ML20151D043
| ML20151D043 | |
| Person / Time | |
|---|---|
| Issue date: | 07/18/1988 |
| From: | Hutchison W NRC OFFICE OF INVESTIGATIONS (OI) |
| To: | Mcknight J NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8807220321 | |
| Download: ML20151D043 (30) | |
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/ o, UNITED STATED l [ g NUCLEAR REGULATORY COMM!SSION 7; p WA$HING TO N, D. C. 20555
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July 18, 1988 MEMORANDUM FOR: James C. McKnight, Senior Document Reviewer Document Control Branch Division of Information Support Services ,
OfficeofAdministrationandResourcesManagement,[// ~
William D. Hutchison, Operations Officer FROM: .
Office of Investigations
SUBJECT:
VISITTONUCLEARMANAGEMENTANDRESOURCESCOUNCIL(NUMARC)
At 1:00 P.M., July 14, 1988, Ben B. Hayes, Director, Office of Investigations (01), visited the NUMARC offices in Washington, D.C., accompanied by James Fitzgerald. 0GC, and William Hutchison 01:HQ. A meeting was held with Bryon Lee, Jr., President and CEO, NUMARC; Joe F. Colvin, Executive Vice President and C00, NUMARC; and Robert W. Bishop, General Counsel and Secretary, NUMARC.
The greater part of this meeting was consumed with an overview briefing regarding NUMARC presented by Mr. Colvin, and based on the attached documents.
Thereaf ter, Mr. Hayes talked for about ten minutes regarding the organization and mission of 01. The meeting was concluded at approximately 3:30 P.M.
Please place this memcrandum with attachments'in the Public Document Room.
Attachments:
- 1. NUMARC Organization Chart
- 2. NUMARC Key Concepts
- 3. NUMARC Priority Issues
- 4. NUMARC Breakdown Chart
- 5. NP0C Chart
- 6. NUMARC Mission Statement
- 7. NUMARC Issue Update (February 1988)
M i i 8807220321 880718 POR REVGP ERGNUMRC PDC
e NUMARC l BOARD OF DIRICTOR$ l EXICUTIVE COPMITIEf f
Robert K. Campbell, Chairman Donald W. Mazur
- Shelby T. Brewere Pennsylvania Power & Light Washington Pubitc Powr Supply System Combustion Engtr.cering, sa:.
Warren H. Owen, Vice Chairman Walter J. McCarthy, Jr. Willlas J. L. Kennedy Duke Power Company Detrott [dison Company Stone & Webstcr Engineering Jack H. f erguson Eugene R. McGrath Charles W. Pryor, Jr.
Virginia Power Consolidated (dison Co. of New York, Inc. Babcock & W61 con Willtas Lindblad Cordell Reed Harry O. Reinsch Portland General flectric Company Commonwealth (dison Company Bechtel Power Corporation George A. Maneatis J. Gary Weigand
- Theodore Sterns Pacific Gas and Electric Company Vermont Yankee Nuclear Power Westingnouse Electric Corp.
Jerry L. Maulden C. O. Woody e l'ertram Wolfe e Arkansas Power & Light Company Florida Power & Light Company CE Nuclear Energy I
,, Stron Lee. Jr.
President and Chief Executive Officer
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3 y Issues Management .._. . ,
. Committee Loe F. Colvin
[secutive Vice President and Chief Operat'ng Of ficer/
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V Robert W. Bishop Robert A. Stalay
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utW ; 4 f General Counsel and Executive Assistant Secretary
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to the President
' I I OPfRAI 5. MANAGI. MINT &
SUPPORT 5[RVIC(5 TfCIMICAL 155U(5 IfouSTR1 & GOVlP9MfMT RttATIONS ADMINISTRAI!ON Thomas E. Itston-Director William H. Rastn-Director Thomas J. Price-01 rector Joe. F. Colvin-(Acting) Director e Identify. rev few & monitor radiologi- e Identify, review & monitor technical, o Provide policy interface and coordina- o Provide services in Personnel cal, cperational, management and hardware,.:nd design issues. tion with industry organtrations and Administration, Financlai Management human resource issues, such as government agencies. and Accounting. Purchasing and emergency preparedness, operator re- e Monitor industry concerns and actions Contracts, Tacilities. Services qualtftcation, etc. on technic:', issues. e Provide Member & Participant services, and Recruiting and Relocation.
e Monitor industry concerns & actions e Collect, analyre & disseminate o Coordinate activities with industry on radiological anJ operational indestry information on generic codes and standards groups and special issues. regulatory technical issues. issue greaps.
e Provide effective Interfaces with e Provide ef fective interf ace with e Promote and maintain industsy aware-regulatcry agency personnel and regulatory agency personnel and ness of NUMARC mission and activttles, industry associations. Industry associations.
o Provide effective interfaces with the o Manage the National [nvironmental international community.
Studies Project (NISP) Program. 5/88 1
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NUMARC KEY CONCEPTS 9 THE PRIMARY INTERFACE WITH THE NRC REPRE-SENTING THE NUCLEAR INDUSTRY ON GENERIC OPERATIONAL AND TECHNICAL REGULATORY ISSUES.
9 DRAWS UPON THE COLLECTIVE EXPERTISE OF UTILI-TIES, INDUSTRY ORGANIZATIONS, A/ES, VENDORS, SUPPLIERS, AND OTHERS.
8 ALL OPERATING OWNERS REPRESENTED ON BOARD CONSISTING OF EITHER THE CEO, C00, OR SENIOR NUCLEAR EXECUTIVE.
4 100% VOLUNTARY OPERATING UTILITY MEMBERSHIP
NUMARC KEY CONCEPTS (CON'T)
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i I e 80% VOTE OF BOARD REQUIRED TO ADOPT FORMAL INDUSTRY POSITION AND/OR POLICY l ,
$ INDEPENDENT, SEPARATELY GOVERNED AND FUNDED i
! 9 DEDICATED PROFESSIONAL STAFF i
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NUMARC PRIORITY ISSUES June 16, 1988 Access Authorization Degree Requirements for Operators Diesel Reliability Emergency Planning Litigation External Events Fitness for Duty Life Extension & License Renewal Maintenance M0V Performance
+ NRC Bulletin 88 Non-conforming Materials - bhgg$
Operator Requalification Seismic Issues Severe Accident Policy Implementation Severe Accident Management Program Standardization and Licensing Reform Station Blackout Technical Specification Improvement 10 CFR 50.59 (Safety Evaluation)
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NOTE: Issue moved, previously on Potential / Dormant issues List !
- Issue moved, previously on Priority issues List 1 Issue moved, previously on Monitored Issues List
+ New issue I
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NVMARC MQRUQBED ISSUES June 16, 1988' Adequate Level of Protection Definition Advanced Light Water Reactor Progrem, including Advanced Reactor Severe Accident Program (ARSAP)
Backfitting
+ Below Regulatory Concerns Activities Bolting Integrity Boric Acid Induced Corrosion of Pressure Boundary Components (Generic letter 88-05)
Chernobyl Follow-up Activities Check Valve Reliability Containment Integrity Containment Leak Rate Testing Decommissioning Deminimis Concept in Radiological Protection Emergency Planning Emergency Response Data System Enforcement Policy and Investigations Environmental Qualification of Equipment EPA Protective Action Guidelines EPA Radiological Protection Standard FEMA Guidance Memoranda Filtered Vent for Centainment Fire Protection
+ Hilti Bolt Hot Particle
+ Human Factors Important-to-Safety Integrated Safety Assessment Programs Integrated Schedules
+ License Admendment Review Process Loss of Air Systems NOTE:
^ Issue moved, previously on Potential / Dormant Issues List
- Issue moved, previously on Priority Issues List
- Issue moved, previously on Monitored Issues List
+ New Issue
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NUMARC MONITORE0' ISSUES (Continued)
NRC Reorganization .
