ML20215M536
| ML20215M536 | |
| Person / Time | |
|---|---|
| Issue date: | 05/07/1987 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8705140005 | |
| Download: ML20215M536 (99) | |
Text
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I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
Title:
Briefing on State of the Nuclear Industry (Public Meeting)
Location:
Washington, D. C.
Date:
Thursday, May 7, 1987 1
i Pages:
1 - 62 l
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Ann Riley & Associates Court Reporters 1625 1 Street, N.W., Suite 921
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Washington, D.C. 20006 (202) 293-3950 hD 870507 l
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This is an unofficlaf transcript of a meeting of the 7
United States Nuclear Regulatory Commission held on S
5/07/87 In the Commission's office at 1717 H Street, 9
'li.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
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. inaccuracies.
13 The transcript is intended solely for general 14 informational purposes.
As provided by 10 CFR 9.1CS, it is 15 not part of the formal or informal record of decision of the 16 matters discussed.
Expressions of opinion in this transcript 17 do not necessarily reflect final determination or beliefs.
No 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
1 1
UNITED STATES OF AMERICA f'.
2 NUCLEAR REGULATORY COMMISSION 3
4 BRIEFING ON STATE OF THE NUCLEAR INDUSTRY 5
6 PUBLIC MEETING 7
8 Nuclear Regulatory Commission 9
Room 1130 10 1717 "H" Street, N.W.
11 Washington, D.C.
12 13 Thursday, May 7, 1987 14 15 The Commission met in open session, pursuant to 16 notice, at 2:35 o' clock p.m.,
LANDO W.
ZECH, Chairman of 17 the Commission, presiding.
18 19 COMMISSIONERS PRESENT:
20 LANDO W.
ZECH, Chairman of the Commission 21 FREDERICK M. BERNTHAL, Member of the Commission 22 KENNETH M. CARR, Member of the Commission 23 24
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STAFF AND PRESENTERS SEATED AT COMMISSION TABLE:
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2 S.
Chilk 3
W.
Parler 4
A.
Bates 5
J.
Conway 6
S. Smith 7
B.
Lee 8
J. Taylor 9
10 11 12 13 14 1
15 16 17 18 19 20 21 22 23 24 25
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PROCEEDINGS
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2 CHAIRMAN ZECH:
Good afternoon, ladies and 3
gentlemen.
I apologize for keeping you waiting.
Commissioner 4
Asselstine is on travel and won't be here today and 5
Commissioner Roberts is not participating in today's meeting.
6 Today's meeting is the annual briefing by the Atomic 7
Industrial Forum on the state of the nuclear industry.
We.are 8
here to hear from a distinguished panel of nuclear industry 9
leaders on the issues that they believe are of great
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10 importance.
11 The nuclear industry organizations in the United 12 States have been reviewed by the nuclear industry and I 13 understand an extensive reorganization initiative is underway.
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14 I understand, for example, that the Atomic Industrial Forum 15 itself will soon be absorbed into other organizations which 16 will focus the industry resources on addressing the needs that 17 they feel are of greatest importance.
18 We are here today to hear about some of these 19 reorganization initiatives as well as other industry 20 improvement initiatives including NUMARC activities and 21 technical policy issues.
22 I hope that the reorganization that you are 23 undertaking will have a positive effect and a positive impact 24 on safety and will enhance our joint goal of providing the 25 benefits of nuclear power to our fellow citizens in a manner
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1 that assures that the public health and safety will be 2
protected.
3 As I see it, the future of nuclear power in the
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4 United States is clearly dependent on the continued safe and 5
reliable operation of our nuclear power plants.
We at the NRC 6
are committed to safe operation of our licensed power plants.
7 I am confident 'that you have that same commitment.
8 I have recently seen this quote from the industry 9
group, "A unanimous recommendation and recognition by all 10 segments of the nuclear industry that we must do more as an 11 industry to strengthen the quality of our operations and to 12 strive for a level of excellence that is truly beyond-13 reproach."
14 I commend you for that attitude and I challenge you 15 to live up to it.
When the industry reorganization was first 16 brought to my attention, I was told that it was to implement i
17 recommendations of the Sillin Report which is entitled, 18
" Leadership in Achieving Operational Excellence" and it was 19 published in August of 1986.
20 I endorsed this report as courageous and meaningful 21 with initiatives that I felt would bring added accountability 22 and credibility to the nuclear industry.
I believe that your 23 reorganization initiatives can strengthen the industry, 24 however, I believe that it.is essential for the nuclear 25 industry to increase its ability for se1f-evaluation and l
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1 identification of both good and marginal performers.
2 I hope that this new reorganization will follow 3
through on the commitments made in the Sillin Report for 4
self-evaluation and self-improvement.
I ask you today to 5
commit yourselves to the worthwhile endeavor of improving the 6
performance and safety of nuclear power in our country.
7 Again, I commend that attitude and I challenge you 8
to live up to it.
Do any of my fellow Commissioners have any 9
other opening remarks?
10 (No response.]
i 11 CHAIRMAN ZECH:
If not, Mr. Conway.
12 MR. CONWAY:
Yes, sir.
13 CHAIRMAN ZECH:
Please proceed.
4 14 MR. CONWAY:
I am John Conway, executive vice 15 president of consolidated Edison Company of New York.
I am 16 also chairman of the board of the American Nuclear Energy-17 Council and I have been chairing a two-day meeting here, the 18 1987 Nuclear Power Assembly and as Sherwood Smith had just i
19 mentioned a few minutes ago, we had an extremely good turnout.
20 There were in excess of 300-registrants for the 21 meetings and the meetings encompassed American Nuclear Energy 22 Council, the Atomic Industrial Forum, Committee on Energy 23 Awareness, all of the electric utility associations both 24 public and power, the APPA, rural electric and EEI.
25 In the two days we spent a gre'at deal of time with
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members of the Senate and the House and their individual 2
staffs.
During our meeting we also passed a number of 3
resolutions which I will submit for the record here and would 4
identify ourselves, each and every one of us representing the 5
various organizations that are here today with you, would 6
associate ourselves with the comments you just made ant,very 7
definitely accept the challenge that you have given to the 8
industry.
9 Among the resolutions that we passed was one, and 10 these were various resolutions calling upon Congress to be of 11 assistance to us and work with us along the same lines that 12 you have just mentioned, and among the resolutions is one that 13 would call for plant standardization and licensing reform and f
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24 we hope to work with the Congress this year in furthering both 15 of those objectives.
16 This morning we are prepared to discuss the various 17 items that you had enumerated.
Sherwood Smith who is chairman 18 and president and chief executive officer of Carolina Power 19 and Light Company will discuss with you and the other 20 Commissioners the status of the nuclear industry and the 21 various initiatives we are taking to make improvements.
22 Byron Lee who is alongside of Sherwood Smith is 23 executive vice president of Commonwealth Edison Company and he 24 is president-elect of the new NUMARC organization and he will 25 discuss with you some of his objectivei and.what he plans to t
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do, p
2 Then John Taylor, vice president for nuclear power, 3
Electric Power Research Institute, will discuss with you technical policy issues. 'obviously, we will be prepared to 4
5 answer any questions you'might have and with that, I turn it 6
over to Sherwood Smith.
7 CHAIRMAN ZECH:
Thank you.
Prodeed, Mr. Smith.
8 MR. SMITH:
Thank you, Mr. Chairman, Mr. Bernthal, 9
Admiral Carr, it is a pleasure to be here and participate in 10 this report to the Commission as we view it on behalf of our 11 Nuclear Power Assembly.
12 I am president of Carolina Power and Light Company 13 and involved in the majority of the constituent organizations 14 of the assembly.
The others on the panel will discuss in some 15 detail NUMARC and the efforts of EPRI.
I will give a general 16 overview of the nuclear industry improvement initiatives and 17 will try to be reaponsive to some extent to the Chairman's 18 opening remarks.
19 But I would like to say initially that we do respond 20 positively and affirmatively to the challenge to improve and to 21 do a better job in overall operating performance and to seek to 22 achieve higher and higher levels of operating safety.
23 I think that is a goal that will never be fully 24 achieved.
I think we will always be able to find ways to i
25 improve our operations and I think that is a great
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1 responsibility that we in the industry have.
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We hope that the assessment that we give you today 3
will enable you as members of the Nuclear Regulatory Commission 4
to not only conduct your business but to better give us 5
guidance and direction through regulation so that we may both 6
seek to achieve our common goal through the performance of our 7
different roles.
8 It is, of course, about a year after the accident in 9
Russia at Chernobyl.
Mr. Lee headed the industry study of 10 what had transpired at Chernobyl.
11 The Commission itself has had its own study done and 12 I won't go into any of the details other than simply to point 13 out that, of course, it was with some degree of pleasure and i
14 one might even say satisfaction that we realize that from a 15 design and technical standpoint, the reactors that we operate 16 in this country are vastly different from the RBMK reactor 17 which caused the accident in Russia.
18 Yet, on the other hand, one is also aware that even 19 though the design of the Russian plant was the fundamental 20 root cause of what happened that t
.e were operator errors there and that personnel in any plant must be carefully 21 22 trained.
There must be consistency.
23 There must be just eternal vigilance with the 1
24 performance of anyone in any operatinj plant and we understand 25 that and we accept that and we feel that throughout this
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country there are thousands of people at work today doing an 2
excellent job in the operation of nuclear power plants.
3 Yet from time to time one sees deviations.
Those 4
deviations are unacceptable totally and completely and must 5
be eliminated and that is our responsibility and we also 6
recognize the role of the Nuclear Regulatory Commission in 7
taking appropriate action where that may be necessary.
8 Our first goal is with respect to the safe operation 9
of our existing plants.
We also have a goal to complete in a 10 timely and safe way those approximately 18 to 20 units that 11 are still under construction and bring them into full service 12 for the benefit of the citizens that we serve in a safe and in 13 an environmentally acceptable way.
14 Last year in the United States the over 100 units 15 generated about 17-percent of our total electric supply.
In 16 some of the areas of the country, it was much higher than 17 that.
In New England, it was much higher.
In the Southeast, 18 it was much higher.
19 For example, in the two Carolinas where our company 20 operates, 12 operating units will provide over 40-percent of 21 the electricity generated there this year.
22 We are committed, as I said, to the highest standards 23 of safety.
I think every chief executive officer and senior 24 official must keep that constantly in mind or on a daily 25 basis.
In addition to our compliance with the requirements of l
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the Nuclear Regulatory Commission in a parallel way through the 2
Institute of Nuclear Power operations, we have undertaken a i
3 number of initiatives that are now coming to fruition and one 4
can measure demonstrable improvement in achievement there.
5 For example, 1986 marked the third year in a row 6
when the average man rem exposure was down.
It was down to an 7
average of five man rem per year.
That is far below the goal 8
of three rem per quarter which would be 12 rem per year which 9
is the minimum requirement of the NRC.
10 our unit availability on average was not up but that 11 was because of problems with a very few plants that were out 12 of service for extended periods of time.
If you delete those, 13 our unit availability was up consistently and we believe that 14 there is a relationship between safe performance and better 15 operating performance.
16 We think that long term safety and long term economic 17 results go hand-in-hand and that you cannot achieve long-term 18 efficient economic operations without full adherence to all of 19 the requirements of safety.
20 We are pleased that the performance of our units in 21 terms of capacity factors averaged 71.6 percent.
That set a 22 new record.
Several achieved individual records.
23 A second major goal of our industry as I said is to 24 assure that the plants that are under construction are 25 completed and INPO has played a role in'the. construction I
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evaluation auditing of those plants.
That role on INPO's part 2
is phasing down as those plants are completed.
3 We have noted that the recent study entitled,
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" Energy Security" that was coordinated by the Department of 5
Energy but in which approximately 13 federal agencies 6
participated again warned about the potential dangers of heavy l
7 dependence upon foreign oil and one of the beneficial aspects a
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of our nuclear plant performance has been a substantially 1
9 reduced dependence upon the importation of foreign oil.
10 An Atomic Industrial Forum study that has been 11 completed recently has demonstrated that if we were able 12 through standardization, more expeditious licensing and the 13 early resolution of issues and disputes that we should be able 14 to build plants in six years and we should be able to build 15 plants that compete very favorably with not only others in the j
16 world but with any other source of fuel, particularly fossil 17 fuels, coal and oil.
18 We are preparing the way to proceed towards 19 standardization both through INPO and through the Electric 20 Power Research Institute.
We are gathering data.
In parallel, 21 the manufacturers are also proceeding with their designs for a
22 what we would call the advanced light water reactors.
23 We appreciate very much the support provided at the 24 Commission level for the concept of standardized plants, a
25 more expeditious licensing and more eariy. resolution of
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important issues.
/
2 One of our goals, of course, involves the nuclear 3
fuels cycle.
We are very interested in seeing that we maintain 4
an adequate supply of uranium enrichment and fabrication in-5 this country and we are very interested in seeing that the back 6
end of the fuel cycle as we have described it is effectively 7
handled in accordance with the provisions of the Nuclear Waste 8
Policy Act of 1982.
9 To the extent that the Commission will be interacting 10 with the Department of Energy in connection with the Department J
11 of Energy's characterization of the three sites that have been-j 12 identified in Texas, Nevada and Washington, we would hope that 13 that process would receive the attention of the Commission as i
14 well as the Commission staff and that there would be an 15 expeditious review of the Department of Energy's work there and 16 we certainly trust that that will be the case.
17 Through INPO one of our very significant areas of 18 achievement was in training.
We now have 65 branches of our 19 national nuclear training academy and some 610 programs that 20 have been or are being accredited.
21 I was pleased that our company, we have four units 22 at three different sites, was the first multi-unit / multi-site 23 utility to have all of its programs accredited.
We have 12 24 utilities that are full members of the academy.
That means 25 that all of their programs are accredited..
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I think that when one looks back to the early
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2 discussions of what was needed by way of improvements and 3
training, it was questioned and I think understandably so, as 4
to whether or industry had the capability of achieving this 5
much this quickly with thoroughness and with diligence and 6
effectiveness.
7 But we have and we are very proud of what INPO, in 8
particular, has been able to do there.
9 INPO has also developed and is administering a s
10 course for senior nuclear plant managers.
The'first session l
11 of this course has been conducted.
The second one is finishing 12 this week.
13 We are very pleased with the results.
I think that 14 perhaps members of the commission may have visited those 15 classes and seen the type of curriculum that is presented.
16 Another of our utility goals working through INPO is 17 to establish long range goals particularly using ten 18 performance indicators realizing that no one performance 19 indicator or no perhaps set of performance indicators in and 20 of themselves gives one the complete guidance that should be 21 followed in the operation of nuclear power plants but they 1
22 certainly give you a great deal of important information 1
23 and they chart a direction.
24 The utilities have set these goals using the INPO 4
25 indicators and significant improvement i'n all areas is being
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1 achieved.
