ML20128K770

Requests Info That Provides NRC Added Confidence & Assurance That Plants Operated & Maintained within Design Bases & Any Deviations Reconciled in Timely Manner,Per 10CFR50.54(f)

ML20128K770
Person / Time
Site:	Cooper
Issue date:	10/09/1996
From:	Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	Mayben W NEBRASKA PUBLIC POWER DISTRICT
References
NUDOCS 9610110176
Download: ML20128K770 (13)

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• WASHINGTON, D.C. 2065!K1001 k...../ October 9, 1996 Mr. William Mayben President and Chief Executive Officer Nebraska Public Power District P. O. Box 499 Columbus, NE 68601

SUBJECT:

REQUEST FOR INFORMATION PURSUANT TO 10 CFR 50.54(f) REGARDING ADEQUACY AND AVAILABILITY OF DESIGN BASES INFORMATION

Dear Mr. Mayben:

The purpose of this letter is to require information that will provide the U.S. Nuclear Regulatory Commission (NRC) added confidence and assurance that your plant (s) are operated and maintained within the design bases and any deviations are reconciled in a timely manner.

Backaround In the mid- to late 1980s, NRC safety system functional inspections (SSFIs) and safety systems outage modifications inspections (SS0 mis) identified concerns that design bases information was not being properly maintained and plant modifications were being made without the licensee having an understanding of the plant design bases. The NRC's findings heightened the nuclear industry's awareness of the need to improve the adequacy and availability of design documentation, and many licensees voluntarily initiated extensive efforts to improve the design bases information for their plants.

To assist the industry in performing design bases improvement programs, the Nuclear Management and Resources Council (NUMARC)1 developed a guidance document, NUMARC 90-12 " Design Basis Program Guidelines." These guidelines were intended to provide a stanpard framework for licensee programs to improve plant design bases information. The NRC staff reviewed the guidelines and provided comments to NUMARC in November 1990. In emphasizing the importance of validating the facility against current design information, the staff

'NUMARC was consolidated into the Nuclear Energy Institute (NEI) on March 23, 1994.

2 As discussed in NUMARC 90-12, these programs or efforts would emphasize collation of design basis information and the supporting design information, not the identification or re-creation of the licensing basis for a niant or the regeneration of missing analyses and calculations.

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Mr. William Mayben stated that the goal of any program should be to establish confidence that the existing facility is in accordance with the current design documents and that any deviations will be reconciled. The staff concluded that the NUMARC guidelines would provide worthwhile insights to utilities undertaking design reconstitution programs and that the guidelines appeared to provide sufficient flexibility for licensees to structure their programs to respond mc:,t efficiently to any unique needs and circumstances of a particular licensee.

The staff requested NUMARC to consider making design reconstitution a formal NUMARC initiative and commented that design documents that support technical specification values and that are necessary to support operations or to respond to events should be regenerated if missing. NUMARC subsequently concluded that a formal initiative was not necessary because most of its members were already conducting or evaluating the need to conduct design reconstitution programs, and agreed to forward the guidelines, with the NRC's comments, to its members for use on a voluntary btsis.

To provide more information to the industry on this topic and to provide an independent view of the design control issue, the staff conducted a survey of six utilities and one nuclear steam supply system vender to determine the status of design control problems and the strengths and wuknesses of the sample utility programs. The result; were published in February 1991 in NUREG-1397, "An Assessment of Design Control Practic.es and Design Reconstitution Programs in the Nuclear Industry." The survey observations were as follows:

The need for a design documentation recons-titution program was directly proportional to the age of the plant.

The general intent of the program should be to provide a central location for design bases information, with emphasis on the design intent (the "why" of the design).

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The design bases documents should be a top-level directory that defines the current plant configuration.

Reestablishment of design bases without reconstitution of the supporting design documents, as necessary, may not provide a sufficient level of information for future modifications or current plant operation, or to quickly respond to operating events.

Minor changes to the design should be tracked to support the conclusion that the changes in the aggregate do not affect the validity of existing calculations and the ability of a system to perform its design functions.

1 3 Mr. William Mayben I Some common weaknesses of licensee programs identified during the survey included the following:

Design reconstitution programs had not identified in advance the documents that are necessary to demonstrate that a structure, a system, or a component will function properly.

(he process for regenerating missing design documentation was not always proceduralized so that it could be handled in a systematic manner.

Validation of the content of specific output documentation was not always thoroughly carried out.

In late 1991, the NRC staff evaluated whether rulemaking, guidance, or a policy statement was needed to address the issue of licensees retaining 3 accurate design bases information. It concluded that the existing regulatory requirements for design control were adequate; however, it determined that the publication of a policy statement addressing design bases information and publication of a generic letter requesting licensees to describe their design reconstitution programs would be beneficial. Additionally, the staff stated its intention to continue to evaluate design control adequacy during its performance-based inspections such as SSFIs and SSOMIs. The staff also expectedthattheenforcempntpolicyguidancetoprovidegreateropportunities for enforcement discretion would encourage voluntary identification of past design, engineering, and installation issues by licensees. With the Commission's approval, the staff proceeded with this approach.

In August 1992, the NRC issued a Commission policy statement " Availability and Adequacy of Design Bases Information at Nuclear Power Plants" (57 FR 35455)

(Attachment 1). This policy statement stressed the importance of maintaining current and accessible design documentation to ensure that (1) plant physical and functional characteristics are maintained and consistent with design bases, (2) systems, structures, and components can perform their intended functions, and (3) the plant is operated in a manner consistent with the design bases. In the policy st:.tement, the Commission recommended that all power reactor licensees assess the accessibility and adequacy of their design bases information and that they be able to show that there is sufficient documentation to conclude that the current facility configuration is consistent with the design bases. The policy statement outlined the additional actions the NRC would take to keep apprised of the industry's design reconstitution activities previously discussed.

Following review by the Committee To Review Generic Requirements (CRGR) and the Commission, a draft generic letter was issued for public comment on March 24, 1993. The proposed generic letter requested licensees, on a 3

NRC would refrain from imposing civil penalties for violations up to Severity Level II if the systematic violations voluntary were identified and corrected as a result of initiatives.

