ML20134D914

Forwards Responses to 850328 Ltr Inviting Commission to Testify at 850417 Hearing on NRC FY86-87 Budget Authorization

ML20134D914
Person / Time
Issue date:	04/16/1985
From:	Palladino N NRC COMMISSION (OCM)
To:	Markey E HOUSE OF REP., ENERGY & COMMERCE
Shared Package
ML20134D918	List: ML20134D914 ML20134D924 ML20134D935
References
NUDOCS 8508190457
Download: ML20134D914 (265)

Text

~

I ]

+f **%o, ,, UNITED STATES f0(L *

! o NUCLEAR REGULATORY COMMISSION j

, WASHINGTON, D. C. 20S58 April 16, 1985

% oo . . #'

CHAIRMAN l

t The Honorable Edward Markey, Chairman Subcomittee on Energy Conservation & Power Comittee on Energy and Comerce United States House of Representatives Washington, D.C. 20515

Dear Mr. Chairman:

Attached are the Comission's responses to pre-hearing questions transmitted in your letter of March 28, 1985, inviting the Comission to testify at the April 17th hearing on NRC's FY86-87 budget authorization.

This letter transmits the responses to questions 1, 2.a., 2.c., 2.f 3.a. 4.a. , 4 b. 4.e. , 4. f. , 5-8, 10-12, 13.b. ,

(without attachments),

13.c., 15-19, 20.a.-20. d, an,d 21-23. Because of their volume, the responses to questions 3.c. 4.c and 20.d will be made available in the NRC public document room. The remaining responses are being forwarded under separate cover.

Sincerely, g g,.

. ., ( ' t . < [ - '-

Nunzio J. Palladino cc: Rep. Carlos J. Moorhead 0500190457 850416 PDR COMP 99 NRCC CORRESPONDENCE PDR l

1

1 1

l

CUESTION 1. PLEASE PROVIDE A DETAILED ACCOUNTING OF THE IMPACT  !

ON NRC PROGRAMS OF THE $100 MILLION DIFFERENCE BETWEEN THE NRC PROPOSED AND OMB ACCEPTED BUDGET AUTHORIZATION. EXPLAIN EXACTLY WHAT REDUCTION IN

~

FUNDING OR ELIMINATION OF PROGRAMS RESULTED ON A PROGRAM BY PROGRAM BASIS.

l i

l ANSWER.

THE FOLLCWING ATTACHMENTS PROVIDE THE IMPACT OF THE OMB REDUCTIONS:

i ATTACHMENT 1 - NRC BUDGET ESTIMATES FY 1986/87 SUBMITTED TO OMB IN SEPTEMBER 1984 ATTACHMENT 2 - MEMO FROM THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) TO THE CHA!RMAN OF JANUARY 9, 1985.

SUBJECT:

REVISED BUDGET EST! MATES  !

ATTACHMENT 3 - MEMO FROM THE CHA!RMAN TO THE EDO OF JANUARY 18, 1985,

SUBJECT:

FY 1986 BUDGET SUBMISSION ,

I L

l l

l I

l -- _ - . . - . - . . - - . - - - - - - - - - . - . - . , . - . . . -

l l

l l CUESTION 2. Please provide the follcwing information with respect to the 1

Office of Investigatiens (01):

l (a) The size of the O! staff and budget per FY for each year

! since its formation, ,

ANSWER.

The size of the Office of Investigations (01) staff has remained at 38 persons since the office was formed in July 1982. The O! budget, except for travel funds, is not a separate line item in the NRC budget. Expenditures for travel are shown below.

FISCAL ACTUAL YEAR EXPENDITURE t

1982 $ 12,087 1983 $224,210 1984 $314,057 l

1985 $300,000'

• As of 1/31/85, $136,381 was expended.

I i

t l

l QUESTION 2. (c) THE NUMBER OF CASES (INVESTIGATIONS AND INQUIRIES) INITIATED AND COMPLETED CACH YEAR

( AND THE NUMBER REFERRED TO THE DEPARTMENT OF JUSTICE SINCE 1982.

ANSWER.

WHEN THE OFFICE OF INVESTIGATIONS (01) WAS FORMED, A SUBSTANTIAL NUMBER OF CASES WERE TRANSTERRED TO THE OFFICE. MOST OF THOSE CASES WERE CLOSED IN 1982.

CASES CASES yJJL& INITIATED CLOSED 1982 253 206 1983 204 160 1984 167 114 1985 (THPV 3/30) 67 25 TWENTY-S!X CASES HAVE BEEft REFERRED TO THE DEPARTMENT OF JUSTICE (00J) SINCE THE IncEPTton 0F 0! In 1982, l

l

j CUESTf0N 2(C) (CONT!NUED) -

i THE DOWNWARD TREND IN THE CASELOAD IS ATTRIBUTABLE TO TWO FACTOPS. [

i FIRST, 0! INHERITED A LARGE NUMBER OF CASES UPON ITS INCEPTION IN 1

JULY 1982 THAT WERE NOT MATTERS PURELY WITHIN 01 JURICDICTION.

l THESE CASES SKEW THE' CASELOAD FIGURES FOR 1982 AND SOME OF 1983.

SECOND, 01 HAS BEEN MORE DISCRIMINATING IN THE TYPES OF CASES THAT ,

IT HAS ACCEPTED FOR INVESTIGATION. THE 1984 AND 1985 FIGURES

{

i REFLECT THIS TREND. THE RESULT OF THIS HAS BEEN TO INVOLVE 0! IN  :

i  !

]

CASES WHICH ARE MORE COMPLEX, TIME CONSUMING, AND LABOR INTENSIVE.  !

j j THIS IS ESPECIALLY TRUE REGARDING THE LARGE NUMBER OF CASES RELATING To NTOL FACILITIES, [

)

3 i I

l f

j .

j 3 ,

4 i

(

i

1 1  :

)

i i

I

)

i i

i

. t 4

i i

CUESTION 2. PLEASE PROVIDE THE FOLLOWING INFORMATION WITH RESPECT TO THE OFFICE OF INVESTIGATIONS (01):

(F) A LISTING OF THE NUMBER OF ALL UNCOMPLETED

!NVESTIGATIONS AND INQUIRIES AT THE TIME OF LOW POWER AND FULL POWER LICENSING FOR FACILITIES LICENSED SINCE 1

l 1982, INCLUDING THE REASON THE CASES WERE NOT COMPLETED

{ PRIOR TO LICENSING, THE SAFETY SIGNIFICANCE OF THE l

ISSUE (S) IF FOUND TO BE TRUE, AND WHETHER THE COMMISSION OR NRC STAFF EVALUATED OR TOOK ANY ACTION TO RESOLVE THE POSSIBLE SAFETY SIGNIFICANCE OF THE ISSUES PRIOR TO LICENSING. PLEASE DESCRIBE IN DETAIL WHAT FORMAL REGULATORY CRITERIA AND PROCESS THE COMMISSION AND NRC STAFF USE TO MAKE LICENSING DECISIONS IN CASES WHERE THERE ARE UNCOMPLETED O! INVESTIGATIONS AND INQUIRIES OF ISSUES WITH POSSIBLE SAFETY S!GNIFICANCE.

