication of casks with Carbo Zinc 11, or its various i

grades, and to use an alternate coating that does not react with borated water

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or other potential environments to produce combustible concentrations of i

hydrogen gas.

In a letter dated November 20, 1996, Sierra Nuclear Corporation (SNC) informed NRC that it was investigating suitable alternate coatings for future VSC-24 casks.

SNC is in the process of qualifying potential coatings and expects to identify a suitable alternate coating by mid-1997.

SNC plans to discontinue use of Carbo Zinc 11, or its various grades, pending the successful qualification of a suitable alternate coating.

E Transoort Packaae Modified to Include Valve Protection Device On November 25, 1996, the Spent Fuel Project Office issued an amendment to Certificate of Compliance No. 9234, for the Model No. NCT-21PF-1 package. The package is used to transport up to 2.5 tons of low-enriched UF contained 6

within 30-inch diameter cylinders.

Physical testing of the package performed in 1995 indicated that the cylinder valve could leak under hypothetical accident conditions. The U.S. Enrichment Corporation designed a valve protection device which could be installed on the UF cylinder.

Packages with 6

the valve protection device were subjected to the accident test sequence in 10 CFR Part 71, including a 30-foot free drop, a puncture test, and a 30-minute fire test. The valve remained leak-tight after these tests. The Certificate was amended to authorize use of packages with the valve protection l

device. A complete safety analysis report for the package with the valve protection device will be submitted to the Nuclear Regulatory Commission by March 1, 1997.

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Office of Nuclear Regulatory Research Items of Interest Week Ending November 29, 1996 IAEA Consultants Meetina to Revise NVSS Safety Guides on Sitina During the week of November 11-15, 1996, Mr. Robert Kornasiewicz participated as an invited consultant in the International Atomic Energy Agency (IAEA)

Consultants Meeting to Revise "NUSS Safety Guides on Siting" Related to External Events which was held at the IAEA Headquarters in Vienna, Austria.

Along with Mr. J. Riera of Brazil, he prepared a draft of Safety Guide SG-Sil,

" Extreme Meteorological Events in Nuclear Power Plant Siting." This draft is an updated revision and combination of two existing Safety Guides, SG-SilA,

" Extreme Meteorological Events in Nuclear Power Plant Siting, Excluding Tropical Cyclones" and SG-S11B, " Design Bases Tropical Cyclone for Nuclear Power Plants." The Safety Guide can be used in the evaluation of nuclear power plant sites in relation to hazards posed by extreme meteorological events (e.g., tornadoes, hurricanes, severe thunderstorms).

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Office for Analysis and Evaluation of Operational Data Items of Interest Week Ending November 29, 1996 Nuclear Enerav AaenCY Expert Group on Nuclear Emeraency Matters A member of IRD attended a meeting of the Nuclear Energy Agency Expert Group on Nuclear Emergency Matters on November 21-22, 1996 in Paris, France. The

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recent exercise, conducted under the Second International Emergency Exercise program (INEX-2) on_ November 7,1996, and hosted by Switzerland, was the main topic. The. objectives of the exercise were to test the real time communication exchange using the actual facilities, equipment, and procedures; to develop protective actions based on plant conditions, and to test public information and media interface. The preliminary results of the 30 countries that participated in the exercise revealed that there are areas for improvement in international notifications and communications.

Participating countries and IAEA are addressing tt'se areas in preparation for the next INEX-2 exercise which will be hosted by Finland in April 1987.

The U.S. only-exercised the first objective; EPA was the Lead Federal Agency and is preparing the U.S. report for the review meeting to be held in February 6-7, 1997.

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Preliminary Notifications (PNs) a.

PNO-I-96-082, Massachusetts General Hospital, FIRE IN RESEARCH BUILDING AT MASSACHUSETTS GENERAL HOSPITAL.

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PN0-III-96-070, S. C. Johnson and Son, Inc., MISSING DENSITY GAUGE SOURCE.

NOVEMBER 29, 1996 ENCLOSURE D

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Items of Interest Week Ending November 29, 1996 Procurement Reform -- Manaaement Directive 11.7 On November 21, 1996, the NRC Management Directive (MD) 11.7 Users' Group met with DOE representatives to discuss: (1) progress on the revision to DOE's policy on waiving its added factor charge, (2) allowing DOE laboratories to i

submit proposals directly to the NRC, and (3) the status of streamlining MD 11.7.

DOE stated that it would consider an NRC request to waive the added l

factor charge as DOE's CF0 had recently approved such_a waiver for the EPA.

l DOE al:;o agreed to write to its operations offices supporting the streamlining measure to allow its laboratories to submit proposals directly to the NRC.

The NRC reported that agency comments on revised MD 11.7 had been received, and that, after incorporating the comments, DOE comments on MD 11.7 would be j

requested.

Security Guard Contract Oversiaht Phntographers representing the Government Computer News newspaper visited NRC on November 21, 1996, to photograph IRM system engineers and SEC security officers in connection with an article soon to be published on " Guard Force Time and Attendance." The article explains SEC's efforts to obtain an automated method of recording guard force time and attendance information.

