ML20244C097
| ML20244C097 | |
| Person / Time | |
|---|---|
| Issue date: | 02/07/1983 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| TASK-PINV, TASK-SE SECY-83-058, SECY-83-53, SECY-83-58, NUDOCS 8302280077 | |
| Download: ML20244C097 (55) | |
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February 7, 1983 SECY-83-58 POLICY ISSUE I
(Notation Vote)
For:
The Commissioners e
From:
Executive Director for Operations
Subject:
NUCLEAR DATA LINK (NDL) PROTOTYPE STUDY
Purpose:
To provide the Commission with information on NDL and to obtain Commission approval to proceed with the NDL prototype study.
Discussion:
On April 28, 1981, the Commission, in response to SECY 81-153, approved a plan to proceed with implementation of an NDL prototype program. _The staff _ prepared a Request for Proposals (RFPLto conduct the prototype analyses and announced,intheCommerceBusiness. Daily.{Jun.e_1982_),
the agency'.s_in. tent _to._rel ease.*the.RFP..H_ow ver, as a direct result of Congressional concerns over_e'the potential scope of NDL operation and NRC's use of a fully implemented system, the staff has n.ot yet been authorized to proceed wijh the,'p~~rototype project. Specifically, the prototype study has been delayed at the request of Representative Bevill who asked the Commission, on June 17, 1981, to defer actions on NDL until Congress completed action on FY 82 appropriations (Enclosure 1), and by Representative Udall, on June 4, 1982, who requested deferral of NDL actions pending Congressional action on NRC's FY 82-83 authorization (Enclosure 2).
In addition to these specific requests from Committee Chairmen, the mixed nature of Congressional sentiment on NDL is evidenced by the legislative history on this issue. presents both a summary and excerpted statements on nuclear data link from pending legislation and from reports of two conference committees and five standing committees of the Congress.
Most recently, in NRC's Authorization Bill for FY 82-83 (signed as P.L.97-415,1/4/83), the Congress authorized
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The Commissioners,
$200,000 for a "small test prototype nuclear data link" program and to conduct a study of the following issues:
(1) the appropriate role'of the Comission during L
abnormal conditions at a nuclear ~ reactor licensed by the Comtsion; (2) the information which should be available to the Commission to enable'the Commission to fulfill such role and to carry out other related functions; i.
(3) various alternative means of assuring that such information is available to the Commission in a timely manner; and (4) any changes in existing Commission authority necessary to enhance the Commission. response to abnormal conditions at a nuclear reactor licensed by the Commission.
Addit-ionally, Public Law 97-415 prohibits the Commission from.taking any action on actually implementing NDL in advance of Congressional consi'deration of the proposed action. The staff interprets favorable Congressional and Presidential action on NRC's Authorization Bill as effec-tively removing the restriction against proceeding with the prototype study. Contingent upon Comission approval, the staff plans to utilize $700,0001/ of FY 81 carryover funds for contractual support in carrying out the protocype study.
As noted in a memorandum dated December 8,1982 from W. J. Dircks to Chairman Palladino (Enclosure 4), the staff has develcped the RFP to ensure the study will be responsive to Congressional actions on NDL.
The results of NRC staff and contractor efforts on the prototype evaluation will be used to develop the information required to respond fully to the issues raised by 1/
Conference agreement does not restrict use of FY 81 carryover funds for the NDL prototype.
Of $3 million appropriated for NDL in FY 81 $700,000
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remains as carryover.
$2.3 million was previously reprogrammed. NRC's budget request for FY 84 and FY 85 contains $1 million and $4 million, respectively, for the NDL.
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9 T'he Commissioners l Congress and to provide the Commission with a staff recommendation on whether and how to implement NDL.
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order to accomplish this, the study is planned to include an NDL prototype evaluation at one pressurized water reactor (PWR), one boiling water reactor (BWR), and two reactor simulators (1 PWR and 1 BWR).
The prototype program has been designed to develop the technical specifications of components necessary to permit the NRC to monitor, following licensee initiation, vital plant conditions during emergencies.
Following this, prototype systems will be procured and tested in the field, as a link to the NRC Operations Center, in order to evaluate both technical and operational considera-tions. Additionally, the study calls for an assessment of alternative means for providing to the NRC-the same or functionally equivalent information as that provided by the tested prototype systems as well as detailed cost estimates for implementing NDL alternatives.
The NDL prototype RFP has been designed to reflect the agency's current range of NDL concepts and has evolved as a result of expressed Congress,ional concern, comments from outside the agency, and NRC's own re-examination of its role in emergencies. The agency has recognized that the licensee has the immediate and primary continuing responsibility for limiting the consequences of an incident at a nuclear power reactor. This includes providing recommendations to local, state, and federal authorities who are ultimately responsible for taking specific actions te protect the public's health and safety.
In order to fulfill its primary regulatory role of assuring that licensees take appropriate protective action and to provide radiological assistance to offsite authorities (including confirmation of licensee recom-mendations) during emergencies, the NRC has further recognized its need for the capability to monitor emergency plant conditions.
The current range of concepts for NDL, and hence the design of the prototype study, has changed from that which resulted from a major study completed soon after the Three Mile Island accident. Although the staff expects I
the contractor to evaluate alternatives and make a recom-mendation, we have eliminated from consideration those i
concepts which involve both continual Federal monitoring I
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The Commissioners '
of plant conditions 2/ and direct NRC interaction with a licensee's plant computer. The staff now views NDL as 3 licensee-initiated system which will monitor a speciried set of plant conditions 3/ only during emergencies.
Additionally, based on preliminary cost estimates, current NDL concepts are less expensive than earlier ones and include NRC capability to assimilate and use data as transmitted instead of requiring licensees to standardize their data input formats. provides a brief comparison of the original and current NDL concepts. These more focused concepts have been used in the RFP as primary guidance to contractors who may wish to submit proposals.
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The staff's projected schedule for completion of this study is presented below.
Release RFP following Commission
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.5 month approval Award contract for Prototype System
+ 4.0 months Evaluator Report to Cormission on fi,nal
+12.0 months evaluation of prototype system operation and technology, and seek Commission decision whether to proceed Sub~mit report on final evaluation of
+ 4.0 months prototype system including responses to Congressional issues and Commis-sion's decisions whether to proceed Earliest date for initiating NDL
+ 2.0 months implementation assuming favorable review TOTAL
+22.5 months
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In order to access critical data generated early on in an accident, a l
" flight recorder" system would be used as part of the NDL.
Data would l
be recorded and stored for a predetermined period by the licensee at i
d e plant and could be transmitted to NRC Headquarters as needed.
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Data needs will be re-examined in the prototype study, but are expected to be smaller than originally detailed in R.G.1.97.
The current concept would be more comparable to the licensees' Safety Parameter Display System (SPDS).
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The Commissioners.
Recommendation:
That the Commission:.
(1)
Instruct the staff to' issue the RFP and to' select a contractor to conduct the NDL. prototype evaluation.
(2) Transmit the attached letter to appropriate Congressional' committees (Enclosure 6).
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b Ns W llia J. Dircks Executive Director'for Operations
Enclosure:
1.
Ltr to Chrm. Hendrie fm Rep. Bevill dtd 6/17/81 2.
Ltr to Chrm. Palladino fm Rep. Udall dtd 6/4/82 3.
Legislative History on.NDL 4.
Memo to Chrm. Palladino fm
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W. Dircks dtd 12/8/82 5.
NDL: Original.and Current Concepts 6..
Draft 1tr to Congressional Committees re NDL Commissioners' comments or consent should be provided directly to the Office of the Secretary by c.o.b. Tuesday, February 22, 1983.
Commission Staff Office comments, if any, should be submitted to the Commissioners NLT Tuesday, February 15, 1983, with an information copy to the Office of the Secretary.
If the paper is of such a nature that it requires additional time for analytical review and comment, the Commissioners and the Secretariat should be apprised of when comments may be expected.
DISTRIBUTION:
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""'"it:^74"ft Honorable Joseph M. Hendrie Chairman U.S. Nuclear Regulatory Comission Washington, DC 20555
Dear Mr. Chairman:
The Committee has no objection to your request to reprogram $2,750,000 to fund the October 1,1980, pay raise, as explained in your letter of May 29, 1981, and additional funds described in your letter to support the Commission's " Licensing Recovery Plan" may be transferred as proposed.
I request that you defer any actions on the Nuclear Data Link until the Committee has concluded action on the FY 1982 budget.
Sincerely, Tom Bevill, Chairman Subcommittee on Energy and Water Development h
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.The Honorable Nunzio Palladino Chairman United States Nuclear Regulatory Commission
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Dear Mr. Chairman:
This pertains to near-term Commission actions associated with the. nuclear data link - (NDL1 program.
'It is my understanding that NRC staff have draf ted a Request for Proposal (RFP) for the purpose of selecting a contractor who will assess and further. evolve the NDL concept by assembling, testing, and evaluating alternative prototype systems.
As you know, the conference committee on the NRC Authorization
. bill for fiscal years 1982 and 1983 is' currently considering legislation that will affect the dimensions and purpose of the In my view, the issuance of any nuclear data link program.
such RFP prior to the completion of the conference would be I respectfully premature and potentially counterproductive.
request, therefore, that the Commission defer its decision to release the RFP until this matter has been resolved by the Congress.
