ML20214H836
| ML20214H836 | |
| Person / Time | |
|---|---|
| Issue date: | 11/20/1986 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8612010056 | |
| Download: ML20214H836 (70) | |
Text
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DR!GINAL !
( UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of:
COMMISSION MEETING Periodic Meeting with NUMARC (Public Meeting)
Docket No.
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3 Location: Washington, D. C.
Date: Thursday, November 20, 1986 Pages: 1 _ gg
- -- ANN RILEY & ASSOCIATES
, Court Reporters
\- 1625 I St., N.W.
Suite 921 8612010056 861124 Washington, D.C. 20006 PDR 10CFR (202) 293-3950 PT9.7 PDR .
,4-4 1 D i SC L A I MER 2
3 4
5 6 This is an unofficial transcript of a meeting of the 7 United States Nuclear Regu l a t ory Ccene i s s i on held on s 11/20/86 . In the Commission's office at 1717 H Street, 9 N.W., Washington, D.C. The meeting was open to public 10 attendance and observation. This transcript has not been 11 reviewed, corrected, or edited, and it may contain
(, 12 inaccuracies.
IS The transcript is intended solely for general 14 informational purposes. As provided by 10 CFR 9.105, it is 15 not part of the formal or informal record of decision of the 16 matters discussed. Expressions of opinion in this transcript l 17 do not necessarily reflect final determination or beliefs. No i
18 pleading or other paper may be filed with the Commission in 19 any proceeding as the result of or addressed to any statement 20 or argument contained herein, except as the Commission may 21 authorize.
22 23 24 25
/ .
s 1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION -
3 ***
4 PERIODIC MEETING WITH NUMARC 5 ***
6 [PUBLIC MEETING) 7 ***
8 Nuclear Regulatory Commission 9 Room 1130 10 1717 H Street, Northwest 11 Washington, D.C.
12 13 Thursday, November 20, 1986 14 15 The Commission met in open session, pursuant to 16 notice, at 2:04 p.m., the Honorable LANDO W. ZECH, JR.,
17 Chairman of the Commission, presiding.
18 COMMISSIONERS PRESENT:
19 LANDO W. ZECH, JR., Chairman of the Commission 20 THOMAS M. ROBERTS, Member of the Commission 21 JAMES K. ASSELSTINE, Member of the Commission 22 FREDERICK M. BERNTHAL, Member of the Commission 23 KENNETH M. CARR, Member of the Commission 24 STAFF AND PRESENTERS SEATED AT THE COMMISSION TABLE:
25 WILLIAM C. PARLER
f
. 2 1 JOHN HOYLE 2 JAMES MILLER 3 WARREN OWEN 4 JOHN FERGUSON 5 BRUCE KENYON 6 AUDIENCE SPEAKERS:
7 WILLIAM CONWAY 8 VINCENT BOYER 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
, 3 1 PROCEEDINGS
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.2 CHAIRMAN ZECH: Good afternoon, ladies and , - -
3 gentlemen. The purpose of today's meeting is for the !
e 4 Commission to receive a periodic status report on issues being 5 addressed by the Nuclear Utility Management Resource Committee '
6 known as NUMARC. Today's meeting is a discussion nd a 7 briefing for the Commission and no votes are anticipated -
8 today.
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9 I understand that NUMARC will address a number of 10 areas of interest; training, fitness for duty, maintenance, 11 operator requalification, access authorization, station ,
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12 blackout, and containment issues. Mr. Miller informs me that 13 Bruce Kenyon will go on first to talk about access 14 authorization because he has another commitment and we'll .
15 certainly be happy to accommodate that.
16 Perhaps it would be well to hear your thoughts, at 17 least briefly on a recent memo we received from the Executive 18 Director for Operations discussing the actions to improve 19 effectiveness of initial start-up programs.
20 MR. MILLER: Yes, sir, I have discussed that memo 21 with Zach Fate who heads INPO. And Mr. Conway is with us 22 today and he will address that subject. ,
23 CHAIRMAN ZECH: Fine, good. It might be interesting 24 for us if you've had a chance to think at all about what we've 25 just learned would be the new realignment of organizations in
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'l 1 the utilities and industry, the UNPOC effort. If you can talk 2 a little bit about that I think it would be of great interest 3 to all of us.
4 MR. MILLER: It is on our agenda to discuss.
5 Mr. Owen will discuss that.
6 CHAIRMAN ZECH: All right, fine, thank you. We have 7 Region IV listening in on us today. Do any of my fellow 8 Commissioners have any opening comments?
9 COMMISSIONER ASSELSTINE: No.
10 CHAIRMAN ZECH: All right then, Mr. Miller, if 11 you'll proceed, please.
c.
12 MR. MILLER: Thank you very much. I'm Jim Miller, 13 president of Georgia Power Company and chairman of the NUMARC 14 steering committee, and we thank you for letting us appear 15 before you today.
16 NUMARC was founded March of 1984, and in our first 17 meeting with you we committed to brief you from time to time 18 on the activities of NUMARC and the results we see from our 19 programs. And this is the seventh time we've appeared before 20 you.
21 With me today are Warren Owen, executive vice l 22 president of Duke Power, vice chairman of the NUMARC steering 23 committee; Bruce Kenyon, senior vice president, Pennsylvania 24 Power & Light, chairman of the NUMARC working group on access 25 authorization; and Jack Ferguson, president of Virginia Power
f
, 5 1 and chairman of the NUMARC technical subcommittee.
2 In addition to these gentlemen at the table we have 3 other NUMARC executives present and at this time I'll ask them 4 to please stand. Would you please stand, gentlemen?
5 [ Audience participants stood.)
6 CHAIRMAN ZECH: Welcome.
7 COMMISSIONER BERNTHAL: It looks like we're missing 8 a couple today.
9 MR. MILLER: No, sir, I don't think so. I hope 10 not. One of them tried to get away and we caught him at the 11 door.
12 (Laughter.)
13 CHAIRMAN ZECH: All right, fine.
14 MR. MILLER: In addition, as I mentioned, Bill 15 Conway who is group vice president of INPO is with us today 16 and will be prepared to discuss that other matter, i 17 In today's presentation, Bruce Kenyon is going to 18 start by addressing the status of access authorization. And 19 if you have any questions on that we'd appreciate it if we 20 could go ahead and address them because Bruce has a conflict.
21 After that, Warren is going to briefly discuss our 22 efforts in training, fitness for duty, operator requal, check 23 operator, and maintenance. Warren is going to address i
24 maintenance because C.O. Woody had an unavoidable conflict and i 25 could not make it.
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- o. 6 1 Jack Ferguson is going to discuss the activities of 2 the NUMARC technical subcommittee concentrating on station 3 blackout, containment integrity, and other issues. And then 4 Bill Conway will discuss actions related to improving start-up 5 and initial operation of nuclear plants.
6 Warren will then close -- will then present the 7 discussion on the future of NUMARC and the new organization.
8 And then I'll close.
9 I'm pleased to report to you that though we set our 10 sights high 32 months ago when we first set up NUMARC, the 11 commitments that should have been made by today have been 12 carried. And they're reported to us by the utilities as being 13 complete. In each major area all the utilities have reported 14 their status on the individual items as complete, with the 15 exception of a few plants that are not yet in commerci'al 16 ' operation. Except for our commitment related to the 17 accreditation of training programs, our action items did not 18 address plants that were not yet commercial.
l 19 With these few exceptions all industry companies 20 report they have met all of the commitments made to the NRC '
I I
j 21 through NUMARC; 59 individual commitments within the 10 major 22 areas -- an impressive accomplishment. And I'm providing to '
23 yo1 otr action plan, which lists the commitments we made and 24 the status of each, and that is provided to you and also will 25 be provided at the rear of the auditorium.
r e
. 7 1 Bruce, will you go ahead, please?
2 MR. KENYON: Yes, I will, thank you. The purpose of 3 my presentation is to provide an update on the status of 4 NUMARC's effort with respect to access authorization. For 5 purpcses of background, I want to go back only as far as 6 NUMARC's meeting with the Commissioners that took place,on 7 March 20th, 1985. One outcome of which was that NUMARC formed 8 a working group to take an overall look at the area of 9 security, and I have served as chairman of that working group.
10 The immediate issue was access authorization, in 11 that the insider rule package was nearing the completion of 12 the rulemaking process. A review by this working group 13 identified a number of substantial concerns with respect to 14 various aspects of the rule, particularly as it would have to 15 be implemented in accordance with the provisions of the 16 proposed regulatory guide.
17 During June and July of last year this NUMARC 18 working group met with personnel from the Division of 19 Safeguards in a series of very candid meetings. The Staff 20 discussed reasons for and the security value of the various 21 proposed rule requirements. We in turn discussed those 22 proposed rule and implementing regulatory guide provisions 23 that we believed were particularly impractical or difficult to 24 implement, and which, again in our opinion, were not justified 25 by our perception of the security value.
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' 8 1 Both groups worked sincerely to agree on those 2 elements of an access authorization program, which would not 3 only provide the essential security features, but also could 4 be reasonably implemented by the industry. The result of that 5 effort was a NUMARC document entitled Industry Guidelines for 6 Nuclear Power Plant Access Authorization Programs. On August 7 28th of last year the NUMARC executive group endorsed revision 8 7 of these guidelines. And on September 5th, we forwarded 9 those to Bill Dircks.
10 On June 18th of this year you approved the issuance 11 of a policy statement which would endorse NUMARC's guidelines 12 on access authorization in lieu of the rule. And then on June 13 25th you issued a requirements letter. This directed the 14 Staff in cooperation with NUMARC to address two items.
15 The first was to develop a policy statement for your 16 approval endorsing the NUMARC guidelines. And the second was 17 to recognize the NRC position that an appeal procedure is an 18 important element of this process.
19 Now a separate but relevant event occurred on August 20 27th. This was the signing of the omnibus Diplomatic Security l 21 and Anti-tcrrorism Act of 1986, which among other provisions i
22 requires all individuals permitted unescorted access or access l
23 to safeguards information to undergo an FBI criminal history 24 check based on submitted fingerprints.