Nuclear Plant Aging Operator Professionalism-Piping Integrity -
Pressurized Thermal Shock /RPV Embrittlement Probability of Causation / Radiation Tort Litigation
_ Quality Assurance Radiation Protection Safety Goals / Cost Benefit Safety Implications of Control Systems Security Senior Manager on Shift Shutdown Decay Heat Removal Single Phase Erosion-Corrosion Source Term !
Systems Interactions ,
10 CFR 20 Rulemaking i
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NOTE:
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Issue moved, previously on Potential / Dormant Issues List ;
- Issue moved, previously on Priority Issues List I
- Issue moved, previously on Monitored Issues List I
+ New Issue
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POTENTIAL OR DORMANT ISSVES June 16,.1988 Auxiliary Feedwater Reliability Buckling Behavior of Steel Containments +
Classification of Instrumentation, Control and Electrical Equipment Component Cooling Water System and Service Water Safety System Reliability Containment Venting (Operational Issue)
Control Room Design Standards Control Room Habitability Criteria for Safety Related Operator Actions !
DC Power Reliability Disturbance Analysis System Failure of HPCI Steam Line w/o Isolation Flooding of Safety Systems Via Floor Drains ;
4 HP Injection Systems ;
1 Hydrogen Combustion in Containment Structures Hydrogen Control for Large Dry Containments Hydrogen Control Measures and Burn Effects I&C System Reliability '
Initiating Feed and Bleed Procedures In-Situ Testing of Valves Inspection Procedures for Upgraded Emergency Operating Procedures
, Interfacing System LOCA Interlocks and LCOs for Class IE Tie Breakers y Lightning Protection of Nuclear Power Plant Structures
! Loads, Lead Combinations, Stress Limits i Local Control Stations low Temperature Overpressure Protection NRC Balance of Plant Inspections NRC Policy on Plant Staff Work Hours, Shifts, etc.
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- Operator Training and Qualification Litigation
^ Issue moved, previously on Potential / Dormant Issues List l NOTE:
- Issue moved, previously on Priority Issues List Issue moved, previously on Monitored Issues List t New Issue 2
l P0TENTIAL OR DORMANT ISSVES (Continugdl :
i PORV and Block Valve Reliability !
Reactor Coolant Pump Seal Failures l Reevaluate Position to Auto Isolate FW from SG During Steam Line Break l Reliability Engineering Research on Training Simulators Review Criteria for Human Factors Aspects of Controls & Instruments Safety Systems Status. Monitoring (RG.1.47)
Spent Fuel Pool Accidents Steam Generator Integrity ;
1 TVA Cable Testing Two-Phase Natural Circulation Water Hammer 2
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Issue moved, previously on Potential / Dormant Issues List
- Issue moved, previously on Priority Issues List Issue moved, previously on Monitored issues List
+ New Issue
a OTHER'IMPORTANT ISSUES June'16, 1988-
,-DOE Nuclear Production Reactors 00E Programs on HTGRs DOE Programs on LMRs Financial Considerations / Cost-effectiveness Fuel Cycle (Enrichment, Mining and Milling, Reprocessing:(alternate.
fuel cycle))
Fusion High Level Waste Disposal / Spent Fuel Storage / Rod Consolidation International Safeguards / Proliferation Low Level Waste Disposal
.TMI-2 Recovery / Decontamination Issues Transportation of Nuclear Material / Waste
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NOTE: ^ Issue moved, prcviously on Potential / Dormant Issues List
- Issue moved, previously on Priority Issues List
- Issue moved, previously on Monitored ~ Issues List
+ New Issue
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EVALUATION PROCESS FOR PRIORITIZATION OF ISSUES NUHARC has the responsibility for analyzing information concerning generic operational and technical regulatory issues and for the identification of those issues that affect er have the potential to affect a substantial portion of the nuclear power industry. In order to carry out that responsibility, NUMARC has created an Issues Management Committee to review and advise NilMARC on the identification, evaluation and prioritization of issues facing the industry. The Issues Management Committee will also assist with the develop-ment of strategies and implementation plans to be carried out by NUMARC.
The identification of issues will include member-initiated issues as-well as the historical regulatory-initiated set. The evaluation process for the prioritization of issues has five elements.
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- 1. GENERIC APPLICABJLITY -- The first step in the process is to determine l whether an issue is generic to the industry. A generic issue is'one that i
effects or has the potential to effect a substantial portion of the nuclear l power industry.
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- 2. 'MPORTANCE -- Next, an identified generic issue is reviewed to l determine whether the , sue has a high, medium or low level of importance in terms of safety, reliability, or economic impact.
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- 3. IMMEDIACY -- The third step in the process'is to evaluate an issue for its immediacy against the following criteria: (1) prompt action by the industry is necessary to address industry or NRC concerns; (2) action is in progress but there are no near term, urgent deadlines; or (3) no near term action is necessary and/or desirable.
- 4. INVOLVEMENT -- Next, an issue is reviewed for NUMARC involvement using-the following guidelines: (1) direct involvement of NUMARC appears to be necessary and appropriate to resolve the issues (2) industry action is in progress, but action by NUMARC may be necessary to achieve integration, commit-ment and closure or (3) the issue is being effectively handled by other organi-zation(s) and action by NUMARC does not appear to be necessary or appropriate.
- 5. OTHER FACTORS - The last step in the nrocess is to consider "other factors" not covered in the first four steps t. tke into account special considerations that bear on the overall pr::rity _of an issue. These "other factors" include factors such as high Congressional interest, public concern, NRC concern including rulemaking, and pending legal actions. These. factors should be explained when this element is used.
After an issue has been identified, evaluated and prioritized by_ the NUMARC staff and reviewed by the issues Management Committee, it will be assigned to one of four categories: NUMARC Priority, NUMARC Monitored, Poten- !
tial or Dormant, or Other Important Issues. l I
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0 ISSUE PRIORITIZATION This document supports the activities of NUMARC and the issues Management Committee by identifying, reviewing and prioritizing issues for potential action by NUMARC.
The following issues were identified based upon information from the NUMARC Technical Subcommittee, the AIF Policy Committee on Nuclear Regulation, EPRI, utility NSSS Owners Groups, and contributing utilities. The issues were reviewed and separated into four categories:
NUMARC PRIORITY ISSUES:
Issues that have major (potential) impact and are of high importance to the industry. Issem in this category are issues under active management by NUMARC and/or its working groeps and generally require the commitment of significant NUMARC and iidustry rescurc25 to achieve effective and timely issue resolution. Issues that involve a formal industry position or formal policy, as well as commitments made to the NRC, are generally in this category.
1 NUMARC MONITORED ISSUES: l Issues that involve potential future impact and are of importance to the industry as well as issues that are "emerging" and could become "priority" I l
issues. Issues in this category are issues that are being closely followed l by NUMARC and may include issues that have been resolved but full implemen-tation is not yet complete. Issues are managed by NUMARC or may involve NUMARC i monitoring of work performed by other organizations or groups.