Sincerely, AO IS K. UDALL Chairman
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' Enclosure 3 LEGISLATIVE HISTORY ON NUCLEAR DATA LINK
' A.
SUMMARY
FY 82-83 AUTHORIZATIONS Conference Morris Udall, Chairman 1.
$200,000 authorized for a "small test prototype nuclear data link" and analysis of Congressional questions.
2.
Required NRC to submit a report to Congress at least 60 days prior to any NRC action to implement NDL.
Senate Committee on' Environment and Public Works Subcommittee on Nuclear Regulation Alan Simpson, Chairman 1.
Authorized full budget request ($5,013,000).
2.
Limited spending to $1,000,000 until the Commission reports to Congress on the results of a prototype study.
House Committee on Interior and Insular Affairs Subcommittee on Energy ano the Environment Morris Udall,. Chairman l
Restricted authorization to $200,000 until the Commission justifies a larger amount by addressing Congressional questions.
l House Committee on Energy and Commerce Subcommittee on Eneroy 1
Conservation and Power Richard Ottinger, Chairman 1.
Authorized full budget request, with funding not limited prior to submitting a report.
2.
Calls for a prototype as a first step.
FY 82 APPROPRIATIONS l-Conference Tom Bevill, Chairman 1.
Provided $200,000 for NDL.
2.
Required report on Congressional questions.
' Enclosure 3
_ Senate Committee on Appropriations Subcommittee on Eneroy
- Water Developmer.t Mark Hatfield, Chairman 1.
. Appropriated full budget request ($5,013,000),
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Limited spending to $1,000,000 until the Commission reports to Congress on the results of a prototype study.
1 House Committee on Appropriations Subcommittee on Energy and Water j
l Development Tom Bevill, Chairman
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Deleted full budget request.
2.
Retained 1 manyear for the purpose of examining NDL issues.
FY R3 APPROPRIATIONS
- Conft,ence:
None reported. NRC is operating under a continuing resol; tion in FY 8?.
Senate Committee Provides full budget request.
House Committee 1.
Deletes all additional NDL funding.
2.
Stated the Commission could request reprogramming in order to carry out a study of alternatives for obtaining emergency data.
B.
EXCERPTS FY 1982-83 AUTHORIZATIONS Conference Udall, Chairman.
- The 97th Congress did not agree on a FY 83 Appropriations Bill.
Congres's approved the 1983 Continuing Appropriations Act under which funding levels for NRC activities in FY 83 are governed by NRC's FY 82 Appropriations Bill.
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7 Szc. 8. (a) Of the amounts authorized to be appropriated under this Act for the 6 scal yean 1982 and 1983, not mon than $200,000 is authorized to be used by the Nuclear Regulatory Commission for-
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(1) the acquisition (by purchase, lease, or otherwise) and in-stallation of equipment to be used for the "small test prototype nuclear data link"progmm or for any other prognm for the collection and tmnsmsssion to the Commission of data from li-censed nuclear reactors.dunng abnorrral conditions at such re-
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actors; and (2) the conduct of a full and complete study and analysis of-(A) the appmprute role of the Commission during abnor-mal conditions at a nuclear reactor licensed by the Com-mission; (B) the information which should be available to the Commission to enable the Commission to fulfil such role and to carry out other related functions; (C) various alternative means of assuring that such infors motion is available to the Commission in a timely manner; and (D) any changes in existing, Commission authority neces-sary to enhance the Commission response to abnormal con-ditions at a nuclear nactor licensed by the* Commission.
The small test pmtatype referred to in pamgraph (1) may be used by the Commission in canying out the study and analysis underpam-gmph (2). Such analysns shall include a cost-benept analysis of each alternative examined under subpamgmph (C).
tbX1) Upon completion of the study and anlaysis requirvd under subsection (aX2), the Commission shall submit to Congress a de-tailed report setting forth the results of such study and analysis.
(2) The Commission may not take any action with nspect to any alternative described in subsection (aX2XC), unless a period of 60 calendar days (excluding any day in which either House of Congras is not in session because of c.n adjournment of more than 3 calendar days to a day certain or an adjournment sine die) passes after the receipt, by'the Committee on Energy and Commerce and the Com.
mittee on Interior and Insular Affairs of the House of Representa-tives and the Committee on Environment and Public Works of the Senate, of notice submitted by the Commission containing a full and complete statement of the action proposed to be taken and the facts and circumstances relied upon in support of such proposed action.
Senate Comittee (Simpson)
The bill authorizes $5,013,000 in fiscal year 1982 and $6,300,000 in fiscal year 1983 for the Nuclear Data Link System. The bill specifically provides, however, that the Comission shall spend not more than $1,000,000 in fiscal years 1982 and 1983 until such time as the Comission has established a prototype system and, upon assessing the results of such prototype system, submitted a report to the Congress containing, among other,. things, a Comission recommendation on implementing a specific system for all operating nuclear power plants.
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The Commission's budget nquest included $5.013 million for fiscal l
vent IM2 and S6.3 million for fiseni year 1983 for n Nuclear Data T.iak (NDL). The Commission's 1980 Annual Report contains the following description of the NDL:
The Nuclear Data Lit & (NDL) would be a data trans-mission system designed to send a specified set of variables from the plant to the NRC Onerations Center in Bethesda, Md. Its purpose is to provide management penannel at NRC headquarters with timely, reliable and accurate plant systems, meteomlogical and radiological information. When an incident occurs the NRC must be prepared to provide advice and support to' the nuclear facility operator oE-sits State and local authorities and other Federal officials. NRC management must be able to make independent assessments s
of the actions taken by the licensee and oK-site authorities to
- pmtect the public health and safety. In addition, the NRC is responsible for keeping Federal. State and local officials and the general public informed about the technical and radio-logical aspects of the incident and subsequent emergency response activities. The NDL data also would help NRC headquarters personnel provide. timely support to regional NRC penonnelatthe plantsite.
In all emergency situations. the NRC's maior role will be
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to monitor the situation and advise protective actions. but will not extend to any manipulation of nnelear facility con-
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trols. However, in e.xtreme cases. the NRC may direct that certain operations be nerformed at tha nnelent facility. Any such direction wonid come fmm tb NRC Diree+nr af Site Operations after his arrival at the site and from NRC head-quarters prior to that time.
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.. Enclosure 3 The NDL has been criticized on several grounds, particularly, with regard to the temptation it would create for NRC stad to direct that
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- certain operations be performed at the nuclear facility." Dr.
Carson afark, Chairman of the Advisory Committee on Reactor Saf,e-guards testified that the NDL "" *
- is an expensive thing which will have a chance to work once in a while, but the NRC stad will I fear.
make it so fancv that one will wish we didn't have it. It is not clear what thev will do with it, and I certainly do not want them to be run-ninr thin ~gs up in Bethesda if we can avoid that."
Commissioner Gilinsky wrote in answer to a question as to his view concerning the purpose of the Data Link:
Commissioner Gilinsky's response to Question 3(a) :
If NRC Headquarters is to have a remote link with reactor control room displavs. which NRC will then monitor, this must be arranged in'such a way that the responsibility of a licensee for clant safety will not be diminished. I adt con-cerned that the relationship between the NRC and the licen-see will be afected by the existence of such a data link in ways that could be harmfurduring an accident or even during nor-mal onerations. I do not think this point has been given suffi-cient thought.
.Tohn H. Garrity. Director of Nuclear Engineering and Licensing.
Maine Yankee Atomic Power Company wrote to Chairman Udall stating that:
The nuclear dats' link would at best prompt the Bethesda stad to ask many auestions that. to be answered, would divert the attention of the utility stas from dealing with an acci-dent, and at worst might tempt the stas to pressure the utility stas to take measures the utility would not agree are most prudent based on their own on-the-scene impressions of rese-tor plant conditions. Clearly, the cost of the NDL. both to the tarpsyers and the utility customers is not justified.
Former ACRS Chairman Milton Plesset testified that the data link itself could detract from plant safety as a consequence of the neces-sity to connect the data link to the devices whh:h sensed plant parnm-eters. Dr. Plesset was referrine the problem of spurious electrical signals being fed from the data link apparatus into the plant controls.
Dr. P!esset stated:
I would like to add another point.We had an ACRS Fellow explore this in detail and be was very negative about the whole 2 des.
There is another featute of it that has not been touched on aside from trying to run the plant from Bethesda. and that is goine into all thcee power plants and tapping orI all the sen-sors they have in thert which could be a destructive thing.and could really make the plant less safe.
I think. personally. it is a had ides.whose time should not come.
Chairman TTdall stated to the Commissioners the following assess-mentof the NDL:
The mwnitude of this prormm snerests that the Commis-l sion envieions a divact role in reactor ooemting decisions during accidents. With ie mrd to the nrnnosed Nuclear Data Link and wnmptions underivine it. I find it a miestionable
. Enclosura 3 premise that NEC staff in Bethesda Maryland, will be better conipped to mspond to conditions at a remote reactor than
- ,re the acople at the site. It seems more likelv that. those who live with the plant and will develop an understanding of its idiosyncracies, an understanding that is unlikely to be acquired by NRC staff. If it is in' deed the case that you be-lieve your own start will have a better understanding than a utility's onsite personnel of what to do during an accident to bring a reactor under control, I would question the suitability of thr.t utility to operate a nuclear power plant in the Erst place. I believe further commitments to this program should not be :nade until we have had an opportumty to examine it and, if necessary, to hold hearings on your proposal.