25 So as a consequence of your requirements letter and I
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9 1 the fingerprint legislation, the NUMARC working group met with 2 the Staff on several occasions in September with the following 3 agreed to results. The first is that a requirement to submit 4 fingerprints in conjunction with the granting of a temporary 5 clearance was added to the guideline. And the second is, a 6 review process for any employee whose employment has been or 7 will be terminated as a direct result of access authorization 8 revocation or denial has been added to the guidelines.
9 These changes have been agreed to by the Staff.
10 They were incorporated into revision 8 of the guidelines, and 11 they were approved by the NUMARC executive group on October 12 29th. Now this approval means that following your approval of 13 a policy statement endorsing these guidelines, all licensees 14 are committed to amend their security plans such that the 15 revised plans will meet or exceed all elements of the 16 guidelines.
17 By amending our security plans the access 18 authorization elements become subject to inspection and 19 enforcement by the NRC, as are the other elements of our 20 security plans. Consequently, we believe that the previously 21 mentioned issues have been satisfactorily addressed. We urge 22 the Commission to approve the policy statement which has been 23 drafted to endorse these guidelines.
24 And in closing my remarks, I'd like to state that I 25 think there have been two important results from what has
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,. 10 1 transpired. The first is that through interactions with the 2 Staff have established a superior approach to access 3 s authorization. Superior because it contains the security 4 features which are essential to a good access authorization 5 program. These have been agreed to by the Staff. And 6 superior because it represents an approach which can be 7 implemented much more readily by the industry.
8 The second result is that the process we went 9 through, in our opinion, is an excellent demonstration of how 10 NUMARC and the industry can and should interact to develop 11 necessary and appropriate solutions to issues. At this point 12 I'd be happy to address any questions you may have.
13 CHAIRMAN ZECH: Thank you very much. Any questions 14 from my fellow Commissioners? Commissioner Roberts?
15 Commissioner Asselstine?
l 16 COMMISSIONER ASSELSTINE: I guess the only question 17 I would ask at this point, the development process, I take it, 18 in this case is pretty typical of the NUMARC efforts; is that 1:e right?
20 MR. KENYON: Typical in a general sense. I think 21 the one thing that was different about this process is that 1
22 the working group got into the issue relatively late in the 23 rulemaking process, and we would desire to do that much 24 earlier.
25 COMMISSIONER ASSELSTINE: Do you feel that basically l
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, 11 1 the advice and the recommendations that you made are reflected 2 in the policy statement as it now stands?
3 MR. KENYON: Yes, the policy statement is a very 4 straightforward statement, endorses the guidelines and we're 5 fully satisfied with the draft that we've seen.
6 COMMISSIONER ASSELSTINE: Okay.
7 CHAIRMAN ZECH: Thank you. Commissioner Bernthal?
8 COMMISSIONER BERNTHAL: No.
9 CHAIRMAN ZECH: Commissioner Carr? I don't have any 10 other questions either so we thank you very much, Mr. Kenyon, 11 appreciate it.
12 MR. KENYON: Thank you.
13 MR. MILLER: Thank you very much. Warren?
14 MR. OWEN: I'm Warren Owen, vice chairman of 15 NUMARC, and we've agreed to provide you with an update on a 16 number of things this afternoon, the first of which is 17 training.
18 'On March the 20th of 1985 you issued -- the NRC c 19 issued a policy statement on training and qualification of i
{ 20 nuclear power plant personnel. The policy statement specified 21 that "all utilities have committed to achieving accreditation i 22 of each of the above training programs. It is understood that 23 each licensee will exert best effort to have all such programs
( 24 ready for accreditation. That is, final self-evaluation 25 report submitted to INPO by the end of 1986."
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12 1 Now I know that you were briefed by INPO just a few 2 weeks ago on the status of accreditation. But we made a 3 commitment to you and we thought we ought to at least mention 4 it briefly. As Zach said in his presentation to you, INPO 5 believes that utilities will meet the December 31st, 1986 6 deadline for submitting training accreditation self-evaluation 7 reports to INPO that are acceptable to INPO. And as of this 8 meeting today, all but four of the 610 SERs have been 9 submitted to, and approved by INPO. And the remaining SERs 10 are expected to be submitted shortly to allow for INPO review 11 prior to the end of December.
12 I just want to tell you from my personal experience, 13 it was must easier to make that commitment than it was to 14 carry it-out. Many of us who thought we had excellent 15 training programs still had to do a great deal of work to meet 16 the rigorous criteria established by INPO. In my view, 17 accreditation is a good program, and as we refine it and gain 18 more experience, then I believe it will continue to serve the 19 industry well.
20 (Commissioner Asselstine left the room.]
21 MR. OWEN: Now on fitness for duty, as you know, 22 NUMARC has been working with the NRC Staff, with INPO, and EEI 23 in the fitness for duty area. In December 1984 NUMARC 24 endorsed a proposed policy statement on fitness for duty, 25 which was then forwarded to the NRC in January of 1985. We
r 13 1 proposed that as an alternative to rulemaking.
2 Later when we met to discuss this issue with you in 3 November of 1985 you expressed concern because the policy 4 statement did not clearly establish Commission policy relating 5 to drugs and alcohol at nuclear power plants, nor did it 6 describe the minimum essential elements of a fitness for duty 7 program.
8 The policy statement was revised to address these 9 concerns, and you requested that the Staff discuss that 10 proposal with INPO and NUMARC. And that was done on March the 11 5th, 1986 when representatives of the NRC, INPO and NUMARC met 12 in Atlanta to review and discuss the revised statement. The 13 meeting was productive and resulted in a better understanding 14 of the issues and the implementation of the policy statement.
15 The policy statement was again modified based on 16 this meeting, and the steering committee of NUMARC then met 17 with the NRC representatives, Vic Stello, Jim Sneezak and Jim 18 Tay, lor on April 9th and a revised policy statement was 19 drafted.
20 The revised policy statement was overwhelmingly 21 endorsed by the NUMARC executive group. The vote was 54 for 22 and one against. And the one vote against the policy 23 statement was because the policy statement did not go as far 24 in its required testing as that company wanted to see us go.
25 (Commissioner Asselstine returned to the room.]
I 14 1 MR. OWEN: The revised policy statement was 2 forwarded to the NRC on May 6th, 1986 and it was approved by 3 the Commission and published in the Federal Register on August 4 the 4th, 1986.
5 During our last two steering committees meetings and 6 our last executive group meeting we have explored what actions 7 we as an industry must take to ensure we are successful in 8 this area. We sent out a fitness for duty survey recently and 9 -- I say we did; INPO sent out the survey. And we'd like to 10 share with you some of the things that were identified in that 11 survey.
12 For example, at the time of the survey -- and it was 13 as of June 1986 -- 54 utilities reported that their fitness 14 for duty policies addressed drug use both on- and off-site.
15 Forty-nine utilities reported that they used chemical testing 16 both for pre-employment and for cause. All utilities reported 17 having an employee assistance program.
18 The survey responses clearly indicate that the 19 industry has taken the lead for the American industry in i 20 fitness for duty matters, and has already implemented 21 significant improvements in this area.
22 However, the survey'also revealed that a number of 23 the utility programs have one or more areas in which actions 24 still appear to be needed to fully satisfy our commitment. In l
25 areas where there appears to be a discrepancy between the
r 15 1 survey response and our commitment, INPO is following up to 2 determine if a discrepancy really does exist, and where 3 necessary additional action will be taken to ensure that the 4 problems are corrected. The results will then be checked 5 during INPO's ongoing plant and corporate evaluations.
6 We also know that the NRC is closely monitoring 7 industry progress in the fitness for duty area. We're aware 8 that several special teams have conducted investigations at 9 several utilities and we would appreciate any feedback that 10 comes out of those investigations that would be helpful to us 11 in improving our fitness for duty program.
12 Now in the area of maintenance I'll try to provide 13 an update on actions since our February briefing, February '86 14 briefing of the Commission. Since June of 1984 the NUMARC 15 maintenance group has brought together a large amount of 16 industry, nuclear industry expertise to look into these l 17 maintenance issues. Their efforts have certainly given us a 18 better insight into maintenance and have resulted in a number -
19 of various activities that we have discussed with your 20 before.
21 They include such items as a review and analysis of 22 industry maintenance activities, a multi-year root cause 23 analysis of 653 significant events, assistance in the 24 development of INPO's guidelines for maintenance test and 25 calibration procedures, and support for the maintenance peer
16 1 evaluator program which is well underway.
2 The maintenance working group continues to interact 3 with the NRC Staff. And most recently we have reviewed the 4 maintenance and surveillance program plan phase 1 report and 5 the draft schedule of the phase 2 projects in that plan.
6 Based on these reviews, we provided specific written comments 7 on October the 6th, 1986.
8 And as you may recall our written comments, we 9 expressed concern with the overall direction and thrust of 10 that maintenance and surveillance program plan. We continue 11 to believe that the documents project a perception of 12 maintenance in the industry that is too negative in view of --
13 with respect to the current industry initiatives and the 14 progress that we've made since starting in 1984.
15 The working group has also reviewed the report 16 entitled An Investigation of Contributors to Wrong Unit or 17 Wrong Train Events, identified as NUREG 1192. That report 18 identified proposed mitigating actions for wrong unit, wrong 19 train causes.
20 We provided written comments based on our review,
, 21 and we again believe that the information in the report does i
22 not reflect the current scope and depth of irtustry 23 improvements in the primary contributors to wrong unit, wrong 24 train events, such as labeling, procedure modifications that 25 we made, communications, independent verification, and the
17 1 personnel performance criteria that have been established.
2 And lastly, I guess we would point out that at the 3 recent INPO CEO workshop last week there was a presentation on 4 the importance and the potential impact of maintenance on 5 operational activities. And I just might comment that I 6 thought that was a brilliant presentation, since someone I 7 know very well made it. But I think we are committed to 8 improvement in the maintenance area and I can assure you we're 9 making substantial progress, although there still needs --
10 there are things that still remain to be done and we intend to 11 see that they are done.