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. Mr. William Mayben voluntary basis, to submit information and schedules for any design bases ,

programs completed, planned, or being conducted, or a rationale for not '

implementing such a program. All but one of the commenters concluded that the l generic letter was unnecessary and unwarranted. NUMARC responded that it i believed the NRC's request for descriptions, schedules, and dates would have a i negative impact on ongoing design efforts and that NRC's focus on schedules would undermine the licensees' ability to manage the activities. In  ;

SECY-93-292, " Generic Letter on the Availability and Adequacy of Design Bases  !

Information," dated October 21, 1993, the staff recommended that the generic letter not be issued. The staff stated that publication of the policy statement and the proposed generic letter conveyed to the industry the Commission's concerr and that publication of the generic letter would not l further licensees' uareness of the importance of the activities. The staff l proposed to continue performing design-related inspections and to gather  !

information and insights as to how well the licensees' design-related programs '

were being implemented. The Commission issued a staff requirements memorandum that agreed with the staff's proposal.

In response to the findings relating to the regulatory burden of team inspections identified in the 1991 Regulatory Impact Survey, during the past ,

several years the staff has reduced its effort on specific, '

resource-intensive, design-related team inspections, and followed the issue of i accurate and accessible design documentation at plants principally as an element of inspection and followup of operations-related activities. The issuance of the NUMARC guidelines and ongoing industry efforts to improve and i maintain design bases information also contributed to this decision. ,

Current Proble Over the r ;everal months, NRC's findings during inspections and reviews have id ad broad programmatic weaknesses that have resulted in design and confit .,

n deficiencies at some plants, which could impact the operability of rec,_. red equipment, raise unreviewed safety questions, or indicate discrepancies between the plant's updated final safety analysis report (UFSAR) and the as-built or as-modified plant or plant operating procedures. These inspections and reviews have also highlighted numerous instances in which timely and complete implementation of corrective action for known degraded and nonconforming conditions and for past violations of NRC requirements has not been evident. Overall, the NRC staff has found that some licensees h failedto(1)appropriatelymaintainoradheretoplantdesignbases,pve

'As described in 10 CFR 50.2, design bases is defined as, " Design bases mean that information which identifies the specific functions to be performed by a structure, system, or component of a facility, and the specific values or ranges of values chosen for controlling parameters as reference bounds for design..." The design bases of a facility, as so defined, is a subset of the licensing basis and is contained in the FSAR. Information developed to j implement the design bases is contained in other documents, some of which are i docketed and some of which are retained by the licensee. ,

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Mr. William Mayben l (2) appropriately maintain or adhere to the plant licensing basis,5 (3) comply with the tepms and conditions of licenses and NRC regulations, and (4) assure that UFSARs properly reflect the facilities. Attachment 2 provides examples of some of the deficiencies recently identified by the staff. As a consequence of this new information, the NRC believes that the I industry's voluntary efforts to improve and maintain design bases information I for their plants, consistent with NUMARC 90-12, the staff's comments on the industry guidelines, and the Commission policy statement, have not been effective in all cases.

1 The magnitude and scope of the problems that the NRC staff has identified raise concerns about the presence of similar design, configuration, and operability problems and the effectiveness of quality assurance programs at other plants. Of particular concern is whether licensee programs to maintain configuration control at plants licensed to operate are sufficient to demonstrate that plant physical and functional characteristics are consistent with and are being maintained in accordance with their design bases. The extent of the licensees' failures to maintain control and to identify and correct the failures in a timely manner is of concern because of the potential impact on public health and safety should safety systems not respond to challenges from off-normal and accident conditions.

It is emphasized that the NRC's position has been, and continues to be, that it is the responsibility of individual licensees to know their licensing basis, to have appropriate documentation that defines their design bases, and to have procedures for performing the necessary assessments of plant or procedure changes required by NRC regulations. Attachments 3 and 4 are a recent exchange of correspondence between J. Colvin, NEI, and Chairman S. Jackson, NRC, regarding these subjects.

5 The licensing basis for a plant originally consists of that set of information upon which the Consission, in issuing an initial operating license, based its comprehensive determination that the design, construction, and proposed operation of the facility satisfied the Commission's requirements and provided reasonable assurance of adequate protection to public health and safety and common defense and security. The licensing basis evolves and is modified throughout a plant's licensing term as a result of the Commission's continuing regulatory activities, as well as the activities of the licensee.

Dhe FSAR is required to be included in, and is one portion of, an application for an operating license (0L) for a production or utilization facility.

10 CFR 50.34(b) describes the information which must be included in an FSAR.

The FSAR is the principal document upon which the Commission bases a decision to issue an OL and is, as such, part of the licensing basis of a facility. It is also a basic document used by NRC inspectors to determine whether the facility has been constructed and is operating within the license conditions.

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- Mr. William Mayben Action The NRC has concluded that it requires information that can be used to verify compliance with the terms and conditions of your license (s) and NRC regulations, and that the plant UFSAR(s) properly dpscribe the facilities,s as well as to determine if other inspection activities or enforcement action should be taken. Therefore, you are required, pursuant to Section 182(a) of the Atomic Energy Act of 1954, as amended, and 10 CFR 50.54(f), to submit a l response to this letter within 120 days of its receipt. Your response must be  ;

written and signed under oath or affirmation.

Please submit the original copy of your response to the NRC Document Control ,

Desk, and send a copy to the Director, Office of Nuclear Reactor Regulation  :

and to the appropriate regional administrator. The following information is required for each licensed unit:

(a) Description of engineering design and configuration control

processes, including those that implement 10 CFR 50.59,  ;

10 CFR 50.71(e), and Appendix B to 10 CFR Part 50; '

(b) Rationale for concluding that design bases requirements are translated into operating, maintenance, and testing procedures-1 i

(c) Rationale for concluding that system, structure, and component l configuration and performance are consistent with the design I

bases;

(d) Processes for identification of problems and implementation of corrective actions, including actions to determine the extent of problems, action to prevent recurrence, and reporting to NRC; and i

i I

7 A number of design bases inspections are being planned, and your response will be used in the planning process.

sSection VII.B.3 of the NRC Enforcement Policy addresses how old design issues involving past problems in engineering, design, or installation are to be handled from an enforcement standpoint. In a related matter, the Commission recently approved changes that would modify this policy to encourage licensees to undertake voluntary initiatives to identify and correct FSAR noncompliances by (1) the exercise of discretion to refrain from issuing civil penalties for a two-year period where a licensee undertakes a voluntary initiative in this area and (2) the exe cise of discretion to escalate the amount of civil penalties for violations associated with departures from the FSAR identified by the NRC subsequent to the two-year voluntary initiative period.