In the course of its consideration of the NRC's budget request the Committee did not receive adeqtiate infonnation in response to the r
kinds of criticisms noted above. In particular, the Commission did not pr6 vide a clear statement of its position with regard te the follow-ing: the Commission's infonnation needs during an ac ident; the Commiwion's responsibility to monitor, and,if necessary, direct rese-tor operations durine an accident the mannerin which NDLinforma-tion would be used ' uring norm;al operations; and a j'ustiScation as,
d to why the proposed system is the minimum necessary for the Com-mission to fulfill its responsibilities.
The lack of adequate Commission response to the criticism leveled at the NDL reinforced the Committee's belief that the Commission's information requirements can be satisfied with a system much. less elaborate than that implied in the Commission's budget request. Ac-cordingly, the Committee voted to restdct NDL funding to a tot.al of
$200.000 in fiscal year 1982 and fiscal year 1983, unless the Commission submits to the Congress a proposal for a hieher level of expenditure and neither House rejects such pronosal. A Commission proposal for a greater expenditure could be submitted to the Congress only after the Conunission had conducted a study of the NDL issues and prepared a report on its study. Anv such nronosal is to be accompanied by a state-ment of the reasons and justification for the proposal The study must include. at a minimum. an examination of:
(A) the appropriate role of the Commission during abnormal conditions at a nuclear reactor licensed by the Commission; sio(n to e.nnble the Commission to fulfill such role and to carry ou B) the information which shon1d be available to the Commis-other related functions:
(C) various alternative means of assurine that such information is available to the Commission in a timely manner; and (D) any chances in existing Commission authodtv necessary to enhance the Commimion remonsa to abnormal conditions at a nuclear rvactorlicensed by the Commission.
In addition to limitimr Com' mission expenditure on the FDL. the Committee rwinced tha Commimion's fiscal rear 1982 and 1983 authori-zations by $4.813 and RA.3 million respectively, the amounts requested forthe NDLin each of these years.
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. Enclosure 3 House Committee (Ottinger)
As one of'the major problems identified in the studies of the accident at the Three Mile Island nuclear reactor was the poor communication of needed technical information regarding operating conditions, and as one of the primary recommendations was the establishment of such an instantaneous data link, the committee provided the Commission with the amount requested for this activity, without making the availability of such funds subject to further congressional action.
In doing so, the committee expects that the Commission will proceed to establish this system in an orderly and cautious fashion, installing first a prototype linking the NDL with a limited number of representative operating reactors and possibly a simulator.
Experience gained from such operation will be used in designing the ultimate system. The committee expects that, following the establishment of a prototype, the Commission will submit to the Congress a report evaluating its experieince with such a system, and afford the appropriate authorizing committees of Congress the opportunity to c9termine if the establishment of the entire system is desirable. The committee wishes to emphasize that the establishment of this system is for the purpose of transmitting data in the event of a nuclear incident or abnormal occurrence in order to monitor such events, and that in all events, the responsibility for the actual operation of the reactor rests with the licensee.
The committee recognizes that the Commission and its staff are not as competent to operate a reactor as those at the site, who are familiar with the idiosyncrasies of the particular unit, and that the information transmitted by the NDL will, in no way, be used to usurp the operator's prerogatives. The committee expects that the Commission will promptly identify the nature and scope of the information which needs to be transmitted in the event of an incident or abnormal occurrence, and establish criteria for the circumstances under which such information is to be transmitted.
FY 82 APPROPRIATIONS Conference (Bev111)
A total of $200,000 is provided for the nuclear data link and the Commission is to submit a rep' ort addressing those issues identified in House Report No.97-177 in FY 1982.
i Senate (Hatfield)
The Committee recommendation restores the House reduction and includes the requested funding for the nuclear data link system.
This prototype system is designed to improve emergency response and enhance the quality and quantity of technical data available to NRC headquarters emergency response personnel.
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,. Enclosure 3 The Committee believes that the Commission should proceed with a prototype system to further determine feasibility and cost effectiveness of this project.
Although the full budget request is approved, the Commission is directed to spend no more than $1,000,000 until such time as it has submitted a report to the Congress and has received the approval of the Committees on Appropriations.
House (Bevill)
The fiscal year 1982 budget request includes $5,013,000 for the nuclear data link (NDL), which has been under consideration by the Commission for a number of years.
During hearings before the Committee, NRC answers indicated that the Commission itself had not yet determined whether or not to proceed with the NDL.
Until the Commission decides to implement the NDL, the Committee cannot justify an appropriation for the activity.
Furthermore, the Committee is not convinced that the NDL is an appropriate regulatory tool for the NRC.
Inasmuch as all nuclear power plants are constructed and operated under licenses granted by the NRC, are run by personnel certified by the Commission and are under continual supervision by senior-level resident inspectors, it may be that any incremental value the NDL may have in assisting the NRC in addressing s'ecific nuclear incidents or accidents is marginal.
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question of accountability of the Commission qnd the Government for management of incidents is unclear in the proposal cnd needs to be resolved prior to additional effort on the NDL.
Finally, responsibility for crisis management of specific incidents or accidents has never been vested in the Commission' through legislation and the question of how far the Commission or its staff could or should go in recommending actions in regard to a nuclear incident or accident should be fully considered by the appropriate authorizing committees before additional expenditures are made on the NDL.
For these reasons, the Committee recommends deletion of $5,013,000 and reduction of 2 of the 3 manyears of effort associated with NDL.
One position may be retained to examine those issues identified above.
FY 83 APPROPRIATIONS
- Conference None reported.
'The 97th Congress did not agree on a FY 83 Appropriations Bill.
Congress approved the 1983 Continuing Appropriations Act under which funding levels for NRC activities in FY 83 are governed by NRC's FY 82 Appropriations Bill.
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- Enclosure 3 Senate Committee The Committee recommendation restores the House reduction and includes the requested funding for the nuclear data link system.
This prototype system is designed to improve emergency. response and enhance the quality.and quantity of technical data.available to NRC headquarters emergency response personnel.
House Committee 1
The Committee does not recommend any additional funding for the nuclear data link program. The Committee believes that there are too many unanswered questions concerning this program to warrant its funding.
Should the Commission wish to proceed with an evaluation of alternative means of obtaining emergency data consistent with a defined set of NRC-operator responsibilities the Committee would be agreeable to considering such a request through the established reprogramming procedures.
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ENCLOSURE 4 e
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' Enclosure 4;
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WASHINGTON,0. C.2055s Q
,f DED 8 1982-4.e pn MEMORANDUM FOR:
Nunzio J. Palladino Chairman FROM:
Wi111am'J.'Dircks Executive Director for Operations REPORT TO CONGRESS CONCERNING THE NUCLEAR DATA LINK'(NDL)
SUBJECT:
g Your memorandum dated November 4, 1982 recognized tnat, through a series of documents, Congress has asked the Commission to conduct studies of several issues and to' report the results to Congress. You requested that-I direct the L
staff to complete a study of the issues referenced in the FY 1982 Appropriations Conference Report and that a schedule for completion of.the. study be provided to the Commission in approximately two weeks..In addition, you stated that the Commission requests an explanation of why the study was not started and whether the staff believes the study can be ifone without a Rrototype.
In responding to'your request I believe it is important to review some of the
~
. background:
and three
' 1.
The NRC's FY 1982 budget request included $5,013,000 positions for HDL implementation.
2.
House Report 97-177 -(July 14,.1981) recommended deletion of.the full S5,013,000 and reduction of two of the three man years of effort associated with the NDL.
The remaining position should be used to examine the issues identified in House Report 97-177.
The Senate Ccmmittee on Appropriations Report 97-256 (October 28, 3.
1981) recommended restoration of the requested funding with a limit that no more than $1,000,L00 be spent until the Commission conducts a prototype study, submits a report to Congress, and receives the approval of the Committees on Appropr'iations.
4.
The FY 1982 Appropriations Conference Report 97-345 provided $200,000 4
4.
for the NDL and required the Commission to submit a report addressing the issues identified in House Report 97-177.
It has been the. staff's interpretation of the Appropriations Conference Report that the issues identified in House Report No.97-177 would be addressed in the provided. The staff's intent to address NDL prototype study using the S200,000some of the issues through the in my memorandum to you dated December 8, 1981 regarding decisions FY 1982 budget (Enclosure 1).
w
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' 'Nunzio J. Palladino-.the prototype to_ enable the Commiss on to prepare the report requested by i
Further detail on'this approach was provided to the Commission in my Congress.
March 23,.1982 memorandum to you summarizing the NDL effort (Enclosure 2).
Thestaff'sIapproachisreinforcedbySection8.(a)ofH.R.2330,theFY 1982-1983 Authorization Conference Bill, which authorizes for the fiscal years 1982 and 1983 not more than $200,000 for the acquisition and installation of
. the "small test prototype nuclear data link" and the conduct of a full.and complete study and analysis of a somewhat different set of issues. The bill,
.which has passed the Senate and is awaiting House action, specifically states that the small test prototype may be used in carrying out the required study' and analysis.