O POTENTIAL OR DORMANT ISSUES:
Issues that are believed to be of some importance and have some future-potential impact on the' industry. Issues'in this category contain'a large number of open or unresolved issues identified by the NRC, ACRS, the industry or others and are tracked because of their future potential impact. Issues are not actively worked or monitored by NUMARC and may or may not be worked' by other' organizations or groups. No immediate future action by NUMARC is contemplated.
OTHER IMPORTANT ISSUES:
Other issues of high importance and of concern to the industry and/or the NRC that may have an impact on NUMARC activities in the future. Generally, issues in this category are under active management by other industry associa-tions or government organizations and NUMARC is following developments in close cooperation and coordination with the other industry associations.
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FCCLEAR M ANAGEMENT AND RESOURCES COUNCIL MlSSION STATEMENT PURPOSE the resolution of problems between funded independently through the NRC and the nuclear power contributions from Members and The Nuclear Managernent and industry by providing a unified, Participants.
Resources Council (NUMARC) effective avenue of communication The Chairman of NUlvv 1 ., a
. provides a unified nuclear power between the Commission and the member of the Nuclear Pows industry approach on generic industry. Oversight Committee (NPOC), which ssues and intera ts w th he N clear NUMARC works closely with other coordinates the activities of and Regulatory Commission (NRC), or industry groups, such as owners provides support for policy, othe, government agencies as groups, utility groups and special formulation by the nuclear industry appropriate, on those issues. Issue groups, to provide overall organizations which are represented NUMARC is responsible for industry coordination on generic on NPOC.
coordinating the combined efforts of regulatory and technicalissues.
utilities holding NRC operating NUMARC is responsible for licenses or construction permits for initiating' Industry self improvement ORGANIZATION nuclear power plants, and of other efforts when it finds them necessary Membership: NUMARC has two nuclear industry organizations that for the public health and safety, as categories of membership, as are NUMARC participants, in all well as for directing attention to and follows:
matters involving regulatory po!'cy acting on regulatory issues the NRC issues and on the regulatory aspects Members: This category is considers important. NUMARC comprised of utilities holding of operational and technical safety complements the activities of the issues affecting the nuclear power operating I! censes or construction institute of Nuclear Power permits for nuclear power plants industry, it is the basic objective of Operations (INPO) in furtherance of NUMARC to draw upon the nuclear from the NRC. Members are operational excellence and the represented through their power industry's knowledge. attainment by all nuclear utilities of operational and techmcal respective oppointees to 'he Board anindustry standard of acceptable of Directors, and an elected experience, and responsibility for the performance. In carrying out its l safe operation of nuclear power Executive Committee, as provided !
responsibilities, NUMARC draws in NUMARC's charter and by-laws.
plants to contribute to the upon the expertise and capabilities {
enhancement of nuclear power plant of Members, Participants and other a@ah Ms caMgoy 2 .
i safety and reliability and the industry organizations. com%sd of Wm d near i attainment of operatirinal excellence. steam supply systems, architect--
NUM ARC identifies, develops and engineering organizations involved NUMARC serves as the nuclear implements nuclear power industry power industry's principal in nuclear power plant design or initiatives designed to assure high construction, owners of interests mechanism for conveying industry levels of safety, reliability, and views, concerns, and policies in nuclear power plants other than economic ef ficiency in nuclear licensees, and such others as shall regarding industry-wide regulatory power plant operation, and provides be determined by NUMARC's issues to the NRC and other for exchange of information to help government agencies as appropriate. Board of Directors. Participants ;
assure continuing improvement in are represented through elected I in carrying out that responsibility, nuclear power plant operation.
NUMARC seeks to improve the membership to the Board of nuclear power ,ndustry i s NUMARC is responsible for Directors and the Executive monitoring the development of Committee, as provided in effectiveness in developing and analyzing information concerning ndustry codes and standards and NUMARC's charter and by laws.
genenc regulatory and technical issues and to improve the quality and constructive charscter of n and coordination of codes and GOVERNING BODIES contributions made by the industry standards development. NUMARC is governed by a Board to the evolution of regulatory NUMARC is independent of any of Directors and an Executive analyses and decisions. A principal other nuclear industry or electric Committee, with membership as objective of NUMARC is to enhance power industry organization. It is follows:
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I Board o/ Directors: Membership . authority to make policy and fiscal technical issues and will recommend consists of one representative from commitments for the member's utility proposed formal nuclear utility each Member utility. The on any issue before the Board that industry positions or policies on representative may be the has been announced and included major nuclear regulatory issues to Member's Chief Executive Oflicer, on a previously published agenda. the Executive Committee for its
- Chief Operating Offmer, or a Actions of the Board adopting consideration. Tho utility members senior executive responsible for formal nuclear utility industry of the Executive Committee shall nuclear operations. In addition, the positions or policies on major review such proposals and reier -
Board shall elect to merrbership regulatory issues shall require an those as are appropriate to the Board thereon six Participant affirmative vote of eighty percent of for adoption.
representatives having the the utility membership of the Board. Upon adoption by the Board of a
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equivalent level of executive Participant members of the Board formal nuclear utility industry responsibility as the utility and Executive Commitiee shall not po3; tion or policy on a major nuclear members of the Board.The vote on such positions or policies; regulatory issue, the Chairman of the President of NUMARC shall serve nor shall they vote on other issues Jxecutive Committee, the President, as an ex o//icio, non-voting primarily affecting nuclear utilities, or another person designated by the member of the Board. as such may be determined by the Executive Committee, shall be Executive Committee: utility members of the Executive empowered to present that position Membership consists of twelve Committee. or policy to the responsible .
utility members of the Board of President and Other O//icers government officials or to such other Directors, elected by the Board' The Board is responsible to elect a individuals or groups as may be and the six Participant members of President, who shall be the Chief appropriate.
the Board. Executive Committee Executive Officer of NUMARC and The President, or another membersh,p i is intended to include, shall report to the Board through the NUMARC representative designated as respects its utility members, a Executive Committee. Yne Doard by the President, may act as liaison mix of Chief Executive Officers' shall also have the authority to elect with the NRC or other government -
Chief Operating Officers, and an Executive Vice President, who agency to determined concerns or may be the Chief Operating Officer needs for action as relevant to the xe utive Terms f ce on the f NUMARC, a Secretary, and a mission of NUMARC.
Executive Committee for both Tmasumr (who may sme When a formal nuclear utility utility and Participant members #
shall be for three years, with industry position or policy acopted and such oth r ic members' terrns expiring on a posi presidents o s 'and officers as the Board a an s alsd h a staggered basis. The objective .in n agen y s d on shall deem necessary The President n the part of an individual utility or Executive Committee composition shall have the authority to hire, and - group of utilities, the Chairman of shall be an appropriate mix and shall supervise the activities of, a the Executive Comm,ttee, the rotation of membership.The i
. staH President, or another NUMARC President of NUMARC shall also be an ex o//icio, non-voting
, 88/.0(R s e representative designated by the budge tpproved by the Board. Executive Committee, shall make member of the Executive Committee. appropriate recommendations to the N utility or utilities involved.
The Board will elect its Chairman and Vice Chairman from among the NUMARC relies on the support When an issue requires action by utility Directors serving on the and involvement of its members and or cooperation from a Member, a Executive Committee. The Chairman Participants to help formulate Participant or another industry and Vice Chairman of the Board will nuclear power industry contributions organization, the President or, also serve as Chairman and Vice to the evolution of regulatory another NUMARC representative Chairman of the Executive analyses and decisions NUMARC designated by the President shall Committee. The Board may create will establish such advisory make appropriate recommendations special committees, other than the committees or working groups as to the senior officials thereof and Executive Committee, for specific necessary, comprised of shall coordinate actions taken in purposes deemed necessary; and the repmentatives of Members, response to the recommendations.