Mr. William Mayben (e) The overall effectiveness of your current processes and programs ir> concluding that the configuration of your plant (s) is r.onsistent with the design bases.

In responding to items (a through (e), indicate whether you have undertaken any design review or recon)stitution programs, and if not, a rationale for not implementing such a program. If design review or reconstitution programs have been r.ompleted or are being conducted, provide a description of the review programs, including identification of the systems, structures, and components (SSCs), and plant-level design attributes (e.g., seismic, high-energy line break, moderate-energy line break). The description should include how the program ensures the correctness and accessibility of the design bases information for your plant and that the design bases remain current. If the program is being conducted but has not been completed, provide an implementation schedule for SSCs and plant-level design attribute reviews, the expected completion date, and method of SSC prioritization used for the review.

This request is covered by the Office of Management and Budget (0MB) clearance  !

number 3150-0011, which expires July 31, 1997. The reporting burden for this l collection of information is estimated to average 400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> per response, I including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to the Information and Records Management Branch (T-6 F33), U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001, and to the Desk Officer, Office of Information and Regulatory Affairs, NE0B-10202 (3150-0011), Office of Management and Budget, Washington, D.C. 20503. The NRC may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. .

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i In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of l this letter and your response will be placed in the NRC Public Document Room (PDR), the Gelman Building, 2120 L Street, N.W., Washington, DC, and in the local pubile document room (s) for your facility or facilities. ,

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. Mr. William Mayben If you have any questions about this matter, please contact the staff members listed below, or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.

Sincerely, d

ff mes M. T4 or xecutive irector for Operations Docket No. 50-298 Attachments:

1. Policy Statement on Availability and Adequacy of Design Bases Information at Nuclear Power Plants

2. Background Information on Recently Identified Problems 3.

Letter from J. Colvin (NEI) to Chairman S. Jackson (NRC) I dated 8/2/96 i 4.

Letter from Chairman S. Jackson (NRC) to J. Colvin (NEI) i dated 8/14/96 j

Contacts: Kristine M. Thomas, NRR ,

(301) 415-1362 Internet: kmt9nrc. gov Eileen M. McKenna, NRR (301) 415-2189 Internet: emm@nrc. gov cc w/atts: See next page I

Nebraska Public Power Company Cooper Nuclear Station i

i cc:

Mr. John R. McPhail, General Counsel Lincoln Electric System Nebraska Public Power District ATTN: Mr. Ron Stoddard P. O. Box 499 11th & 0 Streets Columbus, NE 68602-0499 Lincoln, NE 68508 Nebraska P blic Power District Midwest Power AT~.1: Mr. John Mueller, Site Manager ATTN: Richard J. Singer, Manager-Nuclear P. O. Box 98 907 Walnut Street Brownville, NE 68321 P. O. Box 657 Des Moines, IA 50303 Randolph Wood, Director Nebraska Department of Environmental Nebraska Public Power District Control ATTN: Mr. Robert C. Goodley, Nuclear P. O. Box 98922 Licensing & Safety Manager Lincoln, NE 68509-8922 P. O. Box 98 Brownville, hE 68321 l Mr. Larry Bohlken, Chairman Nemaha County Board of Commissioners Mr. Guy R. Horn Nemaha County Courthouse Nebraska Public Power District 1824 N Street P. O. Box 499 Auburn, NE 68305 Columbus, NE 68602-0499 Senior Resident inspector U.S. Nuclear Regulatory Commission  :

P. O. Box 218 l Brownville, NE 68321  ;

Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011  :

1 Ms. Cheryl Rogers, LLRW Program Manager Division of Radiological Health Nebraska Department of Health .

301 Centennial Mall, South P. O. Box 95007 Lincoln, NE 68509-5007 Mr. Ronald A. Kucera, Department Director of Intergovernmental Cooperation Department of Natural Resources P.O. Box 176 Jefferson City, M0 65102

u 35453 Rules and Regulations r d" i " si '"

Vol. 5L No.154 htonday, August 10.19C Program Guidelines." NUh1 ARC 90-12. functional characteristics are This section of the FEDERAL REGISTER maintained and are consistent with the contains regulatory documents having While developing these guidelines, ceneral appi cab +ry and legal eNect. most NUMARC discussed them at several design bases as required by NRC of whsch are keyed to and Codifad en public meetings held with the NRC. The regulation. (2) systems, structures, and the Code of Federal Regulations. Ach is staff has concluded the NUMARC components can perform their intended uI hed under 50 titles pursuant w 44 guidelines provide a useful standard functions. and (3) the plant is operated framework for implementing design in a manner consistent with the design The Code of Federal Regulatons is sold bases.The Commission believes the reconstitution programs.The staff also by the Supenntendent of Documents Pnces of new books are listed in the agrees no single approach would enable regulatory framework already exists to utilities to best accomplish the address the need for accessible design first FEDERAL REGISTER issue of each bases and control of design information.

weet reconstitution task. The NUM ARC guidance appeared to provide sufficient The availability of current design and flexibility for individual utilities to licensing bases will also expedite the NUCLEAR REGULATORY vructure their programs to respond most license renewal process.

COMMISSION efficiently to their unique needs and The Commission believes, as a result chumstances. of NRC inspections and licensees'self-to CFR Part 50 The staff sent comments on the assessments, that all power reactor guidelines to NUMARC on November 9. hcensees should essess the accessibility Availabi!Ity and Adequacy of Design 1990. Commission paper SECY-90-365 and adequacy of their design bases Bases Inf ormation at Nuclear Power mi rmed the Commissioners in advance documentation.The results of this self-Plantst Policy Statement about the staff response to NUMARC. assessment should form the basis for a AGENCY: Nuclear Regulatory The staff requested NUMARC licensee's decision whether a design Commission. consider making the design bases effort reconstitution program is necessary and ACTION: Policy statement. a NUMARC initiative. NUMARC the attributes to be included in the concluded they would not pursue a program. The Commission recognizes sUMMAHv: t.he Nuclear Regulatory formalinitiative, but would forward the the need for a design reconstitution Commission is issumg this pohey guidelines to their members to use on a program to be tailored to meet the statement on availability and adequacy voluntary basis. Their reason for not unique needs of a particular utility.The of design information at nuclear power pursuing an initiative was that most of structure and content of the design plants. Th,si policy statement describes their membars were already conducting document reconstitution program will be the Commission's expectations and or evaluating the need to conduct design influenced by various factors. such as future actions with regard to the bases reconstitution programs. the utility % organizational structure, the availability of design information and The Commission's evaluation of the availability or unavailability of design emphasizes the Commission s view that status of reconstitution programs clearly documentation, and the intended users facmties should nut be modified without indicates the licensees' substantial of the documentation.The Commission a clear understanding of the apphcable investment in these programs should expects that after completing a engineering design bases. yield positive safety benefits for a reconstitution program, or as a basis for EFFECTIVE D ATE: August 10.1992. majority of sites.The NRC commends concluding that such a program is FOR FURTHER INFORM ATION CONT ACT:

those licensees that are acting to ensure unnecessary, the licensee will have Eugene V. Imbro. Office of Nuclear technically adequate and accessible current design documents and a fequate Reactor Regulation. U.S. Nuclear design bases documentation is technical bases to demonstrate that the Regulatory Commission. Washington. maintained. plant physical and functional DC 20555. telephone (301) 504-2967 However. the Commission is characteristics are consistent with the concerned some situations exist where design basis the systems. structures.

SUPPLEMENTARY INFORM Aff0N: NRC licensees have no' critically examined and components can perform their inspection findings have demt... rated their design control and configuration intended functions and the plant is being that some licensees have not adequatelv

' management processes to identify operated in a manner consistent with maintained their design bases requisite measures to ensure the plant .is the design basis.

information as required by NRC NUMARC has developed guidance for operating within the deugn bases regulations. Both the problems identified en" lope. Therefore. the Commission is the conduct of design bases during the NRC inspections and those articulating its expectations with regard reconstitution programs. The guidance identified by licensees have prompted to design information and elaborating on outlines a framework to organize and niost power reactor licensees to initiate. its planned activities to confirm the collate nuclear power plant design bases over the past several years. design information. This information provides integrity of the as. configured plant with bases reconstitution programs. To the rationale for the design bases respect to the plant design bases.

implement a reconstitution program. consistent with the definition of design licensees seek to identify missing design Policy Statement documentation and to selectively bases contained in 10 CFR 50.2.

NUMARC 90-12. " Design Basis Program Posinon regenerate missing documentation as The Commission has concluded that Guidelines." was issued in October 1990 required. for voluntary use by NUMARC memb 2r in 1989. Nuclear Utilities Management maintaining current end accessible and Resources Council. inc.. (NUMARC) design documentation is important to organizations as a reference point from began developing their " Design Basis ensure that (1) the plant physical and which licensees would review their Attachment 1

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35458 Fedtral Register / Vol. 57, No.154 / Monday August 10, 1992 / Rules and Regulations existing or planned efforts to collate ensuie their validity for the life of the DEPARTMENT OF THE TREASURY supporting design information. The facility, including any renewal period.

Commission believes NUMARC's in order to ensure the Commission is Office of Thrift Supervision i approach provides a useful framework appraised of mdustry's activities, the 12 CFR Part 584 I and worthwhile insights to those utilities NRC will take the following actions. l undertaking design basis programs. '

(1) The staff willissue a generic letter 192-1951 The Commission believes a licensee requesting alllicensees to describe the should be able to show that it has programs that are in place to ensure klN 155N4 sufficient documentation, including design information is correct. accessible.

calculations or pre operational, startup and mainta,med curretit. Those licensees Registration, Examination and Reports; Statements, Applications, or surveillance test data to conclude the that are not implementing a design Reports and Notices To Be Filed current facility configuration is reconstitution program will be requested consistent with its design bases. The to provide their rationale for not doing ACENCY: Office of Thrift Supervision.

Commission further believes the design so. lf a reconstitution program is under Trea3ury.

bases must be understood and way. the schedule for implementation Action: Final rule.

documented to support operability and completion will be requested.

determinations and 10 CFR 50 59 SUMMAmy:The Office of Thrift evaluations that may need to be made (2)The staff will prioritize NRC Supervision (OTS)is hereby amendmg quickly in responding to plant events. .nspections of licensee's management of its regulations pertaining to holding The design bases related information design and configuration using SSFl. company reporting requirements. In should be retrievable within a type techniques based upon responses updating existing forms to reflect reasonable period of tirne. however. it is to the generic letter and other plant changes necessitated by the Financial not necessary for all design basis specific information known to the NRC. Institutions Reform. Recovery, and documentation to be organized in one Additional staff guidance will be Enforcement Act of 1989, the OTS has place. The information used solely to developed where needed. for the design combined several forms to streamline i support the development of a bases aspects of these inspections. the reporting process and ease the ,

modification package would not need t "8" 'Y "" "8 '

• be able to be retrieved as expeditiously (3) The NRC systematic assessment of holding companies. In particular, the )

as information needed to support an licensee perf rmance (SALP) process reporting requirements set forth in operability determination. will be modified to explicitly address Forms H-(b)3. H-(b)4. H-(b)5 and H-assessment of licensee programs to (b)10 Registration Ctetements are now in the event the design bases control design bases information that contained in one body of instructions for information is found technically reflect NRC inspection activity in this all Registrants, the H-(b)10. In addition.

inadequate or not accessible. licensees area and assure consistent evaluations. the H-(b)11 Annual Report and the H-should consider whether remedial action (b)12 Current Report have been merged is warranted. A methodology should be (4) The staff will continue t into one set of instructions requiring an developed and implemented to ensure encourage self. identification of design annual filing with quarterly updates licensee resources are focused on design bases issues through application of the, informing the OTS of any changes.The mformation regeneration in a timeframe provisions of the Comm+ssion s commensurate with the safety enforcement policy.The ttaff will, H-(f) Dividend Notification has been reacinded, since the requirements significance of the missing or erroneous however, pursue enforcement actions for contained in the Capital Distributions information. engineering deficiencies whose root regulation are sufficient for the OTS's The Corrmission also emphasize o is cause lies in the inadequacy or monitoring and supervision purposes.

very important that modifications to a Fnavailability of design bases ErrecTive DATE: September 9.1992.

facility be made after a thorough review information and which are identified has been conducted and an during NRC inspections.