' The ' staff has anticipated that, as you indicated in your November 4,1982 letters to Mr. Udall and Mr. Bevill, we must study all of the issues related to the NDL and respond to the questions raised by the conferees on authorization and appropriations bills. Those issues are:
From House ~ Report 97-177, (1) whether the NDL is an appropriate regulatory tool for NRC; (2) the extent of accountability of the Commission and the government for management of incidents; and
~(3) the question of how far the Commission or its staff could or should go in recommending actions in regard to a nuclear incident or accident.
From H.R., 2330, the appropriate role of the Commission'during abnormal condiUons at (1) a nuclear reactor licensed by the Commission; (2) the information which should be available to the Commission to enable the Commission to fulfill such role and to carry out other related functions; various alternative means of sssuring that such information is' (3) available to the Commission in a timely manner; and (4) any changes in existing Commission authority necessary to enhance the
~
Commission response to abnormal conditions at a nuclear reactor licensed by the Commission.
The situation is one where the staff has already started to address these Those issues that are of a policy or legal nature have been addressed issues.
by the staff and reported to the Commission. For example, the issues relating to' clarification of the Commission's Tole, particularly as it relates to that of licensees and offsite authorities, is addressed in Manual Chapter 0502 which was transmitted to the Commission'on July 21, 1982.
The question of accountability of the Commission and the government for management of incidents and the i
o e,*
~,
e 3-
Nunzio J. Palladino question of how far the Commission could or should go in recommending actions The staff's in regard to a nuclear incident have been addressed by the staff.
response to these questions was attached to my memorandum to the Commission 30, 1982. That memorandum forwarded a suggested letter to dated September Congress with an optional attachment (Enclosure 3) providing the status of the staff's response to the HDL' issues identified in House Report 97-177 and referenced in the appropriations language as enacted. The option was whether to provide a partial response to Congress at that time or to complete the study of all issues and submit a comprehensive report to Congress.
' The staff continues to believe that the remaining issues raised by Congress can best be addressed by the actual experience gained through the prototype evaluation.
For these issues, little or no new information is going to be gained by another Examples of these issues are:
(1) the appropriateness of NOL as paper study.
a regulatory tool, (2) how far (technically) the Commission could go in recom-mending actions in a nuclear incident, (3) the information necessary to enable the Commission to fulfill its role, and (4) the alternative means of assuring that such information is available in a timely manner. The Request for Proposal (RFP) for evaluation of a NDL prototype specifically calls for the issues raised by Congress to be examined in the context of the prototype evaluation.
This approach also addresse's the final request in yqur memorandum for (1) a description of the steps the staff proposes to take in responding to our authorization and appropriation bills, (2) a discussion of the prototype concepts currently envisioned, and (3) a discussion of any alternative means I am attaching a copy of for transmission of data from nuclear power plants. The staff has carefully the Statement of Work from the RFP (Enclosure 4).
followed Congressional actions with respect to the NDL and has developed the RFP to ensure that the prototype study will be responsive.
Although the staff does not hold a specific concept of the prototype design and is looking to the contractor to evaluate alternatives and make a recommendation, we can say that we have eliminated from consideration the concepts of continual Federal presence These and of enabling the NDL to interact with the licensee's computer.
concepts, considered in earlier studies, represent capabilities that are inappropriate to the Commission's role as it has been defined.
The staff's projected schedule for completion of this study is presented below.
Inasmuch as there is currently a Congressional hold on the prototype study, this timetable is based on receiving approval t'o proceed with the study.
Approval +.5 month Release RFP
+ 4 months Award contract for Prototype System
~
Evaluator
+ 12 months Report to Commission on final evaluation of prototype system operation and technology, and seek Commission decision whether to proceed 9
L_._____
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-+ 4 months Submit report on. final evaluation of prototype system including responses to Congressional issues, Commission's decisions whether to s
proceed, and an implementation plan
+ 2 months
. Earliest date for initiating NDL implementation assuming favorable review 22.5 months TOTAL In the event.the Congress raises additional issues beyond those currently on If the nature of the record, the staff would continue its present approach.
issue is such that it can best be addressed in the context of the prototype study, the staff proposes to incorporate the issue into.that study.
The staff would study any legal issue itself and would, as appropriate, address any policy issue with the Commission.
-(SigntSWilliam j.Dircks William J. Dircks Executive Director for Operations
Enclosures:
1.
Memo dtd. 12/08/81 from W. J. Dircks to Chairman Palladino 2.
Memo dtd. 03/23/81from W. J. Dircks to Chairman'Palladino 3.
Attachment to Memo dtd. 09/30/82 from W. J. Dircks to Chairman Palladino 4.
Statement pf Work from the Request for Proposal cc w/ enclosures:
Commissioner Gilinsky Commissioner Ahearne Commissioner Roberts Commissioner Asselstine OPE OGC SECY b
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14EMORA;CL'M TO:
Chairman Palladino FROM:
William J. Dircks Executiva. Director for Operations J
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DECISIONS ON FI 1982 BbDGET SUS 1ECT:
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This is. in ra'spcase to.your reques'. to develop a ravised budget biss'd. en the HRC' FI 1932 A i
i Act.
The Act,.. as signed by the President on.
, December '4,.pr'ppropr at onovides for appropriations.. of'. 5465.7M.which. is l$101
' revised budgat of 5455.cM that the Comission had app ~ roved' and sent. to CM3 Ten '.
October 25, 1981 to meet. the OMB.targat'.
Basically tha.'resourcs allocation
,3 that the tcmmission had approved remains the.same. except.. for. the. fo11owihg.7- ~
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adjustments:
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Of the ~ $10.1M' over the' OMS target, 'SS.dM will be.all'ocated lo".'the. //
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LOFT'prograr:r.undar RES' and the rama.ining $2.1M wi,11 be,6 sadto help ' offset
.approximately,'35. parcent of tha projected payraise: incr. ease' and will be" a.. atlocatad to sall aries: and.b'ansfits
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.s f.D The Congress directed. the agency "to. carry ouk;. the testi'ng matrix and-
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f.sched.ule identified by.the Office of Nuciaar Regulatory Resaarch: drawing from-tha LOFT Speciar Raviaw G.rcup."
Mhila. this directive does.not recuire us to' i
fund LOFT at tha originally proposed level of $44.0M, the directive does involva carrying cut the preposed testing-program in NRC's F(
1982 Congressional budget submission.
It does not appear likely thai; the Cor.gressional cemitteas would approve reductions in ~ the proposed. testing I
program.
Therefore, the attached revisad budgat aliccatas '542.0M for LOFT which includes 54.5M frca a redistribution of funds within RES along with the SS.CM discussed above.
Through careful rsview to reduca costs and solicitina additienal cutsida finanT;ial support, we expect to keep HRC's F( 19S2 LOFI funding at. or bsic.i this level.
To the extent our FY 1932 funding needs c:n be reduced balcw tha $42.0M level, tha excass would be ussd to foretard fund LOFT work in F( 1533.
In this regard, it shc.'uld be nota'.i that while fundinc i
LOFT in F( 1932 does not appsar to be an insurmountable preblam, our revised budget submission to CMS for F'I 1933 rsduced LOFT funding to 515.0M which is 525.5M below the laval originally estimated as necessary to carry out tha propos2d tast program.
Thus, 'the impact of the FI 1922 Congressional diractive is considerably more severe in F! 1933..and should be cddressed in any future na;ctiations with CMB.
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Within ILE, th? Managamant Dirsctica and Support Oscisica Unit will be reduced by $200 thousand and thost funds rsallocattd to the Eastgancy'-
preparedness Cecisita. Unit to provide for the completien of the NDl. prototypa -
J This $2004heusand along with $800 thousand of FY 1981 carryover funds.
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will pr,5vi-drr,,or.the 51.0M estimate baing projected for the prototype phasa to-enable. tha Comisaien to prepare the. rsport requested by Congress. prior to -
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imp'lemsnting a fu1T-scala MDL. program.
,7
' Tha attachment contains the above changes to the Comiss' ion-approved FY.1582. t.1-L
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budcet that was.. provided OM3.cn'.Octcbar 2Ei.1981c.-
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..c With.regara to C'emissioner Ahaarns's spacific points. in his Ndvember:23,11951' m morandum to you, the.ravised FY.1.98E budget. allocating the funds provided under the Appropriatier Act includes the foT1owing::
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NRR is being authorizad'te: ovarhire 25 additional full-time'. M
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equivalent (FTE) sta.ff years. th work. on generic. issues and::174I action: items.:c..;
. Tne UREp, operater. licensing, and TMI-2c,cleantip efforts havef not been.' i.
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The leveT of r'ese' arch Ter onsite emergency preparednessLrema. ins. thi- :..'--
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same as providad for under the OM3t.r.evised budgat.
o I believe thit this alloc'ation substantially complies with that approved by.'
the Commission.
I propose to issue financial plans and allotmsnts as'soon as!
11RC recaiver its apportionment from CM3.
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p'iam J. Dircks
~-
Will Executive Director for Operations Attachmtnt:
F.svised FY 1982 Budgat e
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.a MAR 2 3.1932
.MEl'.ORANDUM FOR: Chairman Palladino William J. Dircks FROM:
- Executive Director for Operations -
l S,UBJECT:
HUC(EARDATALINK Enclosed is a brief sumary of the Nuclear Data Link effort ah requested by your memorandum of March 8, 1982.