Executive Committee has the Participants or others, to assist it in This Mission Statement is intended authority to establish such other the achievement of its overall to provide a broad overview of committees as it deems necessary to objectives. NUMARC, consistent with its charter accomplish the mission of NUMARC. and by-laws. The charter and by-The President of NUMARC shall Each utility member of the Board, keep the Executive Committee laws of NUMARC should be teferred or designee acting on such informed of the status of ar,tions to to for specific details related to the member's behalf, shall have the full address generic regulatory and organization.
1776 i Str iet, NW Suite 300 Washington, DC 20006-2496 (202) 872-1280
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NUCLEAR MANAGEMENT AND RESOURCES COUNCIL /SSUB Update February 1988 FITNESS FOR DUTY Background In August 1986, NRC deferred rulemaking on Fitness for Duty (FFD) and issued a policy statement as guidance for the industry to develop its own FFD programs. The industry continued with its implementation of FFD programs using the EE! (Edison Electric Institute) guidelines and INPO's periodic evaluations underway since late 1984 Anticipating a decision by the Commissioners to continue with the policy statement or to go forward with the rulemaking, NUMARC briefed the Commission in December 19S7 on the status of industry FFD programs, including the preliminary results of an INPO survey. The Commission complimented the industry for meeting its FFD commitments in a timely, professional manner.
Actions resulting from the December wting include NUMARC establishing a Fitness for Duty Working Group, chaiied by Phil Clark, president of GPU Nuclear Corporation, and the NRC staff preparing a proposed Fitnces for Duty Rule for the Commissioners' review by March 1.
The Working Group had its first meeting on January 14,1988. During this meeting, it was agreed that the group would address drug and alcohol issues as they relate to fitness for duty. Future actions of the group include identifying the elements needed for an effective program, developing responses to several questions identified and commenting on the applicability of the draft guidance, "Department oflicalth and liuman Services Guidelines for Federal Drug Testing Programs."
Speel//c The Working Group Chairman and NUMARC staff met with the NRC staff on Concerns January 20 to exchange information. The specific concerns highlighted included:
. Is a fitness for duty program effective enough without mandatory testing?
. Utilities should be uniform in deciding which drugs to test for and which cutoff levels are to be used; a llow can Employee Assistance Programs (EAPs) be effective (including maintaining confidentiality) yet ensure people unfit for duty don't stay on the job?
. What is the extent and quality of uti ny' contractor FFD programs?
. liow is information shared betwcN utilities on persons who have been discharged or refused employment because of drugs?
. What happens if someone fails pre-employment testing?
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. Is the NRC consistent with other federal regulatory agencies? j l
. Are the utilities performing self assessments that determine the actual effectiveness of their FFD program?
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l SUITE 300,1776 EYE STREET, N.W., WASHINGTON, DC 20006-2496 (202) 872-1280
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Questions It is our understanding that the NRC staff will have a proposed rule with options to
. To Be the Commissioners in early March of this year, in a staff requirements Answered memorandum to Victor Stello, Executive Director for Operations, the staff was directed that "To the extent appropriate, the proposed rule should not displace the t
good features of tne industry's efforts." Some of the major elements of the fi ness for duty issue that the Working Group must address are; ,
- 1. What constitutes an effective FFD program? .
2 What measures of effectiveness will be used to judge it?
3, Should the programs be standardized and include the handling of contmetors and NRC personnel? Should they include only persons with u.' escorted access or everyone in the industry?
- 4. Is random testing necessary for effective programs? If required by .
regulation, how will random testing be implemented? .What percent of the workforce will be tested each year?
- 5. For what substances (drugs and alcohol) will people be tested and what levels (for screening and confirmation) will be specified?
- 6. How can Employee Assistance Program (EAP) confidentiality be maintained and meet reporting standards?
- 7. .What criteria will be used: degree of impairment (as suggested by the 1973 Rehabilitation Act) or "zero tolerance" (as suggested by NRC Chairman Lando Zech)?
Contact:
Thomas E. Tipton e
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- - Lp L m L2 .m NUCLEAR MANAGEMENT AND RESOURCES COUNCIL /SSUB Update February 1988 THE DISCRETE RADIOACTIVE PARTICLES (DRP OR "HOT PARTICLE")
ISSUE Background The detection of exWmely small discrete radioactive particles (or "hot particles") on workers' clothing or skin at several nuclear power plants has resulted in a regulatory issue requiring cany resol : ion. Rese microscopic (30 to 70 microns) particles are insoluble fuel fragments and activation products. The "hot particle" issue is considered more a regulatory matter than a significant health issue because of the extremely conservative approach used by the NRC in evaluating radiation doses to exposed workers. No specific regulation or guidance exists for "hot particles."
Standard The NRC issued IE Information Notice No. 86-23, "Excessive Skin Exposures Due Needed to Contamination with Hot Particles" in April 1986. This notice stated that,"For purposes of showing compliance with 10 CFR 20,101(a), calculating a skin dose averaged over 1.0 cm2 at a depth of 7mg/cm2 is appropriate." This is a very conser.
vative calculation. INPO issued SER 18 87 Rev.2,"Radiation Exposure from Small Particles" in July 1987 NRC issued anotherinformation notice in August,1987.
On December 4,1987, NUMARC wrote to Thoinas Murley, Director of NRC's Office of Nuclear Reactor Regulation, urging him to resolve this 'ssue quickly -
cither by issuing a reasonable interim standard, or by implementing new regulations that would incorporate recommendations of the scientific committee studying the prob!cm. This committee, established by the National Council on Radiation Protecdon and Measurements (NCRP) at the request of the NRC staff, is to report its find.;ngs in the spring of 1988. Generally,incorporatin3 recommendations into regulations requires considerable time.
Murley responded, in his letter of December 22,1987, that th: NRC agrecs an interim standard is desirable. However, the NRC feels a "suitable basis for such a standard" is not available at this time.
The problem at nuclear powcr plants results from the ultra conservative guidelines now used by the NRC regional staff in evaluating compliance. The current approach results in unrealistically high dose assignments to some plant workers. In addition.
citations have been issued for not mair.taining control of radioactive material. An inter.m standard, approved by the NRC,is needed soon to apply more reasonable dose calculation methodology. As a result qf an EE! survey of 22 member utilides represenng 47 ";,its,it was noted that the industry sp:nt an average of 51.3 million per month for control of hot particles. The industry is also averaging an additional 20 person rem per month to implement programs for controlling worker exposure to hot particles.
EPRI has a major research project associated with DRP's. This includes problem identification and assesshg the magnitude of the skin dose problem as a function of particle size and the magniwde of the scaling fector proble'n as a function of quantity and frequency of DRP's in waste streams. EPR! has surveyed sixty one plants: seventeen reported no DRP's, eighteen reputed fuel DRP's and fony two reported activation DRP's. The BWRs suruyed have identified only activation DRP's, no fuel fragments.
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Follow <up In its letter to the NRC, NUMARC indicated that it was working with a skin :
contamination group of the EEI Health Physics Committee that is preparing a -
technical repon on principal industry concerns. It will include data on the costs -
utilities are incurring to ensure adequate health protection from."hot particles.". A' j letter will be sent to the NRC early in 1988.