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There is a commitment to achieve improvements in the 3
knowledge base of our own industry people who are working in 4
the plants.
INPO has expanded its peer evaluator, its 5
corporate evaluation adviser and its industry observer programs 6
in 1986.
7 The body of technical expertise which is being 8
developed and the dissemination and understanding and use of 9
that expertise is improving every year.
10 Another important program that grew significantly 11 last year was our Human Performance Evaluator System.
This is-12 a voluntary program conducted under the INPO umbrella.
We now 13 have 23 utilities that participate including two from beyond 14 the United States.
15 We are seeing positive results in all areas of plant 16 operations.
Sometimes when there is publicity and naturally 17 so of problems at different locations, it is impossible to 18 place those in the complete context of what is happening at 19 every plant on every shift but if one were able to do that, 20 despite the problems which are totally unacceptable, I think 21 one would have a feeling of steady improvement in the level of 22 our operations around the country.
23 Much of the direction for this improvement has come 24 from the report that has been mentioned, " Leadership in Achieving operational Excellence" that was. produced by Admiral 25
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Dennis Wilkinson, Mr. Lee Sillin, Mr. Mark Rowden.
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privileged to work with Bill Lee of Duke Power Company and Jim 3
O' Conner of Commonwealth Edison on the steering committee and j
4 I followed it closely.
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5 I am very much personally committed and I think my G
feeling is representative of our industry that indeed se must j
7 go forward and implement those recommendations in improving 8
our operational performance and improving the way in which we 9
respond to and interface with the Nuclear Regulatory 10 Commission.
11 And as Byron Lee will discuss in a few minutes, the 12 establishment of NUMARC as a permanent staffed organization to 13 interface with the NRC, we think is going to go a long way in y i l
14 improving our performance.
15 The nuclear utility management and resources 16 committee, NUMARC, has two key objectives.
We are going to 17 use our industry operational and technical knowledge to 1
18 improve safety and reliabiatty and we are going to provide a 19 unified line of communication with the NRC with respect to 20 those matters.
21 The Atomic Industrial Forum, one of the original 22 constituent groups of the Nuclear Power Assembly, is in the 23 process of doing two things.
Its substantial technical 24 expertise is being merged into NUMARC in all of those areas 25 relating to the operation of nuclear poker plants in this
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country.
2 The other technical expertise which it has in its 3
public information function is being merged with the 4
U.S. Committee for Energy Awareness and the new organization j
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will be called the U.S. Council for Energy Awareness.
6 We understand the responsibility that we have to 7
communicate effectively to the public.
Public understanding 8
and acceptance is tremendously important for the further 9
development of our industry.
10 As John Conway said, the American Nuclear Energy 11 Council will continue very much as it has-before to be the i
12 industry's prime trade association for interfacing on 13 government affairs, particularly legislative affairs and with 14 the executive branches of government.
15 I had mentioned NUMARC.
We have an umbrella group 16 that was established in 1979 as a response to what occurred at 17 Three Mile Island and that group was initially called the TMI 18 Oversight Committee.
It later became the Utility Nuclear 19 Power Oversight Committee.
20 It is made up of representations from the eight 21 major groups here before you today presenting the report of 22 the Nuclear Power Assembly and it is being strengthened to 23 serve as an umbrella organization and its name is being 24 changed to the Nuclear Power Oversight Committee to represent 4
25 the fact that we will have vendors and architect / engineer r
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representatives as part of the board structure.
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As I said, I think we have made major strides in the 3
last few years since INPO has been set up.
We have lowered.
4 the number of unplanned scrams. -We have reduced the amount of 5
waste.
We have lowered the number of significant events that 6
are reported each year.
7 We realize that our job is far from done and we have 8
neither the right to rest on our laurels nor do we have 9
laurels upon which to rest.
I think that our industry has 10 demonstrated, however, its ability to do the job that needs to I
11 be done and if one visited the plants and saw what transpired,-
i 12 I think that everyone who was a knowledgeable observer would i
13 conclude that.
14 Our responsibilities towards self-improvement and 15 the industry's responsibility for the assurance that federal 16 standards are adhered to in its overall integrated safety-17 approach toward the utilization of nuclear power are 18 complementary.
They are different roles but we have the same 19 goals of-safety and reliability.
20 As I said, we are proud of what the industry has 21 done.
We still have far to go and we assure you of our i
22 commitment to excellence and the diligent efforts that we will 23 make to achieve that.
I would like to pause now, I will be 24 available, of course, for any questions and ask if Mr. Lee may 25 proceed.
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CHAIRMAN ZECH:
All right, proceed.
2 MR. LEE:
Thank you, Mr. Chairman and Commissioner 3
Bernthal and Carr.
It is a pleasure for me to be here.
It 4
has been several years since I have appeared before the 5
Commission.
Today I am here in a slightly different role even 1
6 though the card says, " Executive VP of Commonwealth Edison," I 7
guess I am really here appearing as the president and CEO of i
8 the newly formed NUMARC.
9 I would like to talk a little bit today about the 10 status and the mission and how we can hopefully work together 4
11 with the Nuclear Regulatory Commission to improve the operation 12 of our country's nuclear power plants.
13 When the Sillin report recommended the establishment 14 of a' unified nuclear utility industry organization that would t
15 interface with the NRC in a better fashion, many in the I
16 industry felt we already had the basic elements in the Nuclear 17 Utility Management and Resources Committee that had been in i
18 existence about three years.
19 That committee had been interacting frequently with 20 the staff at the NRC to identify areas where improvements 1
h 21 could be made in our operations.
22 A positive course of action had been taken on a 23 number of issues in our mind and we believe through this 24 process an increased sense of cooperation and trust had 25 developed between the NRC and the industry.,
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We view our new organization really as just an 2
opportunity to build further upon those successes.
3 The Nuclear Management and Resources Council, the 4
word " utility" has been dropped from the title, it has now 5
expanded beyond just the utility industry and the committee is 6
now a council, will retain the acronym NUMARC and it was 7
established to provide a unified nuclear power industry 8
approach on generic regulatory and technical issues.
9 Its responsibilities include coordinating the 10 combined efforts of licensee utilities and other industry 11 organizations that are NUMARC participants and I will explain 12 a little bit about the organization in a few minutes in all 13 matters involving regulatory policy issues and on the 14 regulatory aspects of operational and technical safety issues.
15 NUMARC serves as the industry's principal mechanism 16 for conveying our views, our concerns and our policies to the 17 NRC and other governmental agencies when they are involved.
18 NUMARC will also initiate industry self-improvement efforts 19 when we feel they are necessary and direct attention to and 20 act on regulatory issues that the NRC considers important.
21 NUMARC will carry out its responsibilities by 22 drawing upon the knowledge, operational and technical i
23 experience and safe operational responsibility of the entire 24 nuclear industry and i think there is a tremendous capability 25 out there.
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We seek to improve the industry's effectiveness in r~
2 developing and analyzing information concerning the generic 3
regulatory and technical issues and to improve the quality and 4
constructive character of contributions made by the industry 5
to the regulatory analyses and decisions.
6 NUMARC has two categories of membership.
One is 7
that of a member and will consist of the utilities, all 8
utilities, who hold operating licenses or construction permits 9
for nuclear power plants and as of this morning, all of the 10 utilities in the country who have OL's or CP's have agreed to 11 be members except for one and that is strictly a technicality.-
12 There is a board meeting tomorrow and so we are assured that 13 they, too, will be members.
So we have a full slate of 4
14 membership.
15 The second category is that of participant and is 16 comprised of the NSSS vendors, the architect / engineers and 17 consulting organizations that have been deeply involved in 18 plant design or construction and then the owners of interests 19 in nuclear power plants who are not the licensees.
20 The board of directors'will consist of one 21 representative appointed by each member utility and we have 22 those members all ready appointed.
They represent the chief 23 executive officers, the chief operating officers or the top-l 24 nuclear executive in the company so we have a very high level s
25 group of representation on our board and as.well, the six
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participant representatives will be elected to the board by 2
the members.
3 The executive committee is elected by the board and 4
includes the 12 representatives along with six participant i
5 representatives of the board.
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6 Actions of the board adopting formal industry I
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7 positions or policies on major regulatory issues impacting
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8 utilities require an affirmative vote of 80-percent of the 9
utility membership of the board.
i I might say that is basically the same policy 10 11 that was followed in the NUMARC committee as a committee.
12 Participant members of the board do not vote on such 13 positions or policies or on other issues primarily affecting 14 the utilities.
15 The goal for the implementation of NUMARC was July 1 16 of this year.
We are still holding to that date and are 17 making significant progress.
We were incorporated on April 1
18 7th and we have our initial board meeting of directors 19 designated.
20 The nominating committee of the board has designated i
21 Robert Campbell, the president and chief executive officer of 22 the Pennsylvania Power and Light Company who has also been the 23 chairman of the response and implementation committee that has 24 been working on the reorganization for six or eight months, I i
25 guess, Sherwood, as the chairman of the board.
I will be
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NUMARC's president and chief executive officer and Joe Colvin,
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2 who is. sitting right behind me and I believe you all know, who 3
has been INPO's director of government relations will be th's 4
executive vice president.
5 We will be integrating the licensing and regulatory 6
functions previously conducted by the Atomic Industrial Forum 7
as Sherwood said in our working organization over the next 8
several months.
By July 1, we expect to have the initial 9
staff and temporary office set up and be in business.
10 Near the and of this year, we hope to be in our 11 permanent offices on 18th and Eye and to be successful though,-
12 we must be working closely with the industry and with the 13 industry and with the Nuclear Regulatory Commission, we
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14 believe the two major repositories of nuclear operational i
15 safety expertise, to further enhance the operational 16 excellence.
17 I hope that this objective is an objective that we 18 all share and I am sure it io as you have said, Mr. Chairman.
4 19 Working towards a common objective utilizing the combined 20 expertise of the NRC and the industry will serve to benefit 21 all of us and our country, t
22 To sum up, NUMARC represents a new unified nuclear i
23 industry that is focusing on a wide range of regulatory 24 issues, can exercise initiatives to enhance safety, and is dedicated to improving communications between the industry and 25
23
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1 the NRC.
2 The NUMARC committee, by establishing a coordinated 3
industry management approach, has had a positive impact, we i
4 believe, in its three years of existence.
We can identify the 5
results and we can see how NUMARC has provided a closure 6
mechanism on several generic issues.
7 The NRC, for its part, has been willing to take 8
industry initiatives into account and to work cooperatively 9
with the industry and give recognition to several of our 10 programs.
11 You have also been willing to consider alternative 12 regulatory approaches that recognize our efforts and are 13 consistent with your regulatory responsibilities.
Continuation 14 of these cooperative efforts will enable us to move further 15 down the road to operational excellence, which, in the end, is 16 our common objective.
17 Again, I would like to thank you for your time.
I 18 hope that I have been able to transfer some of the enthusiasm 19 that I sense in talking to the industry top executives for the 20 endeavor that we are embarking on but much of our success 21 certainly depends on a good working relationship and mutual 22 respect that the NUMARC committee had started in our minds.
23 I might say that I am excited by the prospect of 24 what we together will be able to achieve and I look forward to 25 being here many more times in the future.
3 24 1
CHAIRMAN ZECH:
Thank you very much.
We appreciate gs 2
it.
Proceed.
Thank you.
3 MR. TAYLOR:
Chairman Zech, Commissioner Bernthal, 4
Commissioner Carr, although we are still living with the 5
repercussions of the Soviet Nuclear Power Plant accident at 6
Chernobyl, intensive evaluation of the information given to us 7
by the Soviets on the Chernobyl reactor characteristics and on 8
the course and consequences of the accident have substantially 9
clarified our perspective of the accident and its implications 10 to U.S. commercial plants as compared to a year ago when we 11 discussed these matters with you.
12 This work has led to several major conclusions.
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13 First, the design and institutional differences between the 14 Chernobyl-type, water-cooled graphite reactor and U.S.
light 15 water reactor power plants are so fundamental that the Soviet 16 accident should not impact the processes of design and 1
17 regulation of U.S. nuclear reactors.
18 Second, the Chernobyl accident confirms U.S. choices l
19 in nuclear technology, supported by our public regulatory 20 program.
A very deliberate determination was made at the 21,
foundation of the U.S. nuclear industry that we could not 22<
tolerate the same risks as other industries.
23 From the beginning, conservative reactor plant and 24 containment designs, higher safety standards, defense-in-depth, 25 and operating discipline were imposed. 'Our. record of j
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protecting the.public is an affirmation of this safety
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philosophy.
Continued striving for excellence in all these aspectsisstlIIlassential.
3 4
Third, comparisons made between the Soviet accident 5
and the less severe Three Mile Island accident lead to very g"f
?
6
.important observations.
The TMI-2 accident caused no physical 7
harm to the public or the plant's workers, primarily due to 8
defense-in-depth design features-including a full containment.
9 However, the TMI-2 accident identified weaknesses in
/
10 U.S. reactors and their methods of operation.
Major 11 improvement efforts were made as a result which are continuing-12 to this day.
13 Now as satisfying as these conclusions are, they do i
14 not engender a sense of complacency in the industry.
A 15 Chernobyl accident response plan has been developed and 16 approved the Utility Nuclear Power Oversight Committee which 17 outlines three major areas of work.
18 First, to complete further detailed evaluation of 19 the accident incorporating additional information provided 20 by the Soviets, emphasis being placed on documenting the 21 industry's best estimate of the actual Chernobyl source term 22 and reconciling variations in source term estimates to date, 23 in estimating long range health effects, land contamination 1
4 24 and decontamination methods and in evaluating emergency 25 planning and response at Chernobyl.
~
j t
i l
26 1
Secondly, to review the adequacy of the present 2
U.S. nuclear plant designs and operations in light of the 3
overall Chernobyl experience.
Emphasis is being placed on i
4 four broad topics, reactivity coefficients, core neutronic 5
stability and the design and operational features which 6
protect U.S.
light water reactors against prompt criticality.
7 Second, containment issues.
Although the lack of 8
full containment in the RBMK was not a cause of the accident, 9
this factor, of course, had a direct impact on the seriousness 10 of its consequences.
11 Comparisons between LWR and RBMK approaches to 12 containment already testify to our more comprehensive and 13 conservative approach to public protection.
The ability of 14 U.S. containments to withstand beyond design basis events, as 15 demonstrated in probabilistic risk assassments and industry 16 degraded core analysis, and by the TMI accident, should 17 continu4 to be evaluated and documented.
i 18 Areas of specific focus include pressure suppression 19 designs, the possible need for containment venting and plant 20 emergency procedures.
21 Third, occupational and plant risk from severe 22 accidents.
Areas of specific focus here include protection 23 for operators and emergency response personnel, implementation 24 of the recently issued NRC Severe Accident Policy and.
25 multi-plant site safety considerations."
i i
27 1
Operational safety.