. Os1pc0 Wilhau. Birt *e William J. Dircks Executive Director for, Operations l.-
Enclosure:
Nuclear Data Link Sumary Commissioner Gilinsky s
cc:
Commissioner Ahearne
. Commissioner Roberts OPE
'0GC SECY 4
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Plans The Nuclear Data Link (NDL) effort is scheduled at this time only through The results of the program will then be completion of the Prototype Program.
reviewed, and any subsequent implementation of an operational system will require'a decision by the Commission in accordance with memorandum SECY 81-153 dated April 28, 1981.
Any funding that subsequently may be requested for implementation is also contingent on satisfactory resolution of several issues The over-raised by Congressional authorization and appropriations committees.
..all purpose of the NDL Prototype Program is to provide the operational and technical information needed prior to deciding 'whether and how the NRC should implement an automated data system with each operating commercial nuclear power Such a system would be used only during emergencies.
plant.
The immediate task is to award a competitive contract to begin installation and The schedule for making the contract award-evaluation of the prototype systems.
in July will hopefully allow for resolution of' current differencesin the Senate and House version of our FY 1982 Authorization. Provision related to the ND Once' installed, the prototype systems will'be evaluated for their ability to
, provide timely and accurate data to NRC headquarters response persohnel during Details of scheduled tests and exercises, including some with State personnel..
the NRC role in relation.to licensee and State personnel during an emergency, i
informati6n needed to fulfill that role, and alternative means of providing.the c
~.
information (such as facsimile and remote CRTs, for example) will be evaluated ip conjunction with the analyses of the uses and value of the data provi during emergency scenario's.
pated throughout the Prototype Program.
Risources Cost and schedule are competitive factors in the RFP for a program contractor.
5700,000 and may prove to be substan-Contract cost is estimated not to exceedw.ill be funded with FY 1982 appropriated tially lower.
A maximum of $200,000The NRC will furnish equipment space and t
~No funds.
other resource requirements (other than staff time) are anticipated at this time for this aspect of the effort.
Milestones
- Award contract for Prototype System Evaluator (formerly July, 1982 called " System Integrator").
- Status report to Congress required by Appropriations Act.
September, 1982
- Report to Commission on final evaluation' of prototype system March, 1983 operation and technology.
- Commission decision on full implementation for emergency use July,1983 only.
N r~,micc. inn would. of course, receive the report to Congress 'for review by
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"U S.. NUCLEAR REGULATORY COMMISSION-IREPORT TO. CONGRESS ON NUCi. EAR DATA' LINK
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ISSUES IDENTIFIED IN: HOUSE REPORT NO 97-177" ~
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ENCLpSURE 3
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1 1.
INTRODUCTION AND BACKGROUND The concept of transmitting limited data automatically from commercial' powerreactorstoNRCresponsepersonnelwasfirsk: suggested before the accident at'.Three Mile Island. Soon' after the. accident' a major study -
'a' resulted in a proposal for a' much larger s'ystem-that, for example,. would-continuously gather datalfrom the reactors 'and annunciate.off-normal' i:
conditions..Significant questions and opposition arose about the : '
justification for the larger system, which could not be reconciled with' the ideas then emerging from. NRC's own re-examination of-its. role in. '.
emergencies.. The-NRC recognizes:th,at.the-licensee has the immediate and' primary continui'ng responsibility' for limiting the consequences. of an.
incident at a nucle $r power. reactor which itrc'1'udes providing.recom. -
~
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mendations-to local, Sta,te, and. Federal'authori, ties for specific actiens ' - '
to protect the public's health and safety.. The NRC further recognizes
~
that it is the State and. local authorities who are ultimately responsible for acting on the basis of such' recommendations to protect the public.
To support and assist the licensee and State and local authorities, the NRC needs data to monitor the adequacy of the licensees. response to the-incident and to be prepared to provide advice or confirm recommendations to State and local autt)orities based on NRC's independent assessment of the plant situation.
The process of clarifying the NRC's role has helped to focus the scope of the nuclear data link for emergency response purposes.
Most of the issues raised
?
by Congress show concern for the way a data link would be operated and used.
l The revised scope of a data link has abandoned the concept of its being used I
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f as a continuous. regulatory presence.
The current data link concept is a smaller system that would be activated between a plant and the NRC.
~
Operations Center when the licensee reports an, incident.
On April 28,
^
1981 the. Commission directed the staff to evaluate prototype systems to determine what was reaTly needed.
This report summarizes ac'tivities 1
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related to that evaluation program since. the previous. report to Congress'
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on the subject in September IS80.
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II.
CONGRESSIONAL ACTION AND THE RESPONSE
- A. Appropriations Act s
The NRC.is req'uired by Conference Report No( 97f 6 which accompanies.
the current Appropriations Act (P.L. 97-88)', to report to the Congress addressing'certain issues related to the proposed Nuclear Data. Link. (NDL).
ConferenceReport97-3N5definesthaissues.tobeaddressedas"those issues ide'ntified in House Report No.97-177.'"
Those issues afe addressed belowr
- 1. "The Commission itself had not yet determined whether or not to proceed with the NDL."-
This issue was partially addressed by the April 28, 1981 Commission decision to proceed with the NOL Prototype Program.
The Program will
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provide the Commission with additional information upon which to base decisions on whether and how to fully implement an NDL.
4 3
- 2. The NDL may not be an " appropriate regulatory tool..*.
It may be that any incremental value the NDL may have in assisting the NRC in address-4 ing specific nuclear incidents or accidents is marginal."
This issue has been partially addressed by the revised scope of the NDL Prototype Program and decision. that. NOL is not to be designed or operated.as a continuous. regulatory presence. The NDL's value during
- nuclear' incidents will be addressed in.the Prototype Program which is ~
. discussed below..
- 3. "The' question of accountability of the Commission aiid the. government-for management.of incidents...needs to be resolved."
The question of governmental' liability for p'ersonal injury or' property damage arising out of HRC'.s actions during an emergency would be
. governed by the provisions of the Federal Tort Claims Act. */ The Federal Tort Claims Act permits recovery against the United States for
~
negligent acts of federal employees, unless those acts involve the performance of or failure to perform a " discretionary function within-the meaning of 28 U.S.C. 5 2680(a).
The NRC's determination whether or not to take certain, actions during' ah emergency would'most likely be viewed by the courts as involving:the exercise of discretion in carrying out the Commission's regulatory functions.
However, once the Commission riad determined to undertake performance of certain actions or to take control of a facility, the possibility of liability would increase.
If
/ The Price-A'nderson Act previsions (Atomic Energy Act 5 170, 42 U.S.C.
S 2210) regarding limitations on liability would not apply to claims against the NRC itself.
_____m-_ _ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ _. - _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ _ - _ _ _
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the actions of the NRC did not involve the exercise of governmental discretion at the planning, policy-making level but rather involved performance of functions at an operational level, the United States would be potentially liable for the negligent acts and omissions of NRC employees.
Whether in undertaking certain actions during arr emergency-the NRC, and hence the. United States, would be liable for consequence's J*.
of its actions would depend on such circumstances as the nature and ~
scope of NRC's actions, whether the actions were negligent, and
.. 1 / ~
whether the actions caused the. alleged injury.
~ '-
- 4. " Responsibility for crisis management of specific incidents or-accidents has never been vested in the Commission through iggislation '
and the. questio'n of howlar the. Commissten or 'its staff could. or, -
~
' should go in recommending actions in regard to a. nuc1 ear incident or-
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accident should be fully considered..."
Although neither existing legislation nor NRC regulations specifically
~
add ess NRC's role during a-nuclear power plant emergency, the Commission has authority under the Atomic Energy.Act of 1954, as amended, to
' potentially direct all safety-related aspects of operation during an emergency.
Under the existing regulatory framework, licensees are primarily responsible for ensuring safe operation of their facilities.
However, the Commission could order a licensee during an emergency to
. take any number of possible protective actions, ranging from obtaining NRC concurrence before the licensee takes certain actions to taking specific Commission-ordered actions to permitting actual cperation of the facility by the Conmission.
The legal basis for o.rdering the
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licensee.to take certain actions stems from Section 161 of.the Atomic
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Energy Act, as amended (42 U.S.C. 5 2201), which authorizes the' Commission to issue orders governing the use of radioactive material and operation of nuclear ~ facilities.**/ Section 186c of.the Atomic-
+
Energy Act, as amended (42 U.S.C. 5 2236(c)), authorizes the Commission
"[1.]n cases found by the Commission to be.of extreme importance....'to' 1
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the. health and safety of the public" to. " enter uporr and' operate the '
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facility. prior' to any of the procedures provided. under the.
Administrative Procedure Act."
The: reference to tha. Administrative Procedure-Act. in Section.186c s to'
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the general rule applicabla to all NRC. orders. that, in ordinary.
circumstances, the. Commission is. require *d to afford. the licensee: notice,
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and an opportunity 'o be heard before the licensee is bound to.take.the' t
ordered action.
Notwiths,tanding the general requirement that a licensee-j
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be-given a prior opportunity to be heard, the Commission could issue orders that are effective upon. issuance to require a licensee to take i
certain actions in circumstances compelling immediate action to protect public health and safety. 'See Administrative Procedure Act 5 9(b),.5 i
U.S.C. S 558(c); 10 CFR 2.202(f) L 2.204.
The use of immediately effective orders must be justified by the emergency nature of the situation and by an overriding need to protect public health and safety by immediate action.