NUbfARC
Contact:
Thomas E. Tipton f
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k k NUCLEAR MANAGEMENT AND RESOURCES COUNCIL /ssue Update February 1988 10CFR50.59 SAFETY EVALUATIONS Background Title 10 of the Code of Federal Regulations, Part 50.59, establishes the conditions under which a utility holding an operating license can make physical or procedural changes to its plant or conduct tests and experiments. This regulation gives the licensee the authority to make changes without prior Nuclear Regulatory Commission approval. Thus,10CFR50.59 limits the need for regulatory approval to unreviewed safety questions and technical specifications issues only.
C/arl//catlon Some of the language in 10CFR50.59 is brief and may be misinterpreted. Evidence Needed of differing opinions may be found by examining implementation procedures at individual utilities,INPO evaluation results and the findings of various NRC inspection teams.
A 10CFR50.59 guidance document has been drafted by an industry working group.
This document clarifies the language in 10CFR50.59 to assist utilities in developing adequate and consistent implementation programs.
There is considerable regulatory interest in this issue. It was identified as an issue in the NRC's Interim Policy Statement on Technical Specifications improvements it was also discussed in draft NUREG-1251,"Implications of the Accident at 4 Chernobyl for Safety Regulation of Commercial Nuclear Power Plants in the United i States." l The draft guidance document was sent out to the industry on November 12,1987.
Comments were due back by January 15,1988. The NRC staff has been involved in reviewing the draft document. There have been detailed comments on the draft. In addition, there have been suggestions as to the next step in the process. These suggestions will t>e evaluated with a determination on closure of the issue within the )
next month, i
Contact:
Thomas E. lipton j SUITE 300,1776 EYE STREET, N.W., WASHINGTON, DC 20006-2496 (202)872 1280
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NUCLEAR MANAGEMENT AND RESOURCES COUNCIL /SSUB Update i l
February 1988 l EROSION-CORROSION Bacl(ground On December 9,1986, an 18-inch diameter elbow in the condensate system at Virginia Power Company's Surry Unit 2 failed. The cause of failure: crosion-corrosion of the seamless A106 Grade B carbon steel pipe. Virginia Power and the Nuclear Regulatory Commission (NRC) conducted a failure analysis of the event.
That analysis found nothing about the Surry system design, materials or operating history to indicate that the single-phase erosion-corrosion was unique to the Surry plants.
NUMARC In March 1987, the NUMARC Technical Subcommittcc organized a Working Working Group: Group, chaired by Virginia Power's William Stewart, vice president of nuclear Seven Polnt operations, to develop an industry posidon on single phase erosion-corrosion. The Af/ssion Working Group's mission is to:
- 1) review industry plans for inspecting high-cricrgy single phase piping systems that may be susceptible to erosion-corrosion;
- 2) evaluate technical information from EPRI and others on criteria, extent and scheduling ofinspections;
- 3) identify parameters affecting crosion-corrosion in r$uclear power plant piping and their reladve importance;
- 4) provide screening criteria,inspecdon and acceptance guidelines, and possible remedies for near term concerns;
- 5) determine whether an industrywide program to n'onitor pipe vmil thinning is jusdfied technically;
- 6) consolidate and coordinate industry positions and plans to ensure that any potential generic concems are addressed; and
- 7) formulate actions and provide industry liaison with the NRC.
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To date items 1 through 5 have been completed.
To support NUMARC's Working Group, EP.RI developed the CHEC (Chexal Horowitz Erosion-Corrosion) code in spring 1987. The code is used to predict l
crosion-corrosion in single-phase carbon steel piping systems and aids idendfication i of the most susceptible locations. The code was mMe available in July 1987 to all utilities requesting a copy. A revision to the code was released in December. l l
The NUMARC Working Group has three recommendations:
- 1) conduct appropriate analysis and a limited but thorough baseline inspecdon program;
- 2) determine the extent of thinning, if any, and repair / replace components as necessary; and SUITE 300,1776 EYE STREET, N.W., WASH'NGTON, DC 20006 2496 (202) 872 1280
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- 3) perform follow up inspections to confirm or quantify thir.ning and take longer. >
term corrective actions (i.e., adjust chemistry, operat;og parameters or other.
variable;) as apprcpriate.- D In the months ahead, the NUMARC Working Group will consolidate industry -'
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positions and formulate a response to NRC concerns.
Contact:
William II. Rasin .
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$W l NUCLEAR MANAGEMENT AND RESOURCES COUNCIL /SSue Update February 1988 IDCOR Background in October 1980, the Nuclear Regulatory Commission published an Advance Notice of Proposed Rulemaking reporting that it intended to determine if nuclear power plants should be required to accommodate accidents beyond the design basis.
Specific consideration was to be given to features such as "core catchers," filtered vented containments, and whether such features should be required as backfits. In response, the nuclear industry created the Industry Degraded Core Rulemaking Program (IDCOR). Its mission:
. to assemble the best technical information available on degraded core accidents;
. to determine whether design changes to existing nuclear power plants were needed; and to participate in the rulemaking.
The IDCOR Stecting Committee was chaired by Cordell Reed, vice president of Commonwealth Edison Company.
IDCOR's membership consisted of most U.S. nuclear utilities, the U.S. reactor vendors, several A/E firms, and consortiums from five foreign countries. These members have contributed about $20 million toward a three-phase program:
implementing a technical program; e resolving cpen issues; and preparing to implement the severe accident policy statement.
IDCOR The IDCOR technical program demonstrated that the risk frcm severe accidents at Findings nuclear power plants is small. Costly design modificadem to acec,mmedate the effects of these accidents, therefore, are unnecessa:y C # search in this area supports similar conclusions. Based on these result ' ';!M' formally withdrew its Advance Notice of Proposed Rulemaking in 1985. In its pla,c, the agency publis!.J a Policy Statement on Severe Reactor Accidents. Tnis statement concludes that research has shown that existing nuclear poww plants pose no undue risk. It also notes that research has shown fxtors imponant to risk tend to be plant.
specific. Thus, a systematic evalaation of e'ach licensed U.S. plant would be required once discussions between che NRC and the industry defined the method.
Fourissues Technical agreement has been reached with the NRC on all but four issues:
Not Yet Resolved effect of direct containment heating;
. the amount of hydrogen generation expected in a severe accident;
. behavior of the core once "slumping" begins; and
. the ability of a BWR Mark I containment liner to survive contact with molten core debris.
SUITE 300.1776 EYE STREET, N.W., WASHINGTON, DC 20006 4496 (202) 872-1280
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Additional research into these issues continues. .
.The final phase of IDCOR prepared a methodology for conducting plant
- ar.;cssments. His Individual Plant Evaluation (IPE) methodology is based on probabilistic risk assessment txhniques. The IPE methodology has been reviewed .
by the NRC. Obtaining approval is IDCOR's final task. This approval is expected to be cart of a generic letter requiring all plants to conduct either an IPE or a -
Probabilistic Risk Assessment (PRA).'
Due to delays in the NRC's issuing of thh generic letter, NUbiARC is coordinating technical interactions with the NRC. The Steering Committee of industry ;
representatives, which has overseen IDCOR,is continuing in that role. The generic .
letteris expected to be issued soon.