The issue of paramount 2
importance in this review is to continua striving to achieve 3
operational excellence through an enhanced posture of 4
self-improvement and self-regulation.
5 Operator training programs, extensive use of 6
simulators, operating experience and safety review programs 7
must be maintained at the highest possible level.
Areas of 8
specific focus in the response plan include U.S. utility 9
policies for control of testing, management oversight of 10 operational safety, operating staff accountability and staff 11 training on severe accidents.
12 The final element of the response plan is that the 13 industry seek out opportunities for improved international s
14 cooperation in nuclear safety that can help improve reactor 15 design and operations over the globe.
16 Two papers have been prepared by the Industry 17 Technical Review Grou'p on Chernobyl, chairad by Byron Lee and 18 approved by UNPOC, which detail the summary statement I have 19 just made and are available to you.
20 They are "The U.S. Nuclear Industry Position Paper 21 on the Chernobyl Nuclear Plant Accident in the Soviet Union" 22 and the "U.S. Nuclear Industry Plan of Response to the Soviet 23 Nuclear Plant Accident at Chernobyl."
24 I would like now to discuss briefly one of the 25 repercussions of the accident with which we.are still living.
28 1
Prior to the accident, the industry and NRC were moving on a
', - ~
2 slow but convergent course toward resolution fo the source 3
term which comprises the key technical bases for estimation of 4
public risk in the event of a severe accident.
5 The accident has disrupted that progress, although 6
at this time, we have found nothings about the accident which 7
significantly changes the technical bases for the U.S. reactor 8
source term work.
9 The draft report NUREG-1150 has been billed as a 10 major step in firming up NRC's technical position in this 11 area.
We have not completed our evaluation of this voluminous-12 set of documents but offer the following comments based on our 13 initial review.
14 We certainly applaud the intent of the effort which 15 is to provide a comprehensive record of the technical bases 16 for source term evaluation and even more importantly to 17 establish quantitative uncertainty bands on the key physical 18 phenomena and risk-dominant accident scenarios.
19 We are concerned, however, that this intent has not 20 been achieved even though it is evident that substantial 21 effort has been devoted to preparation of NUREG-1150.
22 One of the findings of the report is that none of 23 the plant modifications considered appear to be significantly 24 cost effective in reducing risk and this is certainly in 25 agreement with the judgments and conclusions coming from the T
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industry studies to date.
,~
2 One of our concerns is that'the "Delphi" process of 3
using expert judgment to assign uncertainty bands appears 4
insuf'ficiently disciplined and is poorly documented so that 5
an outsider cannot assess the validity of the judgments.
6 In the written testimony given to you, I have given 7
an example of that from the report and I will not take the 8
time at this point to go over it.
9 Now EPRI has used expert judgment to flesh out a 10 sparse data base in its recent reassessment of seismic hazard 11 in the eastern United States.
Our experience demonstrated the-12 importance of assuring that the process was disciplined and 4
13 carefully structured, that all experts had a common data base 14 and were required to document the bases for their judgments, 15 and finally-that all experts participated in workshops in 4
16 which they received feedback both from their peers and from 17 the results of the calculations.
18 I note that NRC and the U.S. Geologic Survey 19 geoscientists attended the workshops and are now completing a 4
20 review of this work.
For its next version of NUREG-1150, we 21 recommend that NRC establish a similar process and involve 22 experts from industry organizations.
23 Furthermore, we recommend the introduction of an 24 interim step prior to the elaborate calculation of 25 uncertainties.
It is to use an integrated deterministic I
,-----g---
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30 1
methodology, such as that used by IDCOR to define the risk 2
dominant scenario, do best estimate evaluations of the 3
resulting radioactive releases and consequences, and then to 4
vary key parameters in a sensitivity study.
5 This approach provides a more scrutable product for 6
peer review and greater insight into which phenomena are 7
important.
We expect that this work will show that the end 8
values are sensitive to some parameters which can be eliminated 9
from the subsequent uncertainty estimates.
10 Best estimate calculations and sensitivity studies 11 require that major attention be placed on the verification and-12 validation of the codes used.
In NUREG-1150, a substantial i
13 number of calculations were performed and reported utilizing e
i 14 codes which have never been published, let alone verified and 15 validated.
16 These codes which industry is using for its 17 evaluations have been published, and are in the' process of 18 verification and validation in recognition of this need.
19 The industry has applied this deterministic process 20 in its evaluation of four typical nuclear plants and has 21 concluded in the IDCOR program that each is adequate to assure 22 public safety in accordance with NRC criteria.
23 The industry is now ready to start to apply such an 24 evaluation process to each U.S. plant as soon as NRC staff 25 endorses the methodology.
It is important that the current t
l i
31 1
cost benefit criteria be applied as that work proceeds.
2 The overall concern with the NUREG-1150 draft is 3
that it is not contributing to the convergence process.
It is t
4 not narrowing down the areas which require the most attention 5
to reach a satisfactory state of knowledge to permit realistic 6
regulatory decisions to be made.
s, 7
The uncertainty bands have grown since the 8
publication of WASH-1400, the original safety study, by factor 9
of more than 100 in spite of intensive experimental work, 10 analytical methods development and the opportunity to evaluate l
n 11 severe accident data from TMI-2.
12 In view of the many millions of dollars of R&D money 13 that have been spent to date, serious question is raised as to 4
14 the efficacy of continued R&D on this matter.
In' light of the 15 NUREG-1150, of what value will be the $50 million dollars 16 which is planned to be expended by NRC Office of Research on i
17 the source term?
18 The industry too has expended a substantial amount 19 of R&D effort on the source term with the expectation that 20 uncertainties would be reduced by the results.
i 21 In the industry's Chernobyl response plan, an a
22 increase in source term R&D is proposed, a significant portion i
23 of which would be performed under the EPRI program.
Until we 24 have understood the significance of the lack of technical 25 convergence in NUREG-1150, the source term element of the
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32 1
industry response is being deferred.
I 2
Greater assurance is needed that the money and 3
skills to be spent by the utilities on source term R&D will be 4
utilized meaningfully.
We are not encouraged in this respect 5
by the NUREG-1150 draft because the industry results are 6
relegated to an appendix and nowhere in the evaluation or the 7
devel'opment'of uncertainty bands do we find those results 8
being used direction.
9 In summary, we urge that the mechanistic approach to 10 severe accident evaluation, which has been an accepted basis 11 for many years, be reinstated in the NUREG-1150 evaluation and-i 12 that the "Delphi" process of using expert judgment be i
13 implemented in a disciplined and documentable form.
14 Industry results and industry's expertise should be 15 applied directly in those evaluations.
A more cooperative 16 effort is consistent with the common goal of both NRC and the 17 nuclear utility industry to minimize the risks from a severe' 1
18 accident and to assure the safety of the public.
19 Of substantial additional importance to the utilities s
20 is the assurance of the safety of their multi-billion dollar 21 plant investment.
Thank you very much.
22 CHAIRMAN ZECH:
All right.
Thank you very much.
23 Does that conclude your presentation?
24 COMMISSIONER CARR:
That concludes our portion.
25 CHAIRMAN ZECH:
Thank you very~much.
Comments from i
33 j
1 my fellow Commissioners, Commissioner Bernthal?
2 COMMISSIONER BERNTHAL:
I have a number of comments 3
and questions.
Maybe I will start with you John.
I had-4 better start with a disclaimer first.
John and I have not 1
5 talked with each other since staff presented NUREG-ll50 here i
6 but I hear a lot of echoes here of the issues that I raised at 7
that meeting.
I 8
I couldn't agree with you more that the Delphi 9
process and generally the way that we have handled 10 uncertainties in publishing NUREG-1150 needs a very serious 1
11 look.
I not long ago was out at the Sandia laboratory and
+
1 12 spoke with the people who carried out the work.
They are a 13 very bright group of folks and I am convinced that there is a t
14 good way to do this that is helpful to me as a regulatory i
15 official.
16 You may have one problem.
The problem at least in 17 my view on this side of the table is that I can find no 4
18 regulatory indicator in the way those uncertainties have been i
i 19 handled and it leaves us in a bit of a quandary as responsible i
l 20 officials.
21 Let me ask a couple of broad questions here and then 22 I had one or two specifics on your presentation, John, that I l
23 did want to touch on.
24 I am concerned about the sense that appears on the 25 last page of your testimony, the sense "of the industry that
9 34 1
the source term research work, NUREG-1150, is apparently in i
2 questionable enough condition at this point that if I am 3
reading you correctly, the electric utility industry is going 4
to withhold further support at least at some level for more -
5 research in that area until you are convinced that the effort will indeed lead to meaningful results.
6 7
,I understand that in a way and I share your specific 8
concern and, in fact, I was forced to testify on the Hill, 9
well, not forced to but I found it necessary to testify on the 10 Hill a week or two ago that in my judgment, our research 11 budget at this point was adequate by default.
12 What I meant by that was that it wasn't clear that 1
13 we would know what to do with another $50 or $100 million 14 dollars even if we were offered it at this point.
It sounds 15 like you are saying much the same thing.
16 What I am concerned about then and maybe you can 17 answer is the broad commitment that exists within the industry, 18 the electric utility industry, generally to support the kind of I
19 basic research that would be consistent with a $100 billion 20 dollar plant investment as you now have.
21 I am hearing signals that suggest that the focus is going to be away from basic research investment in the years 22 23 ahead.
Maybe you could comment just briefly on that.
24 MR. TAYLOR:
I would like very much to do that, I
25 Commissioner, because I don't want my statement to be I
35 1
misunderstood.
The utility industry is sponsoring a very f~
.2 strong R&D program at EPRI which encompasses safety issues 3
directly and a variety of important issues in reliability i
4 including maintenance of technology that are fundamental to-i 5
effective operation and I know you are also vitally interested 6
in.
7 There is no movement to decrease that overall 8
effort.
In fact, in just the past few weeks the Institute has 9
increased the overall nuclear power division budget by a 10 couple of million dollars to provide increased supps -*. to the 11 NUMARC operation, new NUMARC operation, which is undergoing.
12 What we are saying is that there are many things for 1
13 us to do with that money and if we are not going to get 14 results in a given area, there is no point in spending money 15 there.
It is rather to put that money on other matters.
They 2
16 might well be safety issues but not in the severe accident i
17 subject.
18 l
That is what we have to re-examine in light of the j
19 bottom line message from NUREG-ll50.
If extra research increases uncertainty, then from a practical standpoint what 20 21 is the point of carrying it on?
22 COMMISSIONER BERNTHAL:
All right.
Fair enough.
I 23 would hope that the broad commitment, not just on source'termt, 24 but the broad commitment of this industry to the fundamentals in this business, to the fundamentals of re. search that relate 25 i
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1 to the nuclear power industry for sure, and I would hope other 2
areas as well though, has not diminished and that efforts are 3
being made to justify that to those state officials that are 4
responsible for approving such investments.
5 MR. TAYLOR:
I see no indication of that broad 1
6 commitment being diminished.
7 COMMISSIONER BERNTRAL:
Good.
I am glad to hear 8
that.
I would make one comment, John, on the statement that l
9 the accident at Chernobyl disrupted the source term progress 10 in this agency or words to that effect on page four of your 4
11 testimony.
12 I don't think that was the problem.
At least, I 13 didn't sense that Chernobyl itself caused a great hiatus here 14 in analyzing or continuing with the source term evaluation or 15 knowing where to go.
16 I think NUREG-1150, itself, provided sufficient food 17 for thought that we have been in a bit of a hiatus ever since 18 it came out so I would not lay that lack of progress to the 19 Chernobyl event.
20 I also wanted to inquire specifically about a matter 21 that came up in a recent meeting that we had with 22 representatives from General Electric because I understand 23 that EPRI is working with General Electric and, of course, with their counterparts in Japan on the advanced boiling water 24 25 reactor design.
l
37 1-The proposal is, as you all know, that at some point l
2 in the not very distant future, I think their projected date 3
is 1991, they would come in here and hope to have completed a 7
4 design certification under the Commission's yet to be completed 1
5 nuclear power plant standardization policy.
6 I was particularly intrigued by the safety goal, 7
however, that I would assume with considerable support from j
8 EPRI that the GE/ Japan /EPRI consortium, if that is the right i
9 word, seems to feel they can achieve with this plant.
10 As a matter of fact, as I understand it, it was that 11 a radionuclide release, a large release from a nuclear power 12 plant accident, should not result in a dose more than 25 rem I
13 at the site boundary and that the probability for such an
!k i
14 event would be once in a million reactor years of operation.
l 15 I was intrigued by that because that not only meets 4
16 the criteria that I had been urging that the commission adopt 17 in respect to the safety goal here, but it actually exceeds it i
18 and the industry is now indicating to us that they apparently 19 can achieve that kind of safety goal.
20 John, can you comment a little bit on the level of 21 confidence that EPRI has in that safety goal al.d how you 22 arrived at that number?
23 MR. TAYLOR:
It is clearly a goal at this time, i
24 Fred, and we will not know for sure whether it is a reality 25 until all the detailed work is complate'.
We have set the d
38 1
goal on the basis that I think has been identified to you by 2
these other senior officials, that the, industry is committed 3
3 to achieving excellence and in many respects, we hope that 4
will at times exceed the minimum requirements of the Nuclear
.5 Regulatory Commission.
6 The reason we believe we can meet it is that we are i
i 7
introducing in light of experience a higher level of passive 8
safety characteristics which will put the burden off the 7
4 9
operator of having to act as rapidly as he does on the present i
10 plants.
j 11 I don't want that goal for improvement which we all i
12 are dedicated to infer that the present criteria which the 13
(
present plants are meeting is not an adequate criteria for 1
14 public protection.
i 15 We know that in every aspect that we can determine i
16 factually, we have not only achieved that protection but we 17 estimate it is a better level of protection than any other 18 major industrial type of activity.
19 So I would not like that to be the case but we know 20 that it is very valuable even to the economy of the utility
'21 industry to make those improvements and we are dedicated to j
i 22 try.
23 COMMISSIONER BERNTHAL:
All right.
Can you give me 1
4 24 a sense of a confidence level or have you tried to quantify it 1
25 at all that you place in this safety goal estimate, the goal
~
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39 1
that you have set for the' advanced boiling water reactor?
2 MR. TAYLOR:
Having reviewed the advanced boiling 3
water reactor work which has been primarily carried out by GE i
4 and the Japanese, I have a substantial level of confidence 5
that they can achieve the goals they have sited to you.
6 They have gotten into a substantial amount of detail 7
and the evaluations from that design detail of the reduced 8
need for immediate operator response which is the heavy 1
9 element of achieving that, I think is there.
10 our work is trying in some instances particularly 11 the small reactor studies to carry it even further and it may -
12 not represent a change in that criteria but an even greater
]
13 assurance that in the practical everyday world that we live in i
14 when those plants are operated, they are even better assured 15 to meet those criteria.