Michael P. Scott. Program Manager.

understanding of the applicable (202) 906-5748. Supervision Policy.

underlying design bases has been Paperwork Reduct. ion Act Statement Office of Thrift Supervision.1700 C gained in order to ensure appropriate This final policy statement does not Street. NW., Washington DC 20552.

design margins are preserved. contain a new or amended information suPPLcutNTARY INFORM ATION:

collection requirement subject to the future Actions Paperwork Reduction Act of1980(44

' 8' ""

. . U.S.C. 3501 et seq.). Existing The OTS is today issuing a final rule ,

The Comm.ission will continue t amending its holding company reporting requirements were approved by the l inspect routinely the adequacy of design Office of Management and Budget requirements. This amendment affects l control program effectiveness. The proval number 3150-0011. the registration, annual, and current Commission concludes that ensuring the reporting requirements.

design bases and configuration of a Dated at Rockville. Marylend. this 4th day facility are well understood and Reg /Strotion Slotements of August.1992.

controlled in plant documents will also As previously structured, holding ensure that those parts of the current for the Nuc! car Regulatory Commission- companies were required to choose from l licensing bases of most safety four separate registration statements.

significance are understood and Samuel l. Chilk. These separate statements were controlled. Other aspects of the current Secretary of the commission- originally deemed necessary to licensing bases. such as emergency (FR Dec. 92-18895 Fi!ed B-7-92. 8 45 mm) acem OePdWdWM preparedness and security plans. should companies (i.e., companies that become also be appropriately examined to mLLmo coot n* savings and loan holding companies as S-310999 0002(00K07-AUG 92-12 00 32) 4 On NfT .f1n ant . 4an.o2

l BACKGROUND INFORMATION ON RECENTLY IDENTIFIED PROBLEMS Over the past several months, design and engineering information has been obtained that indicates that design bases at certain plants have not been appropriately maintained or adhered to. Specific examples follow:

Millstone Units 1. 2. and 3 An NRC inspection team recently found examples in which design bases information and the Updated Final Safety Analysis Report (UFSAR) did not agree with the as-built plant, operational procedures, and maintenance practices.

The team found inconsistencies that required analyses, procedure changes, and design changes to resolve. For example, the Millstone Unit 3 operating procedures required isolation for the turbine-driven auxiliary feedwater pump during certain plant conditions, in conflict with technical specification requirements for operability. The team found that certain protective relays at Millstone Unit 3 were not set in accordance with the design bases information. This required re-analyses and resetting of tertain relays.

Based on the team's findings, the licensee initiated design changes to correct nonconforming conditions between the UFSAR and the as-built plant, including changes to the design of the Millstone Unit 2 reactor protection system to meet the design bases with respect to physical separation of redundant channels and changes to the design of the Millstone Unit 2 (post-loss-of-coolant accident (LOCA)) hydrogen monitors to meet the design bases for single failure vulnerabilities.

fi1# am Neck An NRC inspection team found examples in which the design bases information and the UFSAR did not agree with the as-built plant, operational procedures, and maintenance practices. The team identified a number of deficiencies in engineering calculations and analyses that were relied upon to ensure the adequacy of the design of key safety systems. Deficiencies were identified in the calculations and analyses supporting the station batteries, emergency diesel generators, containment cooling system, and other key safety systems.

In some cases, the inspection findings were resolved by revising the calculations and analyses. .In other cases, procedure and design changes were required to resolve the issues. For example, the team identified that the design bases calculations supporting the size of the station batteries were inconsistent with the design bases stated in the FSAR. Field measurements and design modifications were required to resolve this issue.

Other issues were identified by the NRC and the licensee following the issuance of this special team inspection report that led the licensee to enter a refueling outage earlier than originally scheduled. Discrepancies included inadequate configuration management of the containment sump design and as-built conditions; a lack of detailed analysis and technical justification for the reliance on post-accident back pressure inside the containment to assure adequate net positive suction head for the residual heat removal pumps; inadequate inspection and verification of the sump as-built and material Attachment 2

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conditions; and the lack of aggressive action in response to generic' .

communications of industry events, which contributed to an inadequate  !

operability determination regarding the sump screen design and mesh size.

These issues impacted the operability of the emergency core cooling systems (ECCSs) under certain postulated design basis events.

Maine Yankee On January 10, 1996, the NRC issued a Confirmatory Order Suspending Authority for and Limiting Power Operation and Containment Pressure and a Demand for  !

Information to the Maine Yankee Atomic Power Company. The order was based, in part, on the NRC's determination that Maine Yankee did not apply a computer code that was proposed to demonstrate compliance with the ECCS requirements of 10 CFR 50.46 in a manner that conforms to the requirements of 10 CFR Part 50, Appendix K, nor to the conditions specified in the staff's safety evaluation

. dated January 30, 1989. Specifically, the licensee did not demonstrate that the RELAP5YA code will reliably calculate the peak cladding temperature for all break sizes in the small-break LOCA spectrum for Maine Yankee, nor has the licensee submitted the justification for the code options selected and other justifications and sensitivity studies to satisfy conditions in the staff's safety evaluation.

In addition, the licensee assumed an initial containment pressure of 2.0 psig for calculating peak design-basis accident pressure, even though the plant's technical specifications allow a maximum operating pressure in containment of 3.0 psig. Assuming an initial containment pressure of 3.0 psig results in a calculated peak accident pressure in excess of the containment design pressure '

described in the UFSAR. _

Refuelina Practices Survey In a survey of licensee refueling practices conducted during the spring of i 1996, the NRC identified deficiencies in the management of design bases assumptions. Many plants were found to have aspects of their design bases that were only loosely proceduralized or not procedura11 zed at all. Typical of this kind of discrepancy was the identification of a lack of procedures for controlling the assumptions regarding hold-up time before beginning fuel transfer. The NRC found a number of instances in which other design bases ,

assumptions were not captured in procedures. In addition, it was necessary for licensees at 12 sites (23 units) to upgrade procedures to directly implement the design bases assumptions. In other cases, the licensee

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performed engineering analyses, documented pursuant to 10 CFR 50.59, as necessary, to ensure that the planned activities would not exceed design bases assumptions.