""/ Orders would be issued by the Cc= mission or specified staff officers as provided in 10 CFR 2.202.and 2.204.
C---____.__.____________--____
'^
- Y B. Authorization Bill
"^
An FY 1982-1983 authorization bill is not yet out of' conference.
At.
this writing the House.and Senate bills are before a conference committee.'.
v; l.
III.
STATUS OF THE NDL PROTOTfPE PROGRAM l
The Commission. staff-has. developed a-program plan in accordance with tha,.;.'
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provisions of. the 1981 Commission decision, of the-Appr opriations Act, and of current'. versions. of the authorization bills.. A' Request fer'.
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Proposals to perform the required analyses, 's'ing rudimentary prototype. '
u data. systems, was prepared and announced 16* Commerce Busine'ss Daily. -
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In a ' letter dated June 4,.1982 the Chairman of the Hous'e: Committee on Interior and Insular. ffairs asked the Commission to de.fer release of theRequestforProposalsuntil"thismatterhasbeenresolve[bythe Congress", i.e. until the issue clears the conference committee.
1 A. Objective and Scope The Objective of the NOL Prototype Program is to provide the NRC with','
sufficient operational and technical information to decide, first, whether an automatic data acquisition and transmission system should be fully implemented for use during emergencies and, second, the best way to do so if it should.
The NRC plans to select a contractor (through competitive bids) who wil.1 assemble, test, and evaluate-a range of
'9 7,
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i prototype systems at one BWR, one PWR, and a simulator.
Proposed cost, schedule,. and approach will-all be factors in the selection of the 1
contractor.
The prototype systems will be evaluated for their ability to provide timely and accurate data to NRC Headquarters response personnel during scheduled tests and exercises.
DetaiTs'or the NRC role-in relatierr to ' licensee and State personnel during an emergency, informa-i.
tion needed to fulfill that role,. and alternative means of providing the.
l
~
l information (such as,facsjmi~1e and remote CRTs, for example) will be -
evaluated. in conjunction with analyses of the uses and value of %e data previded during emergency scenarios.
Extensive industry and State l
~.
Even if prototype evaluations involvement is anticipated throughout.
show a significant benefit, no operating systems will be installed until 1
[,"
the Commission decides. specifically to do so and the C6ngress is given-1.
time to review both the evaluations and tha decision.
Once a decision is made to proceed with the NDL prototype, extensive l
licensee and State participation will be essential because the NRC role, when its details are defined, should be defined in" relation to the roles of other participants in an emergency.
Some licensees and States have-already expressed interest in being part of the-Prototype Program.
The NRC staff is c,urrent1[in the. process of selecting volunteer candidate sites.
The Request for Proposals now awaiting release asks each respondent to propose equipEen't and procedures that wi11 involve NRC, State and licensee personnel at the selected sites in resolving the l
remaining issues concerning a data lirik.
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B. Technological _ Concerns
- The major remaining technological question concerns the translation of inputs from any facility into a consistent presentation of information' -
for NRC specialists.
TheNRCintends'toavoid$requiringthelicensees to make extensive retrofits for NDL.
This increases,.however,.the!'
I complexity. of' the software that NRC.must dehelop to ' handle.the integra. -
t tion and. interface c. compatibility-problem.;. The complexity and cost cf ^
l developing. such software will continue. to grow until specific NDL' f. '.
' requirements are defined for licensees.
The Prototype Program contractor-l will address this. problem.
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IV.
FUTURE REPORTE..
l, Once the issue clears the conference' committee, assuming.a favorable decision to proi:eed with the NDL. Prototype Program, the;NRC will release the Reqpest for Proposals and pursue selection.
The NRC will at the conclusion' provide Congress with a Summary report that contains the Commission's decision whether to fully implement an automatic data acquisition and transmission system with all licensed power reactors.
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.p nen UNITED STATES,
/
o NUCLEAR REGULATORY COMMISSION
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' A,**.*/
June 10,1982 I
'dentlemen:
Subject:
Request for Proposal No. RS-01E-82-250
" Nuclear Data Link (NDL) Prototype System Evaluator" Entitled:
~
The U.S. Nuclear Regulatory Connission (NRC) is soliciting proposals for the project' entitled above. The full scope of work anticipated is as set forth in that part of the. Request for Proposal entitled, " CONTRACT SCHEDULE - STATDiENT OF WORK."
I,t is our intention by this solicitation to secure the best qualified organiza-l
' tion available to perform this project, cost and other factors considered.
L
('
If you desire to respond, your proposal should addres,s the proposc1 content requirements set forth in the body of the solicitation. All proposals will be evaluated against the evaluation. criteria shown in Part II. For your convenience.
L an "RFP Sum.ary" has been provided as Enclosure A.
Instructions for completing
. and submitt'ing your proposal are provided in Enclosure B.
Should you determine that you do no[wish to submit a,n offer, a "NO-OFFER RESPONSE FORM" is.provided as Enclosure C.
The solicitation package is included as' Enclosure D.
A preproposal conference will be held at the Phillips Building, Room P 110, 7920 Norfolk Avenue, Bethesda,14aryland 20814 on June 29,1982, at 9:30 AM.
See Part II, Paragraph 20 of the RFP for details.
If you have any questions concerning the requirements of this solicitation, please contact 14r. Levi Baisden at (301) 492-4297 (collect calls will not
.beaccepted).
Sincerely,
... I rg.- hI Kellogg VI 14orton, Chielf-L Research Contracts Branch Division of Contracts Office'of Administration
Enclosures:
A.
RFP Sunnary B.
Proposal Submission Instructions C.
HO-OFFER RESPONSE FORM Solicitat, ion Package (Standard I
D.
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RFP No. RS-0!E-82-250 Page 36 of 50 PART 111 CONTRACT SLr!EDULE ARilCLE I - STATEMENT OF WORK 1.
BACKGROUND s
This section describes the purpose of a nuclear data link (NDL), the use of prototypes in a program for detemining the value and specifications for an operational NDL system, and the complementary roles of a Prototype System Evaluator and the NRC in that program.
1.1 Purpose of the NOL The NRC, by virtue of its position as regulator of comercial nuclear power plants, will be directly involved in any emergency at. a licensed reactor that has the potential of af.fecting the public health and safety.
While the licensee is always responsible for operating the plant, the NRC has a role in evaluating the overall response strategy and in asses-sing the overail adequacy of licensee act$cns and recommendations for mitigating the accident consequences and' protecting the public.
The NRC may also develop independent analyses to assure that the public is fully protected, because experience ~ indicates that Governors and other authorities will call on both the licensee and the NRC for advice.
This NRC role in protecting the health and safety of the public requires access to certain data from plants during emergencies that is as timely and accurate, though n.t as ' extensive, as that available Questions remain, however, about the specific data to the. licensee.
needed and how it will be used by the NRC to fulfill the agency role.
At this time data is still inadequately gathered during emergencies by
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manual data collection and telephoned reports, a process that occupies licensee personnel who could be used in other ways during the critical The Comission believes that there may early hours of an. emergency.
be a substantial ^ improvement in assuring the health and. safety of the public to be obtained by the use of a reliable automatic data link The Comission has from each operating plant to NRC Headquarters.
therefore directed the staff to proceed with installation and evalua-tien of prototype systems. for the purpose of obtaining the information needed to determine, first, whether an automatic data link should be fully implemented =.nd, second, the best way to do so if it should.
1.2 Procram Plan _
1.2.1 Phase 1 The first phase of the NDL program -- the anelysis of NRC operational requirements and definition of an RDL concept -- is complete and has been documented in NUREG/CR-1932 and NUREG/CR-2025.
The initial concept has been revised subsequently in one notable way:
The NDL will now be used only during emer3ncies.
That change greatly reduces the si:e of the system and affects some of the other details in NUREG/CR-1932, but it does not affect the concept of operations during emergencies.
The data description in NUREG/CR-2025 can be used
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RFP No. RS-0!E-82-250 Page 37 of 50 L.
1 The second phase of the program will be used to develop 1.2.2 Phase 2 the infomation that will be required by the Comission and the Congress l-to decide whether and how the NRC should fully implement an automated data system to satisfy its operational requirements during emergencies.
For example, the current House of Representatives authorization bill' (H.R. 2330) requires:
l "at a minimum, an examination of --
L The appropriate role of the Comission during abnormal conditions
..A.
at a nuclear reactor licensed by the Comission; l
/
The information which should be available to the Comission to i
B.
enable the Comission to fulfill such role and to carry out other related functions; I*
Various alternative means of assuring that such information is C.
available to the Comission in a timely manner; and Any changes in existing Comission authority necessary to enhance l.
D.
the Comission resporise to abnormal co'nditions at a nuclear reactor licensed by the Comission.
Ths study shall include a cost-benefit analysis of each alternative examinedundersubparagraph.(C)."
L The Appropriations Act (P.L. 97-88) has a similar provi.sion.
The third phase' --- system implementation --- is subject 1.2.3. Phase 3_
L to Comission and Congressional approval based on results of the second i
Third-phase efforts are not included in this Statement of Work.
phase.
1.3 Role of Prototyoe System Evaluator _
Tha Prototype System Evaluator shall assess and further evolve the NDL concept by assembling, testing, and evaluating alternative prototype One pressurized water reactor-(pWR), one boiling water j
l systems.
reactor (BWR), and a' reactor simulatot Will be selected by the NRC for installation of the Evaluator's prototype systems which will then be Eacle such system used as both operational and technological test beds.