4 I
16 COMMISSIONER BERNTHAL:
All right.
I am tremendously j
17 encouraged by that kind of goal.
I think that is what it is i
la going to take in this business as a safety goal in the years j
19 ahead and I would hope that following the lead now of the d
)
20 industry in this area that that kind of stringent goal finds 1
i 21 its way into the Commission's own safety goal deliberations.
22 I think I am going to defer one or two other things 23 here and give my colleagues a chance and if there is some time 24 left, we will come back over maybe.
4 25 CHAIRMAN ZECH:
All right.
Com'missioner Carr.
i j
40 1
COMMISSIONER CARR:
I only have one comment and that 1
2 is where you put your money and your industry emphasis in the 3
next short period of time and I think that should be on 4
maintenance and human performance.
5 I think those are the areas where we can make the 6
greatest strides and I think we should make every effort to 7
get away from two standards of maintenance, one in the reactor 8
plant and the other in the balance-of-plants.
I think we 9
should only have one standard of excellence and maintenance 10 and it should be throughout the plant.
11 CHAIRMAN ZECH:
All right.
Thank you.
Just a 12 comment on the NUREG-1150 comments, I certainly appreciate 13 your views and recognize that this is a controversial 7
\\
14 publication.
15 Perhaps that is good, we are getting a lot of 16 interest in it and maybe we will get some good responses.
I 17 hope though, I think that the uncertainties are real in there 18 and apparently they are pretty tough.
19 I had' hoped some time ago that with perhaps a little 20 more optimism that we would be able to move ahead with this i
21 but it is my understanding that those uncertainties are very difficult and they are real but I hope you are not going to 22 l
23 defer your efforts in this regard as I kind of read your j
24 message, too.
25 I would be disappointed if you'did.that even though 4
41-1 the challenge is very real and it looks like a tough problem,
.f" 2
I think we are making progress but we certainly expect the 3
industry to continue their efforts in this regard and we i
j 4
welcome critical comments of the NUREG or any other procedures 1
{
5 we are taking.
4 6
Just because a problem is hard, I don't think, we i
7 should walk away from it and I think we should move forward as i
i 8
best we can recognizing it is tough but maybe that is why we i
9 need a little more effort and not a little less.
10 As far as NUMARC is concerned, that is the new 11 NUMARC, I guess I would refer you to your page 10 of your l
12 remarks in the bottom paragraph where you say, "The 13 recommendations" and this is the Sillin Report you are talking 14
- about, "The recommendations of the report covered three main i
15 areas.
First, improving operational performance of nuclear j
16 power facilities; second, improving the nuclear utility 17 industry interface with NRC; and third, establishing a unified i
18 nuclear utiiity industry organization."
19 Now those are all_three areas of great importance, I 20 agree and I would hope that you could focus a lot of attention j
21 on the first area, improving operational performance of 22 nuclear power facilities.
I 23 I think the way I would read it is that the second 24 and third areas you are talking about there are really
)
25 established perhaps to accomplish the fi'rst.one.
The first t
l i
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42 1
one is improved operational performance of nuclear power
/"
i 2
facilities.
3 I submit there is room for improvement as you have 4
indicated and I think that in the NUMARC effort, your new 5
organization, I am certainly going to be watching to see what 6
you are doing to improve operational performance and the 7
Sillin Report gives you some challenges.
8 I think they are real.
I think it was a good report 9
and I think NUMARC's challenge is to implement those kinds of 10 improvements in a real sort of way, not just organizationally 11 or diagramatically or mechanically but in a real sort of way,-
12 real improvements.
13 My view is that there are improvements in the 14 operations of nuclear power plants in our country but that 15 doesn't mean that we can't improve more.
I returned not too 16 long ago from a trip to Finland, went through a plant in 17 Finland, the Lovisa plant.
They have been operating between 18 90 and 93-percent capacity for several years.
You never hear 19 figures like that in our country.
20 I submit and I hope that you are perhaps watching 1
21 some of those other countries.
I would like to hear from one 1
22 of you on what kind of real interface do you have with your
\\
23 overseas counterparts?
Are you interfacing directly with the 24 international program?
x 25 I know you are doing that through INPO and through i
43 1
IAEA.
I have seen representatives of our industry at those t
2 conferences, but I guess on an operational basis, are we 1
3 really studying, are you studying what they are doing in 4
their plants?
5 You know, capacity factor is not everything.
Don't 6
get me wrong.
Safety is what it is all about but they are j
7 managing those kinds of factors with safety and operating in a 8
reasonably good manner.
9 Now I know that some of the plants in our country l
{
10 are operating extremely well, also, but I think we can learn i
11 perhaps from others outside of our country as well as inside j
{
12 our country.
4 13 Can you tell me anything specifically you are going
)
14 to perhaps learn the lessons of some of our overseas nuclear i
15 power plants?
16 MR. TAYLOR:
Mr. Chairman.
17 CHAIRMAN ZECH:
Yes, John.
18 MR. TAYLOR:
I will answer it in part from the J
l 19 viewpoint of our activities.
We have technical exchange i
20 arrangements with essentially all the major countries to range id 21 through the utilities through which we do on a continuing 1
22 basis gain the benefit of their experience and I will give a l
23 few examples.
1 j
24 One of our problems, of course, in the boiling water j
25 reactors has been the pipe cracking that has occurred.
The
44 1
Swedes have been pioneers in boiling water reactors and have, 2
in fact, a better operational record than we do.
3 We have engaged the utilities 'in our owner's group 4
activities as an active participant.
They have been willing, 5
in fact, to not only lend us their skills but some of their 6
money and we have under contract their contractors, like ASEA 7
Atom, to provide us with their operational experience in water 8
chemistry, in particular, so that we can in a detailed way use 9
that information.
10 We have a series of cooperative efforts with 11 Electricite de France.
One I will identify to you.
We are 12 pooling records of operator response in emergency conditions 13 on simulators with the object of being able to develop a 14 quantification of operator response which can be used to 15 improve the probabilistic risk assessments as well as the 16 treatment of procedures, operator training and so on in the 17 future.
18 We pool our data.
We are pooling our analyses so 19 that we can both share each other's experiences.
20 CHAIRMAN ZECH:
But is that information getting at 21 to our licensees and are they doing something about it?
22 MR. TAYLOR:
All that information is disseminated to 23 our members.
If there is a safety issue, we inform all the 24 utilities.
25 CHAIRMAN ZECH:
But do they us's it.?
Do you have any
4 45 1
track?
Can you run a thread through and say, "Well, we I
2 learned that.
EPRI involved ourselves in it and now it is in 3
that plant.
Here is what they are doing."
l 4
MR. TAYLOR:
Yes, sir.
i
}
5 CHAIRMAN ZECH:
Who tracks that?
{
6 MR. TAYLOR:
One of or technology transfer methods l
7 is to develop what we call guidelines synthesizing a lot of i
8 fairly esoteric scientific information into more simplified i
j 9
guidelines the people in the field can use.
j 10 They are disseminated to the utilities.
INPO not 11 only helps us in developing them but then is a recipient of t
12 those guidelines and uses them as part of their good practice i
13 philosophy.
14 CHAIRMAN ZECH:
All right.
}
15 MR. TAYLOR:
I will tell you one more example if I
)
16 might.
l 17 CHAIRMAN ZECH:
Go ahead.
i s
18 MR. TAYLOR:
There are many but it is very recent, 19 erosion / corrosion problem, a single phase.that was of evidence 20 from the surry-2 accident.
We got within a matter of weeks a voluminous amount of information from Central Electricity 21 22 Generating Board in the U.K. and from Electricita de France on 23 this subject which we were able to incorporate into initial i
24 information for purposes of utility action in this area.
It is vital information that would have taken ps years to develop 25 t
i
- ~
46 1
if we had to start from scratch.
j, ~.
2 COMMISSIONER CARR:
Why didn't you learn that before 3
the accident?
4 MR. CONWAY:
Why didn't we have it before the 5
accident?
6 COMMISSIONER CARR:
Yes.
It looks we should have s
7 had it and been able to operate on it before it happersd.
1 1
1 8
MR. TAYLOR:
Obviously, we can and I have asked that i
9 question myself.
Have you ever had an event whether it be an i
10 accident or an unexpected result on a test that doesn't 11 suddenly tell you that all this information here is applicable-a i
j 12 and usable.
l 13 In fact, the significance of this subject was not-14 understood not only in the nuclear program here but in the 15 fossil program.
That is a very simple answer I can give.
Now i
j 16 if we were smarter, better, et cetera, sure.
We are going to j
17 try to be smarter and better in the future.
.i l
18 CHAIRMAN ZECH:
All right.
Well, as long as we are i
19 getting that information.
I know you are interfacing overseas 20 and I hear that from them in the many overseas countries that i have visited, but my concern is that that information get i
21 J
22 down to the operator.
i 23 MR. TAYLOR:
This maintenance initiative that i
24 Sherwood mentioned, one element of that is that we are being 1
25 loaned by EDF their senior man who has g'uided their centralized 4
i
47 1
maintenance technology program for the past decade.
He is f-.,
2 coming to EPRI for a one to two-year period to assist in I
3 framing our program based on the experience that he has.
i
{
4 May I be so bold, Admiral, as to comment on another 5
statement you made on you believe the uncertainties are real.
j 6
CHAIRMAN ZECH:
Go ahead, certainly.
We might learn 7
something.
Maybe y.ou can make them less uncertain.
8 MR. TAYLOR:
We don't believe all the uncertainties j
9 identified there are real.
j 10 CHAIRMAN ZECH:
Good.
I am glad to hear you say 11 that.
12 MR. TAYLOR:
I have given two examples here which i
i 13 evidence two reasons.
One is the use of the Delphi process.
1 j
14 The process is all right but they way it was used in our 15 judgment has led to an expansion of the bands and we have 4
given one example showing that.
16 17 The.other is in the lack of emphasis on the j
18 deterministic processes and we have given an exampla showing j
19 that.
We think with those corrective actions mentioned, these 20 uncertainty bands will come down and they will tend to center
];
around the issues that the American Physical Society peer 21 22 review identified as significant uncertainties.
23 Now another reason for our wondering whether we are i
24 spending our money effectively in this area are our data and j
25 the skills of our people has not been u' sed in this process.
x
=
48 4
1 We are willing to have,them used.
p.
I 2
CHAIRMAN ZECH:
If you give up, they will not be 3
used.
e.
]
4 MR. TAYLOR:
We are going to try.
4 5
CHAIRMAN ZECH:
Go ahead.
Don't back off then.
6 MR. TAYLOR:
But I wanted you to know that they 7
weren't used.
{
8 CHAIRMAN ZECH:
That's fine.
You have told us that 9
but you also said you are deferring action and that kind of 10 troubles me a little bit.
All I am saying is don't back away i
11 from the fight.
If you think you are right, tell us about j
12 it.
We will listen.
l lf 13 MR. TAYLOR:
We are deferring an increase in activity
\\
l 14 which we had felt was appropriate because the Chernobyl i
15 accident was just making it necessary to even go further in 1
justifying this work.
I am afraid we are going to have to 16 4
I*
17 examine that issue.
j 18 CHAIRMAN ZECH:
That's fine.
j 19 MR. TAYLOR:
That money can be used for other j
20 purposes.
1 21 CHAIRMAN ZECH:
I hear you, but if you back away 22 from it, we are not going to make much progress.
l 23 MR. TAYLOR:
We are not going to back away.
l 24 CHAIRMAN ZECH:
Don't back away from it and then 4
s.
25 come back and tell us that we are not ma' king any progress.
We J
49 1
are counting on your continued efforts in this regard and if
~-
(
2 you tell us that you are not going to do it, then don't come 3
back and tell us that we are not making any progress in our i
4 country.
You are part of the team.
5 MR. TAYLOR:
Yes, sir.
I 6
CHAIRMAN ZECH:
We talked about improvements.
Who l
7 wants to talk to me about Peach Bottom?
8 (Laughter.]
9 MR. SMITH:
Mr. Chairman, from an industry standpoint 10 the events there that I am sure you have in mind are totally L
11 unacceptable.
They are aberrations.
T h a t m a k e s t h e m n o l e s s,-
12 unacceptable.
I know that the NRC staff is there conducting a 1
]
13 very thorough investigation.
J!
14 When I say they are unacceptable, I am simply 15 stating the same thing that the chief executive of that l
16 utility has said immediately and I know they are more 17 u'nacceptable to him than anyone else in the world.
4 l
18 The company has formed a team of its independent 19 directors and they are investigated.
I believe Admiral l
20 Wilkinson is working with that team.
T}ie Institute of Nuclear l
21 Power Operations has established a team to investigate the 22 situation.
It is obviously a situation of a breakdown in 23 management at the plant and at levels above the plant that is l
24 unacceptable and I think that is as good a word as any.
i 25 I don't think it would be appro'priate for myself or s
i i
i 1
., _ - - _ _ _, _ _ ~. _ _ _ _,. _ - -. _... _. _ _. - _ _, _
_.. _ =.
i 50 j
1 I don't think anyone else has been there or been directly
'p 2
involved in it to comment on it, but after the NRC 3
investigation and the other investigations are completed, then 1
j 4-I think that the industry in the appropriate way through INPO L
1 5
and through NUMARC will address whatever activities took place 6
there to see that they never again in any plant in this 7
country or elsewhere if we can help it are repeated, i
8 CHAIRMAN ZECH:
Fine.
We have to be somewhat l
9 circumspect in our comments, too, of course, because the
~
j 10 investigation is going on and I am aware that it could come to I
)
11 us for review but I wanted to give you a chance to comment l
12 because I thought it was appropriate and I think you have ij,.
13 stated your position very well.
l\\
j 14 When we talk about improvements and all the good 15 things that we are talking about and all the efforts to 16 improve performance, that is simply something that we have to
]
17 focus on and absolutely not tolerate any kind of lackadaisical 18 performance.
i 19
]
In my view this is a demanding industry, demanding t
j 20 technology and we need to have everybody tending to business i'
21 in a disciplined, formal, business-like manner and I think it i
l 22 is absolutely vital andsI appreciate the industry, the 4
j 23 utilities, stance because it is your challenge in that regard.
i 24 Commissioner Bernthal, you had other questions?
l\\
25 COMMISSIONER BERNTHAL:
I had 'one or two things.
I i
i
51 1
didn't want to completely neglect the rest of this (n.
2 distinguished delegation here.
I wanted to touch on ene or 3
two institutional issues here.
What about the Fitness For
^
4 Duty policy statement and the industry's attempts'to conform 1
l 5
with that commission policy statement?
6 Can someone give me a quick thumbnail sketch on the i
7 progress there and perhaps also on the legal experience in l
1 8
respect to any attempts to implement Fitness for Duty programs a
j 9
within your plant?