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• Joe F. Colvm August 2.1996 The Honorable Shirley A. Jackson Chairman U.S. Nuclear Regulatory Commission Washington. DC 20555-0001

Dear Chairman Jackson:

On July 23.1996, the Nuclear Strategic Issues Advisory Committee (NSIAC) held a special meeting to discuss industry actions for ensuring the licensing basis of nuclear plants is being maintained consistent with the regulations. The chief nuclear officers of the nuclear utilities approved an initiative to provide additional assurance and confidence that existing programs are adequate to ensure that:

. Licensees are operating their plants in conformance with their licensing basis:

. Licensees are adequately maintaining their licensing basis:

. There are no differences between operating practices and the licensing basis that could result in a significant public health and safety concern: and

. Degraded or non-conforming conditions are captured on tracking systems and resolved in a timely manner.

Under the initiative. each licensee will conduct an assessment of the programs in place to reaffirm that plants are operated in conformance with their licensing basis.

The program assessment is accomplished by sampling (1) FSAR information. (2) programs in place for processing changes to procedures and the plant that may impact the FSAR and (3) changes that may not be governed by licensee programs.

Alany licensees have already commenced or recently completed similar program assessments.

Differences identified through the sampling process will be evaluated to assess the overall effectiveness and adequacy of programs. Programmatic enhancements will be made if needed. The overall significance of any differences will be characterized to determine if additional sampling is warranted.

Differences that represent degraded or nonconforming conditions will be captured on a tracking system and resolved in a timely manner. Each licensee will notify the NRC of any differences that are subject to reporting requirements per the regulations.

Un9 l DM ~( Attachment 3 V " - *]t

' V

The Honorable Shirley A. Jackson ,

August 2.1996 Page 2 The results of the individual plant assessments will be provided to NEI for compilation in an industry summary report. The summary report wt1] be provided to the NRC for information The industry has developed a draft guidehne to assist utihties in performing the programmatic assessment. The guidehne will be finabzed subsequent to resolution of the issued discussed below Enclosure 1 provides a copy of NEI 96-05 (Draft)

Rension D. "Guidehnes for Assessing Programs for .\laintaining the Licensing Basis. ' for your information.

There are a number of related issues that require a mutual agreement between the i industry and the NRC before the industrv can proceed with the initiative in a consistent manner. These include-

. The legal standing of the Updated Final Safety Analysis Report and the NRC s Safety Evaluation Reports.

. The scope of what constitutes the current bcensing basis: and

- The adequacy of NSAC-125 for performing 10 CFR 50 59 safety evaluations The industry is committed to completing the initiative within six months of the resolution of these issues initial progress in resolving these issues was accomphshed during the NRC pubhc meeting also held on July 23.1996. We  ;

appreciate very much the participation of your senior staffin this meeting and the opportunity to discuss these issues. Expedited closure on these fundamentalissues is needed to minimize confusion within the NRC regicns and the plants and focus our resources on addressing the programmatic issues.

We look forward to a continuing dialogue with the Commission and NRC staff to achieve timely resolution of this matter.

Sincerely.

44AL -

( F Colnn

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i Enclosure c Comnus.-toner Kenneth C Rogers. NRC Commi-sioner Greta .L Dicus. NRC

.\f r Jame. .\l Tavlor. NRC

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i O \

NEI 96-05 (DRAFT)  ;

Revision D l NUCLEAR ENERGY INSTITUTE l

1 GUIDELINES FOR ASSESSING PROGRAMS FOR MAINTAINING THE LICENSING BASIS 1

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JULY 25,1996 b ' '? ? ftr2t!,g l.; f y -

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1.0 INTRODUCTION

Licensees have implemented various programs / processes over the period of their licenses for ensuring that the licensing basis is known. is maintained current and is accurately described in the FSAR and associated referenced documents. The NRC.

through a review described in SECY 94 066. determined that bcensees were adequately maintaining the licensing basis of their facilities. As a result of events that have occurred over the last several months, the NRC has increased attention on licensee compliance with the plant's bcensing basis. Differences can occur due to problems in those processes / programs intended to effect changes in the license basis, missing programmatic controls to translate changed operational activities into the licensing basis, or a lack of awareness oflicensing basis features.

Licensees employ various programmatic mechanisms for identifying, evaluating and/or processing changes in plant activities that could affect the licensing basis or that are intended to make changes to the licensing basis. These include:

. Final Safety Analysis Report (FSAR) updates per 10 CFR 50.71(e)

. Safety E.aluations per 10 CFR 50.59

. Changes to Quahty Assurance. Security and Emergency Plans per 10 CFR 50.54

. License amendments per 10 CFR 50.90

. ASME Code rehef requests per 10 CFR 50.55a

. Procedure changes (not subject to 50.59)

. Design changes (not subject to 50.59)

. Regulatory commitment changes

. Degraded or non conforming conditions

. Configuration management changes (e.g., operator workarounds, extended operation of equipment in manual mode rather than a tomatic operation modes, and Technical Spectfication positions / interpretations) 1

2.0 PURPOSE AND SCOPE 2.1 Purpose This document provides guidance for performing a self assessment of the adequacy of programmatic controls for maintaining the licensing basis in order to identify missing or incorrectly applied programmatic elements that can lead to licensing basis differences.

2.2 Scope The assessment approach consists of a data-gathering phase and an evaluation phase. The data gathering phase employs a three-tiered sampling technique. The first tier involves in-process sampling for the programmatic elements intended to effect a change in the licensing basis. Since programmatic elements may be missing or incorrectly applied. the next two sampling tiers involve a search for differences by samphng for potential operational changes that could be made without procedure changes. and samphng backwards by comparing selected FSAR statements with operational practices. The purpose of the data gathering phase is to identify a set of potential differences between the operational practices and tiie licensing basis.

The evaluation phase determines if potential differences are valid. Valid differences are categorized in order to draw conclusions about the adequacy of particular programmatic controls for maintaining the licensing basis. The signtficance of the findings are used to develop recommendations for programmatic enhancements.

It is recognized that many bcensees have performed safety system functional inspections (SSFIs) and other reviews that have assessed the adequacy of their programs to maintain the licensing basis of their plants and to ensure tha accuracy ofinformation in the FSAR. These completed activities can be credited, as appropriate, in meeting portions of the assessment described below.

The assessment methodology described below represents only one way of performing the assessment of the adequacy and effectiveness of programs for maintaining the licensing basis. Although the methodology contains a reasonable amount of detail, it is not intended to be prescriptive. Other approaches that provide an equivalent scope of review can also meet the intent of this assessment.