(consisting of data acquisition components at the sites, communications components to link the selected sites with the NRC Operations Center in Bethesda, Maryland, and user components at the Operations Center) will be tested and evaluated in various configurations by the Prototype System Evaluator to determine how best to satisfy NRC operational l
requirements during emergencies.
l The Prototype System Evaluator shall assume complete technical and administrative responsibility for completion of work described in a plan that has been approved by the NRC, within any limits that may be imposed by Federal or NRC regulations.
l
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,...<3 RFP No. RS-01E-82-250 s.
Page 3B of 50 The Prototype System Evaluator.shall not subsequently supply hardware or software for an operational NDL-system, should one be approved.
1.4 Role of the NRC The NRC will provide overall program direction, a gen
' total and incremental funding levels; and will review and approve all plans and other deliverable documents.
r The NRC will arrange. for utility and governments 1' representatives to participate in tests to help resolve details of the interrelated roles and other operational issues related to use of data.
4 Once a plan is approved, the NRC will assist the contractor in obtaining access to information available to the NRC and agreed by The the NRC to be needed to complete the work described in the plan.
NRC will select licensee participants and will complete. initial arrangements with'them for contractor access and licensee participa-The NRC will monitoi the contractor.-licensee interaction to help prevent interference in the licensee's operation or other diffi-tion.
culties and to help resolve any problems that may arise.
The NRC will retain the primary responsibility,for interactions with local, State, and other Federal organizations.
2.
OBJECTIVE _
The objective of this effort is to provide the NRC with sufficient op'e'ra-tionni a'nd technical information to decide whether and how to implement a data link, the capabilities of which must be explicitly related to NRC emergency roles and functions.
3.
SCOPE _
The efforts being sought under this contract constitute the second, or prototype, phase only of the NOL program as described in Section 1.2.2.
4.
WORK STATEMENT _
The contractor shall provide the necessary personnel, eq stated otherwise in this work statement.
The contractor may choose to subcontract, but shall be responsible for all
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efforts thereby engendered, incitding preparation of Requests for Proposals, evaluation of proposals, negotiation, award, administration, and funding.
The contractor shall define work to be subcontracted, select subcontractors, and make such contractual arrangements as are best suited to achieving NRC The contractor shall be objectives within the terms of this contract. accountable to the NR
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RFP No. RS-0!E-82-250 Page 39 of 50 4
-The contractor shall notify the NRC Project Officer as soon as possible of
.any circumstances that may cause a "significant variation" in the-effort Failure to meet a or schedule from that described in the approved plan.
scheduled milestone and ten percent or more overrun at the end of any month-4 above the budget planned for that month are examples of "significant varia-These reporting requirements are in addition to ahy other reporting tion."
requirements required by the terms and conditions of this contract.
4.1 Familiarization and Initial Evaluation _
4.1.1.The contractor shall beccme familiar with the NRC Incident Response Program, including the roles and responsibilities of the agency and its response personnel as described in the NRC Incident Response Plan (NUREG-0728), NRC Manual Chapter 0502, and other documents to be made available by the NRC.
The contractor shall assist the NRC in testing and evaluating 4.1.2 displays and ' associated data system components in accordance with a formal evaluation plan to be made available by the NRC.
The NRC will provi@ O,r this test-and evaluation of such compo-nents as it consioen candidates for upgrading the analytic The components will capabilities in the Operations Center.
usually include tabula.r and graphic displays, printers, and The NRC will schedule and computer hardware and software.
conduct any test procedures that require participation by NRC The contractor shall observe such tests, response personnel.
analyze test results in accordance with the evaluation plan, and conduct such other assessments of the components as it considers necessary to identify a preferred selection of components for satisfying users of plant data (transmitted automatically or otherwise) in the NRC Operations Center.
The formal evaluation of Operations Center components will be completed approximately six months after contract award.
The contractor shall prepare a report (Report No. 2) that describes the test and evaluation of Operations Center compo-nents, results, and recommendations for hardware, software, and procedures in the NRC Operations Center based on those The recommendation shell include the costs and bene-results.
fits of preferred and alternative components and shall differ-entiate between components and capabilities considered by the contractor to be essential and those considered to be desirable, but not essential.
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RFP No. R5-01E-B2-250 Page 40 of 50 4.2 Prototype plan and Initial Installation 4.2.1 The. contractor shall:
- 4. 2.1.1 Define, in detail sufficient for procurement, the initial-1 components of prototype NDL systems linking'one boiling -
water reactor and one pressurized water reactor (both to be selected by the NRC) to the NRC Operations Center. Hard-ware. software, and connections to licensee equipment shall-be included-in the contractor's definition. The NRC will select sites from which data can be acquired from an existing
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data acquisition system. Simulators may also provide data to
' NDL prototype equipment at the selected sites. No plant sensors will be tapped by the contractor.
Data on no more than 150 variables wili need to be trans-mitted to the NRC at any time during this effort. The NRC will furnish 300/1200 baud data to,lephone service between the reactor sites and the Operations Center.
Since it is envisioned that the prototype installations cay be modified from time to time after initial installa- '
tion to evolve the best possible system, the initial com-ponents need represent only the contractor's best estinate, at the time, of a system that will do the job for a reasonable cost.
4.241.2 Define the means by which the prototype installations can use appropriate simulator data during their test and evaluation.
4.2.1.3 Prepare a plan, schedule, and monthly budget for acquiring, installing, testing, evaluating, and documenting the effort on each of the prototype systems. The plan should identify:
The proposed method of operation of the prototypes a.
during test and evaluation, including the purpose and scope of each scheduled exercise;
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b.
Requirements for participation by NRC, licensee or simulator personnel; Opportunities for participation by State, local and c.
nuclear industry personnel; d.
Alternative 6eans of providing to the NRC the same or functionally equivalent information as that pro-vided by the prototype systems, and propcsed procedures for evaluating those alternatives.
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RFP No. RS-0IE-82-250
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- Page 41 of 50 O
The proposed method for integrating the 'results e.
of Task 4.1.2; f.
Evaluation criteria to be used; and
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The estimated cost, including acquisition and g.
installation, of each major element of the plan as defined by the contractor.
4.2.1.4 Prepareareport(ReportNo.1)ontheabove.
4.2.2 Following NRC approval of the plan described in Section 4.2.1.3, the contractor shall assume complete technical and administrative respcasibility (except as specifically excluded by other portions of this contract document or by other documents) for installation of the prototypes as described in that plan.
(See'Section1.4). The Govern-ment will not acquire' title to any-equipment leased or purchased by the contractor for this effort.
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4.3 Prototyoe Test. Evaluation, and Documentation 4.3.1 The contractor shall assume comp 1.ete technical and administra-tive responsibility (except as specifically excluded by other portions of this contract document or by other documents) for test and evaluation of the prototypes. Test and evaluation will be conducted in iccardance with the plan described in Ser. tion 4.2.1.3 as approved by the NRC. The contractor shall assure that the test and evaluation is adequate to provide a sound basis for the recommendations described in Section 4.3.2(c).
l 4.3.2 The contractor shall prepare a report (Report No. 4) which shall include the following:
A description of the evolution of the BWR and PWR prototype' a.
installations, with rationale.for each major modification after initial installation; b.
An explanation of the test and evaluation process, includ-ing evaluation criteria, and a sumary of the results; If justified by the test and evaluation results, recommended c.
NDL system design, cost estimates, and schedule for imple-mentation at all commercial nuclear power plants; d.
A description of the flow and use of NDL data and informa-tion during a. hypothetical incident, including the function of each user and the relationship of those functions to the NRC role;
=
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l,g i-w RFP No. RS-01E-82-250 Page 42 of 50
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i A comparison of the benefits, problems, and approximate e.
costs of alternative means of providing the same or.
functionally equivalent information.
5.
RESTRICTIONS 5.1 Hardware and Software Sources The need for objective evaluations (under Section 4 above) places s' requirement on the contractor to consider the.use of hardware and.
software manufactured by all available. sources, or the contractor must demonstrate that the sole use of. one particular brand name will not prejudice the evaluations. Minor items of hardware or software used, in the opi~nion of the NRC, solely to integrate components of the prototype systems and,to expedite the operational or technical evaluation of those components or systems will not be considered to be impediments to objective evaluations.
5.2.pDPEauiomentProcurement.
Any requirements fo'r the use of ADP resources (e.g., hardware, software, and special telecommunication equipment inc,1uding the lease,' purchase, or use of existing systems, and the' subsequent disposal at-the completion of the prototype demonstration) ii~ the responsibility of the contractor, except as specifically stated otherwise in the Work Statement (Section 4).
l 5.3 Programming _
All major programming efforts should be documented in accordance with FIPS PUB 38 and ANSI Standard 413-1974.
6.
REPORT REQUIREMENTS Monthly letter progress reports in five (5) copies to the contracting 6.1 Officer's Project Officer (PO) and one (1) copy to the Contracting Officer, shall be due by the 15th day of each month and shall, as a minimum:
Relate actual efforts to those planned; a.
Describe anticipated delays or other problems; b.
Show actual expenditures (for labor and equipment separately) c.
for the month of the report and. cumulative to the' date of the r.e. port for. each.m.ajor el,ement identified in the approved plan.