10 By that, I mean, of course, the question of randon 4
11 drug testing that is on everyone's minds and on the minds and -
3 12 desks of various courts right now, I guess.
You i.ight in the 13 same breadth comment on whether this is unusual circumstance i
14 where a ruling might actually help you.
15 MR. CONWAY:
Fred, if I may address that for a
,i i
16 second because I have a problem right now, not in the nuclear l
17 plant but with'in the company.
As far as the legal situation, l
18 I have a letter right now to the Secretary of Labor.
l 19 I had an individual who was working for our company, not in the nuclear plant, who was on our alcoholic program and 20 21 is coming along okay but then we found out that he was using t
22 drugs.
)
23 I think we have had someone on the order of 20 to 30
{
instances where the examinations of him indicated he was using 24 25 illegal drugs.
We fired the man.
The 'Depa.rtment of Labor, 4
- - _ _ _ - - -, ~,
~-
... _... _ - - _ - _ _. _ - - - _. -. - -... - - - -... -... -,, ~. -. _ _ _
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52 4
1 their lawyers have looked at it, and said that we should not 1
2 be able to fire him.
3 Because he uses drugs, that makes him a handicapped 4
person and as a handicapped person, he has certain rights and 5
unless you can prove specifically that the' job he is doing l
6 cannot be that it is affecting his job, you cannot fire him.
7 We are arguing that if a man is using illegal drugs, i
8 refuses to stop that, we have offered to put him in a program 9
which we will pay for to try to get him off the drugs and he 10 refuses to take the program, and the Department of Labor at 11' the local level in New York has held that we cannot fire him.
12 I have written directly to the Secretary of Labor, I 7
13 think, last December.
(
14 COMMISSIONER BERNTHAL:
l j
15 MR. CONWAY:
The Secretary of Labor in Washington, I
16 D.C. personally and to the top legal officer, I think his 17 title is Solicitor and I have sent copies to him, also, and i
h 18 asked him to please review this because it is stupid, their i
1 19 position.
I 20 As of this day, I still have not gotten a response a
21 back.
I get a call, I think, every 30 days because there is
{
l 22 some kind of rule, they have to let us know that they still 23 have it under review.
I get a call, nothing in writing, i
24 saying that we still have it under review.
That is the 25 situation I am facing in a non-nuclear ' plan.t.
i
. _. ~. _.., _ _ _, _ _ _ _ _ _ -. _ _ _... _. - _. _ _... _ _ _ _ _, _. _ _.. - - _.. _. _. _..
... _ _. _... _.... -. ~.. - _,..,., _
53 1
COMMISSIONER BERNTRAL:
I was about to ask.
Thank
.l #-
i 2
you.
i 3
MR. SMITH:
Let me respond from the generic 4
standpoint if I may, Commissioner Bernthal, and others may 5
also wish to comment.
6 Sometime ago the Edison Electric Institute developed 7
an EE guide to drug and alcohol Fitness for Duty policy for 8
use by all nuclear utilities and in other areas.
In the 9
situation that John described, of course, should that occur 10 while we might struggle with the question of being able to 11 fire a person or not, you immediately reassign him.
12 You would not let a person simply because any 13 Department of Labor says you can't fire him, that doesn't mean
-t 14 that you ist him work on sensitive equipment.
So you move him 15
- out, 16 Both INPO and NUMARC have studied this question of 17 Fitness for Duty as have individual utilities.
I think it is 18 incumbent upon the industry to come out with a generic program 19 that deals not only with drug abuse but alcohol as well and in 20 my thinking, it should deal with any sort of aberrant behavior.
21 A person should not work in a nuclear control room 22 because of disease or illness or because of extreme fatigue or 23 because of depression or a mental illness as well as drug or 24 alcohol dependence.
25 We, at our company, have a pro' gram,of training our i
i i
.. _.. _. _, I
54 1
supervisors in how to observe the people that work with them t
7, 2
and we have a program of call-in.
We call it our " Quality 3
Check Program" whereby people are urged to call in and they
)
4 may call in' anonymously.
i 5
They may say, "I am concerned because my fellow 6
worker who does this, that and the other appears to be acting 7
strangely or unusually" and I don't have to give my name.
If 8
I want to follow up on what happens, I could give a number.
I 9
can say, "I don't want to give my name but my number will then 10 be number ten" and I can call back in a week and find out what i
11 happens.
12 When aberrant behavior is observed, then the person 13 is required to be testing and that is mandatory.
In the past l
14 the traditional policy, I think, has been immediate suspension 15 and, or course, we all test for drugs before you hire him now.
16 I think that the medical community and others in i
17 rehabilitation work have found that ther's is a better way.
18 Rather than immediate suspension, a program of counselling and 19 rehabilitation is better and if a person feels that they will 20 not jeopardize their job if they, in effect, turn themselves 21 in, they are more likely to report themselves and their peers 22 are more likely to report if they know they-will get the 23 appropriate attention which is what we do.
24 It is a difficult problem in society to handle 25 because you have to respect certain individual rights and i
t
55 1
rights of privacy.
However, in any safety related work such 2
as the work in a nuclear power plant, I think the safety of 3
the whole body public overrides certain individual concerns.
4 4
But I would say that it is a matter of priority with 5
our industry.
It is on the front burner and individual 6
utilities have already moved out and I think that INPO and 7
NUMARC will be addressing that.
i 8
But I think the way to do it is through supervisor j
9 training, having programs where peers are encouraged without 10 fear to report on fellow employees without feeling that they 11 would be immediately fired with strong programs of 12 rehabilitation and education.
13 You have to go at it in a very, very comprehensive
(
14 way.
i 15 COMMISSIONER BERNTHAL:
Are you prepared yet to J
i 16 address the specific question that I have had raised with me a time or two An plant visits that the uncertainty of y'our legal 17 18 situation and random drug testing, for example, might make it 19 desirable for a common standard, a legally set common standard, 20 to be promulgated by the NRC in the form of a rule?
4 21 I realize that is an unusual thing generally for our i
22 licensees to ask for a rule but I have had a suggestion or two like that at this point suggesting that it may indeed help the 23 24 situation in the courts.
Are you prepared to speak to that 25 yet?
~
x
56 1
MR. SMITH:
Not from a legal standpoint.
If it 2
would help in the courts, then that certainly is one argument 3
to do it but the way in which you control any sort of deviant 4
behavior is by good supervision and good management controls 5
at the plant.
6 You do have to deal with union contracts.
You do g
7 have to deal with rights of individual privacy but my personal 8
opinion is that a rule is not necessary.
I wouldn't call that 9
position a cop out because I don't know what it is.
1 10 COMMISSIONER BERNTHAL:
I am really not talking 11 about the implementation though.
I am talking specifically 12 about the question of your legal foundation and the strength 13 of your legal case without a rule.
Maybe this isn't the right
(
14 forum to pursue this.
I 15 MR. SMITH:
Certainly you have state laws.
You have 16 Department of Labor rules.
Anything that the NRC could do --
17 COMMISSIONER BERNTHAL:
The Constitution.
18 MR. SMITH:
-- the constitution -- to support safety 19 but we operate airplanes, we operate a lot of devices that are 20 very dangerous if not properly handled.
In my opinion, we s
21 could and should hat.dle this in the plants and we should be 22 able to observe our people and tell and have programs in place 23 that would pick it up without a rule.
24 My thinking has changed on this.
I sometimes have 25 very quick reactions that are usually w'rong.and last year as
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57 1
this whole emphasis on drugs and certain things that were 2
reported around the country, I felt that mandatory testing was 3
desirable and it would be accepted.
4 In fact, I talked with our operators and I think the 5
majority of them would have accepted'it.
But I don't think 6
that is the best way to deal with it because people can beat a 7
system and if you have a system of mandatory testing,'some of 8
the ingenious ways that have been reported, that people have 9
found there are ways to beat that system, would just astonish 10 you.
11 What you want to do is have employees who don't want 12 to be in a debilitated situation by being dependent on drugs 13 or alcohol or having other mental problems.
I think it is our s
14 responsibility to run organizations and have personnel policies 15 so that we do that.
16 MR. CONWAY:
May I also comment?
17 COMMISSIONER BERNTHAL:
Yes.
)
18 MR. CONWAY:
In my company we have a Dr. Doyle who 19 has been one of the leaders, first off in the alcoholic 20 program and now within the industry in this field, and after 21 talking with him and implementing our own program, he has 22 taken a very strong position and a lot of his associates in 23 the medical profession against the random testing and I would 24 associate myself with Sherwood Smith about how the unions j
25 feel.
~
58 1
We do test.
All our employees are required to have
=w, 2
a medical test before they receive a position, a job, with our j
i 3
company.
That is mandatory no matter how low a job it is, l
4 clerical or otherwise.
One of the things we do test for is-5 drugs and we will not appoint somebody to any kind of a 6
position, even clerical or sweeping the floors, if we find 7
they have been using illegal drugs.
We are very careful on it 8
and the tests are such that if we do see an indication if it, 9
then we go to a more sensitive type drug testing.
10 obviously, we are very sensitive to those who are 11 employed in our nuclear plant.
But the union also feels very-12 strongly about random testing.
We do have a program where 13 people can put themselves into a program and we will take them 14 into our own program.
We will pay the costs and they will not 15 lose their job.
We try to help them as we do with our 16 alcoholic program.
17 But I think Sherwood has his finger on it.
We have 18 to train our supervision to watch for this and if you begin to 19 see some behavior or given any indication and the big thing we i
20 try to impress upon our employees and particularly the 21 supervisors, these people who are using illegal drugs are 22 endangering the other employees through accidents that can 23 occur or what have you.
t 24 We similarly have a program where the supervisor is 2r expected to send them to medical becaus~e of,an indication.
s i
l l
l
59 1
There as to be some indication that the person is on illegal 2
drugs before he can be sent.
We also are against the random 3
testing.
4 COMMISSIONER BERNTHAL:
I am sure we will hear more 5
about the issue here.
I want to make one brief further 6
comment and then I will quit here.
One of you or maybe more 7
than one raised the issue of public education and, of course, 8
the context is that you are about to re-form your 9
representation in the city here to have a broader based public 10 education program.
11 You are acutely aware, I am sure, of how far behind 12 the curve you all are in this area; we are, I think, in this 13 agency.
We have not even begun to win this battle for public i
14 opinion and public confidence.
15 The American people are skeptical to say the least in the wake of the Chernobyl accident and they have every 16 17 right to be.
That is something we are going to live with for 18 a long time.
19 But it is of great interest to me and to you, I 20 know, that a recent poll also showed how perceptive the 1
21 American people are about their understanding of the i.asue.
22 Seventy percent of them said that they felt that they needed 23 to know more about issues that surround nuclear power and 24 radiation and the dangers of radiation.
25 There has been a massive failure in education in
~
~
- - J
60 9
1 this country and Lord knows, it is not all at the doorstep of I I 2
the industry.
It is throughout our educational capabilities 3
wherever they might be.
We have all failed in that respect.
4 I would hope that there is a renewed effort and a f
5 renewed commitment to getting the facts before the American 6
people in this area perhaps without any editorializing, just 7
raw, bare facts so that they can learn to judge for themselves 8
and I would hope that there is a tradition established in 9
whatever efforts you make that it is nothing but the facts and i
10 then I think the American people will reach the right 11 conclusions.
12 That is the end of my editorial comment and I 13 appreciate all you gentlemen being with us today.
14 CHAIRMAN ZECH:
Commissioner Carr, anything further?
15 COMMISSIONER CARR:
No, Mr. Chairman.
16 CHAIRMAN ZECH:
Let me just thank all of you and say 17 we have talked about a number of problems and we have mentioned 18 improvements and there are improvements.
I think that is 19 important to recognize and I encourage all of you to continue 20 to focus your efforts on improved performance so that we can 21 see more reliable and safer plants.
I think it is important-22 that we recognize though that there are improvements.
23 There are mistakes made occasionally and when 24 see the mistakes, they ought to be faced up to, treated with
(
35 appropriate action but recognizc that t'here,are a lot of good t
e 61 1
things going on, too, and it is important to encourage those f
2 good things and the many good people we have in our regulatory i
3 agency and the competent professional dedicated staff we have 4
here as well as those people in the industry that I have seen 5
many times that are also dedicated to safety.
6 I think it is important to remember we have the same 7
goal, the regulators and the regulated and as you form this 8
new industry, Byron and that part of NUMARC that is going to 4
9 interface with us, I hope we can have a very productive and 10 constructive and arms-length as it should be, but professional 11 relationship so that we can accomplish the common goal and the 12 common goal is public health and safety to supply nuclear 13 energy to our fellow citizens in a safe manner.
~
14 That is our common goal.
That is our goal.
We come 15 at it from different ways.
Our role is regulation and l
16 framework and government policies demanding performance and 17 compliance and enforcement when necessary.
18 But your role is operations, maintenance, management 19 and that is your role and we come at it but our goal is the 20 same and I think it is important to recognize that and also to 21 recognize that the importance, the absolute crucial importance 22 of operating our plants safely in a responsible manner, not just wita senior leadership like you at the table today but 23 24 all the way down in your organizations, all the way down to 25 everyone in the organization and not ju'st the operators either 1
i l
~*
- ' * " ' ' ' * ' ' " ' ' ' ~ ~ ' '
- 4 62 1
but the maintenance people, the equipment operators, the
(.
2 security people.
They are all part of the team.
3 So that is a challenge for us and for you.
But I 4
think that your efforts and your focus on improvements, your 5
willingness to face the challenges that you have laid out for 6
yourselves are encouraging and I commend you for that and ask 7
you to just remember the great responsibi,lity we all have, we 8
on this side of the table and you on that side of the table 9
for safe operations of these plants to contributing to a 10 better life for the citizens of our country.
11 Thank you very much.
12
[Whereupon, the meeting of the Nuclear Regulatory Commission was adjourned at 4:05 o' clock p.m.,
to reconvene at 13 14 the Call of the Chair.]
15 16 i
)
17 4
18 19 20 21 22 23 24 25 s
l t
1 t'~
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:.Brp.efi'ng on State of the Nuclear Industry 8
PLACE OF MEETING:
Washington, D.C.
9 DATE OF MEETING: Thursday, May 7, 1987 10 11 were held as herein appears, and that this is the original 12 transcript thereof for the file of the Commission taken 13 stenographically 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
- D 2Jk-g i i 2-----
19 20 21 22 Ann Riley & Associates, Ltd.
23 24 25
.,,-,---,..,-,---_.y
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SCHEDULING NOTES TITLE:
BRIEFING ON STATE OF THE NUCLEAR INDUSTRY SCHEDULED:
2:00 P.M.,
THURSDAY, MAY 7, 1987 (OPEN)
DURATION:
APPROX 1 1/2 HRS PARTICIPANTS:
INDUSTRY REPRESENTATIVES 50 MINS AND AGENDA
- OVERVIEW AND REPORT ON INDUSTRY IMPROVEMENT INITIATIVES, REORGANIZATION SHERWOOD SMITH CHAIRMAN, PRESIDENT, AND CHIEF EXECUTIVE OFFICER CAROLINA POWER AND LIGHT COMPANY
- NUMARC ACTIVITIES, AGENDA IN TRANSITION i
BYRON LEE, JR.