12 Operator requalification. That's another area where-13 we've been actively interfacing with the Staff, both on the 14 requalification process with respect to operators and the 15 check operator concept. During our last briefing in February 16 we discussed the area of operator requalification exams.
17 Based on that discussion we conducted a survey in April to 18 provide data so that the operator requalification working 19 group could draw conclusions on the status of requalification 20 exams.
21 As you may recall, the data indicated that passing 22 rates wer,e about the same for either the utility administered 23 requalification exams or the NRC administered requalification 24 exams. For Ros, that was 82 percent in each case. For SROs 25- it was 80 percent for the utility administered exams versus 78
. i 18 1 percent for the NRC administered exams. Well within the 2 expected agreement. -
3 Based on this data NUMARC and the NRC Staff reviewed 4 the current rationale for NRC administered requalification 5 exams. And as a result the NRC Staff developed a pilot 6 '
program with each region involved on utility administration of 7 the operator requalification exams with the Staff in a 8 monitoring role. The pilot program had the utility preparing 9 the requal exam and providing the exam to the NRC Staff for 10 review. The utility then administered and graded the exam 11 with the Staff selectively reviewing the grading.
12 For the operational portion of the requalification 13 process, the utility provided the NRC with the simulator 14 scenarios for review and then conducted the simula'or t portion 15 and oral walk-through with the NRC Staff selectively 16 monitoring the process.
17 The results of the pilot program were mixed, from 18 the viewpoints of both the NRC Staff and the utilities 19 participating in the program. And we understand the NRC Staff 20 will be recommending a six-month extension of the pilot 21 program for utilities with accredited operator training 22 programs with a final recommendation to be made to the 23 Commission in mid '87.
24 And NUMARC will be -- or the working group will be 25 meeting with the Staff to review the advantages and the
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e 19 1 disadvantages of the pilot program and discussing ways 2 to fine tune this approach. We feel that a program such as i
3 this would result in an operator requalification process that 4 will provide a good solution to the problems that have been 5 raised under the current process.
6 Now on the question of check operator. We feel that 7 it really should be treated separately from the operator 8 requalification program. There are a few utilities that 9 currently use a check operator. But a number of other ;
10 utilities have effective but different methods for independent 11 evaluation of the operator candidates for both initial 12 qualification and requalification.
13 We found the term check operator not to be as 14 descriptive as we would like and would recommend that the term 15 independent evaluator be used to encompass the check operator 16 approach. NUMARC initiated a follow-on survey in September of 17 this year to obtain additional data on this independent 18 evaluator concept. And we're compiling the results of that i
l 19 survey and plan to answer some questions that we opposed on 4
i 20 ' independent evaluation, such as who does the evaluation; where i
21 do the results of the evaluation go within the organization 22 involved; what does the utility do with the results of the j 23' evaluation; and does the process result in effective i 24 interaction within the utility.
25 And when we have those results, we'll certainly
.e n i
20 1 share them with your Staff and can discuss them in detail with 2 you at one of our future meetings.
3 I just might add that we have recently reviewed the 4 -- or we've reviewed the recently announced reorganization of 5 the Commission with a great deal of interest. We've had some 6 discussion with senior -- with the EDO and we'd like to 7 express our support for your initiatives. We feel they're 8 directed at consolidating and streamlining a number of 9 functions in the NRC.
10 And we believe your aim of aligning the agency's 11 management structure more towards its role of overseeing 12 operational safety is timely and will benefit the industry.
13 And we stand ready to fully support that, and I'll be covering 14 a little bit later in our program the industry's effort at a 15 similar kind of reorganization which I also think is timely 16 and can mean good things for us in the future.
17 CHAIRMAN ZECH: All right. Thank you very much.
18 We're covering a very large number of subjects this afternoon, 19 and each one of them could be a subject of an entire meeting 20 itself, I'm aware of that. I think my fellow Commissioners 21 are, too, as are you gentlemen. So I'd ask my fellow 22 Commissioners if they have any comments or questions. But 23 would try to keep them pointed so that we can at least cover 24 all these subjects.
25 I know you're giving us a status report, but it's an
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21 1 awful lot of important areas we're covering.
2 MR. MILLER: We have about 20 minutes more if you 3 have the time.'
4 CHAIRMAN ZECH: We can make it through. But all I'm 5 saying is that we'll try to make our questions as pointed as 6 we can, or our comments. Commissioner Roberts, do you have 7 anything that you want to say? Commissioner Asselstine?
4 8 COMMISSIONER ASSELSTINE: I'd let them go through 9 the whole presentation. I think I'll hold my questions. I've 10 got a few, but I'd be prepared to let them go through the 11 presentation first.
12 CHAIRMAN ZECH: All right. Is that all right with 13 you?
14 COMMISSIONER BERNTHAL: Sounds fine with me. I have i
f 15 one on fitness for duty particularly, but maybe we ought to go 16 on.
! 17 CHAIRMAN ZECH: All right, why don't we do that.
18 And then we'll hold the questions until you've finished the
- 19 entire briefing.
( 20 MR. MILLER: All right, sir.
i 21 CHAIRMAN ZECH: All right, proceed, please.
22 MR. MILLER: Jack Ferguson.
23 MR. FERGUSON: The technical subcommittee was l
24 constituted about 14 months ago to identify important generic 25 technical issues that were amenable to the NUMARC process to 1
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22 1 establish high level industry working groups to address these 2 issues, and then to coordinate and integrate the activities of 3 these groups.
4 There are now five working groups under the 5 technical subcommittee. One is chaired by Bruce Kenyon whom' 6 you heard from earlier, and has representatives from each of 7 the owners' groups, AIF, EPRI, and INSAC, as well as t
8 individual utilities, which prioritizes the issues. And the 9 four other working groups address the issues of highest i
- 10 priority. ,
- 11 There are also three other groups working on issues 12 which had activities well underway that have been acknowledged 13 and are being supported by the technical subcommittee, rather 14 than forming separate NUMARC working groups. I'll comment j 15 briefly on the activities of each of these groups. .
16 First, station blackout. On March 21, 1986 the NRC i
17 published a proposed rule on station blackout for comment. On l 18 June 17th, NUMARC provided comments to the NRC on the proposed
. 19 rule and advised of four initiatives that were being i
j 20 undertaken by the industry. We undertook these initiatives 21 because we felt that the anticipated benefits from the 22 proposed rule would be derived from improvement at a limited
- 23 number of plants.
24 As a result, we feel it's unnecessary for the NRC to i
25 expand its regulations in this area. I'll describe the four 1
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, 23 1 initiatives very briefly.
2 Initiative one has each utility reviewing their -
3 sites against the criteria specified in NUREG 1109. And if f4 the sites fall into the category of an eight-hour site after 5 utilizing all the power sources available, the utility will 6 take actions to reduce the site's contribution to the overall 7 risk of station blackout. Non-hardware changes will be made 8 within one year. Hardware changes will be made within a i
9 reasonable time thereafter.
10 Initiative one involves each plant determining its 11 blackout coping duration requirements. Procedures for 12 determining coping duration requirements have been reviewed 1
13 and concurred in by the NRC Staff, and have been distributed
,i 14 to each nuclear utility. In addition, two workshops have been 15 held to instruct utilities in how to determine their coping 16 requirements and to help ensure a consistent approach to 17 completing initiative number one.
18 While initiative number one addresses all plants, 19 its focus is on a limited number of plants that contribute to
- 20 the majority of the station blackout risk.
j 21 The other three initiatives are to help ensure that
- 22 all plants minimize their contribution to risk for station 23 blackout. Initiative two has each station reviewing its 24 precedures and developing and implementing needed procedures 25 to cope with the restoration of A/C power in a station
. 24 1 blackout event, and to prepare plants for serious weather 2 conditions.
3 Initiative three addresses the elimination of cold 4 fast starts of emergency diesel generators for testing. And 5 initiative four monitors the emergency A/C power availability.
6 Since June 17th, NUMARC representatives of our 7 NUMARC station blackout working group -- and that group is 8 chaired by John Opeka, executive vice president of Northern 9 States Power -- has met with the NRC Staff four times to 10 discuss our comments and to review the four initiatives. It 11 is our hope and understanding that the industry comments and 12 actions will influence the NRC's perception of the need for 13 additional regulations.
14 The attention of our station blackout working group 15 is now focused on helping the industry with the four 16 initiatives. We believe that progress is being made and 17 will reduce the risk associated with station blackout, and 18 that our alternative to rulemaking will satisfy our concerns 19 on this issue.
20 on containment integrity, that's been a focus of 21 discussion recently, partly because of the accident at 22 Chernobyl and partly because of the reassessment of severe 23 accident risks being prepared for NUREG 1150. NUMARC 24 established the containment integrity working group in 25 September 1986 at the request of the industry because of
, . 25 1 recent interactions between the NRC and the BWR owners' group 2 and because the issue is not limited solely to BWRs. The 3 chairman of.that group is Vince Boyer, senior vice president 4 of Philadelphia Electric.
5 The objective of the working group is to evaluate 6 containment integrity issue, and if appropriate, assess 7 potential improvements and minimize off-site releases in the 8 event of severe accident conditions. These potential 9 improvements will be compared to an appropriate cost benefit 10 goal.
11 Technical support for this effort is being provided 12 by EPRI and the vendors owners' groups and they'll use the 13 IDCOR results. The working group evaluation will begin with 14 the pressure suppression containments. Issues affecting BWR
, 15 containments will be considered first. Based upon the results 16 of this effort, the need for evaluation of other containment 17 types will be determined.
18 Details of the evaluation are still being
! 19 formalized, but it's our plan to perform a technical l
l 20 evaluation using severe accident analysis already performed, 21 and to take as qualitative an approach as it practical.