ANSWER, ALL ALLEGATIONS ARE SYSTEMATICALLY REVIEWED BY THE NRC TECHNICAL STAFF. ALLEGATIONS ARE REVIEWED FOR BOTH TECHNICAL AND WRONGD0 LNG ISSUES. SHOULD THE STAFF FIND THAT THE ALLEGATION CONTAINS BOTH TECHNICAL AND WRONGDOING PORTIONS, THE STAFF ASSIGhS THE TECHNICAL PORTION TO THE APPROPRIATE SECTION FOR REVIEW AND ASSESSMENT PRIOR TO LICENSING. THE STAFF ASSIGNS THE WRONGD0!NG PORTION TO 01.

i I

ISSUES WHICH ARE FOUND TO BE SAFETY SIGNIFICANT AND HAVE A BEARING ~

i

~0N THE LICENSING DECISIONS ARE ADDRESSED PRIOR TO LICENSING. OTHER l ISSUES (SUCH AS WRONGDOING) ARE FOLLOWED THROUGH TO COMPLETION, i

BUT NEED NOT BE RESOLVED PRIOR TO THE ISSUANCE OF AN NRC LICENSE.

ALL THE UNCOMPLETED INQUIRIES AND INVESTIGATIONS ON THE ATTACHED j LIST RECEIVED SUCH A REVIEW BEFORE A LICENSE WAS ISSUED FOR THAT FACILITY. THESE PROCEDURES ARE CONTAINED IN NRC DRAFT MANUAL l l CHAPTER 0517 lATTACHED).

l l

MORE0VER, WHAT IS NOT REFLECTED HERE IS THE VAST AMOUNT OF  !

]

RESOURCES SPENT ON ALLEGATIONS AND TECHNICAL CONCERNS WHICH ARE l OPENED AND CLOSED PRIOR TO LICENSING. MUCH OF THIS EFFORT IS IN j THE~ INSPECTION AREA. FOR EXAMPLE, MAJOR TASK FORCE EFFORTS WERE

{ MOUNTED IN THE CASES OF WATERFORD 3 AND COMANCHE PEAK. FOR WATERFORD 3 THE EFFORT INVOLVED AS MANY AS S!XTY STAFF PEOPLE ON SITE AT ONE TIME. IN FACT IN EXCESS OF 20,000 MANHOURS WERE SPENT

!' ON 350 ALLEGATIONS. THE BULK OF THIS ONSITE EFFORT WAS EXPENDED j gn APRIL, MAY AND JUNE OF 1984.

l ALTHOUGH COMANCHE PEAK HAS NOT YET PECEIVED A LOW-POWER LICENSE THE STAFF CURRENTLY HAS A TEAM OF ABOUT 50 PERSONS REVIEWING APPROXIMATELY 600 ALLEGATIONS. THE COMANCHE PEAK TEAM HAS BEEF!

WORK!NG ON THESE ALLEGATIONS SINCE MARCH 1984 I

l i

i

3 CcMMISSIONER ASSELSTINE ADDS:

[N ANSWER TO YOUR QUESTI0f!, THERE ARE NO REGULATORY CRITERIA. THE PROCESS IS AS STATED ABOVE.

l l

i

~

~ QUESTION 3. PLEASE PROVIDE THE FOLLOWING INFORMATION WITH RESPECT TO THE OFFIC.E OF INSPECTOR AND AUDITOR:

(A) IHE NUMBER OF CASES INITIATED AND COMPLETED EACH YEAR SINCE 1983; ANSWER: .

DEPENDING ON THE SIGNIFICANCE AND SUBSTANCE OF AN ALLEGATION, THE OFFICE OF INSPECTOR AND AUDITOR (0IA) INITIATES EITHER AN INQUIRY OR FORMAL INVESTIGATION TO RESOLVE THE MATTER, SINCE 1983, OIA HAS INITIATED AND COMPLETED THE FOLLOWING NUMBERS OF CASES:

CY 1983 INQUIRIES INITIATED: 27 INQUIRIES COMPLETED: 27 INVESTIGATIONS INITIATED: 19 INVESTIGATIONS COMPLETED: 14 CY 1984 INQUIRIES INITIATED: 22 INQUIRIES COMPLETED: 19 INVESTIGATIONS INITIATED: 30 INVESTIGATIONS COMPLETED: 20 CY 1985 (JANUARY l - MARCH 31, 1985)

INQUIRIES INITIATED: 19 INQUIRIES COMPLETED: 10 INVESTIGATIONS INITIATED: 6 INVESTIGATIONS COMPLETED: 4

QUESTION-3 (CONT *NUED) (C) A LISTING BY SUBJECT OF ALL AUDITS COMPLETED SINCE 1983 INCLUDING THE DATE THE PROJECT WAS INITIATED, THE DATE IT WAS COMPLETED, THE RECCMMENDATIONS MADE AND THE CURRENT STATUS OF IMPLEMENTATTON OF THOSE RECOMMENDATIONS; ANSWER:

THE REQUESTED INFORMATION IS ATTACHED.

4 i

TITLE DATE DATE f 0. OF STARTED QMLETD PECO'f M ATIO 6 ATTX}+ 0fr

1. OIA Report on fGC Ingmst 01/01/82 02/28/83 3 A Fund

2. OIA Survey cf PRC's Office 09/07/82 03/30/83 0 of the Executive Legal Directer

3. Paview of PRC's Peactor Safe- 09/11/81 04/06/83 24 S auartfs Pmcram 4 Charging Licensees for Wpaid (observation 04/12/83 1 C Volmtary Overtime mport, no fortal mview)

5. Peview of Reactor Operator T/16/82 Oa/19/83 6 D Licensing

6. Peview of the Irrelenentation T/13/82 04/19/83 0 t of the Policy and Planning Guidance

{

j

7. Sunev of the Autanted Material 01/27/83 06/03/83 0 Accounting Statistics Systen

8. Survey cf the Office for Analysis 11/24/82 06/10/83 9 E and Evaluation of Operational Data

9. Survey of the Office of 04/25/83 07/26/83 11 F I

Policy Evaluation

10. Iremverents in Contract 02/83 08/12/83 0 Inferration Systen Data Entry Procedures

11. OIA Survey of Recent fEC 02/25/83 09/12/83 0 Pegionalization Efforts

12. Peview of Contmls Over 01/15/83 09/15/83 3 G Year-End Spending

13. OIA Suney Audit of the Use 11/08/82 10/26/83 0 of Interim Staff Positions In Incosing Technical Requirwents 14 OIA Peport on fRC's Inprest 01/01/83 11/17/83 0 '