EXECUTIVE VICE PRESIDENT COMMONWEALTH EDISON COMPANY
- TECHNICAL POLICY ISSUES JOHN TAYLOR, VICE PRESIDENT ELECTRIC POWER RESEARCH INSTITUTE
~
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4 a
.---r
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,a T
f Presentation by John J. Taylor Vice President - Nuclear Power Electric Power Research. Institute To the Nuclear Regulatory Commission On the State.of the Nuclear Industry May 7, 1987 CHERNOBYL ACCIDENT AND THE SOURCE TERM i
Although we are still living with the repercussions of the Soviet nuclear power plant accident at Chernobyl, intensive evaluation of the information given to us by the Soviets on the Chernobyl reactor characteristics and on the course and con-sequences of the accident have substantially clarified our perspective of the accident and its implications to U.S.
commercial plants as compared to a year ago when we discussed these matters with you.
Tnis work has led to several major conclusions:
1.
The design and. institutional differences between the Chernobyl-type, water-cooled graphite reactor and U.S.
light water nuclear power plants are so fundamental that the Soviet accident should not impact the processes of design and regulation of U.S. nuclear reactors.
The acci-j dent does point up the importance of the emphasis that the U.S.
plants place on high-quality training and procedures, and strict adherence to administrative controls.
2.
The Chernobyl accident confirms U.S.
choices in nuclear technology, supported by our public regulatory program.
A very deliberate determination was made at the foundation of the U.S. nuclear industry that we could not tolerate the
~
same risks as other industries.
From the beginning, con-servative reactor plant and containment designs, higher safety standards, defense-in-depth, and operating i
t
_ _... _. _ _., _.. _ _. _ _ _ - - _ _. _ _. _ _ _. -. ~... _ _ _ _.. -.. _.. _. _. _. _
n f
)
discipline were imposed.
Our record of protecting the-public is an affirmation of our safety philosophy.
Continued striving for excellence in all these aspects is still essential.
3.
Comparisons made between the Soviet accident and the less severe Three Mile Island accident lead to very important observations.
The TMI-2 accident caused no physical harm to the public or the plant's workers, primarily due to defense-in-depth design features including a full contain-ment.
However, the TMI-2 accident identified weaknesses in U.S.
reactors and their methods of operation.
Major improvement efforts were made as a result, which are continuing to this day.
I As satisfying as these conclusions are, they do not engender a sense of complacency in the industry A Chernobyl accident i
response plan has been developed and approved by the Utility Nuclear Power Oversight Committee (UNpOC) which outlines three l
major areas of work:
1.
Complete further detailed evaluation of the accident, incorporating additional information provided by the Soviets.
Emphasis will be placed on documenting the industry's best estimate of the actual Chernobyl source i
term and reconciling variations in source term estimates to l
date, in estimating long-range health effects, land contam-
)
ination and decontamination methods, and in evaluating emergency planning and response at Chernobyl.
l l
2.
Review the adequacy of the present U.S. nuclear plant designs and operations in light of the overall Chernobyl
(
experience.
Emphasis la being placed on four broad topics:
1-l (a)
Reactivity coefficients, core neutronic stability, and the design ~and operational features which protect U.S.. -
x,}
LWRs against prompt criticality.
Areas of specific focus include low power and new fuel conditions, advanced core designs, and sequences involving an improper bypass of protection systems.
(b)
Containment issues.
Although the lack of full con-tainment in the RBMK was not a cause of the accident, this factor had a direct impact on the seriousness of its consequences.
Comparisons between LWR and RBMK approaches to containment already testify to.our more comprehensive and conservative approach to.public protection.
The ability of U.S.
containments to withstand beyond design basis events, as demonstrated in PRAs and industry degraded core analysis, and by the TM1 accident, should continue to be evaluated and documented.
Areas of specific focus include pressure j
suppression designs, the possible need for containment venting, and plant emergency procedures.
(c)
Occupational and plant risk from severe accidents.
Areas of specific focus include protection for' opera-tors and emergency response personnel, implementation 1
of the recently issued NRC Severe Accident Policy, and multi-plant site safety considerations.
(d)
Operational safety.
The issue of paramount importance in this review.is to continue striving to achieve operational excellence through an enhanced posture of self-improvement and self-regulation.
The. inherently safer reactors in the U.S. must not give rise to operational complacency.
The Sillin report, which was initiated over a year ago and was drafted essentially in its final form before Chernobyl, is particularly timely in this respect.
Operator training programs, extensive use of simulators, operating experience and safety review programs must be maintained at the i
highest possible level.
Areas of specific focus in the response plan include U.S. utility policies for control of testing, management oversight of opera-tional safety, operating staff accountability, and staff training on severe accidents.
f l
The final element of the response plan is that the industry seek out opportunities for improved international cooperation in nuclear safety that can help improve reactor design and operations over the globe.
r Two papers which have been prepared by the Industry Technical Review Group on Chernobyl, chaired by Byron Lee and approved by a
f :
d I
UNPOC, detail the summary statement I-have just made and are being provided for your information today.
They are "The U.S.
Nuclear Industry Position Paper on the Chernobyl Nuclear Plant Accident in the Soviet Union" and the "U.S. Nuclear Industry Plan of Response to the Soviet Nuclear Plant Accident at Chernobyl."
l l
1 would like now to discuss briefly one of the repercussions of the accident with which we are still living.
Prior to the accident, the industry and NRC were moving on a slow but con-vergent course toward resolution of the " source term" which comprises the key technical bases for estimation of public risk in the event of a severe accident.
The accident has disrupted that progress, although at this cine, we have found nothing about the accident which significantly changes the technical bases for the U.S.
reactor source term work.
i The draft report NUREG-1150 had been billed as a major step in firming up NRC's technical position in this area.
We have not completed our evaluation of this voluminous set of documents, but offer the following comments based on our initial review.
We certainly applaud the intent of the effort, which is to provide a comprehensive record of the technical bases for l
source term evaluation, and even more importantly, to establish l
quantitative uncertainty bands on the key physical phenomena I
and risk-dominant accident scenarios.
We are concerned, however, that this intent has not been achieved, even though it isevidentthatsubstantialefforthas{beendevotedto preparation of NUREG-1150.
I One of the findings of the report is that none of the plant l
modifications considered appear to be significantly cost-l effective in reducing risk.
This is in agreement with the judgments and conclusions coming from the industry studies to date. -,.
I.
f One of our concerns is that the "Delphi" process of using expert judgment to assign uncertainty bands appears insuf-ficiently disciplined and is poorly documented so that an outsider cannot assess the validity of the judgments.
l'd like to cite an example to illustrate our concern.
Evaluations of I
the Surry reactor source term carried out prior to NUREG-ll50
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by both industry and NRC have identified the "V sequence", a i
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check valve failure in the decay heat removal system as the j
dominant risk accident sequence contributing 70-80% of-the total risk. 'In fact, the central value quoted in NUREG-ll50 based upon NRC calculations substantiates that conclusion.
In the expert opinion approach, it was decided to select
" pessimistic" cases in which direct containment heating and high-pressure sequences were made dominant issues..The basis for this selection appears to be an arbitrary and " pessimistic" walkthrough of the cont;inment event tree and source term uncertainties.
This approach extended the range of risk variation and clearly contributed to the wide range in the uncertainty band.
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EPRI used expert judgment to flesh out a sparse database in its recent reassessment of seismic hazard in the Eastern United 4
States (Charleston earthquake issue).
Our experience demon-strated the importance of assuring that the process was' disci-1 plined and carefully structured, that all experts had a common database and were required to document the bases for their judgments, and finally that all experts participated in work-shops in which they received feedback both from their peers and from the results of the calculations.
I would note that NRC and USGS geoscientists attendad the workshops and are now completing a review of this work.
For its next version of NUREG-1150, we recommend that NRC establish a similar process and involve experts from industry organizations.- EPR1 staff l
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would be pleased to assist NRC by making available its'exper-ience in the Delphi process and by participating in the workshops.
I Furthermore, we recommend the introduction of an interim step prior to the elaborate calculation of uncertainties.
It is to use an integrated deterministic methodology, such as that used by IDCOR or in Level 2 PRAs, to define the risk-dominant scenario, do best-estimate evaluations of the resulting radio-active releases and consequences, and then to vary key para-meters in a sensitivity study.
This approach provides a more scrutable product for peer review and greater insight into which phenomena are important.
Hopefully, this work will show that the end values are insensitive to some parameters which can be eliminated from the subsequent = uncertainty estimates.
Best estimate calculations and sensitivity studies require that major attention be placed on the verification and validation of 5
the codes.
In NUREG-1150, a substantial number of calculations were performed and reported utilizing codes which have never been published, let alone verified and validated.
The codes which industry is using for its evaluations have been published, and are in the process of verification and validation in recognition of this need.
1 An example of the lack of attention in NUREG-1150 to l
i deterministic physical processes is in the evaluation of j
factors that might increase radioiodine releases from the j
primary system and containment sump at the Zion plant.
The evaluation indicates a rise in the iodine source term by as auch as four orders of magnitude, a surprising result for two reasons.
Revolatilization of iodine from the primary system has been included in industry analyses for some time, and it was found to have a relatively small effect for Zion.
Also, it i
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is well known that iodine will tend to remain in water solutions that are alkaline, and yet no consideration apparently was given to estimating the pH of the sump water in evaluating this factor.
It does not seem appropriate to use l
such effects to enlarge the uncertainty band of this contribution.
j There is a major inconsistency in the treatment of common cause failures.
The report acknowledges that common cause failures are plant-specific but uses a generic approach.
Many of the dominant accidents are driven by common cause failures.
A correct plant-specific treatment of common cause failures can radically change the risk perspective as reported in the pie 4
charts for core damage frequency.
Since the subsequent source term analyses are heavily driven by these interim results, we believe that it is especially important to do the best possible iob on this systems analysis.
Your Office of Rcssarch has been i
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working with EPRI to prepare more refined analysis procedures 4
for common cause failures and to benchmark their use.
We
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recommend that the next version of NUREG-1150 incorporate the i
NRC/EPRI plant-specific methodology for common cause failures.
A major concern with the NUREG-1150 draft is that it is not contributing to the convergence process, i.e.,
narrowing down the areas which require the most attention to reach a satis-l factory state of knowledge to permit realistic regulatory decisions to be made.
The uncertainty bands have grown since the publication of WASH-1400 by a factor of more than 100, in 1
spite of intensive experimental work, analytical methods development, and the opportunity to-evaluate severe accident data from TMI-2.
In view of the many millions of dollars of R&D money that have been spent to date, serious question is raised as to the I
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efficacy of continued R&D on this matter.
In light of the NUREG-1150, of what value will be the $50 m'illion which is planned to be expended by NRC Office of Research on the source tern?
The industry too has expended a substantial amount of research and development effort on the source term. with the expectation that uncertainties would be reduced by the results of our R&D.
In the industry's Chernobyl response plan, an increase in source term R&D is proposed, a significant portion of which would be performed under the EPRI program.
Until we have
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understood the significance of the lack of technical convergence in NUREG-1150, the source term element of the industry response will be withheld.
Greater assurance is needed that the money and skills to be spent by the utilities
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on source term R&D will be utilized meaningfully.
We are not l
encouraged in this respect by the NUREG-1150 draft, because the
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industry results are relegated to an appendix and nowhere in the evaluation or the development of uncertainty bands do we find those results being used directly.
In summary, we urge that the mechanistic approach to severe accident evaluation, which has been the accepted basis for many years, be reinstated in the NUREG-1150 evaluation and that the "Delphi" process of using expert judgment be implemented in a l
disciplined and documentable form.
Industry results and industry's expertise should be applied directly in'those evaluations.
A more cooperative effort is consistent with the common goal of both NRC and the nuclear utility industry to 1
minimize the risks from a severe accident and to assure the safety of the public.
Of substantial additional importance to the utilities is the assurance of the safety of their multi-billion dollar plant investment.
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[]/#Ig,i tp,y Yl RESOLUTION ggg NUCLEAR ENERGY VIABILITY p d A b d.v Q W f 5 & l (/97F)
WHEREAS, this nation and many of its allies and trading partners are likely to.become more dependent in the future on oil imports, particularly from suppliers in the Persian Gulf and other' members of the Organization of. Petroleum Exporting Countries (OPEC) ;
WHEREAS, higher import dependence would increase the risk of major supply disruptions that are damaging to our nation's economic well-being and energy security; WHEREAS, the increased use of nuclear-generated electricity can further reduce dependence on foreign oil and contribute to this nation's energy security; WHEREAS, since 1974, nuclear energy has been responsible for about one-third of the generating capacity that has been added-in the United States to meet the growing demand for electricity and to reduce the need for oil and natural gas; WHEREAS, the nation now has more than 100 operating nuclear power plants that provide approximately 16 percent of the country's electricity, increasing to over 20 percent by the early 1990's; WHEREAS, according to the U.S. Department of Energy. report entitled " Energy Security:
A Report to the President of the United States," the nation by the year 2000 will need approximately 100 gigawatts of new electric generating capacity j
(beyond plants now under construction) to maintain adequate electricity supplies; and, RHEREAS, coal and nuclear energy are proven, domestically-secure, 4
abundant and economic sources of electricity, and together can provide the bulk of our electricity requirements for decades to come; 1
THEREFORE, be it resolved that representatives of the Boards of Directors of the American Nuclear Energy Council, the American Nuclear Society, the American Public Power Association, the Atomic Industrial Forum, the Edison Electric Institute, the National Rural Electric Cooperative Association, and the U.S.
Committee for Energy Awareness, meeting jointly on May 7, 1987 in l
conjunction with the Nuclear Power Assembly, reaffirm our.
I commitment to the efficient and safe use of nuclear energy for the g(neration of electricity and urge Congress and the Administration to take the necessary and appropriate actions j
necessary to maintain nuclear energy as a viable. energy source for the future.
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RESOLUTION PRICE-ANDERSON RENEWAL I
WHEREAS, the authority of'the Nuclear Regulatory Commission (NRC) to enter into new indemnity agreements for licensed nuclear facilities expires on August 1, 1987, unless Congress extends'the Price-Anderson Act prior to that time;-
WHEREAS, the authority _ of the Department of Energy (DOE) to indemnify government contractors also expires on August 1, 1987;.