22 We know that the NRC has efforts underway on 23 containment integrity, but we believe that providing an 24 industry perspective is also important. And therefore, we 25 would request that the NRC defer any regulatory action on l
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. 26 1 containment integrity to give NUMARC time to complete our 2 evaluation and present it to the Commission. We recognize 3 that the NRC Staff has excellent technical capabilities'.
4 However, we believe that the nuclear industry drawing upon the 5 nuclear utilities, the major suppliers, architect engineers 6 and others can focus substantial technical resources on this 7 important issue.
8 On safety goals cost benefit working group. This 9 group was organized in November of 1985 to provide industry 10 evaluation of the NRC safety goals, their implementation into 11 the regulatory process and associated cost benefit analysis 12 issues. The working group is chaired by Wally Wilgiss, vice 6
13 president of Florida Power Corporation.
14 The three principal areas of discussion between the 15 industry and the NRC Staff regarding the Commission's safety 16 goals policy are, (a) whether there should be a quantitative 17 accident prevention criteria that is independent of public 18 safety criteria; (b) whether averted on-site cost of potential 19 accidents should be included in the regulatory cost benefit 20 analysis; and (c) whether the safety goal criteria should be 21 applied to individual plants. In each case we believe the 22 extensions cited above are unnecessary.
23 Shutdown decay heat removal working group. This 24 working group is chaired by Jerry Niles of Northern States 25 Power and has reviewed the entire background of this issue.
o
. 27 1 It has found that the NRC task action plan has been revised 2 five times, and these revisions have resulted in a dramatic 3 change of focus.
4 Originally the issue was the risk of decay heat 5 removal system failure after shutdown. The issue now appears 6 to have been broadened considerably to include everything 7 except LOCA and ATWS. We would like to work more closely with 8 the Staff in seeking a mutually satisfactory resolution to 9 this issue.
10 The working group believes that the broad issues now 11 being addressed should be dealt with under the severe accident 12 policies. We believe the original narrower issue of decay f 13 heat removal system reliability is the appropriate issue, and
\
14 that each plant should review its systems, making those 15 physical and procedural changes that are needed. And guidance 16 for ther.e reviews is available in several INSAC and AEOD 17 reports, as well as in INPO SERO 85-4.
18 Check valve reliability. The San Onofre water 19 hammer event brought into question the reliability of check
, 20 valves. The industry was asked by the NRC Staff to look'at 21 the issue and develop a program.
22 An owners' group task force has been formed by the 23 four owners' groups under the chairmanship of Hal Tucker, vice 24 president of Duke Power. This owners' group is cooperating 25 with INPO in developing a significant event report, and the
o
-
- 28 1 SOER has identified misapplication of check valves as the 2 outstanding reliability problem.
- 3 The task force has decided to fund development of a 4 document application guide for check valves. EPRI will manage 5 this effort for the committee. Rather than form a new NUMARC 6 working group, the technical subcommittee has endorsed this 7 owners' group task force and its efforts. And we believe that 8 their efforts will satisfactorily address the concerns about 9 check valve reliability.
10 10 CFR 50.'59. Each year the nuclear unit may make 11' several hundred changes to hardware and procedures. And 10 12 CFR 50.59 is the regulation that governs the review of those 13 changes. Interpretation of that regulation has varied
\
14 widely. And the varied perceptions of what is required have l 15 resulted in substantial fines by the NRC.
16 The INSAC task force subcommittee has been working 17 on the design change process since 1984. This group augmented 18 by AIF has been acknowledged by the NUMARC technical 19 subcommittee as the official industry effort to clarify 10 CFR 20 50.59. In July of this year EPRI published INSAC 105, 21 guidelines for design and procedure change in nuclear power 22 plants.
23 That report did not attempt to achieve uniform 24 industry definition of terms or interpretation of the 1
25 regulations. Therefore, the task force subcommittee plans to i
. 29 1 create a document that would offer the needed clarification.
2 They've met with Bill Russell and Jin Partlow and have 3 established points of contact for NRC review of their planned 4 report. The intention is to arrive at a uniform industry 5 position that can be accepted by the NRC.
6 Finally, plant life extension. The preliminary 7 results of the Surrey and Monticello pilot studies have 8 indicated the technical feasibility of life extension of 20 9 years or more and associated economic benefits of $1 million 10 or more in present dollars. However, since no regulatory 11 process for license renewal exists, we need to work with you 12 and your Staff to develop a coordinated, proven license 13 renewal process by the mid-1990s when it will be required.
14 An aggressive, comprehensive program beginning now 15 is required to meet this goal. The Nuclear Utility Plant Life
- 16 Extension or NUPLEX steering committee, which has been 17 acknowledge by our technical subcommittee, is drafting a la five-year plan which outlines the activities required to meet 19 the above-stated needs and is coordinating the industry's 20 responses to the recently issued NRC questions on license 21 renewal policy.
22 This committee is composed of techn!;al codes and 23 standards, licensing and administration subcommittees. DOE 24 and EPRI are providing the technical and administrative 25 support to --
~* 30 1 CHAIRMAN ZECH: Could you get the microphone a 2 little closer to you, please. I don't think they can hear you 3 in the'back. Good, thank you.
4 MR. FERGUSON: And in conclusion, I'm very pleased 5 to report that the progress --
6 (Laughter.]
7 MR. FERGUSON: What did I do now?
8 CHAIRMAN ZECH: They couldn't hear you very well, 9 Jack. It wasn't your fault. We should have let you know 10 earlier.
11 MR. FERGUSON: Okay. A completed report at the i
12 progress achieved since my last report to you. This report
, 13 that we received from EPRI, INPO, AIF, the owners' groups, and
\
14 of course, the individual utilities has been very gratifying.
15 The NRC Staff has been very cautious, but generally 16 cooperative.
17 (Commissioner Bernthal left the room.)
18 MR. FERGUSON: Results are beginning to show, but 19 obviously much remains to be done. And I'm optimistic though 20 that our results, our efforts will be decisive and will drive 21 these issues to a mutually satisfactory conclusion. Thank 22 you.
23 CHAIRMAN ZECH: All right, thank you very much.
24 MR. MILLER: Warren?
25 MR. OWEN: Okay, I've been asked to talk a little
. 31 1 bit about the future of NUMARC. And this may be a little bit 2 off the cuff because things are developing every day.
3 As you know, the Utility Nuclear Power Oversight 4 Committee called UNPOC sponsored a study of the nuclear 5 industry commencing in September of 1985. And that was aimed 6 at making recommendations to accelerate the achievement of 7 exemplary operational performance by all of our nuclear power 8 plants. I know you're aware of this study which was entitled, 9
9 Leadership in Achieving Operational Excellence, commonly ,
10 referred to as the Sillen report, and have been provided with 11 a copy of the final report.
12 (Commissioner Asselstine left the room.]
13 MR. OWEN: As you may recall, the report had threo
, 14 sections. One of which called for the establishment of a new, 15 unified nuclear utility industry organization to be the focus 4
16 for regulatory issues. And this is the one I want to discuss 17 briefly today.
18 First, I think we should recall that NUMARC is an ad 19 hoc group of dedicated nuclear utility executives. It is not 20 incorporated. It functions primarily with the support of 4
21 volunteers from our membership and staff support of industry 22 organizations such as INPO and EPRI. And the UNPOC report has 23 given the industry a real opportunity to look long term at our 24 needs and to try to structure an organization that will be 1
25 permanent, that will be staffed with technically competent
. 32 1 people and will provide a focus for all generic regulatory 2 issues and an interface with the NRC on these issues.
3 As you may know, this week is the AIF, ANS meeting 4 here in Washington, ana all of the boards of the organizations 5 that are covered by this realignment within the industry met 6 this week. I'm pleased to say that the realignment covered in 7 the press release issued yesterday was unanimously adopted by 8 all of those boards of directors of those organizations.
9 And just briefly, the realignment includes the 10 following: UNPOC, which has -- it will be. formally constituted 11 as a coordinating and oversight organization for all nuclear 12 industry association activities.
13 (Commissioner Bernthal returned to the room.]
14 MR. OWEN: It will be renamed. Its board will be 15 expanded and it will be permanently headquartered and staffed 16 as required. And in that new form it will be responsible, 17 among other things, for strategic planning for the industry, 18 coordination, international cooperation, and the policy 19 leadership of ANEC, AIF, USCEA and the Nuclear Utility l 20 Management and Resources Committee.
21 (Commissioner Asselstine returned to the room.]
22 MR. OWEN: The duties of the existing associations 23 will be structured along functional lines, ANEC, AIF, NUMARC 24 and USCEA will be restructured in the three organizations 25 responsible for the following areas: regulation and technical
33 1 support, the new unified industry organization to interface l
2 with the NRC. Another organization to handle communication, 3 educational and technical services. And a third organization 4 to handle governmental, legislative affairs. And each of 5 those organizations will be organized with its own board of 6 directors, a president, and necessary full-time staff.
7 Now a response and implementation committee, which 8 Jim Miller and I serve on has been active in working to 9 implement the unified regulatory interface organization
. 10 addressed in that report. And we've been active over the past 11 few months.
12 Since the UNPOC press release establishes that 13 new organization for coordinating all matters involving
- 14 industry-wide regulatory policy issues and the regulatory 15 aspects of operational and technical safety issues affecting 16 the industry, then we're certainly free to move ahead with 17 that implementation of the unified organization.
18 It has been concluded that the new organization 19 should be the sole interface with the NRC on generic 20 regulatory matters. The new organization will be freestanding 21 and independently funded, and will embody the concepts that 22 you are used to and presently used by NUMARC.
l 23 The new organization will also draw on the 24 collective expertise of other industry groups; the nuclear 25 steam suppliers and the ANES and other suppliers that involve
_ _ _ _ _ _ _ _. . .. ~ _ _ _.__ __ - , _ _ _ _ _ _ _ . _ , ___. ~ ~ .
, 34 l
1 those groups and the regulatory issues as appropriate.