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s RFP No. RS-01E-82-250 Page 43 of 50
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i d.
Show approximate projected' expenditures for the following month.
Ten copies of a draft report (Report No.1) documenting the results 6.2 of the_ efforts described in Section 4.2.1 shall be delivered to the NRC within two months after contract award. The report will be used by the NRC to decide,to proceed with installation of the prototype Partial drafts systems in accordance with the contractor's plan.
may be submitted for earlier approval if the contractor believes it necessary.to. avoid delay in procurement of long lead-time items.
Twenty-five copies of a final report shall be delivered 'to the NRC within two weeks after receipt by the contractor of NRC written approval of the draft.
Tencopiesofthedraftreport(ReportNo.2)describedinSection 6.3 4.1.2 shall be delivered to the NRC within one month after the NRC terminates test and evaluation of displays and associated Operations The~ report kill be used by the, NRC to'. identify Center components.
the preferred Operations Center components of ap operational NDL system, should such a system be approved. Twenty-five copies of a final report and plan shall be delivered to the NRC within two weeks after receipt by the contractor of NRC written approval of the draft.
Ten copies of a draft report (Report No. 3) of the status of all 6.4 efforts under this contract shall be delivered to the NRC by March 31, The report will be used to assist the NRC and the U. S.
1983.
Congress in deciding the appropriate level of funding for the NDL The report should include any results, their basis, and program.
their importance to the objective of this effort (Section 2); tasks underway, their objectives, and major difficulties encountered; and Formal projected efforts, their objectives, and the planned approach.
Twenty-five copies of a final briefings may be requested by the NRC.
raport and plan shall be delivered to the NRC within two weeks after receipt by the contracter of NRC written approval of the draft.
The schedule for the report (Report No. 4)Irequired by Section 4.3.2 6.5 shall be as stated in the contractor's approved plan. Ten copies of the draf t will be delivered to the NRC, and twenty-five copies of a final report shall be delivered to the NRC within two weeks after receipt by the contractor of HRC written approval of the draft.
The contractor will be requested to prepare occasional brief sumaries 6.6 or oral briefings related to the contract work, attend meetings or comment on documents to assist the NRC in describing or explaining the NDL Prototype program.
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RFP No. RS-01E-82-250
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LIST OF REFERENCE DOCUMENTS 7.
Definition of a-Nuclear Data Link _, Volumes 1-6, USNRC Repcrt
^ a.
huREG/CR-1932, June 1981.
. Preliminary Interface 5pec'ification for NOL Data Acquisition System b.
~and NRC Terminal,. SNRC Report NUREG/CR-2025, June 1981.
U Report to Congress [ HRC Incident Response Plan, USNRC Report NUREG-0728, c.
ESeptember 1980.
Agency Procedures for the NRC Incident Response Plan, USNRC Report d."
huREG-0845, March.1982.
Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Succort of Nuclear Power Plants,
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USNRC: Report NUREG-0654 Rev.1, November -1980.
Functional Criteria fo'r Edergency Respon'se Facilities. USNRC Report
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huREG-0696, Jebruary 1981.
The above r,eferences are available in the Public Document Room.
This document USNRC Manual Chapter 0502, NRC Incident Response Program.
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.is in revision.
version will be.made available in the Public Document Room as soon as It does not differ from reference 7.c (NUREG-0728) in any way possible.
that should traterially affect proposals, and its lack by any offeror will not affect the selection of a contractor.
Requests to the NRC Public Document Room Washington, DC 20555 for Note:
these documents must identify the specific document, and reference this RFP (RS-01E-82-250). The telephone number is (202) 634-1380.
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ENCLOSURE 5 t
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i NDL:
ORIGINAL AND CURRENT CONCEPTS I
L The NRC's interest in acquiring'a Nuclear Data Link (NDL) arose from the l'
incident at Three Mile Island (TMI). The TMI post-accident assessments l-identified as significant problems, the timeliness, and accuracy of information obtained manually and transmitted by the licensee to the NRC i
Operations Center via the telephone.
In adaition, there was at that time a strong emphasis on increased Federal oversight which prompted considera-tion of the concept of a continuous Federal presence in the control room.
Consequently, the initial NDL concept included continuous intensive monitoring of plant operations by NRC with alarms that would be activated in the Operations Center whenever a plant exceeded some predetermined threshold for a given parameter. The NRC has rejected the initial NDL concept through the process of clarifying its role in responding to incidents at licensed nuclear facilities and putting its role in context with that of the licensee and State and local authorities.
The key differences between.the original and current NDL concepts are:
ORIGINAL-CURRENT
Purpose:
Continuous monitoring
Purpose:
Emergency monitoring of of plant conditions.
plant conditions.
Read out triggered by pre-set Licensee activated, alarms on plant parameter thresholds.
Data continuously recorded at
" Flight" recorder located on-site Operations Center.
stores early data for predetermined period.
Some data acquired directly from No direct connection to sensors.
plant sensors.
Dedicated computer onsite permits All data to be provided from NRC to interact.
existing plant computers; no inter-action initiated by Operations Center.
Data list developed in-house, to be Data list to be developed with required of licensees licensee and State input.
Initial data list about 400 variables, Length of data list limited, and later trimmed to 125.
expected to be comparable in size to the data set for plant SPDS's.
Licensee required to meet NRC data Licensee will provide site-specific needs in standardized NRC format.
data in own format.
NRC will trans-late for NRC use.
Estimated total system cost about Estimated total system cost about 525 million.
$8 million.
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j ENCLOSURE 5 1
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t The Honorable Alan Simpson, Chairman Subcommittee on Nuclear Reagulation-Comittee on Environment and Public Works
' United States Senate
-Washington, D.C.
20510
Dear Mr. Chairman:
In its FY 82-83 Authorization Act (P.L.97-415), the U.S. Nuclear Regulatoryr Commission (NRC) has been authorized $200,000 to evaluate a "small test prototype nuclear data l' ink"'and to conduct a study of:
(1)theappropriate role-of the Commission during abnormal conditions at a nuclear reactor i
licensed by the Commission; (2) the information which should be available to the Commission to enable the Commission to fulfill such role and to carry out other.relatedfunctions;(3)variousalternativemeansofassuringthatsuch information is available to the Commission in a timely manner; and (4) any changes in existing Commission authority necessary to enhance the Commission
. response to abnormal conditions at a nuclear reactor licensed by the Commission.
The Commission continues to believe that an NDL prototype evaluation will provide it with the information necessary to respond fully to questions raised by Congress and to develop an agency position on whether and how an automatic data acquisition and transmission system should be fully imple-mented for use during emergencies. The prototype study has been planned to
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V
. Enclosure 6
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refine the Commission's assessment of the technical and operational issues related to the NDL concept, and to further develop the cost benefit informa-tion required prior to any decisicn on NDL implementation.
Accordingly, we plan to release a kequest for Proposals (RFP) and to select a contractor to evaluate a range of prototype systems at one pressurized water reactor, one boiling water reactor, and one reactor simulator for each reactor type.
In addition to the $200,000 of authorized FY 82 funds, the agency plans to make use of no more than $700,000 of FY 81 carryover funds to conduct the study.
As currently envisioned, the range of NDL concepts has changed from that which resulted from a major study completed soon after the accident at Three Mile Isignd. The NRC's own re-examination of its role in emergencies as well as questions from outside the agency led us to eliminate from consideration those concepts which involve both continual Federal monitoring of plant conditions and direct NRC interaction with a licensee's plant computer. We now view NDL as a licensee initiated system which will monitor some specified set of plant conditions only during emergencies. Additionally, current concepts of NDL are much less costly than earlier estimates and include NRC capability.
to assimilate and use data as transmitted instead of requiring licensees to standardize their data input formats. These more focused concepts have been utilized as guidance to contractors who may wish to submit proposals in response to the RFP on the prototype study.
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- 3-L The-Commission has carefully followed Congressional actions 1and' concerns with r.
respect to NDL and will keep Congress informed on significant related-actions.
As.noted previously, we intend'to make use of the results of the prototype study.to fully l respond to the issues raised.in the legislative-reports'and to formulate an agency. position on NDL implementation.
Sincerely, Nunzio J.-Palladino cc:
Sen. Gary Hart' e
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- Enclosure 6-Y p
. Identical' letters-to be'sent to:
1The Honorable Morris K. Udall, Chairman Subcommittee on Energy and the Environment Committee on Interior and Insular Affairs United States House of Representatives
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. Washington, D.C.
20515' s
cc:
Rep. Manuel Lujan The Honorable Richard L. Ottinger, Chairman Subcommittee on Energy Conservation and Power
^
Committee on Energy and Commerce.
United States House of Representatives Washington, D.C.
20515 cc:
Rep. Carlos Moorhead Chairman,-Subcommittee <on' Environment j
Energy and Natural Resources Committee on Government Operations United States House of Representatives Washington, D.C.- 20515 1
cc:
Rep. Joel Deckard i
The Honorable Mark 0. Hatfield, Chairman Subcommittee on Energy and Water Development Committee on Appropriations
. United States Senate Washington, D.C.
20515 cc:
Rep. J. Bennett Johnston
.The Honorable Tom Bevill, Chairman Subcommittee on Energy.and Water Development Committee on Appropriations 1
United States. House of Representatives Washington, D.C.
20515 cc:
Rep. John T. Myers
._______________.___________.____m._______.______.__._______