Funds l

\

15. Peview of the Execution of 02/07/83 12/01/83 6 H Cmmission Guidance Regarding Establishing U erw cy Pesponse Facilities

16. Federal Manaaers' Financial 09/29/83 12/00/83 7 I Integrity Act

17. OIA Folle of fRC Egloyee 07/29/83 12/12/83 5 J Perfemance 4cruisals for tbi-SES Headauar+ers Employees

18. OIA Peview of PRR's Use of 08/16/82 12/30/83 30 K Technical Assistance i

19. Survey of Contracts Aertkd Over 06/15/83 01/10/84 5 L

$250,000

20. Suney Audit of NRC's Limnsee 09/07/83 01/23/84 0 Contractor ard Vendor Inspection Pmgram

21. OIA Inspection of fRC Travel C8/8/83 01/30/84 9 M

/dvance Operatiens and the Palated Intemal Centmls

)

l

22. Intemal Contml Peview of fRC's 09/29/83 03/05/84 8 N l Timekeeping Function '

23. Paview of the Cemittee tofeview 03/09/83 03/30/84 7 0 Generic Requin!nents 24 OIA Pecort of Potential Savings 09/20/83 04/03/84 5 P on large Deposits 1

1 25. Survey of Flexitime Utilization T/15/83 04/30/84 3 Q

26. Anonyrous Allegatici Regarding IE 02/13/84 05/10/84 0 Enfeuxnt Study (Limited Distribution)

27. OIA Report on Work Hours and 08/15/83 06/14/84 6 R Preniun Pay for Egloyees in PSC's 6pcy Operations Response Center

28. Imprcper Salary Payent 03/15/84 07/19/84 1 S

29. Interface of the Autanted 09/29/83 07/25/84 7 T Personnel and Paymil Data Systers

30. Survey of Peseant Direction, 06/20/83 08/03/84 2 U

&nagement and Utilizaticn

31. Review of Statments that NRC C4/10/84 08/23/84 0 Staff Offices Apply Pressure on National laboratories

32. Follow-up Review of Pectrren- 03/15/84 m/30/84 2 V dations in 0IA's Report Entitled

" Review of Travel Voucher Processing" l

33. Review of PRC's Quality Assurance 03/23/84 08/31/94 4 W Inspecticn Pmgram for Reactors Under Constmction 34 OIA Review of the Office of 01/20/84 W/31/84 2 X Inspection and Enforcenent's Pmgram Assessment Function

{

35. Pavent of Salary and Preniun Pay 09/17/84 10/02/84 0 in Excess cf the Statutorv I

Limitations

36. OIA Peview of the Ooerating 07/13/83 10/03/84 6 Y License Review Process for Paer Reactors

37. OIA Peport on fEC's Irprest Funds 01/01/84 12/17/84 0

38. Survey Audit of the Activities of 10/09/84 12/20/84 0 the Office of State Pmgrans

39. OIA's Peview of PRC's Policies 02/09/84 12/20/84 5 Z and Procedures Pelating to Differing Professional Coinions l 40. Federal Managers' Financial 09/26/84 12/21/84 10 AA Integrity Act

41. Intemal Centrol Review cf 09/26/84 01/31/85 0 Payets at PRC l 42. Review of the Office of 02/16/84 02/08/85 2 B8 l Inspection and Enfw s o J.'s

%teriais Inspection Program

43. Survey of the Office of the 05/28/84 03/14/85 17 CC General Counsel

ATTACHMENT CC i

Report Title

" Survey of the Office of the General Counsel" Recomendations To enhance the overall quality of OGC's service and products to the Comission and to improve the internal management of OGC, we recomend that the General Counsel:

1. Meet with each Comissioner, after this audit report is issued to the Comission, to solicit their views on how OGC could better serve the Comission.

2. Review OGC's organizational structure to ensure it provides the best means for supervising and controlling the work of the office as well as accomplishing the office's mission, and that clear lines of supervision are established.

3. Ensure that internal managerent review processes are in place; origina-tors, reviewers and managers formally concur in and approve documents prior to release by OGC; and the concurrence copy of documents is main-tained.

4 Ensure that, where feasible, inadequate work products are returned to the originator through nanagement channels, and that managers are held accountable for ensuring the assignment is completed in the manner desired by the General Counsel.

5. Streamline the broad signature authority allowed within OGC and devise a system that will alleviate any doubt as to whether OGC's or an individual i attorney's views are being represented.

6. Ensure that technical papers are coordinated with the Office of Policy Evaluation. i

7. Ensure that OGC's existing management tools for controlling assignments are adhered to fully.

l Make full use of existing management controls and take whatever 8.

additional action is necessary to ensure that work products are timely and that deadlines are met.

9. Discontinue the practice of allowing staff attorneys to sign memoranda requesting extensions on deadlines.

10. Monitor the concerns raised by the Department of Justice (DOJ) with respect to timeliness of briefs, training of OGC attorneys in preparing briefs, and advance notification of work going to 00J to ensure these concerns are resolved and do not recur.

l 1

11. Ensure that attorneys get adequate feedback on their work products, l including their performance in court.

12. Ensure that the provisions of NRC Manual Chapter 4151, Perfonnance Appraisal System (Non-SES) are adhered to and employees know who is responsible for signing their performance plan and evaluation.

13. Develop an internal operating procedures manual for OGC to include:

supervisory responsibilities; guidelines for carrying out assignants; preparation of work products; signature authority; 00J contacts; training; coordination of technical papers; correspondence control; suspense control; distribution of documents; file maintenance; perfom-ance plans and appraisals; and time and attendance.

14 Consult with the Division of Technical Infonnation and Document Control on OGC's present system of file maintenance; obtain their views on an appropriate system to meet OGC's needs; and make the necessary changes.

15. Ensure compliance with the work hour policies and T&A recordation and certification regulations in NRC Manual Chapters A136 and 4137.

16. Ensure that the Office of Congressional Affairs is provided copies of Congressional-related documents generated by OGC as a result of Office of Managenent and Budget inquiries.

17. Ensure that all open recomendations made by the Office of Government Ethics in its April 18, 1984, report are implemented.

Status of Recommendations All recommendations are open.

I

ATTA.CHMENT A Reoort Title "0IA Report on NRC Imprest Fund" Recommendations We Recommend:

1. The Director, RM, and the Region I Administrator take action to segregate the duties of their respective cashiers so that travel or purchasing functions do not conflict with the internal controls designed te safeguard the cashier operations.

2. Regional Administrator, Region I, assure compliance with Region I desk procedures IV. B. & F. for the proper safeguarding of the funds.

3. Regional Administrator, Regicn V, assure compliance with Region V desk procedures III. C. & G. for the proper safeguarding of the funds.

Status of Recommendations All three recommendations have been implemented.