The " Guard Force Time and Attendance" automated application addresses multiple contract oversight issues, including significant time savings on the monthly preparation of contract invoices.

Facility Security Voorades As part of the facility security upgrade of the White Flint complex, the exterior locks for the WFN complex have been replaced.

This upgrade effort was a result of a recommendation made in the WFN security survey and was counted among the facility security upgrade efforts resulting from the Department of Justice " Vulnerability Assessments of Federal Facilities" made following the Oklahoma City bombing. Contractor work on this project began on November 18, 1996, and was completed on November 25, 1996.

Sianificant F0IA Reauests Received durina the 5-Day Period of November 22 -

28. 1996:

Copy of minutes of 11/14/96 enforcement conference related to Hope Creek Generating Station.

(Individual; F01A/PA-96-492)

Copy of all ComSecys related to international travel; international travel guidelines and policies; international initiatives; international program participation; and international cooperation and research efforts.

(K. Hart; McGraw Hill; F01A/PA-96-493) l NOVEMBER 29, 1996 ENCLOSURE F

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Copy of supporting documentation related to an investigation on 10/21-22/96 at the Hospital of the University of Pennsylvania regarding radiopharmaceutical doses to patients.

(Individual; F01A/PA-96-494) i Records associated with Lehigh Valley Cardiology Associates' license for radioisotopes.

(C. Chapman; Easton Hospital; F01A/PA-96-495) l Listing of IMPAC holders for the state of Arkansas.

(B.Mathews; Today's i

Office; F01A/PA-96-496) j Records related to SDMP for 5/96 through 11/96 and correspondence related to

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Shieldalloy Metallurgical Corp. for 10/95 through 11/96.

(T.Barney; Envirocare of Utah; F01A/PA-96-497) i Correspondence from New Jersey's Governor and/or the Congressional delegates since 1992.

(A.Piore; The Record / States News Service; F01A/PA-96-498)

Records related to an anonymous complaint regarding the Masco Instrument Company in Dallas, TX.

(L.Horan of Guida, Slavich & Flores; F01A/PA-96-500) 01 reports regarding allegations related to Northeast Utilities and Millstone Unit 1.

(Individual; F01A/PA-96-501)

Records related to identified projects, programs, investigations and sites.

(Individual; F01A/PA-96-503)

Records related to activities of named individual regarding radioactive pollution of residential site.

(J.Gourley; Natural Resources News Service; F01A/PA-96-504)

Copy of proprietary version of 11/8/96 Westinghouse response to NRC's 8/16/96 letter referencing Shannon T. Doyle's 2.206 petition.

(S.Doyle; F01A/PA-96-505) i NOVEMBER 29, 1996 ENCLOSURE F

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l Office of Personnel Items of Interest Week Ending November 29, 1996 Arrivals

-MILLER, Patricia SECRETARY (0A) (PFT)

OP/SPAC UHLE, Jennifer NUCLEAR ENGINEER-(PFT)-

RES Retirements CORREIRA,' Arthur PROPERTY INF0 SYS SPEC (PFT)-

ADM WILSON, Richard SENIOR REACTOR ENGINEER.(PFT)

NRR Departures NONE l

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NOVEMBER 29, 1996 ENCLOSURE I i

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Office of Public Affairs Items of Interest Week Ending November 29, 1996 School Volunteers Proaram Brett Leslie, NMSS, discussed geology and rocks at Charles Drew E.S. and Kien Chang, NMSS, talked about NRC careers at Rudolph E.S.

Press Releases Headauarters:

96-169 Note To Editors: Reports from the ACRS on plant-specific safety goals, future role of NRC research, proposed rule on steam generator integrity, risk-based analysis of reactor j

operating experience 96-170 NRC Issues Certificates to USEC for Uranium Enrichment Plants Reaions:

I-96-77 NRC Staff to Discuss Apparent Violations at Haddam Neck and Millstone i

i 11-96-98 NRC Staff Issues Appraisal of Performance at Crystal River Nuclear Power Plant in Florida 111-96-70 NRC Special Inspection Team to Present Preliminary Findings of Independent Evaluation of Dresden Nuclear Plant IV-96-60 NRC Staff Proposes $100,000 Fine for Apparent Violations at WNP-2 I

NOVEMBER 2'9, 1996 ENCLOSURE M 1

1 Region I Items of Interest Week Ending November 29, 1996 4

University of Connecticut Health Center Enforcement Action On November 25, 1996 an Enforcement Conference was held with representatives of the University of Connecticut Health Center.

Primary issues discussed during the conference were security and control of. radioactive materials.

Security and control of radiopharmaceuticals in the Nuclear Medicine i

Department and tracer materials used in research were also discussed.

Examples of apparent lack of security in the Nuclear Medicine Hot Laboratory and research laboratories were presented to the licensee.

i The licensee acknowledged the findings and presented the corrective actions to prevent recurrence.