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3.0 ASSESSSIENT 51ETHODOLOGY 3.1 Data-Gathering Phase The data-gathering phase of the assesstnent employs three sampling techniques.

j Each sampling technique is discussed separatel:.

3.1.1 FSAR Sampling *

. Extract the relevant FSAR sections for the system (s) being evaluated j = Highlight those FSAR statements that meet the following criteria:

. O Descriptive phrases regarding frequencies for tests, calibrations. etc.

Con 6guration descriptions l

Descriptions of system operation in different modes j te.g. normal, abnormal. accident / emergency) j  : Operating limits

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j  : Descriptive functional performance statements i

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• NOTE: The intent is to identify a range of FSAR statements associated with i

operational practices that could be changed and. in the presence of l

programmatic weaknesses, are not adequately reDected in the FSAR.

. Compare the highlighted FSAR statements with current operational l practices using individuals cognizant of the operation of the system and l associated engineering problems. Document the following

0 is the FSAR statement accurate with respect to operational practices (procedures, operating philosophy, standing orders workarounds, etc.)? 1 If not, identify the differences.

0 Is the FSAR statement clearly understood or in need of clarification?

3.1.2 Programmatic Sampling

. Select three unrelated examples of each of the following types of changes:* ;

50 59 ( at least one procedure chance evaluationi 3

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> 50.54 (one each from QA. EP and Security)

Outstanding corrective action for a matarial condition greater than one 2 year old

Operating procedure change not evaluated under 50.59 I

O FSAR change request j 0 50.90/50.55a change and associated SER (where NRC approval I has been received)

o Regulatory commitment addition or change

1 3 0 Design change not evaluated under 50.59

• NOTE: The chances selected should have been completed in sufficient time to have been reDected (if required)in the most recent licensing basis update of the FSAR. QA program. etc.

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• Review the change to determine if the change should have appeared in the beensing basis and. if so. if the licensing basis accurately reDects the change.

For changes that are not accurately reDected in the licensing basis, 4

determine the programmatic step (or rnissing programmatic step) that a

would have ensured its accurate incorporation into the licensing basis.

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• Document the results of the progratntnatic sampling.

j 3.1.3 Sampling for potential changes that may occur separate from l

programmatic or procedure changes )

i a Compile the following:

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0 Workaround list

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l 0 Operations standing orders

' O Technical Speci6 cations positions / interpretations (if any)

Sample of doeurnents that may show potentially routine "NA'ing" of procedure steps (e.c. last completed startup procedure. recently completed a

systern operatine instructions. shift supervisor loc entries for deviationsi 4

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List of equipment being operated in manual i

Old* temporary alterations  ;

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- Old" non conformances 1

Old* tag outs

• "Old" refers to current items that should be reDected (if requtred)in the last FSAR update per 10 CFR 50.71(e)

. Select a sample from each of the above categories based on the number of items compiled.

. Review the item selected to determine if the item represents a change to the l bcensinc basis and if so,if the bcensing basis accurately reDects the change.

For changes that are not accurately reDected in the bcensing basis. l determine the programmatic step (or missing programmatic step) that would have ensured its accurate incorporation into the licensing basis. j

. Document the results of the sarnphng.

3.2 Evaluation Phase 1

At this point in the assessment. the changes to operating practices that should have been reDected in the beensing basis have been identined. Those not accurately reDected in the bcensing basis are differences that must be resolved and categorized.

The evaluation phase cannot be precisely structured. However, the following broad steps should be undertaken.

. Categorize differences in accordance with the following criteria:

0 Procram/ process which should have ensured licensmg basis accuracy 1

0 Significance a Safety significant

- Regulatory sign 10 cant (i e. noncomphance or missed commitment)

- Low stentncance ve.c.. the critinal information was not required to i>e included in the FSAR. or the information could not have been 5

y,--- ,

.e i

t rebed upon by the NRC in reaching a safety conclusion)

[ NOTE Section V of NDLARC 9012. " Design Basis Program Guidelines." provides guidance for assessing the safety significance of l

differences and for determining 'f operability and/or reporting issues exist.]

O 50.59 was correctly / incorrectly applied

. Licensing basis information has always been maccurate (i.e., there was no change in operating practice)

• Identify areas of programmatic weakness or missing programmatic controls.

If uncertain, pursue additional assessment investigation for the programmatic area in question.

• Characterize overall significance of the &ndings. Based on this characterization determine the need to broaden the assessment scope to obtain the necessary confidence that the programs are adequate and are being effectively implemented

• If applicable. generate necessary quality de6ciency documents and identify ,

any reportable situations.

• Prepare recommendations to address programmatic weaknesses.

• Docutnent the results and brief appropriate management.

4.0 NTI REPORT 4.1 Purpose of Report NEl will compile the overall industry results to assess the composite adequacy and effectiveness of programs designed to maintain the licensing basis of tha plants. The overallindustry results will be reported to the NRC by hTI.

4.2 Report Format The report format follows the steps contained in Section 3.0 of this report.

Part 1 - FSAR Samplinc

= Identify the FSAR systems reviewed under Section 31.1

• Indicate the number of FSAR differences identi6ed G

r Part 2 - Programmatic Samoline l Indicate the total number ofitems reviewed. l

. Indicate the number ofitems where the change was not accurately reDected in the bcensing basis.

Part 3 - Sampline for notential chances that mav occur separate from programmatic or orocedure changes Indicate the total number ofitems reviewed.

Indicate the number ofitems where the enange wn not accurately reDected in the licensing basis, if regtured.

Part 4 - Evaluation Phase Indicate the number of differences that were characterized as being safety signt5 cant.

Indicate the number of differences that were characterized as bemg l regulatory signtScant.

Indicate the number of differences where 50.59 was incorrectly applied.

Indicate the number of differences where the licensing basis information has always been inaccurate.

Provide a brief summary of the programmatic de5ciencies identiSed,if any.

Indicate whether the assessment scope is being broadened based on the identt5ed differences.

Describe any departures from the methodology of this guideline.

5.0 DEFINITIONS 5.1 Regulatory Commitment NEI " Guideline for Managing NRC Commitments." endorsed by NRC in SECY-95 300. dennes a regulatory commitment as follows:

"Reculatorv Commitment means an explicit statement to take a spectSc action agreed to or volunteered by a licensee that has been submitted in writing on the docket to the Commission."