1 I

1 1

l

ATTACHMENT B Recort Title

" Review of NRC's Reactor Safeguards Program" Recommendations

1) In order to ensure more consistent review and application of NRC's safeguards requirements we recomend that NMSS:

-- more clearly define in the guidance documents the minimum safeguards program required by 10 CFR 73.55 and related appendices to reduce the degree of judgment and uncertainty now prevalent in the licensing process; and

-- assign a high priority, with established due dates, to upgrading the existing guidance to make it more useful to the staff and responsive to licensee needs.

2) NMSS and NRR, in consultation with ELD, should jointly establish mutually acceptable documentation standards to ensure that safeguards licensing decisions are consistent and made in accordance with regulatory requirements.

3) NMSS should ensure that the infonnation contained in its case files, in itself, is sufficient to fully document and support its licensing decisions.

4) NMSS should ensure that verbal agreements made with licensees are documented in the approved security plans to give inspectors a basis to evaluate compliance with the agreements.

5)

NMSS afforded management a reasonableshould periodestablish procedures of time (e.g., 30 dayswhereby)the to formallyregions comentare on proposed plans or licensing actions. If the regions cannot be afforded a reasonable period of time to coment, the reviewers should call the regional inspectors to either work out a mutually acceptable schedule or, at a minimum, obtain oral coments prior to taking action on the plan or licensing action.

6) To eliminate the apparent confusion we noted among some inspectors, IE should:

clarify to regional safeguards inspectors that, during thei nterimi whileplanchangesarebeingreviewedbyNMSS,onlytheapf{oved plan is to be used in inspecting compliance; and ,

-- provide additional guidance to inspectors on how 50.54(p) changes pending NMSS review are to be addressed in the inspection process.

1 n

7) To more effectively manage the licensing workload, we recomend the Director, SG, require:

-- each reviewer to prepare periodic status reports on his assigned casework. This data should also be reflected on PPSAS.

-- PRSLB to review the licensing files against PPSAS, correct the inconsistencies, and ensure that the system is updated regularly so as to reflect the most current data possible.

-- PRSLB management to periodically review the workload and follow up on the open items to ensure they are being worked on.

, 8) In implementing the regulatory effectiveness review program, we recommend that NMSS management ensure adequate coordination of PRSLB's Regulatory Effectiveness Section with the Regulatory Activities Section and the regions.

9) In order to ensure an inspection program that is complete and workable, we recomend that IE revise the reactor safeguards inspection program with the objectives of:

factoring NMSS and regional office comments into the program; ensuring that the program is consistent with available resources and established p'riorities in the regions; more clearly defining the inspection requirements to reduce the heavy reliance on judgment now required; and clearly defining the level of contingency plan inspections in the inspection program.  !

10) We also recommend that the Deputy Executive Director for Regional Operations and Generic Requirements (DEDROGR) ensure that the regions are uniformly applying the safeguards inspection program.

11) In order to standardize inspection techniques so as to ensure consistent application of requirements, we reconsnend that:

until regionalization is fully implemented and NRC has placed licensing representatives in the regions, DEDROGR develop and issue a policy statement to the regions regarding licensing and inspection priorities. This policy statement should address the relative importance of these two functions, should establish guidelines for completing inspections and for reviewing proposed security plans and amendments, and should provide for the performance and completion of l plan and amendment reviews in order to ensure a greater degree of I uniformity in approved plans, which will facilitate a more uniform inspection effort.

-- IE and NMSS jointly develop format guidelines and schedules for l counterpart meetings between appropriate safeguards licensing, IE, and regional staffs; and

- . , . _ _ . ,-_ . _ _ , , y --- --- .

y y 7-

51

-- IE provide training workshops for inspectors to gain a fuller understanding of the modules and to share inspection experiences with inspectors from other regions.

12) In order to monitor the procurement and installation of safeguards i systems and equipment and to monitor the construction of safeguards related structures, we recommend that the E00 consider: 1) revising NRC's safety QA/QC program (10 CFR 50 Appendix B) to incorporate safe-i guards related functions, systems, structures and equipment; or

2) placing inspectors on site earlier during the construction process.

'l

13) We reccmmend that NMSS improve its system for controlling the filing and tracking of ems and more closely monitor the resolution process.

I

14) In view of their responsibility to factor information concerning the I generic implications in ems back into the regulatory process, we

! recomend that NMSS develop a fonnalized, systematic process for

identifying generic issues, ensuring they are promptly and adequately l

reviewed and resolved and factored back into the regulatory process through the development of guidance, rule changes, etc.

15) In view of the similarity of issues identified by different inspectors in different regions, we recomend that NMSS make all ems and corresponding responses available to all reviewers and all regions.

16) We recomend that NMSS issue periodic status reports to the regions to 4

verify the total universe and status of ems

17) We recomend that NMSS develop guidance for use by inspectors and licensees in evaluating the adequacy of compensatory measures and the length of time they can be used.

18) Regarding T&Q requirements, we recomend that:

l l --

NMSS develop improved T&Q guidance that is comprehensive and j

, consistent with the rule to minimize confusion as to what the rule

'l requires. The guidance should include standard definitions for the terms used in the rule and/or guidance, such as " critical task," and

" practical physical exercise program";

-- in the future, NMSS require licensees to include detailed implementation schedules in their T&Q plans to give inspectors a basis on which to evaluate the interim status of implementation; and NMSS identify and correct the anomalies in Appendix 8 either through rule revisions or preparing specific guidance and criteria to demonstrate generally accepted approaches.

19) Regarding contingency plans, we recomend that:

NMSS require licensees to establish schedules for testing their contingency plans via drills; and

the E00 ensure that NRC is reviewing the compatibility of contingency and emergency plans, and that such compatibility is tested through drills.

20) NMSS should document all oral communications they have with licensees and applicants and make sure that the regions promptly receive copies of all relevent safeguards communications, guidance, regulatory changes and other information to ensure that it is adequately considered in the inspection process. .

21) NMSS, IE and the regions should update the June 25, 1980, Interface Agreement (MOU) to clearly define the respective roles and interfaces in the safeguards regulatory effort.

22) We recommend that NRR:

-- develop a formal charter, establishing and documenting the role and responsibility of SIG and its interfaces with other offices; and develop guidance regarding how SIG reviews of safeguards licensing

actions are to be performed.

23) We recommend that the EDO update the IAT charter to provide guidance on how it should operate.

! 24) Finally, we recommend that the Commission consider directing the staff to:

reevaluate safeguards requirements to determine if the design basis threat requires the level of safeguards currently demanded, and if not, to establish the level actually required. Such a review should consider whether safeguards requirements are compatible with the operational safety requirements imposed on plants; and publish a policy statement defining " safety" consistent with 10 CFP 100, and establishing the relative roles of safety (plant operations) and safeguards under various plant conditions.

Status of Recommendations All recommendations exc'ept I and part 3 of 11 have been closed.