~2 The new organization will be governed by a board of 3 directors composed of one senior executive from each utility 4 that is building or operating a nuclear power plant. In 5 effect, a group that would be analogous to the current NUMARC-6 executive group. And industry positions on regulatory 7 issues. We'll still require an affirmative vote of at least 8 80 percent of the members of that board of directors.
9 The new organization will have a permanent staff.
10 It will be located in the Washington, D.C. area. We can't '
11 give you final details, but I can summarize by.giving you my 12 impression of the outcome.
f 13 The new organization will build upon the strengths
(
14 of the current NUMARC concept. It will expand on our 15 capabilities by giving us a permanent and competent technical
- l 16 staff, and will be designed to help assure more effective 17 interface between the nuclear utility industry and the NRC.
18 When the structure is finalized, I think we'll have an 19 organization with greater ability to deal with the very
[ 20 complex issues that the industry and the NRC face together.
i 21 We committed to Vic Stello in a meeting this morning l
22 that we will begin work early next year to try to define an
~23 appropriate interface with the NRC and that we'll keep you j 24 informed as we proceed with our work to implement this new 25 opportunity. And currently the schedule calls for full
35 1 implementation by July the 1st of 1987.
2 CHAIRMAN ZECH: Thank you very much.
3 MR. MILLER: We have one more speaker,' Bill Conway, 4 who will address the start-up discussion.
5 CHAIRMAN ZECH: Fine, thank you very much.
6 MR. MILLER: Bill is speaking for INPO.
7 CHAIRMAN ZECH: All right.
8 MR. CONWAY: Thank you. I'd like to speak briefly 9 and reflect on the letter that the EDO had furnished or sent 10 to Jim Miller at NUMARC. As Jim mentioned earlier, there had 11 been conversations between NUMARC and INPO and it was 12 concluded that INPO should take the lead on this. And I'll i
13 brief you on what we plan on doing at this point in time, 14 But I think by way of history I'd like to reflect 15 just for a minute on some of the things that the industry has 16 had in the past. I think we should reflect a little bit on 17 some of the ongoing programs that are currently in place or 18 were in place previously to review and enhance the lessons i
19 learned in the transition, particularly from the construction
- 20 phase to the operating phase of plant life.
i 21 They, I think include quite clearly the former 22 construction project evaluations that INPO ran. That process 23 was concluded sometime back, within the last year or so, so we 24 could focus more of our resources on the operating plants.
25 The enhancement of assistance visits to the i
. 36 1 near-term licensees is something that was an industry 2 commitment made through NUMARC. And I think you'll find it 3 reflected in the status report that Jim Miller mentioned a 4 little bit earlier. But I'd like to say that both the plant 5 and the corporate facilities are a part of that enhancement 6 process.
7 Part of that you'll note, is the observation of the 8 shift team effectiveness while simulator exercises are being 9 conducted. And I think very importantly, the plant 10 evaluations are enhanced by the addition of two peer SRO 11 evaluators from other plants of a like vintage. In addition, 12 we I think have recruited very successfully a cadre of 7
13 excellent senior corporate officials from other utilities to
(
14 visit the utilities that are being evaluated to bring some 15 - assistance as well as recommendations to those organizations.
16 Most of the types of lessons learned, I think, and 17 events that take place are factored formally into our 18 significant event report program. I think the most current 19 one is the one that we issued very recently on Chernobyl.
20 I think though it's quick to point out, and should 21 be pointed out that we don't believe there's any absolute 22 panacea to probably being able to put your hand on a 23 particular problem and say you've solved it. But I think we 24 do see this overall situation as being a window of opportunity 25 to try to further develop what we consider to be a good
. 37
-1 ongoing program now.
4 2 Specifically, we would intend to review industry
- 3 start-up history to include the initial operating cycles after 4 transition from construction to operating phases. We would, I 5 think very importantly, utilize the assistance of our INPO 6 members who have very broad start-up experience, to provide 7 that experience to those plants approaching the operating 8 phase.
9 And finally, I think to try to centralize those 10 activities and make them more emphatic. We would schedule 11 meetings and/or workshops to share those experiences on 12 lessons to the facilities who are entering the start-up or 13 really operating cycle phase.
k 14 Thank you.
15 CHAIRMAN ZECH: All right, thank you very much.
16 MR. MILLER: I have about a two-minute closing.
17 CHAIRMAN ZECH: Go right ahead.
18 MR. MILLER: Gentlemen, thank you for letting us be
- 19 with you today. We've been in existence about 32 months. I i
l.
l 20 think we've been able to help a little bit. We've been able
- 21 to agree on a course of action in training and in fitness for 22 duty, and we're working on other courses of action on a 23 mutually agreeable basis. And we think we can help bring 24 those to a conclusion.
25 While each of these separate issues is very
l
~
38 l
1 important, there's one overall undertaking of which each of 2 these is just a part. I believe that throughout these 32 3 months there has developed and is developing a sense of 4 respect and trust between the NRC and its Staff and the 5 industry. I believe this sense of respect and trust that's 6 working toward a common goal on a common problem and bringing 7 together the combined expertise of the industry and the NRC 8 will serve to the benefit of the country.
9 In this process, it is important to recognize that 10 we haven't asked the NRC to abandon its regulatory 11 responsibilities. And we the managers of the industry, have 12 not been asked to give up our managerial responsibilities.
13 What we've tried to do is to look at where improvements are 14 needed in the industry. And by utilizing our individual 15 perspectives and obligations, bring our collective expertise 16 to bear to achieve timely improvement.
17 It's been a great thing for me to be a part of this 18 process. I think I've gained additional insight into the 19 regulatory process. And with that insight has come l
20 appreciation for the very difficult job that you and your 21 Staff faced. I've benefited from interacting with you and am 22 greatly impressed with the desire of y.u and your Staff that I l 23 see to do what is best for our country. And that's very 24 important to me personally.
l 25 This is the last time I'll appear before you as l
H .
l
O
~
39 1 chairman of the NUMARC steering committee. I'll be on the 2 committee until I retire from Georgia power next year. On 3 January the 1st, Warren Owen will take over as chairman of 4 NUMARC and Gene McGrath of Coned will become vice chairman.
5 They both have a dedication to this industry and a 6 determination to do what is right. I'm confident that NUMARC 7 and the new organization will continue to grow and become 8 stronger and be more helpful to you and to our county in the 9 years ahead.
10 Thank you.
11 CHAIRMAN ZECH: Thank you very much, Jim.
12 Appreciate that and all the other presentations, too.
13 Questions of my fellow Commissioners? Commissioner Roberts?
\
14 COMMISSIONER ROBERTS: I didn't know -- you're 15 getting ready to retire?
16 MR. MILLER: I have 11 months, Commissioner. I'll 17 be 65.
18 COMMISSIONER ROBERTS: You don't look old enough to 19 retire.
20 MR. MILLER: I look in the mil or and the mirror 21 says I do.
22 COMMISSIONER ROBERTS: Well, I certainly hope I'll 23 see you again. I've enjoyed knowing you and working with 24 you.
25 COMMISSIONER CARR: Don't count on that retirement.
40 1 [ Laughter.)
2 MR. MILLER: I didn't say you wouldn't see me. I 3 said I wouldn't be up here with NUMARC.
4 COMMISSIONER ROBERTS: That's all.
5 CHAIRMAN ZECH: Thank you. Commissioner Asselstine?
6 COMMISSIONER ASSELSTINE: Just a couple. On 7 maintenance, Warren, you mentioned your comments and reactions 8 to some of the Staff reports that have been prepared on 9 maintenance. And particularly your comment that the Staff 10 reports you thought were too negative and didn't necessarily 11 reflect some of the more recent efforts that have been going 12 on.
. 13 I guess I was wondering, do you differentiate
(
14 between some of the comments that the Staff has that are more 15 subjective, like comments on the effectiveness of preventive 16 maintenance programs as opposed to some of the more factual 17 information that they've compiled? For e,_ ample -- I guess I'm 18 trying to get a sense for whether you disagree about the l 19 Staff's estimates of the percentage of forced outage time l
20 that's due to component failure. The fact that maintenance 21 seems to be an increasingly significant contributor to forced l
22 outage time, to emergency safety feature actuations, to some i
23 of those other elements.
I 24 We got a briefing from the Staff this morning, and i
25 they went through a fair amount of the factual information
- , 41 1 that they've seen in the performance of the plants over the 1
2 past three or four years.
3 MR. OWEN: Commissioner, I don't think that we 4 disagree significantly with respect to the contributing 5 causes. There is a very broad definition of what's involved 6 in maintenance, but we got -- our surveys or our root cause 7 analysis of those 650-some events that we chose to analyze in 8 a very in-depth way by and large confirmed those numbers.
9 We did note, as I recall, that a very large number '
10 of those fall under the category called -- where surveillance 11 is involved. And you can put that in maintenance or take it 12 out and that doesn't really make any difference in what we're
( 13 trying to accomplish. You just have to be careful when you
\
14 start dealing with statistics.
15 But I think the primary thrust of our comment -- and 16 we don't mean it to be critical of the Staff -- but it's 17 difficult when things are changing for any survey to be as 18 current as we'd like to see it. And we do feel, and our 19 convinced that the industry is making significant progress.
20 And we want to have the opportunity to work with the Staff and 21 to see those initiatives that we've undertaken brought to 22 conclusion.
23 Those kinds of -- when you're dealing with as 24 many -- with a complex issue like' maintenance and all of its i 25 -- all of the areas that it covers and all of the programs
._ .. _ _ _ - . _ _ _ , . _ . . _ _ _ _ _ . ~ . _ _ _ _ , - _ ___ _ . - _ _ _ _ _ _ _ _ _ - - -_ _ _ -
. 42 1 and the different companies that are involved, you don't make 2 progress as fast as you might like to see it sometimes. But 3 we are convinced that we're making substantial progress and 4 want to continue that. We have a number of programs underway 5 that we view that are on the verge of producing some insights 6 that will help us all.
7 COMMISSIONER ASSELSTINE: Staff told us this morning 8 that the industry was not in favor of the policy statement on 9 maintenance. And I guess I'd be interested in hearing if 10 that's so, why that's so and what your objections are to a 11 policy statement on maintenance.