NUhfARC
Contact:
William H.Rasin
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NUCLEAR MANAGEMENT AND RESOURCES COUNCIL /SSUO Update February 1988 STATION BLACKOUT Background Station blackout is a total loss of ac power caused by concurrent failure of offsite and onsite sources. Current regulatory requirements do r ot specify that nuclear power plants be designed to accommodate a station blackout. They assume that at least one of the redundant emergency power sources will be available. Nevertheless, risk assessment evaluations of several nuclear power plants show that station blackout can be a significant contributor to the risk of core damage. Accordingly, the NRC designated station blackout as Unresolved Safety Issue A-44.
The NRC published a proposed rule on station blackout in h1 arch 1986. In reviewing the proposed rule, NUh! ARC's Station Blackout Working Group, chaired by John Opeka, executive vice president of Northeast Udlities, formulated four initiatives to address the station blackout risk. These were approved by the NUh1 ARC Executive Group in June 1986 and reported to the NRC along with comments on the proposed rule. The Working Group believed that implementing these initiatives would make the proposed rule unnecessary.
ACRS The NRC staff evaluated all public comments and prepared a final rule for Supports Commission approval. The NUhiARC Working Group and the Nuclear Utility ,
NUAfARC Group on Station Blackout (NUGSBO), which provided technical support, !
Approach continued to work with the staff to explain the NUhiAI(C approach and why the i proposed analytical requirement was unnecessary. The NRC's Advisory Committee on Reactor Safeguards (ACRS) commended NUh1 ARC on its work. With one l exception, the ACRS found the NUh1 ARC initiatives an acceptable solution that l may be preferable to rulemaking. They encouraged the NRC staff to condnue I working with NUh1 ARC.
The ACRS' one reservation was the lack of an evaluation of a nuclear power plant's ability to cope with a station blackouL De NUh1 ARC init:atives concenuated .
instead on plant improv:ments to prev:nt th: event. The NRC proposed rutc l included a requirement for a coping analysis, but its scope was not well defined. l The Working Group developed a methodology for evaluating coping capability to l clearly define the bounds of this analysis. In October 1987, the NUh1 ARC Board of Directors approved this station blackout initiative.
NUAfARC The implementation guidelines associated with NUh1 ARC's initiauves have been l Guldellnes compiled into a single document, designateii NUh1 ARC 87-00, "Guidelines and i' Technical Bases for NUNIARC Initiatives Addressing Station Blackout at Light Water Reactors." This document has been published and distributed to all NUbiARC members. A draft has been discussed with the NRC staff, who agree that its provisions are adequate. The NRC staff still intends to present a final rule to the Commissioners, but told the ACRS in November that the accompanying regulatory guide will indicate that implementing NUh1 ARC 87-00 is sufficient to demonstrate compliar.cc with the rule.
SUITE 300,1776 EYE STREET, N.W., WASHINGTON, DC 20006-2496 (202) 872-1280
o The NRC's rule is expected to be acted on by the Commissioners in early 1988.
Industry workshops, sponsored by NUMARC, will be held shortly thereafter on implementing SUMARC 87-00.
Contact:
\\'illiam H. Rasin l
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4 g_dgO NUCLEAR MANAGEMENT AND RESOURCES COUNCIL /SSUO Update .
February 1988 CONTAINMENT INTEGRITY Background In June 1986, the NRC staff proposed that boiling water reactors with Mark I containments be modified to incorporate features to reduce the consequences of accidents in which the core melts and the reactor pressure vessel fails.
The NRC informally requested that Mark I owners voluntarily commit to installing four hardware changes and to implementing the latest version of the BWR Owners Group Emergency Procedures Guidelines (EPGs). The NRC staff indicated that a generic letter would be prepared imposing these requirements if they were not adopted voluntarily. The staff stated that the need for the proposed cht.nges was great enough that they should be installed before conducting the individual plant evaluations called for by the Severe Accident Policy Statement.
The Intustry Degraded Core Rulemaking Program (IDCOR), at the request of the BWR Owners Group, performed a quick cost benefit assessment of the suggested design changes. 'Ihis review showed no design change was justified. The Owners Group started a more extensive technical evaluation of the risks posed by Mark Is and of the costs and benefits of the proposed fixes. He BWR Owners Group also asked NUMARC to address the policy implications.
Work With A NUMARC Working Group, chaired by Vincent Boyer, consultant to Philadelphia BWR Electric Company, was formed to keep close contact with technical evaluations of Owners the BWR Owners Group and to use its conclusions to determine whether there was a technical need for any changes. No technical assessment of other containment types was initiated, since the NRC and the industry generally agreed that the BWR Mark I would be considered under severe accident conditions. If the BWR Owners Group assessment confirmed the resu!Ls of earlier industry work showing the Mark I posed no undue risk, then evaluations of other containment types would not be needed before individual plant evaluations could be performed.
The Working Group reviewed the results of both the Owners Group work and an l EPRI peer review. It concluded that the risk with Mark I containments was low, that the cost of changes proposed by the NRC outweighed the benefits, and that there were no othet obvious weaknesses that appeared to require a generic fix.
Plant specific features are still considered important to understanding risk, as demonstrated by a study of the Peach Bottom plant. Therefore, the NUMARC Working Group concluded that containment performance should be assessed for each plant as part of its individual plant evaluation. No changes are needed to accommodate severc accident conditions until individual plant evaluations are performed. The Working Group prepared a position paper documenting these conclusions that has been transmitted to the NRC.
Having successfully completed its mission, the work of the Containment Integrity Working Group is now complete.
Contact:
William H. Rasin SUITE 300,1776 EYE STREET, N.W., WASHINGTON, DC 20006-2496 (202) 872-1280 1
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h NUCLEAR MANAGEMENT AND RESOURCES COUNCIL IS8ue UP date February 1988 OPERATOR REQUALIFICATION Background On September 10,1987, the NRC held a public meeting to give industry representatives an opportunity to discuss various aspects of the NRC operator requalification examinations. Based on the industry's input and the NRC's internal review, the NRC decided to suspend its renualification examinations pending further analysis. This decision was conveyed in an NRC letter of September 18,1987, to all power reactor licensees.
In a follow-up public meeting held November 23,1987, the NRC announced major changes to its original program. These changes will be phased in and evaluated in pilot programs. Phase I of the new program staned at Carolina Power and Light Company's H. L. Robinson plant in December. Phase II will begin in February 1988 with participation by one plant from each NRC region. Phase 111, resumption of a full. scale operator requalification program,is scheduled to begin October 1988.
Requall// cation Many of the major issues discussed in the September 10 public meeting have been Procedures addressed. For example, the operators to be examined will be identified by plant management after the utility provides a list of names to the NRC. Thirty days before the examinadon, the NRC will confirm the list of operators to be examined or make any changes. Shift crews that operate as a team will be examined on the simulator.
This evaluation will primarily emphasize the team rather than the individual.
The utility will name an individual from operations and training to work with the NRC staff in developing the examination. Finally, an open book format will be used for the written portion of the exam. The NRC insis:ed that each plant being examined should have a good examination question bank and simulator scenarios available w hen the revised examination program is in place.
NUMARC has formed an Operator Issues Working Group, chaired by Don Schnell, vice president of Union Electric Company, to provide an industry perspective on the issue.
The Working Group held its first meeting on December 16,1987. It was decided to )
focus its activities iaitially on the Operator Requalification issue. The group was l briefed on the INPO initiative to improve operator professionalism. Several issues ;
were identified that need to be addresed, including:
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. What is expected of the operator in terms of his knowledge outside the control room?
. In developing the simulator scenarios, questions and written exams,is it explicitly stated that the preparcrs are bounded within the design basis of the plant?