(

m

ATTACHMENT C

. Report Title

" Charging Licensees For Unpaid Voluntary Overtime" l Recc eendations

,l We believe that there is a legal Question regarding whether NRC can charae

licensees for work perfomed on a " voluntary basis" since tFa emoinyee was not t

compensated for the work. We recomerd that one of the legal offices of NRC be directed to prepare and support a position on this sub.iect.

i Status of Recommendations This recommendation is closed.

}

l j

l 1

i i

i 1

i t

1 I

ATTACHMENT 0 Recort Title

" Review of Reactor Operator Licensing" Recommendations We recommend the E00:

1. address the staffing problems in OLB by

a. assuring that more resource efficient examination techniques are aggressively developed and promptly implemented, including considering the establishment of fixed timeframe schedules for examinations,

b. directing DHFS and O&P to jointly explore creative pay, recruiting and hiring techniques to improve NRC's ability to hire operator examiners, and

c. assuring that adequate staff positions continue to be available for carrying out operator licensing responsibilities;

2. ensure that DHFS develops and administers an appropriate and resource efficient requalification examination in a timely fashion;

3. direct NRR to develop a policy for renewing RO and SRO licenses until such time as all license renewals are predicated on NRC administered j requalification examinations; 4 reevaluate the regionalization of the operator licensing function and the basis on which it was proposed;

5. direct DHFS to expedite revision of the examiner's manual for use by Headquarters, regional, and contract examiners; and

6. ensure that a workable management information system is established for the operator licensing function without delay.

Status of Recommendations All six recommendations are closed.

i ATTACHMENT E l

Report Title

" Survey of the Office For Analysis and Evaluation of Operational Data" Recommendatfons We recommend that the Director, AE00:

1. Institute a formalized tracking and follow-up system for AE00 recommendations and send follow-up reports to the office directors and the E00 for their information.

2. Encourage more face-to-face communication between AE00 staff and the

program offices

3. Formally establish points of contact for AE00 reports and recommenda-tiens.

4 Ensure that SCSS cevelopment is monitored closely and crovide status reports to the EDO.

5. Ensure that the proposed LER rule will provide data requirements consis-

'ent witn SCSS needs, j We recemrene that the Program Office Directors

*

6. provide AE00 with a point or points of contact for AE00 recommendations.

7 Encourage more face-to-face communication between their staffs and the AE00 staff, i

We reccmmend that the E00:

8. Ensure that program offices respond to AE00's recommendations within 45 days and, when aporopriate, provide a schedule for implementation of AE00 recommendations.

9. Review the functional responsibilities of AE00 and the program offices; and, more clearly define the respcnsibilities of each office so as to avoid unnecessary duplication of effort.

Status of Recommendations Only recommendation 9 remains open.

i

[,, ATTACHMENT F Recort Title

" Survey of the Office of Policy Evaluation" Recommendations We recommend that:

The Comission:

1. Provide PE with a statement of the role and functions desired of PE. We suggest using the 1979 point paper as a starting point;

2. Reaffirm the Comission's 1977 procedure requiring staff offices to issue staff papers to PE in draf t, PE to coment to the staff on the draf t, and PE to cement directly to the Comission, if necessary, on the final paper;

3. Approve PE's annual operating plans. The preparation of such plans is recomended to the Director, PE, in this report; 4 Reconsider the 1980 rotation policy in light of PE's high turnover rate and either reaffim, modify or rescind the policy and advise appropriate NRC officials of its decision; and

5. Institute a policy establishing a desired maximum number of years a professional employee may stay in PE.

The Director, PE:

6. Using the Comission's guidelines on PE's ' role and functions, update the appropriate sections of the NRC Manual and the Code of Federal Regulations, as needed, and prepare formal operating procedures to carry out PE's functions. We suggest that a copy of the procedures be provided to the Comission;

7. Prepare and submit to the Comission for approval, annual operating plans for PE's activities, and reevaluate the plans at least semiannually and provide a copy of the updated plans to the Comission;

8. Institute a formal record keeping system that will allow PE to accumulate the amount of time spent on the various categories of work, e.g.,

Comission requests, staff paper reviews, and IERs. This data should be beneficial in preparing PE's annual operating plans;

9. Consult with officials in the Division of .echnical Infomation and Document Control on PE's present system of records maintenance and obtain their advice on what records and files PE should maintain;

10. In conjunction with the Division of Organization and Personnel, update PE

' employees' position descriptions, as needed; and

11. Comply with the work hours policy in Manual Chapter 4136 by either adopting one of the flexitime options or requiring the PE staff to work

' 88'"## "" ** #' - - - - - - - - - - - - - -

l l

l

\

' Status of Recommendations Only recommendations 1 and 6 remain open, i

l I

l t

i I

l

[

l i

l I

l l

l

ATTACNMENT G Recort Title

" Review of Controls Over Year-End Spendirg" Recommendations We reconmend that the Executive Director for Operations:

t

1. Deoblicate unneeded funds by -  !

a. Continuing to close out expirad contracts, emchasizino centracts l with the greatest uncosted balances; and l

b. Reouiring ,iustification of uncosted balances with limited activity l prior to the end of the fiscal year.

l

2. Coordinate with institutions and other Government acencies to assure i financial reports are submitted oromptiv and assets and uncested balances  !

are more accurately reflected in agency financial reports.  !

3. Improve orant management by:

a. Developing a system to assure grantees submit reouired financial .

reports within the time limits specified by the uniform adninistra-tion recuirements for grants, OMB Circular A-110;

b. Basing the method of payment for grants on the financial require- .

ments o' the grantee; and '

c. Recuiring reimbursement requests to be based o, actual expenses.

Status of Recommendations i

All three recommendations are open and will be followed-up as part of another  ;

audit later this year. l l

l i

e l

l I

l

~ l ATTACRMENT H Report Title

" Review of the Execution of Commission Guidance Regarding Establishing Emergency Response Facilities" Recommendations (1) We recomrend that the E00 reiterate to the technical staf f that tne current regulatory requirements relating to ERFs are those contained in Supple-ent 1 to RJFEG-0737 Further, the staff should be rerindec that the previsions of previous gutcance should not be trpesed on litersees as rtgulatory requirerents.

We also recommend thJt the EDO:

(I) f.e velop a stercarc1:ec decurert te be usec in the pe rforre*ce cf pes t 1r plemcete t ter. revie*!. Inpst free the regional c'ftces. certractor pe'sernel and hPC's e Derleece dw"Ing ep;ratsals cf 1rter1r EET *s shovic be used in the developrent of this doeurent; (2) Field test the aceraisal decuremt at mere thae ort facility, review the results and revise the appraisel docurent if necessary; (4 1 Pake the corpleted appraisal docurert availatle to licensees, so they know the criteria which will be used for the appraisals; (5) Assure that the appraisel criteria are in conscrance with HEC regulatory recuiren.cnts for ERFs to alleviate the prcbler of using appraisal criteria which are differert frnr the requirer.eett used by licensees to design and construct their ERFs; ard (6) Establish a mechanism to review appraisal results and make revisions to the IE inspection procedures as a result of post-implemertation reviews.