Manaaement Meetina With Acaee/Berthold Corooration On November 21, 1996, staff from the Office of Nuclear Material Safety and Safeguards, the Office of State Programs and Region I met with representatives of Apgee Corp. and EG&G Berthold to discuss Apgee's responses to a Confirmatory Action Letter (CAL) concerning the distribution of devices that I

are not in accordance with the approved designs. Apgee's responses to date have not been adequate and the purpose of the meeting was to discuss the j

additional information necessary to consider these responses as adequate.

This includes such information as the safety significance of the variations of the distributed devices and the need for Apgee to demonstrate that the devices can be used safely.

Acolied Health Physics. Inc.

j On November 22, 1996 the NRC was notified that Applied Health Physics, Inc.

i (AHP) of Bethel Park, Pennsylvania filed for Chapter 11 bankruptcy on October 29, 1996.

This is the second time in two years that AHP has filed for 3

Chapter 11 bankruptcy. AHP possesses two NRC licenses; a radioactive waste brokerage license and a calibration service license. A bankruptcy hearing has 1

been scheduled for December 12, 1996 in the Federal Building in Pittsburgh, Pennsylvania.

The NRC will be represented.

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Region II

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Items of Interest Week Ending November 29, 1996 Florida Power Corporation - Crystal River The Systematic Assessment of Licensee Performance (SALP) report for Florida Power Corporation's Crystal River nuclear power plant was issued on November 25, 1996, indicating an overall decline in performance at the facility since its previous assessment.

The SALP covered a period from September 17, 1995 through October 5, 1996.

The functional areas of Plant Operations and Engineering declined to a Category 3 while Plant Support declined to a 2.

Performance in the functional area of Maintenance was sustained at a 2 level.

It was the second consecutive decline in assessment for Engineering, which has seen its assessment over the last two SALP periods drop twice, from " superior" to

" good," and now to " acceptable".

Common trends which contributed to the performance decline were weak management oversight, ineffective self-assessment, insufficient involvement in quality assurance, and an

" insensitivity" to regulatory requirements. NRC officials will meet with j

company management at the plant site at 12:30 p.m. on Monday, December 2, to discuss details of the report.

Duke Power Company - Oconee Since the Unit 2 second stage reheater drain line rupture and manual reactor trip in late September, all three Oconee Units have been shut down to perform secondary piping inspections and make necessary water hammer related modifications.

Unit 2, which is the lead plant, is currently scheduled for restart on January 6, 1997. Unit I will follow, with a current restart date of January 16.

Unit 3, which is currently defueled in support of Refueling Outage 16, has a scheduled restart date of January 31.

Prior to restarting the Units, the licensee plans to conduct an integrated Engineered Safeguards test of the Oconee emergency power system. This test is being developed to demonstrate that the emergency power system will perform its design basis function under various loading configurations and is currently scheduled for December 19-21.

NRC will review the test procedure, observe its performance, and evaluate the results.

Virainia Power Company - North Anna On November 25, 1996, Commissioner E. McGaffigan, Jr. and the Deputy Regional Administrator for Region II visited the North Anna facility. The Commissioner toured the site and met with the resident inspectors and with North Anna plant management.

Specific items discussed by the licensee with the Commissioner included the current changes in the electric power industry, changes in the regulatory environment (such as the reduced number of Notices of Enforcement Discretion issued), and the Department of Energy's failure to take spent fuel.

NOVEMBER 29, 1996 ENCLOSURE P

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Region IV Items of Interest Week Ending November 29, 1996 Predecisional Enforcement Conference - Grandin Testina Lab. Inc.

A predecisional enforcement conference was held on November 25, 1996, in the Region IV office with Grandin Testing Lab, Inc. (Grandin), a New Mexico licensee, to discuss an apparent violation involving Grandin's failure to obtain authorization under either a specific or general NRC license prior to performing licensable activities at Kirtland Air Force Base.

Grandin filed an incomplete NRC Form 241 in 1994 and was subsequently notified that additional information and the applicable fee must be filed with the Region IV office before Grandin could be authorized to perform proposed work at Kirtland Air Force Base.

Grandin failed to respond to this notification and did not file any other Form 241s with the regional office. An investigaticn determined that Grandin did perform work in calendar years 1994, 1995, ard 1996, and that the failure to obtain authorization from the NRC prior to conoucting activities at Kirtland may have been deliberate.

Predecisional Enforcement Conference - Testina Laboratories. Inc.

A predecisional enforcement conference was held on November 26, 1996, with Testing Laboratories, Inc. (TLI), a New Mexico licensee, to discuss an apparent violation involving TLI's failure to obtain authorization under either a specific or general NRC license prior to performing activities using i

byproduct material at federal facilities determined to be areas of exclusive 1

federal jurisdiction within the state of New Mexico.

TLI had performed activities in areas under NRC jurisdiction from 1991 to 1996 and had submitted NRC Form 241s to report proposed activities on three occasions during the i

above noted period after TLI was prompted to do so by one of the facilities l

where licensable activities were performed. However, a significant portion of the work performed by TLI in areas under NRC jurisdiction from 1991 to 1996 was not reported to or authorized by the NRC. An investigation of TLI's activities has determined that the failure to obtain authorization from the NRC prior to performing activities in areas under NRC jurisdiction may have been deliberate.

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