. How is consistency assured from region to region?
. What is the guidance for preparing open book exam questions and simulator scenarios?
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SUITE 300,1776 EYE S TREET, N.W., WASHINGTON, DC 20006 2496 (202) 872-1280
e The Working Group met with representatives from Carolina Power & Light
' Company on January 26,1988 to discuss the Phase I pilot exam given at 11. B.
Robinson. They felt that the new process of developing and giving the exams was a major improvement. Some of the rewarding aspects identified were that:
- The opportunity to work closely with the NRC examiners proved to be very beneficial;
- The opportunity to enhance simulator evaluation skills was extremely helpful;
. Assisting in preparation of an operations oriented examination was very satisfying; and
. Deleting the requirements for reactor theory and thermodynamics resulted in an examination that is a better indication of operating skills instead of theoretical knowledge.
The Working Group met with the NRC the afternoon of January 26. The NRC n'oted during the meeting that some of the advantages of the new process included the fact that it (1) was compadolc with the INPO Accreditation,(2) provides a less adver-sarial format and (3) strengthens the examiner's credibility and improves his knowledge of the plant.
Two disadvantages identified included the fact that it was a more resource intensive process and had high start-up cost associated with it.-
The plants identified to participate in Phase li are Salem (Region 1), Fort Calhoun (Region IV), San Onofre (Region V). NRC has not yet identified the Region III plant. Since all of the plants identified were PWRs,it was suggested that the Region ;
III plant be a BWR.
A representative group of the Working Graup met on February 2,1988 to develop an overall program plan.
NUh! ARC
Contact:
Thomas E lipton 9
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NUCLEAR MAN GEMENT AND RESOURCES COUNCIL /SSUB Update February 1988 TECHNICAL SPECIFICATIONS IMPROVEMENTS Background Each N5SS Owners Group has begun a major effort to create improved technical specifications that can be implemented efficiently on a plant specific basis. The NUMARC Working Group, chaired by Murray Edelman, vice president of Centerior Energy Corporation, will identify and resolve geceric issues involving creation of restructured technical specifications. Each Owners Group plans to create a topical report containing restructured technical specificadons, with improvements over the present standard technical specifications. Dese topi; ; reports will be developed consistently with the NRC Interim Policy on Technica' Specifications Improvements.
All four Owners Groups have submitted their technical specificatiens split documents to 10 NRC. NUMARC has asted the NRC to complete its review by February 1988. Dere is a three-day meeting stardng February 9,1988, w 'th the staff to review the staffs posidons on the requests.
Remain /ng In addition to the magnitude of the t xhnical specifications, there are identified Problems improvements with the organization of technical specificadow:,incluJing format and presentadon ofinformadon. A Human Factors Improvemots tiport and a Writers Guide are being developed for use by the four NSSS Owner Groups in developing topical reports contaming restructured standard technical specifications. l Drafts of these documents have been submitted to the four Owners Groups and the I NRC staff for resicw and comment.
Key issues in implementing the program were transmitted to the NRC in a November 10,1987, letter for its formal review and approval. The issues have been structured to facilitate plant specific implementation while ensuring that the !
applicab!c regulatory requirements are satisfled. In Romas Murley's (Director of i NRC's Office of Nuclear Reactor Regulation) letter of January 22,1988, respondmg ,
to our request, he noted that "for the most part, we are in agreement with the l approach outlined in your letter." They have, however, proposed some at tematives that they feel will improve the process. Further discussion on these alternatives will I be held soon.
l After securing NRC agreement on these documents, the Owners Groups will l develop topical reports with model standard technical specifications and improved bases.
Contact:
Thomas E. Tipton SUITE 300,1776 EYE STREET, N.W., WASHINGTON, DC 20006 2496 (202) 872-1280
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NUCLEAfUIANAGEMENT AND RESOURCES COUNCIL /SSUB Update l February 1988 CHERNOBYL Background NUMARC commented by letter on November 3,1987, on d aft NUREG 1251,
' implications of the AcciJent at Chernobyl for Safety Regulation of Commercial Nuclear Power Plants in the United States." Its major conclusions agree closely with those reached by the industry and recommended that ongoing programs and studies should be sensitized and sometimes modified to account for Chernobyl implications. In most cases, new independent studies of these areas would not be productive or beneficial.
Four Four significant issues were singled out in NUMARC's letter:
Major Issues . NUM ARC snd NS AC (Nuclear Safety Analysis Center) has e jointly developed draft guidelines for conducting 10CFR50.59 re.iews and submitted them to NUMARC members and participants fer resiew and comment.
If the NRC plans additional action requiring a high level, on site nuclear safety manager, NUMARC wvuld like the opportunity to discuss this further with the staff. Safe operation is the responsibility of everyone st the plant. Considering the programs already in place to monitor and support safe plant operation, an additional level of management is not needed to imp, rove safety.
- NUMARC will coordinate the generic aspects of issues on rextivity accidents and accidents at low and zero power.
Regarding containment integrity, results to date show no overriding generic vulnerabilities. Rather, they support the need to perform individual plant evaluations called for by the Severe Accident Policy Statement.
Since the initiatives required in the future will be pursued by existing industry erganizations and programs, the work of the Industry Technical Review Group on Chernobyl has been completed.
The In September, NUMARC issued a final revision ofits technical summary report on Reindeer the controversy over reind:cr owned by the Swedish Laplanders that were Controversy contaminated by radioactive fallout from the Chemobyl accident. 'This repon describes the problem that existed, tne actio,ns by the Swedish authorities, and a risk estimate that indicates the relative insignificance of the problem from a health standpoint. Information on similar experiences in Alaska during the Soviet weapons testing in the early 1960s is included for comparison.
NUM:aC
Contact:
Thomas E. Tipton SUITE 300,1776 EYE STREET, N.W., WASHINGTON, DC 20006 2496 (202) 872-1280
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NUCLEAR MANAGEMENT AND RESOURCES COUNCIL /SSU6 Update February 1988 STANDARDIZATION AND LICENSING REFORM Background The industry continues to shape und promote licensing teforms to enable standardization of new commercial nuclear power plants. The overall goal is to reinstate nucicar power as an option for meeting future electric demand.
Richard Priory, vice president, design et,Si ncering of Duke Power Company, and chairman of the NUMARC Standardization Oversight Working Group, testified on May 7,1987, before Congressman Philip Sharp's (D-IN) Subcommittee on Energy and Power on the industry's program on standardization. On November 13,1987, he sent a letter to Sham stressing the need for Congressional action on standardization and licensing refona.
NRC On October 20,1987, the NRC held a workshop on standardization to discuss the Workshop NRC's Nuclear Power Plant Standardization Policy Statement issued September 15, 1987. NUMARC's Standardization Oversight Working Group participated for the industry and formally conveyed its comments on the NRC policy statement in a November 10,1987, letter.
Activities Byron Lee, president of NUMARC, testified on November 10 before the Sharp in Subcommittee and responded to questions conceming standardization. NUMARC Congress sent a follow-up letter dated November 25,1987. It included the November 1986 study, "Standardization of Nuclear Power Plants in the U.S," w hich continues to serve as the industry's reference point for statements on standardization and I
tnderscores the need for regulatory and legislative action if standardization is to bwcr. a reality. 'Ihat same day, Lee sent the NUMARC Board of Directors his letter to the subcommittee and a copy of Congressmu William Dannemeyer's (R-CA) October 28,1987, letter to Virginia Power Company CEO William Berry, w hich urged Berry and the nuclear industry to push now for Congressional action on standardization and licensing reform. Lee's letter to the Board noted that ANEC is tur,ing utilities to contact Sharp and members of the energy subcommittee to take action.