Status of Recommendations All recommendations are currently open; however, a follow-up review is currently in progress.

4j ATTACHMENT I l Report Title

" Federal Managers' Financial Integrity Act" ,

Recommendations

) Tc strengther future evaluation precedures, inferr r.anage-s ef their role in internal centrol systems, and iccetify and tracn actice taler on internal 4 ccrtrol ween nesses, we recer: end that the Chair ,Lr, ICC: .

1. Issue the internal cortrol directive incorporating the latest revisier to Circular A-123.

2. Recuest the Division cf Data Automation and Managenent In#ceration, RP.,

te develop a means te trac 6 internal cor.trc1 weaknesses.

l 3. Establish procedures for the ICC to review OIA, GAO, internal managerent are enternal (consulterts) r.anagerent reports are icentify internal certrel wealnesses 'er trac 6 :r g and corre:tive actier.

4 To ensure that fiRC's inventery of assessable units is accurate, be recomend '

! that the Chairr.an, ICC:

l

! 4 Provide each of the Internal Control Coordinators with a list of assessable units in that coordinator's office and rect.est that updates be previoed l as necessary. ,

Te ensure that the 1954 evaluation process will not be delayec, we recomend the.; the Chairr,an, ICC: .

5.

Ensure that the questien aire review process is cendected early in 1954 To ensure that internal control s by other sources (OIA, GAO, etc.)ysters weaknesses which have beer. identified are scheduled for review by trained personnel, we recomend as possible. that the Chairman, ICC, take the following steps as eerly in 19E4

6. Require the ICC to review reports from OIA, GAO, and other sources to determine if there are areas, including ones previously identified as having low vulnerability, which must be subjected to internal control reviews.

7 l Request that all office directors designate individuals for training on how to cencuct internal control reviews, s

1 1

Status of Recommendations All recommendations have been closed, i

ATTACHMENT J Reoort Title "0IA Follow-up of NRC Employee Performance Appraisals for Non-SES Headquarters Employees" Recommendations

[

We recommend that the Executive Director for Operations:

1. Emphasize to the directors of those offices not submitting certifications of performance appraisals the importance of submitting such certifications and the need to do so each year.

2. Direct 0&P to Establish a policy regarding which officials in the Office

• of the Commission are responsible for subnitting certifications of performance appraisals.

3. Emphasize to the management staff in the Office of the Commission and the Office of Congressional Affairs the importance of completing employee a pp ra isal s.

In addition, we recommend that the Director, O&p, rectify the inaccuracies in the automated performance appraisal system by:

4. Excluding employees who enter-on-duty af ter the appraisal rating period; and

5. Developing a written policy designating the office responsible for an employee's performance appraisal when a reassignment occurs and, subsequently, revise the automated performance appraisal system to comply with this written policy.

Status of Recommendations All recommendations are open; however, a follow-up review is currently in progress.

1

ATTACP4ENT K Report Title OIA Review of NRR's Use of Technical Assistance Recommendations Based on our review of the actions taken on the task force recomendations, we recomend that the Director, NRR:

1. Specifically address the 22 task force recomendations which were not included in his memorandum of December 8, 1981; and

2. Direct the implementation of 10 specific recomendations which were addressed in the December 8. 1981, memorandum but have not been fully implemented.

In order to use the technical assistance funds in a more effective and efficient manner, we recomend that the Director, NRR:

3. Assure that advance funding is used by NRR only when necessary. Written justification should be required for all advance funding.

4 Assure that all project managers are provided with a copy of NRC Manual Chapter 1102 for their review and guidance.

5. Assure that DOE laboratories submit their propcsals in a more timely -

fashion. We believe that a reasonable time for submission should be no more than 30 days. The transmittal letters which accompany the 50W should specify the date by which DOE's proposal should be submitted to NRR.

6. Assure that written procedures are developed requiring project managers to place documentation in the official project file to substantiate all essential comunication, verbal or written.

7. Assure that the time recuired to evaluate, review, and accept a DOE proposal is reduced to a minimum. We believe that 30 days is reasonable.

Standardized written procedures should be developed within NRR for this purpose, and distributed to all project managers.

8. Institute a procedure which will assure that the contractor's/

laboratory's RAI's are acted on p omptly upon receipt.

9. Require NRR division / program offices to schedule multiplant reviews in such a manner as to maximize resource use while minimizing delays due to lack of documentation, etc.

10. Direct NRR division / program office directors to fully justify why a -

project cannot be performed in-house.

11. Require NRR division / program office directors to fully justify why any project needs to be divided and the effect on costs of. dividing the _

n....__.__.._ . . . .

12. Require detailed justification prior to submitting the 50W to DOE as to why it is necessary to use a laboratory as opposed to using the competi-tive process,

13. Require NRR project managers to prepare detailed cost estimates prior to submission of a 50W to DOE. These cost estimates should be retained by NRR and used as a measure of comparison of DOE's cost estimates to NRR's.

Differences between NRR's and DOE's cost estimates should be explored by NRR and findings documented in the task order file.

To ensure that proper contracting methods are used, the EDO should:

14 Require the participation of DC in the review and negotiation of the estimated costs to perform any future work assignments under the FRC and SAI contracts and any other large comercial technical assistance contracts.

We recomend that the Director, NRR:

15. Direct PPAS to conduct a review of vouchers recently received to ascer-tain if there are still laboratories which are not breaking out their costs in the manner necessary to allow the assessment of fees and also to monitor the individual details. Any laboratories which are not breaking out their costs should be reported to RM for corrective action.

16. Publish an NRR policy which standardizes the funding of all projects.

17. Require that all 50Ws to the national laboratories include a statement that a laboratory will notify NRR in the project's monthly business report whenever the costs expended to date equal 75 percent of the amount currently obligated.

18. Require that all contractors for all large contracts submit a spending plan with their work schedule whenever the contract or task order price is agreed upon. This requirement should be put into effect imediately for the FRC and SAI contracts.

19. Direct project managers to examine all vouchers carefully and to request from contractors detailed support when necessary.

20. Issue a memorandum instructing all Division / Program Office Directors that if tasks are deleted from a project, a corresponding amount of funds should be deleted. A written justification should be on file to support those cases where a reduction in cost is not appropriate.

21. Issue a memorandum to the Division / Program Office Directors indicating that they are responsible for ensuring that contractual documents are modified prior to the contractor perfonaing work outside the agreed upon 50W.

22. Require that better front-end planning be perfortned in order to ensure that needed documentation is on file and periods of performance are reasonable before a contractor is authorized to begin work.