12 MR. OWEN: I think a more accurate statement of our
( 13 position -- and maybe we didn't articulate it as well as we 14 should have when we communicated -- but we just did not see 15 the, or understand the reasons, what would be accomplished by 16 a policy statement from our standpoint. But we're perfectly 17 willing'to interact as we have in other cases with the Staff 18 on a policy -- potential policy statement and see if we can 19 find one that serves both our purposes. We don't object at
, 20 this stage to one. We just did not see the need for it.
21 COMMISSIONER ASSELSTINE: I take it you view a 22 policy statement as preferable to a rule that basically 23 requires the submission of a preventive maintenance program by 24 every licensee for Staff review and approval?
25 MR. OWEN: Yes, I think this is an area that would
4
~, 43 1 be better served by letting these industry initiatives run, 2 and a policy statement is more conducive to that.
3 COMMISSIONER ASSELSTINE: One of the things that at l 4 least I seem to get from the Staff's presentation this morning 5 was the real problem of lack of uniformity in the maintenance 6 area. Either not everybody making sufficient progress.
7 Perhaps some people not even getting the message that there 8 are maintenance weaknesses out there.
9 I guess that sense is sort of reinforced by the --
10 at least up until now -- the unwillingness on the part of 11 NUMARC to be able to form a majority in favor of some kind of 12 a position in favor of the policy statement or the specific
,j 13 elements of one.
(
14 MR. OWEN: We have not ever asked our executive 15 group to vote yes or no. That was merely a discussion in our' 16 steering committee, and we did not feel that a policy 17 statement was needed or could initiate anything that we had 18 not already initiated. With the peer evaluator program which 19 is working very well; with the pilot programs that we have for 20 self-evaluation; the NUMARC guidelines that have been 21 published and they are committed to be all those utilities 22 that are members of NUMARC -- I mean, members of INPO and 23 that's everyone in NUMARC. So we think a number of things are 24 going on.
25 MR. MILLER: I think there's one key ingredient
. - . - _ , , - , , , . , , , _.,.-c. -_ , _ - - . _ - . , - , , - _ . . _ _ __,_,,..r,, ,. - ,_ ,_-- ,,_....,-, ,__.,,,,..,, -
- m. , , -,_, - = - . . - - - - - _ . , _ _ - _ _
e o 44 1 that's really just coming into play. And that is the major 2 training effort. We're just finishing the accreditation. As 3 a matter of fact, we're just finishing the preparations 4 getting ready for accreditation. And included in those are 5 the maintenance training programs.
6 And that is not -- you know, it's not like taking a 7 tablet and having an instant reaction. It takes a little time 8 to run your guys through that after you've done all that 9 work. And that's in process at a number of -- it's in process 10 at my own utility. And some of us get very disappointed that 11 we don't see instant results and good results. Sometimes we 12 see instant bad results. But I can assure you there's an
- 13 enormous effort going on in the industry today.
k 14 MR. OWEN: I would just comment that when I was 15 asked to make a presentation at the INPO CEO workshop last 16 week, I had mixed emotions personally about how a group of j 17 CEOs would respond to someone getting up and talking about 18 maintenance. But I was -- I really was pleased and surprised 19 by the reaction to it and the fact that so many people seemed 20 to understand and support the message.
l i
21 So I think there's a lot going on. While we can't 22 yet point to the results, I think they're forthcoming.
l 23 COMMISSIONER BERNTHAL: If I could just interject a l
24 comment here, Jim.
25 COMMISSIONER ASSELSTINE: Sure.
1
,_ 45 1 COMMISSIONER BERNTHAL: While I have to say that the !
2 prospect of NRC Staff attempted to scrutinize and sign off on 3 a preventive maintenance program for every plant in the 4 country is, frankly, terrifying to me. And I would hope to 5 many people here.
6 Having said that, I also have to say that it seems 7 to me there's great value in this Commission saying clearly 8 what its position is on matters that, in cases like fitness 9 for duty, for example, I certainly felt strongly we would 10 achieve our objective more rapidly by working through the 11 policy statement mechanism.
12 I have to say that this policy statement business 13 does work in that sense in my judgment. And I believe that i
14 there's much to be said from your statement for knowing on the 15 record. The policy statement does not have the force of law 16 in the sense that regulations do, as you know. But at least 17 you know where we stand.
18 And there have been a number of this kind of thing 19 now. I'm not even sure what we would say in a maintenance 20 policy statement. But I would want always, I think to reserve 21 to the commission the option, and encourage the commission 22 where there can be any doubt of where we stand on fitness for 23 duty, for example, that we follow that route where it appears 24 to be practical and has an impact that's useful, both from the 25 standpoint of our saying clearly what we mean and your
^
, 46 1 understanding what we mean.
2 MR. MILLER: One of the great opportunities that 3 we've found and been able to utilize is that if you can get --
4 if you're going to get the crowd that are going to do the work 5 with you and get them to be part of that decisionmaking and J
6 put it out there on the table and everybody's agreeing, you 7 don't -- really, your work is 90 percent done. You've got to 8 follow up. You've got to be sure that everybody has done it.
9 But most of those horses are out there galloping.
10 And I think our position on this is, we're not for 11 it or against it. And I'm perfectly willing to look at it.
12 If it's for it, I'm going to vote for it. ,
, 13 COMMISSIONER ASSELSTINE: I agree that the policy
.L 14 statement approach can work and I think the training area is 15 an outstanding example of that. But it does seem to me that,
. 16 at least one conclusion I reach is that maintenance isn't good 17 enough. There's room for improvement everywhere, and there's l
L 18 room for substantial improvement in some places.
l 19 It seems to me that what we need in the maintenance 20 area is precisely the same kind of effort that we've had in 21 the training area. That is a detailed understanding of what l 22 needs to be done to bring these programs up to speed for the l 23 long term; a strong commitment by all of the utilities to do l 24 it; and an ability to verify that, in fact, it's working; that 25 the progress is being made on a reasonable time basis.
l l
- 47 1 We can do that by a policy statement it seems to 2 me if we can reach agreements on the specific elements. If 3 not, it strikes me that sooner or later the commission may 4 have to deal with it on its own. I'm perfectly willing to 5 make the policy statement approach work. But at least for 6 myself, I think this is an area where what we've got now just 7 isn't good enough. We have to be better.
8 MR. OWEN: I think most of those -- I would 9 subscribe to most of the thing you said. I think that we 10 maybe have not articulated as well as we should have some of 11 the things that are being done. In the training area, for 12 instance, the maintenance training is really just now 13
~
beginning to produce the kinds of results that we'd like to 14 see.
15 And at the INPO CEO workshop there were several 16 speakers who described their training facilities, including 17 their maintenance training facilities which were of great 18 interest to everybody. And I happen to know that there are 19 several utilities that I visited, and my own, where we are --
.20 either have just completed or are building new facilities to 21 do the sort of training that really produces results.
22 In the predictive and ' reventive maintenance area, 23 that's a developing kind of technology. New tools available 24 to us that we're just going to have to learn how to use and 25 going to have to then transfer that know-how among the 55
. 48 1 companies.
2 The self-evaluation, self-assessment pilot that we 3 have going at five plants is going to give us an insight into 4 the kinds of things that ought to be present, that seem to be 5 working well. But also give us an insight into where those 6 folks have found weaknesses and we can then devise 7 improvements and share those with everybody. And that's the 8 whole idea of a pilot program. To run one industry-wide 9 before we have those kinds of insights may be spending 10 resources inefficiently. But we certainly intend to learn 11 from those pilots.
12 And I think we're perfectly willing -- if we left 13 the impression that we were opposed to a policy statement, I 14 just think we were -- we didn't articulate our position well.
15 We just don't see where it's going to make us do more. But 16 we're perfectly willing to talk about it.
17 COMMISSIONER ASSELSTINE: Good. For myself at 18 least, I would urge a top priority on this item, and perhaps a 19 meeting in the not too distant future so we can assess where 20 we are.
21 I had a question on the check operator concept. You 22 mentioned that you thought the check operator concept was a 23 bit too restrictive and you really had in mind more of an 24 independent evaluator. Does that mean that the evaluators 25 would say, not necessarily be licensed and experienced
. 49 1 operators? Or how do you have in mind that that concept would 2 be different than the check operator concept?
3 MR. OWEN: No, when we got into the check operator 4 concept, as I understand it, and started talking about it we 5 found the term poorly understood. And then as we dug deeper 6 into it, we found a few utilities that were doing what could 7 very definitely be described as check operators. But we found 8 others that were being innovative and using operators as 9 evaluators in a variety of different ways.
10 And that's when we decided that let's just find out 11 what the heck is going on, make sure that a small group of 12 people understand all those processes, and then try to assess
, 13 what gets the. job done. And we believe in the theory that
(
14 what works is infinitely better than what doesn't work. If 15 somebody has tried it and it really works, we want to see if 16 others can't buy into that kind of process.
17 So we just think that the independent evaluator term 18 is a little bit less proscriptive and a little bit broader 19 than the check operator, and we'd like to have the opportunity 20 to innovate in that area.
21 COMMISSIONER ASSELSTINE: Okay. I had one other --
22 one question on" fitness for duty as well. I guess that one is 23 to you also, Warren. In trying to assess how that program is 24 working, that's another one where we've got a policy statement 25 and an industry program. And I guess for myself, I'm not as
. 50 1 confident that that one is working as well as the training one 2 has.
3 You mentioned you're doing some inspections of 4 individual plants. We were informed by the Staff fairly 5 recently that there's a plant that has a couple of operators 6 who have tested positive on drug tests a couple of times and 7 they're still on the job as operators. Now we're doing an 8 inspection to find out what all the facts are.
9 But I guess I'm curious about whether a program 10 would pass, both under the policy statement and under the EEI 11 guidelines, and allow operators who have tested positive on 2 12 drug tests multiple times to remain at plant controls.