In concert with ANEC, NUMARC continues to provide support in 1988 for standardiration and lice esing *eform, both administrative and legislative.
Contact:
Robert A.Sralay SUITE 300,1776 EYE STREET, N.W., WASHINGTON, DC 20006-2496 (202)872-1280
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NUCLEAR MANAGEMENT AND RESOURCES COUNCIL /SSUB Update February 1988 LEG AL ISSUES NUMARC As part of the restructuring and realignment of the nuclear industry's organizations, lawyers the Response and Implementation Committee of the Nuclear Power Oversight Committee Committee (NPOC) concluded that the AIF Lawyers Committee should be reconstituted and the responsibility for Lawyers Committee acdviues assigned to NUMARC because the primary focus of tne Lawyers Committee has been and is anticipated to be on regulatory issues.
The Charter of the reconstituted Lawyers Committee has been approved by NPOC and by the NUMARC Executive Committee for implementation. The major purpose of the lawyers Committee is to provide legal support and advice to NUMARC and the other industry organizations established under the auspices of NPOC and to assist those organizations in a coordinated effort to identify, evaluate and resolve issues facing the nuclear power industry.
Each member of NUMARC and each NPOC industry organization may designate a representative to the Lawyers Committee. A Stecting Committee, comprised of five to seven lawyers with experience in legal matters affecting the nuclear industry, will be selected by NUMARC's c!,ief executive officer. It will act as the functional operat:ng group of the IAwvets Committee to provide an ongoing legal perspective to NPOC organizations. 'I he Stecting Committee will be responsible for establishing task forces to focus on specific topics. Stecring Committec members will be chosen to provide broad representation of the nuclear industry and will include both inside and outside counsel experienced in representing the interests of NUMARC companics.
Public CIIIzen NUMARC has intervened in support of the NRC in a challenge to the NRC's Et Al v. U.S. decision to deny a Petition for Rulemaking filed by Public Citizen and Critical Mass Nuclear Energy Project. Public Citizen had requested that the NRC adopt specific Regulatory regulations setting forth detailed requirements for training and qualification of Commission nuclear power plant personnel in accordance with the statutory mandate of Sec. 306 of the Nuclear Waste Policy Act of 1981. Their lawsuit challenged the NRC's decision to comply with Sec. 306 by publishing a policy ctatement on training and j qualification of nuclear power plant personnel rather than by issuing prescriptive regulations. Oral arguments on this case were heard in the U.S. Court of Appeals for the District of Colambia Circuit on November 19,1987. Based on past experience, a decision should be announced in about six months. j Emergency The Attorney General for the Commonwealth of Massachusetts, the Union of j Planning Concemed Scientists, Suffolk County, New York, and others have appealed the l NRC's Emergency Planning Rule. The rule provides criteria for the evaluation of a l utility's emergency evacuation plan in situations where state and/or local govemments refuse to participate in the emergency planning process for the areas surrounding nuclear power plants. Because of this rule's importance to the nuclear industry, NUMARC and eel intervened in support of the rule. The motions to intervene were filed jointly by NUMARC and eel on December 24,1987. In SUITE 300,1776 EYE STREET, N.W., WASHINGTON, DC 20006-2496 (202)872 1280
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' accordance with the Rules of Federal Civil Procedure, the suits will be transferred - *
- automatically to the First Circuit, where the lawsuit was first filed. Public Senice Company of New Hampshire and Long Island Lighting Company have also intervened in this proceeding. Oral arguments in this case are expected to take place '
in early summer.
NUMARCContact: Roben W. Bishop A
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, A NUCLEAR MANAGEMENT AND RESOURCES COUNCIL /SSue Update February 1988 NATIONAL ENVIRONMENTAL STUDIES PROJECT (NESP)
NUMARC/NESP has nine studies in progress. They are in varicus stages of completion.
A n A utomated Procedurefor Estimating Collective Dose in Nuclear Facilities (in press as NUAfARCINESP-001)
This study will provide a user friendly software pack ge to implement the general procedure for esumating collective dose recommende' 'n NESP-039. By using this progran, plant health physicists can factor dose estimates a carly w hen planning or designing work.
A Technical Basisfor Afetting the 11'aste Form Stability Requirements of 10CFR61 (In press as NUAfARCINESP-002)
This study will recommend technical bases for establishing realistic sampling and testing requirements for waste form stability; present guidance on the steps required to comply with 10CFR61; provide alternative proposals to demonstiate licensee compliance with the intent of 10CFR61, and provide information that may help NRC pru.%cc a mm casonable regulwary guide for waste form Bat will still ensure protection of public health and safety.
Guidclin es for Radiolog! cal Record Keeping (Second draft undtr review by Task Force)
This study will provide the nuclear po. ;r industry with recommendadons for improving its radiological record keeping and practices, pardeularly of occup-donal evposure for use in tort litigation and worker compensation cases. This study will also evaluate the current recording of radiation exposure praedces as a supplementary dau base fer future epidemiological studies.
Benefits of a Graded Response to Nuclear Power Plant Emergencies (Final report being prepared by Task Force)
Th.s study will provide a technical basis for graded response and how it could benefit emergency planning in the U.S. It will outline pro .dures for implementing a graded response, including a description of regulatory considerations.
I SUITE 300,1776 EYE STR7ET, N.W., WASHINGTON, DC 20006-2496 (202) 872 1280 l
V Analysis of Dose Afodelsfor Accidextal Airborne Rsdioactive Releases (First draft offinal report being prepared by contractor)
This study will evaluate and explain the difference among the van >us dose calculation models available for use at nuclear power plants; point out which input variables are most significant in vary"g the output; and, provide a methodolcgy for comparing dose models to be used in a particular application.
A Data Base on Referant Energency Evacuation Experience in the U.S.
(20% complete):
This study will produce a document examining a cross-section of evacuations and the common elements among them; make available information supporting the feasibility of evacuation where there were spenfic plans for particular accidents or natural disastet s; relate evacuaticns to the current emergency preparedness at U.S. nuclear power plants; and devdop recommendations for using the information gained to improve evacuation upabilities for any purpose, but particularly for the nuclear power industry.
Guidelinesfor Obtaining Regulatory Approval to Disc.ose of Afixed Wastes (Proposals under review by Task Force)
This study will examine generating, managing and disposing of m;xed wastes.
Specifically,it will evaluate the impact of exi . ting regulat ons and guidance on these practices. It will also serv as a source af information for generators and regulators in establishing a soun I mixed was e program.
A Re evaluarian ofEmergency Acrion Ler is (Work scope under re.% by To>k Force}
This study will re-examine emergency achon levels (EALs); propose methodologies to bring them in line wi'h BWR and PWR prating conditions; and evaluate the views of utilities, the NRC, and state emergency phnners on improving EALs.
An Evaluation of Current Beta Dosimetry (Approvedforlunding in FY87/83)
This study will dhess the depth at which absorbed dose is determined and the average area exposed when irradiation is non. uniform; review existing instruments and methods for charxterizing beta fields and sources of contamination during maintenance; evaluate measurement techni.;ues ord dosimetrv problems of contact radiation; and compare cur ant research on the biological effects of sLin exposure.
NUbfARC
Contact:
Thomas E. Tipton
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