23. Require that all technical assistance work involving a licensing action be tracked to indicate the status of the licensing action. The Director, NRR, or his representative should be provided with an aged status report on a monthly basis 50 that incomplete actions are highlighted. The first set of actions to be displayed should be the work perfomed and completed by the contractors under the two FRC contracts and the SAI contract.

24 Issue a memorandum to the Division / Program Office Directors indicating that they are accountable for the work results of comercial contracts or DOE task orders, and they must institute procedures to have work completed as required by the 50W.

25. Require PPAS to develop procedures that will result in the close out of projects, the deobligation of funds, and the transfer of data in the computer system to a historical file all in a timely manner.

26. Require a review and report on the status of all projects which have ended. All funds which can be deobligatsd should be.

27. Require all Division / Program 0";ce Directors to submit data to PPA 5 regarding subpar performances on technical assistance projects by comer-cial contractors or laboratories. PPAS should prepare a report showing generic areas where the contractors or laboratories have failed to produce an acceptable product. This information should be updated periodically and used by PPAS in reviewing proposed contracts.

28. Require all subpar performances by a contractor or laboratory to be reported to the Director's office imediately so the contractor or laboratory can be contacted for resolution of the problem.

29. Require close-out evaluations to be submitted in a timely manner after the evaluation forr. is providec by PPAS.

30. Provide written instructions to all parties regarding the specific duties of PPAS. For example, the instructions should include; PPAS' specific role and responsibilities for reviewing actions; Time frames for PPAS to review a 50W, or modifications thereto and reporting results to Division / Program Office Directors;

- PPAS' role in keeping the official files on technical assistarce projects; The reporting of improper contract management activities directly to the Division / Program Office Directors with an infomation copy to the Director, NRR; and The reporting by PPAS of all audit results on completed projects to the Director, NRR. The audits should be based on a sample of completed work,

?

i Status of Recomendations All recomendations are open; however, a follow.up review it currently in progress,

~.

l l

l l

i

ATTACHME.'li L l

1 Recort Title Survey of Contracts Awarded over $250,000 Recommendations To improve the review process for contracts, we reconnend that the EDO:

1. Require the SCRB to document any issues or questions it raises and their resolution prior to project approval; l

2. Request clarification f rom the Comnission concerning the need for review of contracts which do net meet SCRB guidelines;

3. Clarify SCRB responsibilities in areas where responsibilities overlap with those of the HFRG and WMRG; 4 Determine if CRB's 1976 charter is still appropriate; and

5. Revise SCRE procedures to require SCPB review of procurement packages after SEP work is completed.

Status of Recommendations l

l

' Reccmmendation 3 has been closed and the remaining recommendations will be followed up as part of another audit later this year.

l l

)

ATTACHMENT M  !

Rooort Title "0IA Inspection of NRC Travel Advance Operations and the Related Internal Controls" Recommendations We reconnend that the Director RM take the following actions:

1. Take disciplinary action against the cashier (s) responsible for pemitting the f raudulent transactions and the cashier's ivedtate supervisor for violations of the prescribed internal controls.

2. Determine what additional internal controls are needed to safeguard the interest $ of travelers who do net personally pic6 up their travel j advance 5.

3. Require all agency cashiers to adhere to Headquerters Dest Procedures for 1

positivel) icer.iifying individuals picting up advances.

l 4 Require DAF to restrict access to the cashier's office.

5. Require cashiers to follow the presce'tbed procedures for deting and initialling the pink advance copy of the travel authorizations.

6. Require DAF to assign alternate cashier responsibilities to an employee that does not have related travel advance duties.

7. Require DAF to detemine which erployees have lef t the agency owino travel advance funds, and what action can be taken to collect these funds.

8. Require DAF to take corrective action to reduce the backlogs of unpro-

! cessed vouchers and processed vouchers not entered in the travel advance system.

9. Require DAF t send computer print-outs confirming travelers' advance balances by individual rather than organization codes.

Status of Recommendations Recommendation I has been closed.

ATTACHMENT N l

Report Title

" Internal Control Review of NRC's Timekeeping Function" Recomendations To strengthen the internal controls affecting NRC's timekeeping function, we recomend that the Director, Division of Accounting and Finance:

1. Prepare a notice to all office and division directors, certifying officials, and T&A clerks identifying the types of errors noted and the l

correct procedures to be used in carrying out their payroll responsi-bilities.

2. Require Payroll, when improperly prepared cards are identified, to notify the appropriate certifying official to have a corrected card expeditiously prepared and provided to payroll in time for current payroll processing.

3. Comply with the existing NRC Manual Chapter provisions by requiring that T&A cards be submitted by 9:00 a.m. on the Monday af ter the end of the

pay period, thereby reducing the number of corrected cards needed.

I We believe that the Director, RM, should:

l 4 Require office or division directors to assure that each T&A clerk is 1

responsible for only one T&A unit.

i 5. Establish procedures to assure that the upper limit of 24 employees per T&A unit is maintained by offices unless an exception has been granted by the Division of Accounting and Finance for those offices whose total size is slightly over 24 employees, and consider the costs and benefits before establishing a lower limit.

To provide additional controls in T&A processing, we recomend that the

Director Division of Accounting and Finance:

6. Require certifying officials to send TAA cards directly to Payroll and

{ not return them to the T&A clerks.

7. Issue a bi-weekly payroll report to certifying officials showing the infomation contained in the TAA cards processed the period before.  ;

l 8. Examine the T&A cards and detemine if the package can be redesigned to eliminate the problems T&A clerks are currently having, i

i l Status' of Recommendations I

i All recommendations remain open; however, a follow-up review is currently in progress.

ATTACHMENT 0.

Report Title

" Review of the Committee to Review Generic Requirements" Recommendations We recomend that the EDO: l

1. In order to ensure consistent application of CRGR's requirements for complete and sufficient packages:

(a) define and establish specific standards and minimum criteria governing completeness and sufficiency as required by the Charter; and (b) provide clarification to CRGR and the program offices regarding the recuirements for the use and application of quantitative analysis in CRGR packages.

1

2. After the criteria and standards are defined, require the DEDROGR to l return to the 3riginating offices all unacceptable packages as measured I against the newly defined criteria and standards.

3. To eliminate the apparent duplication of effort and confusion assnciated with conducting regulatory analysis regarding value/ impact, cost / benefit studies, (a) assure that all cost studies being carried out within NRC are' coordinated through CAG; and (b) direct CAG to expedite issuance of the final CAG charter, after coordination with all affected offices, and assure that the CAG Charter is disseminated throughout NRC as the policy for conducting cost assessments 4 To enhance CRGR's effectiveness and to ensure that CRGR reviews all applicable generic issues, amend the Charter to specifically authorize the CRGR, through the DEDROGR staff, to " audit" the agency's activities to assure that generic requirements are referred to CRGR.

5. Direct the CRGR to meet to discuss ways to improve the process for recording minutes of CRGR meetings and to resolve the problems regarding the completeness and accuracy of the minutes as written.