' < 13- MR. OWEN: I'm not aware of that situation. I guess k
14 that's one of the reasons we would certainly like to be tied 15 into the feedback and the opportunity to get tied into the 16 feedback from your-inspections. Our discussions and our 17 survey clearly shows that we're making significant progress in 18 a relatively short period of time.
19 And I don't think any of us on the executive group
( 20 would say to you that everything is perfect, but we're a whale
- 21 of a long way down the road. And I think far ahead of the
- 22 rest of the industry in this country, and are dealing with 23 some areas where some difficult questions are there with 2
24 respect to human rights.
25 But I'm surprised to hear what you say. I would not l
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. ~51 1 have expected that.
2 MR. MILLER: I'll tell you, I'm appalled at hearing 3 it.
4 COMMISSIONER ROBERTS: May I ask a question? Do 5 the people in the basic chemical manufacturing business have 6 any sort of trade association that addresses this problem?
7 MR. OWEN: The fitness for duty?
8 COMMISSIONER ROBERTS: Yes.
9 MR. OWEN: I'm not aware of any industry that is as 10 far down the road as we are. And I don't know of anything in 11 the chemical industry -- I do know that the chemical industry 12 has made some informal contacts with some of our industry 13 leaders about.trying to establish something similar to INPO 14 for their industry where they could be more --
15 COMMISSIONER ROBERTS: But to your knowledge it i
16 doesn't exist?
17 MR. OWEN: That does not exist to my -- they have a 18 v.ariety -- I am aware they have a variety of organizations 19 which deal with various segments of their business. But I 20 don't think any -- I don't know of any industry as an industry 21 that has committed to the kind of fitness for duty program, 22 all-encompassing kind of program, that the nuclear utility 23 industry has done.
24 COMMISSIONER ASSELSTINE: I certainly agree that we 25 should share information whenever we have concerns like this l
L- _
t
. 52 1 or our inspection program. But as soon as.that inspection is 2 done, I'd be real interested in getting your reaction to how 3 the program is working. Quite frankly, I think this has 4 caused some concern from the Staff's standpoint, and certainly 5 ours as well.
6 MR. MILLER: You all have been to my plant, and I 7 just.the report yesterday and you found a few things, and one 8 or two of them of consequence. And I appreciate you bringing 9 them to our attention. We'll straighten them out. We might 10 not agree on everything, but the ones that we are slack on 11 we're going to straighten out.
- 12 COMMISSIONER BERNTHAL
- By my calculation, if we had 13 tried to do that by rulemaking, by now we'd just about be --
14 we'd be arguing over a final rule if we were lucky. And maybe 15 another six to 12 months we'd get something done. I still 16 believe that this is the fastest way to achieve the objective, 17 and things have already happened.
P 18 I want to ask one question related to fitness for 19 duty, if I can piggyback again.
20 COMMISSIONER ASSELSTINE: Sure.
21 COMMISSIONER BERNTHAL: As you all know, the 22 Louisiana District Court, I guess, recently issued an 23 injunction against the U.S. Customs Bureau. The court 24 injunction is interesting reading. I suspect that young clerk 4
25 had tongue in cheek, at least partially, when he wrote it. I
53 1 recommend it to your reading.
2 But the thrust of it is dead serious, as all of you 3 know, and very clear on the constitutionality or 4 unconstitutionality of what the Customs Service was attempting 5 to do. When I read that I began to wonder whether this is 6 going to have any impact on utility operations. Is it 7 irrelevant to you? Have you folks looked at that yet to try 8 and make a determination?
9 MR. OWEN: Our people have -- I can only speak for 10 our company. I have discussed that with our human relations
- 11 department people who are responsible for our program, which 12 is a company-wide program not aimed just at our nuclear f
13 people. And they inform me that they don't think it will i
14 have any impact at all on what we're doing. And we don't 15 intend to cut back in any way on what we're doing.
16 And I would suspect that that's true of most of the 17 utilities.
i i, 18 COMMISSIONER BERNTHAL: Well, let me ask the 19 question this way. Will it impact those utilities who had put 20 into place or were attempting to put into place a kind of 21 mandatory, or at least spot check system?
22 MR. OWEN: Random testing?
23 COMMISSIONE2 BERNTHAL: Random testing or spot 24 random testing.
25 MR. OWIN: I think they would have to reconsider, or
?
- 54
- 1. at least consider whether or not they want to change their 2 practices. I think good management practice and good 3 observational training can achieve the result of doing the 4 testing where you really need to do the testing.
5 COMMISSIONER ASSELSTINE: Just two questions on 6 technical issues, Jack. You mentioned on containment 7 integrity that you would ask that the NRC defer any regulatory 8 action on containment integrity until your working group has 9 had a chance to review and comment the situation.
10 Does that mean that you would like the agency to 11 defer action on the Mark I containment issues, the five 12 element program that NRR is working on?
~
13 MR. FERGUSON: We'd like the opportunity to 14 understand that a bit better before there is regulatory 15 action.
16 COMMISSIONER ASSELSTINE: Do you have a timeframe in 17 mind? I think the Staff had in mind trying to put together a 18 generic letter by, I think, next month. Do you know when 19 you'd be in a position --
j 20 MR. BOYER: We have some --
21 CHAIRMAN ZECH: Identify yourself, please.
22 MR. BOYER: Vincent Boyer, Phil'adelphia Electric and j 23 chairman of the containment integrity working group of NUMARC.
24 CHAIRMAN ZECH: Thank you.
25 MR. BOYER: We're underway. We are developing our
4
.. 55 1 plan and program. We need to get a little further down before 2 we can give you a definitive date, but we're shooting for 3 April. We wouldn't be prepared next month, no.
4 COMMISSIONER ASSELSTINE: Okay.
5 MR. MILLER: And that's indefinite at this stage.
6 It's got to.go through another routine after that. So what i
7 he's telling you is the earliest.
8 COMMISSIONER ASSELSTINE: April at the earliest.
9 MR. FERGUSON: But we do intend to move fairly 10 promptly on it.
11 COMMISSIONER ASSELSTINE: Okay. And my other
, 12 question on technical issues was the safety goals and cost 13 benefit working group. You mentioned you were looking at 14 three issues. .I think one of them, if I heard you right, was i
15 the averted on-site -- consideration of averted on-site costs?
- 16 MR. FERGUSON
- Correct.
17 COMMISSIONER ASSELSTINE: Does that mean that you 18 don't have any question or concern about considering averted 19 off-site property costs in the cost benefit analyses?
20 MR. FERGUSON: We don't believe that economic and l
21 safety issues should be mixed. That the economic consequences i 22 to the utility are sufficient incentive in itself, and that I 23 the proper role of the Commission is the health and safety of l
24 the public and not the economic well-being of the utility.
25 COMMISSIONER ASSELSTINE: Yes, I can certainly i
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. 56 1 understand the argument when it comes to the on-site property 2 costs. Off-site, I guess I have a little bit more difficulty 3 with, particularly given the statutory mandate that we have to 4 protect life and property.
5 MR. MILLER: Without trying to be obnoxious on the 6 matter, you've got to understand that this has not worked its 7 way.through the NUMARC group. It has a procedure to follow 8 before it can be presented to you as an opinion of NUMARC.
9 COMMISSIONER ASSELSTINE: Okay.
10 COMMISSIONER BERNTHAL: And the law is very clear.
11 MR. MILLER: An official opinion. I understand 12 that.
13 COMMISSIONER BERNTRAL: I think Jim is exactly right 14 on that. Property is in the law. We don't have a choice on 15 that.
16 MR. MILLER: Yes. I just wanted to point out though 17 that it is not.
18 COMMISSIONER ASSELSTINE: I guess I was more 19 interested in wondering if you were looking at the issue of l
! 20 the off-site costs as well as on-site, or whether you were --
21 MR. FERGUSON: We are now.
i i 22 COMMISSIONER ASF3LSTINE: Okay.
23 [ Laughter.]
24 COMMISSIONER ASSELSTINE: I guess the last -- it's 25 not a question, more of a comment. Jim, your closing remarks
. 57 1 about the sense of respect and trust growing between the 7
2 industry and the Staff. I would agree with that.
3 But I would also say that, I think if you look at a 4 couple of these areas, the sense I get from the Staff is some 5 concern about whether the industry is willing to go far enough 6 in the NUMARC efforts to satisfy what they see as the 7 technical and safety concerns. And I think you see that in 8 the station blackout area, in the maintenance area, on the 9 Mark I containment issues, and on fitness for duty, in the
- . 10 past at least.
11 I guess what I would urge, if this process is 12 really to work, I think it takes a sense of accommodation on 13 both sides.
14 MR. MILLER: Well, I certainly agree. And it would 15 surprise me if we didn't from time to time have that feeling.
16 And there are going to be things, I'm sure from time to time 17 that we don't agree with the Staff on. And I'm sure that l
18 there are going to be things where they don't agree with us.
19 But the important thing is to have the effort and the trust 20 and the interface to bring it about.
21 COMMISSIONER ASSELSTINE: I agree with that. But I t
l 22 think for the long term, if we're to duplicate the kinds of
(
l l 23 successes that I think we've been able to achieve in the 24 training area, I think some of these are pretty gut issues.
25 Questions like containment performance, station blackout
. 58 1 question that the Staff says is one of their biggest concerns, 2 and the maintenance area which I think certainly is one of my 3 major concerns and I think most of us share that. Those are 4 ones that I think really need some attention and some 5 willingness to try and reach a consensus if we can.
6 That's all I have.
7 CHAIRMAN ZECH: Thank you. Commissioner Bernthal?
8 COMMISSIONER BERNTHAL: I think I've covered most of 9 the points that I wanted to mention. I'd just reiterate on 10 the question of off-site property, my reading at least of the 11 law doesn't allow us any option here. We are mandated to 12 protect public property as well as public health and safety.
13 In any case, I suspect that given the way the legal
(
14 system works in this country, financial losses from public 15 liability considerations would exceed any property losses in 16 any circumstance. Perhaps not. It's a guess.