WHEREAS, Price-Anderson provides a valuable benefit to the public by. establishing a system for the prompt and equitable settlement of public liability claims resulting from a nuclear accident', - as well as predictable levels of liability for the industry; i
WHEREAS, Price-Anderson, through' an industry-wide risk sharing arrangement, provides greater financial protection ~to the public than would'otherwise be available; THEREFORE, be it resolved that representatives of'the Boards of-Directors.of the American Nuclear EnergyfCouncil,.the American Nuclear Society, the American.Public Power Association, the j
Atomic Industrial Forum, the Edison Electric Instituta, the-National. Rural Electric Cooperative Association and the U.S.
Committee for Energy Awareness, meeting jointly May 7, 1987 in t
conjunction with the Nuclear Power Assembly,-recommend that:
1.
Congress act expeditiously to renew and extend the Price-i Anderson Act; and, 2.
Congressional renewal of Price-Anderson should include:
(a) 3 the retention of a reasonable overall_l'imit on liability;
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(b) continued authorization for the NRC to issue indemnity agreements for licensed nuclear facilities; and (c) continued authorization for the DOE'to enter into indemnity agreements with government contractors.
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RESOLUTION NUCLEAR POWER PLANT STANDARDIZATION & LICENSING REFORM s
.WHEREAS, nuclear energy is a reliable generating option which has-substantially helped reduce the Nation's dependence on imported oil; WHEREAS, nuclear energy is often perceived by the utility industry and the financial community as a risky investment, owing.
to the large and uncertain capital requirements, long lead times needed to license and construct a plant, and regulatory difficulties in including the costs in the rate base:
WHEREAS, these risks are compounded.by a licensing process that has become inherently unstable and unpredictable; L
WHEREAS,-other countries build nuclear power plants, based on 1
American technology and using comparably rigorous safety standards, in four to six years, while these same plants take up to 14 years to build in the United States; WHEREAS, adoption of a standardized approach to nuclear power-plant design and construction would. increase the confidence of investors and rate payers that original cost estimates will not change drastically, that construction schedules will be maintained, and that the, efficiency and safety of the plants will'
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be further enhanced; i
j WHEREAS, effective public involvement in nuclear power. plant' l
siting would be enhanced by reforming the licensing process tio provide for early public participation; WHEREAS, the use of p're-approved standardized designs in l
conjunction with one-step licensing.and other regulatory i
improvements offers many practical benefits and cost savings, including valuable efficiencies in construction practices, personnel training, maintenance procedures, spare parts programs, i
and overall plant operations; WHEREAS, the cost of electricity from a standardized nuclear I
power plant is believed to be competitive-with =rr ;t.;;;;r *'-a any other energy resource for providing new electric generating 4
capacity; Q,y WHEREAS, standardization would provide a major stimulus to the revitalization of the nuclear option;'
WHEREAS, legislative changes are necessary to create an environment supportive of the development and deployment of-nuclear energy and to obtain the full benefits of-standardization:
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b THEREFORE, be it resolved that representatives of the Boards of Directors of the American Nuclear Energy Council, the American Nuclear Society, the American Public Power Association, the s
Atomic Industrial Forum, the Edison Electric Institute, the National Rural Electric Cooperative Association, and the U.S.
Committee for Energy Awareness, meeting jointly on May 6, 1987 in conjunction with the Nuclear Power Assembly, recommed that:
1.
A combination of administrative actions by the NRC and legislative actions by Congress be undertaken in order to restore rationality and predictability to the licensing process for nuclear power plants in the U.S.; and, 2.
Congress enact nuclear power plant standardization and licensing legislation that includes: (a) standardization-of plant design, (b) early site approval, (c). hybrid hearings, and (d) one-step licensing; and, 3.
Independently, but in direct support of these legislative proposals, the NRC change its policies and regulations in order to establish a regulatory environment conducive to the development of standard designs and the submittal of new applications for nuclear power plants, including the granting of Design Certifications.
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RESOLUTION URANIUM INDUSTRY AND ENRICHMENT PROGRAM i
WHEREAS, adequate electricity is an essential-ingredient for a aodern, _ growing economy; WHEREAS, coal and uranium are the two principal energy sources for additional central-station, electrical generating capacity;-
WHEREAS, the national interest requires that the nation not j
become overly dependent on any foreign source of. energy, including uranium; i
WHEREAS, the national interest, including national security, is served by maintaining a domestic uranium mining industry; WHEREAS, the Department of Energy, under.the requirements of the
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Atomic Energy Act of 1954, as amended,_has determined that the I
domestic uranium mining industry is not viable; l-
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WHEREAS, the national interest also requires the. maintenance of a j
reliable and economic domestic uranium enrichmant capability to 4
ensure that the U.S.
remains competitive with foreign sources of supply; j
WHEREAS, the organizational structure of'the DOE uranium enrichment enterprise has been identified as a major reason for i
the non-competitive position of the DOE enrichment activity in the world market; WHEREAS, electric utilities have already paid to the Federal government the full cost of uranium enrichment production for civilian uses; and, WHEREAS, the intent of the " Uranium Revitalization and Tailings
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Reclamation Act of 1986" (S.1004), as reported by the Senate i
Energy Committee last year, was to revitalize the U.S.
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mining industry and to assure a long-term dependable and competitive U.S. uranium enrichment program:
THEREFORE, be it resolved that representation of the Boards of Directors of the American Nuclear Energy Council, the American
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Nuclear Society, the American Public Power' Association, the i
Atomic-Industrial Forum, the Edison Electric Institute, the National Rural Electric Cooperative Association, and the U.S.
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Committee for Energy Awareness, meeting jointly on May 7, 1987 in conjunction with the Nuclear Power Assembly, reaffirm our commitment to the U.S. nuclear energy commercial-program and urge that Congress support a comprehensive, equitably balanced legislative package which effectively resolves the major issues l
currently inhibiting a competitive domestic nuclear fuel' cycle.
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RESOLUTION NUCLEAR WASTE MANAGEMENT WHEREAS, the nuclear energy industry intends to assure the safe and permanent disposal of nuclear spent fuel and high level waste frem its plants:
WHEREaS, utility customers are financing the Department of Energy's (DOE) nuclear waste management program; WHEREAS, the DOE has a fiduciary responsibility to ensure that the funds provided by generators and owners of spent fuel and high-level waste are allocated effectively and efficiently; WHEREAS, the DOE is statutorily and contractually obligated to accept spent fuel and high-level nuclear waste from generators and owners beginning January 31, 1998; WHEREAS, the DOE has announced significant schedule slippages in meet-ing critical milestones contained in the Nuclear Waste Policy Act of 1982 (NWPA), principally a 5-year delay in the initial operation of the first repository and the indefin-ite deferral-of all site specific work on a second repository; and, WHEREAS, the proposed Monitored Retrievable Storage (MRS) racility is an integral part of the overall waste disposal program; THEREFORE, be it resolved that representatives of the Boards of Directors of the American Nuclear Energy Council, the American Nuclear Society, the American Public Power Association, the Atomic Industrial Forum, the Edison Electric Institute, the National Rural Electric Cooperative Association, and the U.S.
Committee for Energy Awareness, meeting jointly on May 7, 1987 in conjunction with the Nuclear Power Assembly, recommend that:
1.
The Secretary of Energy reaffirm unequivocally DOE's commitment to fulfill its statutory and contractual obligation to accept spent fuel from utilities, beginning January 31, 1998; 2.
The Congress and the Administration act expeditiously to resolve the impasse currently impeding the implementation of the NWPA so as to ensure the timely completion of characterization of three potential repository sites; 3.
The Congress and the DOE take appropriate action to ensure the construction and operation of the Monitored Retrievable Storage facility; 4.
The Congress and the Administration develop broader incentives for state and local governments to host high-level radioactive waste disposal systems facilities; 5.
The Congress and Administration provide equitable payments for defense waste disposal to the nuclear waste fund.
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- I Presentation by Sherwood H. Smith, Jr.
Chairman / President Carolina Power & Light Co.
To the Nuclear Regulatory Commission i
On the State of the Nuclear Industry May 7, 1987 OVERVIEW AND REPORT ON I
j INDUSTRY IMPROVEMENT INITIATIVES 1
I am Sherwood Smith, Chairman and President of Carolina Power &
Light Company and am honored this year to perform this function.
During the past several years, an assessment of the state of the nuclear industry has been provided traditionally i
the culmination of the annual Nuclear Power Assembly.
This at annual tradition provides both you, the commissioners, and us,.
with a first-hand opportunity to exchange our perspectives on the future of the industry and on the role of the regulators in that future.
I am accompanied today by a panel well-known to all of you, but.
i for the audience's sake, let me introduce them.
They.are:
Byron Lee, executive vice president of Commonwealth Edison Co.
- l and president-elect of the new Nuclear Management and. Resources Council (NUMARC), John Conway, executive vice president.
Consolidated Edison of New York and chairman of the American Nuclear Energy Council (ANEC), and John Taylor, vice president of the Electric Power Research Institute.
Together, we hope to give you our assessment of where the industry stands, where we are going, and our intention to exchange help and support with you.
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Our presentation today comes about a year after the Chernobyl nuclear plant accident in the Soviet Union.
During.the past.
u year, our industry has made an extraordinary effort to study the Russian event'and to identify its causes.
We now have a thorough understanding of the accident and of the fundamental i
1.
design flaws of the Soviet RBMK-1000 reactor design, which\\ vere
-l an a root cause of the' accident.
We know that none of those' y
design flaws are present in U.S.-type nuclear plants.
Welare pleased that the, Commission has recognized that a Chernobyl-type' accident is'" precluded" in the U.S.
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8 Despite the vast technological differences, however, the J
Chernobyl accident demonstrates to everyone: involved in the use of nuclear power that we,must be vigilant, determined and consistent in order to achieve and maintdin'high levels of safety in all aspects of our nuclear.operatihns'.
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As we have stressed, ourindustry'sfirstgoalandhghhst-priority is to maintain safe and reliable operation,of'the current generation of nucicar plants in the United States, t
which continues co expand.
Today, 107 nuclear plants are 9
licensed by the Commission to operate.
Since we briefe,d t'he 4
Commission on the state of the industry last year,$six new reactors have been lic'ensed for start up.
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In 1985,;U$5. nuclear plants generated 414 billion kilowatt-
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r" hours of electricity, or nearly 17 percent of the nationy's total.
Another 18 nuclear units still are under construction, and when they are in commercial operation fission energy will i
Provide about one-fif th of the nation's electricity supply..
In absolute te'rms, this will be substantially more ele tricity 4
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than was produced by the ent, ire nation in 1953 when' President Eisenhower delivered'his " Atoms for Peace" speech to the United Nations' General Assembly.
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Today, the safe and reliable operation of these nuclear units is not only a matter of public health and safety, it is increasingly vital to the U.S. electricity supply.
For example, nuclear energy today provides nearly a third of the electricity consumed in the New England states, and approximately one-fourth in the Southeast and Middle Atlantic states.
Our industry is committed to continuing the outstanding-record of success achieved thus far with the current generation of nuclear plants, which have accumulated since the 1950s some 1.050 reactor-years of safe operation.
1 Today, every chief executive officer of every utility company operating a nuclear plant is aware that public acceptance and tegulatory trust are inextricably linked to the quality of eyerational performance.
This is a most important factor in oc! vfforts to maintain a record of success.
Fortunately, in addition to the vigorous NRC safety review process, our industry today already has in place a wide range of programs designed to increase the safety and reliability of U.S.
nuclear plants.
I am pleased to report that these efforts continue to make significant progress, as shown by data collected by the Institute of Nuclear Power Operations (INPO).
I In addition, for example, 1986 marked the third year in a row in which no employee at a U.S. commercial nuclear plant received more than 5 rem annual exposure -- a goal set by the industry to exceed the minimum regulatory requirement of 3 rem / quarter.
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l We would like to be able to report to the Commission that the improvement in U.S. nuclear plant performance took place at every unit in every category of measurement.
Unfortunately, in one category -- plant equivalent availability -- the average '
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performance of all U.S. nuclear units, which has been on the upswing throughout the 1980s, declined last year, owing to the 4
I long-term shutdown of a few plants.
However, problems at these plants are being resolved and we remain confident that U.S.
nuclear plant. performance is on a long-term upswing.
And for the great majority of plants, unit availability did continue to increase.
We are particularly encouraged by the excellent performance demonstrated by the newest U.S. nuclear units.
The seven reactors which began commercial operation in 1986 collectively 3
i achieved a capacity factor of 71.6 percent, and several of them achieved performance levels that set records for new plants.
A second major goal of our industry is to assure that plants-nearing completion today will be licensed to start up and be able to begin safe operation.
It is essential to minimize, if j
not altogether avoid, the economic waste which results from delays in licensing and starting up of_ plants under construction.
i A third major goal is to maintain the nuclear option for the future.
This is essential if utility companies are to supply consumers with adequate amounts of reliable electric power at reasonable prices over the long-term.
J Recently, a major study of U.S.
" Energy Security" coordinated by the Department of Energy with input from 13 federal depart-ments and agencies was completed.
This study warned that the nation is heading once again toward a dangerous reliance on imported oil for its energy needs and it projected that these imports increasingly will come from less stable parts of the world.
The " Energy Security" study concluded, moreover, that
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with increases in demand for electricity the nuclear power
? -
option will have a " key role" to play in assuring U.S.
energy 1
security.
However, for nuclear energy to play its proper role domesti-cally, new nuclear plants must be economical-and confidence must be restored in the licensing process in utility board rooms, public utility commissions and the financial community.
We recognize that some of the things that can be done toward this end -- such as reforming the licensing process and extending the Price-Anderson law -- require Congressional action.
However, there is much the Commission can do and we
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applaud statements indicating an intention to move the Commission forward in the area of standardization.
A report completed last year by an Atomic Industrial Forum study group concluded that standardized nuclear plant designs in the U.S. would significantly reduce construction schedules and cut the cost of building new nuclear plants.
The analysis shows that a standardized nuclear plant can be built in six years for 55 percent less than the best-cost experience model-of recent years.
As an example of cost saving, the study pointed out that if a j
standardized nuclear plant had been ordered in the U.S.
in 1980 under the type of stable economic conditions which exist today, it would have reached commercial operation in 1986 at a capital cost of $932 per kilowatt.
With a 70 percent capacity factor for this hypothetical nuclear plant, the first year capital costs would be 3.2 cents per kwh (or 2.4 cents per kwh level-1 ized over 30 years).
If the current nuclear plant average operation and maintenance cost of 0.9 cents per kwh, fuel costs of 0.6 cents per kwh, and other costs of 0.1 cents per kwh are i..
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l added to these capital costs. total first year generation costs for the plant would be under 5 cents per kwh (or under 4.0 cents per kwh levelized over 30 years.)
This 1986 cost of electricity from a standardized nuclear power plant is believed to be competitive with, or cheaper than, any other energy resource for providing new electric generating capacity.
Steps are being taken now by the industry to prepare the way technically for standardization.
EPRI is working closely with the utilities and suppliers to define. utility requirements for a future advanced LWR, This work will provide a foundation for standardization through uniform utility requirements to be met by the suppliers.