5.2 Licensing Basis 10 CFR Part 54 de6nes th< current "hcensing basis as follows:

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" Current licensing basis (ci.Bi is the set of NRC requirements applicable to a spect5c plant and a licensee's written commitments for ensuring compliance with and operation within applicable NRC requirements and the plant speciEc design basis (including all modi 5 cations and additions to such commitments over the life of the license) that are docketed and in effect. The CLB includes the NRC requirements contained in 10 CFR j parts 2.19. 20. 21, 30, 40, 50. 51, 51, 55, 70. 72, 73. and 100 and appendices thereto: orders: license conditions; exemptions: and technical speci5 cations. It also includes the plant speciEc design basis ,

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information de5ned in 10 CFR 50.2 as documented in the most recent '

j Enal safety analysis report (FSAR) as required by 10 CFR 50.71 and the bcensee's commitments re,aining in effect that were made in docketed licensing correspondence such as licensee responses to NRC bulletins, l licensee

generic letters. and enforcement actions, as well as

commitments documented in NRC safetv evaluations or licensee event 4 reports "

l NOTE Responses to NRC bulletins. generic letters and bcensee event l reports contain sorne commitments that are outside the scope of the CLB in that they are not necessarv to ensure comphance with applicable NRC requirements (e.g., rules. regulations. licenses and orders) or to maintain the plant specinc design basis. 9 e

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w UNITED STATES

[&* *s c NUCLEAR REGULATORY COMMISSION e* . -

1. ' WASHINGTON D C 2055M001 o  !

August 14, 1996

\s*.... / ,

CHAIRMAN Mr. Joe F. Colvin President and Chief Executive Officer Nuclear Energy Institute Suite 400 1776 1 Street, N.W.

Washington, D.C. 20006-3708

Dear Mr. Colvin:

I am responding to your letter of August 2, 1996, concerning industry actions for assessing programs in place to reaffirm that nuclear power plants are operated in conformance with their licensing basis. Your letter also identified three issues that, in your view, require mutual agreement between the industry and the Nuclear Regulatory Commission (NRC) before the industry would proceed with the initiative: (1) the legal standing of the Updated Final Safety Analysis Report (FSAR) and the NRC's Safety Evaluation Reports; (2) the scope of what constitutes the current licensing basis; and (3) the adequacy of NSAC-125, " Guidelines for 10 CFR 50.59 Safety Evaluations," for performing 10 CFR 50.59 evaluations.

We believe that resolution of the issues you identified is not a prerequisite to reviewing, on a retrospective basis, whett'er existing programs are sufficient to ensure that licensees know their licensing bases, whether licensing bases have been properly maintained, and whether licensing basesThe are accurately described in each facility's updated FSAR or other documents.

significant issues recently identified by licensee reviews and NRC staff inspections relate to failures to address degraded and nonconforming conditions properly, failures to perform reviews required by 10 CFR 50.59 before making changes to facilities, and failures to update facility Final In our view, Safety Analysis Reports in accordance with 10 CFR 50.7)(e).

industry initiatives can proceed notwithstanding that ongoing NRC activities under the 10 CFR 50.59 Action Plan will consider, in a broad sense, issues such as those you raise.

Existing regulations and guidance are sufficient to conduct a retrospective review for conformance to existing regulatory requirements. These include:

(1) NRC regulations 10 CFR 50.2, 50.34, 50.54, 50.59, 50.71(e), 50.72, 50.73 and Appendix B; (2) NRC's policy statement - Availability and Adequacy 10,of1992; Design Bases Information at Nuclear Power Plants, 57 FR 35455 August (3) " Design Bases Program Guidelines," NUMARC 90-12 and NRC letter dated November 9, 1990: and (4) Generic Letter 91-18, "Information To Licensees Regarding Two NRC Inspection Manual Sections On Resolution Of Degraded And Nonconforming Conditions And Operability."

Attachment 4

\U 0)Y ) }jh -

l The staff is concerned, however, that the proposed initiative may not be of sufficient scope and depth to identify tha types of design and operability is problems recently identified at several operating plants. Specifically, it not suf ficient to perform a process / procedural based review. An in-depth vertical slice review of actual design basis documentation and comparison of l

"as built" and "as operated" safety systems is more appropriate.

I For example. reviews similar to safety system functional Inspections (Inspection Procedure 93801, " Safety System Functional Inspections"), may be used to evaluate a licensee's program effectiveness to maintain the licensing and design bases. These review should include: (1) an in-depth review of selected systems' design and design basis since issuance of the facility operating license: (2) risk- and safety-based criteria for selection of systems for review; and. (3) a method to ensure that licensee problem identification and correct 1ve action on the selected systems are representative and consistent with other systems. The in-depth review should exa-ine: (1) engineering design and configurstion control; (2) verification cf as-built and as-modified conditions; (3) translation of the design bases requirements into operating procedures, maintenance, and testing; (4) verification of system performance through review of test records and 1 cosenations of selected testing: (5) proposed and implemented corrective acticns for licensee-1dentified design deficiencies; and, (6) modifications ade to the syste s since initial licensing.

In sncrt. the NRC position has been, and 15, that it is the responsibility of Individual licensees to know their licensing basis, to have appropriate documentation that defines their design basis, and to have procedures for b.,

performing the necessary assessments of plant or procedure changes required NRC regulations. Until such time that any regulation changes are made as a result of NRC action plan activities, we will continue inspection and oversight act1vities related to the design basis to ensure compliance with ~

exist 1ng regulations.

Sincerely, b--

Shirley Ann Jackson i

J Distribution for 50.54(f) letter to utility CE0s dated: October 9, 1996 Docket File PUBLIC J. Taylor EDO Rdg File

F. Miraglia/A. Thadani R. Zimmerman 1

DRPW/DRPE/DRPM Directors DRPW/DRPE/DRPM Deputy Directors J. Lieberman J. Goldberg W. Dean

.. G. Tracy l B. NcCabe 4 J. Mitchell

D. Matthews i

E. McKenna K. Thomas F. Akstulewicz OGC ACRS OPA DRPW/DRPE PDs NRR PMs NRR LAs

PD Rdg File

R.W. Cooper, RI i

E. Merschoff, RII

W.L. Axelson, RIII J. Dyer, RIV

K. Perkins, RIV/WCF0 i

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