17 I, too, wanted to make a comment about the 18 containment integrity report. We've heard some discussion of i
- 19 that already, and I know that Vince Boyer and his people are 20 working hard on it. To me it's very important that we have 21 that report in a timely manner.
22 It might be helpful to give you some understanding 23 of what sometimes seemingly mysteriously drives this side of i
24 the table on some of these issues. And let me read you the 25 regulations, which you can consider the law in effect because l ._. _ _ _. _
. 59 1 they have the force of law.
2 There is a part of the general design criteria on 3 reactor containment that reads as follows, "The reactor 4 containment structure shall be designed so that the 5 containment structure and its internal compartments can 6 accommodate without exceeding the design leakage rate, and 7 with sufficient margin, the calculated pressure and 8 temperature conditions resulting from any loss of coolant 9 accident.
10 "This margin shall reflect consideration of - " and 11 I'll skip the first point because that's the one you're more 12 use to hearing. But then the second point is, "the limited
< 13 experience and experimental data available for defining ik 14 accident phenomena and containment responses. And three, the 15 conservatism of the calculational model'and input parameters."
t 16 Without saying more I think that's enough said.
- . 17 We've got to uphold the law in our regulations in this regard, 18 and I view this matter as a matter that needs your direct 19 attention so that we can make a determination here on some 20 short term basis.
j 21 MR. MILLER: We shall be addressing it promptly.
22
~
I'm not a lawyer.
23 COMMISSIONER BERNTHAL: Neither am I.
! 24 COMMISSIONER ROBERTS: You don't have to be 25 embarrassed about that.
l
. 60 1 (Laughter.)
2 MR. MILLER: I'm not embarrassed, but there may be 3 some lawyers present. I have three sons -- or two sons and a 4 son-in-law who are lawyers, so I've got to be careful about 5 it.
6 But we'll address the issue technically. We'll also 7 address the legal issue. I'll just have the lawyers give us 8 an opinion on that.
9 CHAIRMAN ZECH: Anything else?
10 COMMISSIONER BERNTHAL: I had one other question.
- 11 Have your people working on the safety goals evaluation 12 reached a determination or attempted a determination on what 13 reasonable assurance of no core melt might mean? How are you 14 going to interpret that Commission safety goal?
15 MR. FERGUSON: I'm not prepared to comment on that.
16 And I don't think we've got a member of that working group 17 here today.
13 COMMISSIONER BERNTHAL: Well, I would be interested 19 if you come up with a definition of that at some point.
1 20 MR. OWEN: We'll get back.
21 COMMISSIONER BERNTHAL: I think that's all I have 22 for th2 moment really.
23 CHAIRMAN ZECH: Commissioner Carr?
- 24 Let me just make a couple comments then, too, very 25 briefly. First of all on training, the accreditation program y + - - - - - - - - - - , - - -
,--------,-----m,- , - * , - - , - - - -
. 61 1 I think is certainly something you can take great pride in.
2 I've sensed it in my more recent visits to your plants that 3 training is more-visible.
4 And I agree with you that there seems to be a lot of 5 people involved in it,_Mr. Miller, and you're right and that's 6 important. And that's one reason why I felt that the program 7 had a chance of being such a success because you've got a lot 8 of enthusiasm for training now and you've,got a lot more 9 interest in it. A lot more professionalist and the whole 10 accreditation process.
11 I think that truly is something that you can be 12 proud of. And it is going to have, and I think it is starting 13 to show, perhaps, results. But all these programs do take 14 time. But I think that's one that's going to -- it has to be 15 helpful.
16 On the fitness for duty program, it's really just in 17 place. I think we're going to have to watch is closely. I l
18 think the only thing that concerns me, I guess, is that 19 there's enough leeway in it, perhaps, 40 that it can be 20 interpreted in a tough sort of way. sr,,t . ten naybe a way 21 that's not quite so tough. I'm hoping that it will be 22 interpreted in the tough sort of way. I think most of you do,-
23 too.
24 Certainly it's a program where we can't have people 1
25 on illegal drugs operating our nuclear plants. And there's no
. 62 El question in my mind that it's something that we'll have to
'2 watch very carefully. And I think it's too early yet to see.
3 But I think that's still -- that program is still going to 4 have to be watched. But I'm hoping it will be successful.
5 The maintenance program I think needs improvement 6 across the board. And I think there is room for improvement.
7 Some are doing better than others. I'm only encouraged, 8 frankly, by the fact that we're talking about it more these 9 days. You talked about it, Warren, in your meeting in INPO I 10 know, and you mentioned that earlier today.
11 But there's still a lot of action to take place, a 12 lot of results that are necessary. We're still -- I think 13 we're way behind the times on naintennnce. I think it should 14 have been -- emphasis should have been placed many, many years 15 ago. And even though it's started now and I'm encouraged by 16 that -- we should all be encouraged by that -- I think we 17 should recognize that there's plenty of room for improvement.
18 It's a fertile market for improved performance.
t 19 And I think if you look at some of the problems 1
20 we've had, maintenance, people problems in maintenance, 21 operational problems, maintenance people, operators, it's a 22 whole field that can be improved. And I think it does need 1 23 your' constant attention as well as ours.
l 24 Requalification program, I think has gotten I 25 attention, and I think it's perhaps improving. I think there
l l
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.- 63 l
1 is a ways to go in that program, too. I still hear complaints 2 occasionally from your people, your operators when I talk to 3 them. But I do think in general that there's enough attention 4 being given to it now. At least I'm hopeful that it's getting I 5 a little bit more where it ought to be.
6 The requalification program is not the same as the 7 . basic program as far as I'm concerned. It should be an 8 advanced level. Your operators should look to that program as 9 something meaningful, useful to them, not just a chore.
10 Certainly a little theory, it doesn't hurt anybody and we 11 review that from time to time. But it shouldn't be 12 overemphasized in the requal program.
13 It should be a program that's operator oriented,
- 14 systems oriented and safety oriented. I think we're moving in 15 that direction.
16 The programs, Jack, that you're involved in the 17 NUMARC technical subcommittee. All these programs are ones 18 that not only utilities and industry people have expertise in, 19 but here as Staff does have expertise in these technical
, 20 areas. And we have to work very closely together on it.
t 21 MR. FERGUSON: We recognize that.
22 CHAIRMAN ZECH: And I think there's going to be our p 23 biggest challenge, perhaps, because station blackout, the 24 containment areas, plant life extension, shutdown decay heat j ~ 25 removal system, all these things our people do have a fair l
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,' 64 1 amount of expertise in. We have great responsibility, as Commissioner Bernthal has pointed out.
2 We're all aware of 3 that.
4 So these are programs in the hardware area, in the 5 technical area that we have, I think, enough expertise here 6 and enough responsibility that we're going to have to work 7 very carefully in this area. I think certainly the industry 8 and the utilities have great expertise also. But it's 9 something that's a little tougher for me than some of the 10 other, what I'd consider more management oriented, perhaps, 11 program. So in the hardware programs I think it's something 12 we're going to have to work together in very, very closely.
13 And recognizing that we're talking safety and we're i
14 talking our r asponsibility very keenly from the regulatory 15 side. Now your responsibility is from the operational side, 16 maintenance and training and management and all that. I 17 respect that. But I submit again that we're both involved in 18 safety; ours from the regulatory side, yours from the 19 operation, management, training and running the plant and 20 being responsible for safety from the operational standpoint.
21 Our roles is different is all, but the goals are the 22 same. It means we should work together, and as Jim Miller 23 points out, with respect and trust. That's important. I 24 think your organization is lending a great deal of -- is 25 making contribution, a positive contribution towards not only
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, 65 1 .your -- not only the nuclear industry in our country but to 2 our responsibilities as well. And in that way, we're all 3 together better serving the American people.
4 And so I think working together in these programs is 5 extremely important. We've got to be professional. We've got 6 .to lay our cards on the table. We've got to recognize that 7' our goal is the same of safety of operation, but our roles are 8 a little bit different and we come at it a little different.
9 So when we can work together with respect and mutual 10 understanding and honesty, I think we are indeed serving the 11 American people properly and as we should, i 12 So we've covered an awful lot of ground today. I 13 would just like to say, Jim, on behalf of all of my colleagues 14 here how much we appreciate the leadership you've shown in 15 NUMARC in a very interesting and difficult time when we're 16 really just getting started. I would like to commend you on 17 behalf of the Commission for your efforts.- On the part of 18 your colleagues also your efforts in working so closely with 19 resp"ect and trust with the Commission, which I think you've
. 20 done.
21 But mainly I think you've served the American people 22 and helped us serve the American people. So tnat I thank you 23 very much for the leadership you've shown. And I know you're 24 going to continue to support the NUMARC organization, the new 25 organization whatever it might turn out to be, and this
t*
.o 66 1 industry for many, many years in whatever status you might be 2 in. So we all thank you for your contribution very much.
3 MR. MILLER: Thank you, sir.
4 CHAIRMAN ZECH: Are there any other comments from my 5 fellow Commissioners?
6 [No response.]
7 CHAIRMAN ZECH: All right, with that we stand 8 adjourned.
9 [Whereupon, at 3:34 p.m., the Commission meeting was 10 concluded.]
11 .
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14 15 16 17 18
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1 2 REPORTER'S CERTIFICATE 3
4 This is to certify that the attached events of a 5 meeting of the U.S. Nuclear Regulatory Commission. entitled:
6 7 TITLE OF MEETING: Periodic Meeting with NUMARC (Public Meeting) 8 PLACE OF MEETING: Washington, D.C.
9 DATE OF MEETING: Thursday, November 20, 1986 10 11 were held as herein appears, and that this is the original 12 transcript thereof for the file of the Commission taken 13 stonographically by me, thereafter reduced to typewriting by
{^
14 me or under the direction of the court reporting company, and 15 that the transcript is a true and accurate record of the 16 foregoing events.
17 18 --------Pamela k-- Bri _----- ------
19 20 21 '
22 Ann Riley & Associates, Ltd.
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