These utility requirements are under review by the NRC staff to ensure their consistency with licensing requirements.
In parallel, the reactor manufacturers are developing advanced standard LWR designs and preparing these j
for submission to NRC for design certification.
We appreciate the participation of NRC staff in these ptocesses and their support of the technical standardization effort.
We believe the benefits to be obtained from standardization of nuclear power plants have been demonstrated, and that such benefits need not await Congressional action on licensing reform legislation.
Early site reviews and approvals, approval of standardized facility designs and issuance of combined construction permits and operating licenses for a nuclear power facility after provision of opportunity for public hearing should be the cornerstones of any Commission action.
We urge l
the Commission to move promptly on these important advances in nuclear regulation to obtain the safety benefits which are so desirable and which will fl.ow from these actionr..
of course, 4
to make standardization a practical reality, legislation will be required to provide the appropriate foundation for revitali-
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zation of the nuclear option.
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Our fourth major goal involves the nuclear fuel cycle.
Industry is interested in a complete fuel cycle, one that is commercial to the fullest extent practical.
Generally, the Commission has 4
been very responsive to the private sector in developing and applying regulations for nuclear fuel cycle facilities.
We encourage the commission to develop appropriate regulatory Procedures for the licensing of existing or new enrichment facilities operating under private sector auspices.
- Finally, and of great importance, we urge the commission to work diligently and on a timely basis with the Department of Energy.
(DOE) in the implementation of the Nuclear Waste Policy Act.
This should be currently and during DOE's site characterization activities; so that the bulk of the technical issues can be identified and defined prior to the licensing submittal for the high-level waste repository.
We believe that if industry and regulators work together, we can reach each of the four major goals I have outlined.
To improve our interactions with the Commission as we pursue i
excellence in the construction and operation of nuclear plants is one of the driving reasons for the industry reorganization now under way.
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e INDUSTRY IMPROVEMENT INITIATIVES Now I am pleased to report further to you about industry improvement initiatives, particularly those related'to our recent reorganization and other initiatives and accomplishments motivated by the INPO program.
We should start with a perspec-tive on how the INPO-industry relationship works, including information about a few key' accomplishments in 1986.
I plan to be brief because I realize INPO senior management is briefing the commission next week.
The joint efforts of the industry and INPO resulted in signifi-cant progress in continuing the pursuit of excellence in nuclear plant safety and performance.
The effort was most evident in the area of training.
INPO played a key role in assisting the industry in achieving its goal of having ready for accreditation all ten training pro-grams at every plant with fuel loaded at the end of 1984.
That is a total of 610 programs ready for accreditation by the end of 1986.
This commitment was met by all utilities by mid-December 1986.
This is a significant accomplishment and clearly demonstrates the industry's commitment to enhanced nuclear plant safety.
And the effort is continuing with the National Academy for Nuclear Training providing the framework to integrate the industry's training-related activities.
There are now 65 branches of the Academy at nuclear plants around the country: 12 utilities are full members of the Academy, having all programs at their plants accredited; and 404 programs have been accredited by the National Nuclear Accrediting Board.
These numbers are changing rapidly as more programs are fully accredited.
l
1 INPO also developed and is administering a senior nuclear plant management course.
The course provides those managers an opportunity to obtain practical training by emphasizing the case study approach to nuclear plant management issues.
The first class completed this course in the fall of 1986.
The second class graduates the end of this week.
We know you are aware of this program and have met with each class previously.
A new initiative launched in 1987 is the acceleration of efforts to improve maintenance practice among all nuclear utilities.
In February, the industry embarked on a two-fold, cooperative effort:
by INPO to increase its maintenance management and i
assistance programs, and by EPRI to establish a Nuclear Maintenance Assistance Center to enhance the transfer of improved maintenance technology.
Working through INPO, the industry clearly defined where it.
wants to be in 1990 and beyond.
Every utility has now estab-lished its goals in ten overall performance areas for each year through 1990.
While every utility may not fully achieve every goal, we are convinced we'll continue to see positive results in all areas of plant operations.
In fact, 1986 was a year in which we saw good results in seven of the ten indicators.
Most notable were the reductions in collective radiation exposure to personnel and in the generation of low-level, solid radioactive waste.
The commitment to achieve improvements in the knowledge base of industry people was underscored as the industry and INPO con-tinued to expand the peer evaluator, corporate evaluation advisor, and industry observer programs in 1986.
These efforts are providing valuable technical expertise to the Institute's evaluation and assistance efforts and are expanding the knowledge and perspective of industry representatives.
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d Another important program that grew significantly in 1986 was the human performance evaluation system, a means of managing human performance in nuclear power plants.
Participation in the program, which is voluntary, grew from 11 utilities at the beginning of 1986 to 23 utilities, including 2 non-U.S.
utilities, at the end of the year.
We are continuing to see positive results in all areas of plant operations.
INPO has contributed substantially to assisting the industry to continue improving nuclear plant operations and safety.
We will continue to combine our efforts in order to achieve the excellence we all desire.
Much of the overall direction for that improvement in excellence comes from a study you are familiar with -- the Sillin Report.
The Report entitled " Leadership in Achieving Operational Excellence" is a year-long study of '1dustry needs sponsored by the Utility Nuclear Power Oversight Committee.
A three-member panel made up of Leland Sillin, Jr., Marcus Rowden and Eugene Wilkinson examined how the industry could accelerate exceptional nuclear performance.
Along with Bill Lee of Duke Power Company and Jim O' Conner of Commonwealth Edison, I served on the Steering Committee for the Report and followed closely its preparation and completion.
The recommendations of the Report covered three main areas:
(1) improving operational performance of nuclear power facilities; (2) improving the nuclear utility industry interface with the NRC: and (3) establishing a unified nuclear l
utility industry organization.
The industry is striving to implement changes to address these three main areas.
The l
report called for INPO to enlarge its present role by establishing a standard of acceptable performance for the nuclear industry. -.
To improve overall operational performance at plants that might need, or benefit'most from, changes in operations, the industry-and INPO are working together to assure that the best opera-tional systems, methods, personnel practices, and so forth, I
which are present at nuclear plants evaluated as being very well run, are also embraced and'put into practice to the extent appropriate at those plants that have been less effective in meeting desired INPO standards of excellence in operational l
performance.
Efforts for improvements have been intensified.
Peer review and contacts are being strengthened.
Evaluation and assistance programs are being expanded.
In another part of the Report it was recommended that an organization be established to present a unified industry view I
to the NRC.
This recommendation has been instrumental in helping to cause the industry to review the entire industry-NRC relationship, as well as the role of other industry represent-ative groups.
During the past year, the nuclear industry has been planning a l
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major reorganization of industry groups to address better its I
i many publics, including especially the NRC.
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The new Nuclear Management and Resources Council (NUMARC) has emerged from this reorganization.
The new NUMARC will have two key objectives:
using industry opetational and technical knowledge to improve safety and reliability, and providing a unified line of communication between the industry and the NRC on generic regulatory and technical issues.
NUMARC will serve as the principal industry interface with the NRC on technical safety and regulatory policy matters, as well as initiato industry self-improvement efforts when deemed necessary and act on issues the NRC considers important.
The reactor regulatory and licensing responsibilities currently under the Atomic Industrial Forum have been assigned to NUMARC.
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Another part of the reorganization. AIF and the U.S. Committee for Energy Awareness will merge to make a stronger and more effective industry organization.
The merged group will be called the U.S.
Council for Energy Awareness (USCEA).
The main purpose of the USCEA will be to communicate the crucial role of electricity and the importance of both nuclear energy and coal in providing that power.
The USCEA will deal with a wide range of technical issues in addition to its information functions and general trade association' activities including publications i
and conferences.
The new U.S.
Council for Energy Awareness and NUMARC will be located near each other in downtown Washington.
The American Nuclear Energy Council (ANEC) will continue as a separate organization with primary responsibilities for the industry's go'rernment af f airs programs, especially legislative activities.
Its responsibilities include communicating nuclear industry positions to Congress and the Administration.
The Utility Nuclear Policy Oversight Committee (UNPOC) has been formally constituted as a coordinating and oversight organi-zation for all nuclear industry association activities.
It has been renamed Nuclear Power Oversight Committee (NPOC) to include vendor, architect / engineer representatives as part of its Board structure.
In its new form it will be responsible for, among other areas, coordination and the policy leadership of ANEC, USCEA and NUMARC and the remaining industry organi-zations (EEI, APPA, NRECA, EPRI and INPO).
The changes in industry organizations are the result of the maturing of the industry, and a continuing shift from licensing and construc-tion to achieving and maintaining operational excellence.
1 We have made major strides in improving the safety and efficiency of U.S.
commercial nuclear power plants.
In the past five years, we have lowered the total exposure per unit, i
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the number of unplanned scrams, the amount of waste and the number of significant events per year.
However, we must continue to be vigilant and persistent in our pursuit of excellence in nuclear operations.
INPO's perfor-mance ind,icator program is an important management tool for Plant performance and can help us reach our goals.
The realization of these goals is critical not only for today's nuclear plants, but for the future of nuclear power.
Improvements in the nuclear industry must come from the utilities that operate the nuclear units.
We must take the responsibility and continue along the path toward the point when all U.S.
plants will be performing at a level that not only meets but exceeds the respective NRC regulatory requirements.
4 By the end of this decade, the United States will have about 120 operating nuclear power plants, the highest number of any country in the world.
Those plants will produce about one-fifth of the country's electricity needs.
The safety and operational excellence of the plants is important not only to the operating utilities and their individual customers, but to national security and economic strength.
The NRC's responsibilities and the industry's self-improvement programs should be viewed as complementary.
An environment of hard work, trust and cooperation should lead to the result of all U.S. nuclear plants meeting or exceeding the desired high standards.
Industry groups and the NRC have different roles, but they have the same goals of safety and reliability of plants and protection of the public.
We are proud of what the industry has done and is currently doing to meet our goals.
But we.
assure you that we recognize the part that improvement needs and opportunities continue to exist and that there are variances around the country with respect to the quality of Performance at different plants.
Our commitment to excellence will require continuous efforts by the industry and.by individual utilities.
By working together, we can ensure that improvament will continue.
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Presentation by Byron Lee, Jr.
Executive Vice President Commonwealth Edison Company To the Nuclear Regulatory Commission On the State of the Nuclear Industry May 7, 1987 NUMARC ACTIVITIES -- AGENDA IN TRANSITION Good afternoon, gentlemen.
I am Byron Lee, currently executive vice president at Commonwealth Edison Company.
I'd like to expand upon Sherwood Smith's comments regarding NUMARC and also talk about how we, the nuclear industry, and the NRC can together bring about a continued improvement in the operation of our country's nuclear power plants.
When the Sillin report recommended the establishment of a unified nuclear utility industry organization that would interface with the NRC, many in the industry felt we already had the basic element that was needed in the Nuclear Utility Management and Resources Committee.
For three years the NUMARC executives have been interacting frequently with your staff to identify areas in our industry where improvements could be made.
A positive course of action has been taken on a number of issues.
We believe through this process, an increased sense of cooperation and trust has developed between the NRC and the industry.
We view our new organization, the Nuclear Management and Resources Council, as an opportunity to build further upon the successes this process has achieved.
The Nuclear Management and Resources Council, retaining the acronym "NUMARC." was established to provide a unified nuclear power industry approach on generic regulatory and technical e
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issues.
Its responsibilities include coordinating the combined efforts of licensee utilities and other industry organizations that are NUMARC participants in all matters involving regula-tory policy issues and on the regulatory aspects of operational and technical safety issues.
NUMARC serves as the industry's principal mechanism for conveying our views, concerns, and Policies to the NRC and other government agencies as appro-priate.
NUMARC will also initiate industry self-improvement efforts when deemed necessary and direct attention to and act on regulatory issues the NRC considers important.
NUMARC will carry out its responsibilities by drawing upon the knowledge, operational and technical experience, and safe operational responsibility of the entire nuclear industry.
We seek to improve the industry's effectiveness in developing and analyzing information concerning generic regulatory and tech-nical issues and to improve the quality and constructive character of contributions made by the industry to the evolu-tion of regulatory analyses and decisions.
NUMARC has two categories of membership.
One is that of Member and will consist of utilities who hold operating licenses or construction permits for nuclear power plants.
The second category is that of Participant and is comprised of NSSS vendors, A/E and consulting organizations involved in plant design or construction, and owners of interests in nuclear power plants other than licensees.
The Board of Directors consists of one representative appointed by each Member utility and six Participant representatives elected by the Board.
The Executive Committee is elected by the Board and includes twelve Member representatives along with 4
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the six Participant representatives of the Board.
Actions of the Board adopting formal inductry positions or policies on major regulatory issues impactirag utilities require an affirm-ative vote of eighty percent of the utility membership of the Board.
Participant members of the Board do not vote on such Positions or policies, or on other issues primarily affecting l
utilities.
The goal for the implementation of NUMARC was July 1.
We are still holding to that date and are making significant progress.
We were incorporated on April 7 and have our initial Board of Directors designated.
The Nominating Committee of the Board has designated Robert K. Campbell, President and Chief Executive Officer of Pennsylvania Power and Light Company, as NUMARC's chairman of the Board, myself as NUMARC's president and chief executive officer, and Joe Colvin, currently INPO's director of government relations, as executive vice president.
We will be integrating the licensing and regulatory functions previously conducted by AIF into our working organization over the next several months.
By July, I expect to have my initial I
staff and temporary office set up and in business.
Near the end of this year we will be in our permanent offices.
We must work closely with the industry and with the NRC -- the two major repositories of nuclear operational safety expertise
-- to further enhance operational excellence.
I hope this is an objective we all share.
Working towards a common objective, utilizing the combined expertise of the NRC and the' industry, will serve to benefit all of us and our country.
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To sum up, NUMARC represents a unified nuclear industry that is focusing on a wide range of regulatory issues, can exercise 4
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initiatives to enhance safety, and is dedicated to improving communications between the industry and the NRC.
The NUMARC Committee, by establishing a coordinated industry management i
approach, has had a positive impact in its three years.
We can identify the results and we can see how NUMARC has provided a closure mechanism on generic issues.
The NRC, for its part, l
has been willing to take industry initiatives into account, to
. work cooperatively with the industry, and give recognition to our programs.
You have also been willing to consider alter-native regulatory approaches that recognize our efforts and are 5
consistent with your regulatory responsibilities.
Continuation of these cooperative efforts will enable us to move further down the road to operational excellence; which, in the end, is our common objective.
I'd like to thank you for your time.
I hope I've been able to transfer some of the enthusiasm I sense for our endeavors to you.
Much of our success depends on the good working relation-ship and mutual respect that the NUMARC Committee started.
I am excited by the prospects of what we, together, will be able i
to achieve.
I look forward to working with you.
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