6. We recommend that the ED0 assure that the program offices implement their office procedures and develop internal controls to ensure all generic requirements, as defined, are referred to CRGR for review.

7. We recommend that the DEDROGR schedule a CRGR meeting in the near future to discuss, and amend as necessary, CRGR operating procedures.

l L

Status of Recomendations Recomendations la, 2, and 4 have been closed. Follow-up on the ren'aining recomendations is planned for later this fiscal year as part of another audit.

e e

e

ATTACHMENT P Recort Title "0IA Report of Potential Savings en large Deposits" Recommenda tions In the interest of improving NRC's internal control over civil penalty and license fee payments and reducing the interest costs incurred by the Government because of delayed deposits, we recomend that the Executive Director for Operations (ED0):

1. Assign responsibility for the accounting for and collection of civil penalties to RM;

2. Require RM to record civil penalties as accounts receivable at the time they are imposed; '

3. Instruct RM to enter into fomal discussion with the. Treasury Cashier Staff for the purpose of making . arrangements for NRC to use Treasury's Electronic Funds Transfer System and lock-box system for the collection of civil penalties and license fees.

4 Require that, until the adoption of the recomrended Treasury systems:

a) licensees remit civil penalty paymerts'directly to RM; b) RM develop procedures to allow receipts to be deposited imediately and posted to the accounting records after deposit; c) both civi? penalty and license fees be deposited daily on the day of receipt, using night depository wher, deposits cannot be accomplished during nomel banking hours; and d) when, under extenuating circumstances, deposits are delayed, the Director, Division of Accounting and Finance, prepare and retain a written explanation of the circumstances which precluded the deposit.

5. Effect any necessary changes in 10 CFR as may be appropriate in accor-dance with any changes adopted as a result of Recommendations 1, 3 and 4 Status of Recommendations All recommendations remain open. A follow-up review is scheduled to begin in April 1985.

(...._..........__ . . . . . _ . _

ATTACHMENT q Reoort Title

" Survey of Flexitime Utilization" Recommendations We recomrend that the EDO ensure that:

1. NRC's phone systems are modified to include " call pick up" on those 1

systems that do not presently have that capability. I

2. All office directors and regional administrators make provisions for T&A clerks to have positive knowledge of the daily presence or absence of the employees in their T&A units.

3. Only the signatures of authorized certifying officials be accepted by the Division of Accounting and Finance as proper certification of the T&A cards and that the cards not be processed for payment without proper certification.

Status of Recommendations All recommendations are open; however, a follow-up review is scheduled to be completed before June 30, 1985.

l

o ATTACHMENT R 1 Reoort Title "0IA Report on Work Pours and Preniun Pay For Enployees in imC's Energency Operations Response Center" Reconnend2tions We recommend that the Director, IE:

1. Ensure that work schedule practices for the Center are in compliance with the applicable NRC regulations on minimizing premium pay.

2. Tighten ranagement controls over the schedulino of enployees in the Center, particularly at year end, and ensure that only qualified employees staff the Center.

3. Ensure that duty officers discontinue the practice of compressing their workweek on a regular basis by using conpensatory tine / annual leave.

4 Ensure tha: T&A recordberpinc and certification are in accordance with NRC regulations and that Center schedules and T&A cards are in agreenent.

We recorrend that the Director, DAF:

5. Seek reinbursenent for the overpayment of holiday pay to a duty officer,

6. Ensure that the T&A cards from the Center are compared to the Center's

, work schedules and resolve any discrepancies before paymer.t is authorized.

Status of Recommendations All recommendations are currently open.

ATTACHMENT S Recort Title "Imoroper Salary payment" j Recor:vnenda tion To preclude this type of problem from occurring in the future, we recomend the Director, RM/A, take action to ensure that personnel in Payroll are

! complying with the established internal accounting controls.

I

l. Status of Recommendation i

This recommendttion is open.

J J

j i

i 1

4 4

5 1

- ~ , , - . --

-~ ,.--.,,--~.~,-a ..,,-n - , - - , , , . - , , . -.

---..n.v- , -

ATTACHMENT T 4 Report Title

" Interface of the Automated Personnel and Payroll Data Systems" Recommendations Even though some corrective actions have been initiated by O&P and Payroll, we are making recomendations to emphasize the reed for corrective action. We, therefore, recomend:

1. The Director, O&D, modify the match process to include a comparison of individuals' employment status between the personrel and payroll systems.

2. The Directors of O&P and RM/A initiate action to correct the errors identified by us during our review and take appropriate action to preclude these conditions from occurring in the future.

3. The Director, O&P, determine if the personnel system can be changed to accommodate personnel actions which reduce pay and act accordingly.

4 The Directcr, RM/A, collect all overpayments.

To improve the accuracy of the personnel and payroll data systems, we recomend:

5. The Director, O&P, institute administrative procecures to ensure that manually the system.produced or corrected personnel actions are correctly input into 6.

The Directors of O&P and RM/A compare the persernel and payroll systems biweekly and reconcile all mismatches.

7 The Director, RM/A, apprise the Payroll staff of our findings concerning the payroll data and emphasize the need for accurate data in the system.

Status of Recommendations All recommendations are currently open; however, a follow-up review is currently in progress.

J RTTACHMENT U Report Title

" Survey of Research Direction Management and Utilization" Recommendations l OIA recommends that the Director, RES:

1. Ensure the preparation and retention of n NRC Form 367 for all new RES projects and for any substantial changes to existing RES projects.

2. Establish Office Project Files using the alternate plan provided by NRC Bulletin 1401-3 which allows the components of this file to be maintained in more than one location. An analysis should be performed to determine the organizational unit reouiring frequent access to specific components of the file. Responsibility for that component (s) should then be placed i with that organizational unit. The analysis should include a review of all of RES' existing files regarding 00E projects to determire if they are duplicative and should be eliminated, or if their reforr.atting could provide a portion of the Office Project File.

Status of Recommendations All recommendations are open.

ATTACHMENT V Recort Title

" Follow-up Review of Recommendations in OIA' Report Entitled " Review of Travel Voucher Processing" Reccerendations

To ensure that the amount of outstandino travel advances are reduced, we recommend that the Director, Office of Resource Management

1. Issue an announcement to all NRC employees stating a) the requirements to have travel vouchers submitted within seven days after the end of the trip; b} the requirement for travelers to pay any monies due NRC after audited vouchers are returned; and c) that if old debts are not settled, stronger collection action will be taken.

2. Require the Director, DAF, to aggressively work with ELD to develop

! procedures to collect outstanding travel advances due NRC from l individuals' salaries.

Status of Recommendations

These recommendations are open.

I l

1 I

i

ATTACKMENT W Report Title

" Review of NRC's Quality Assurance Inspection Program for Reactors Under Construction" ,

Recommendations We recommend that:

1. The Director, IE reconsider the priorities of the reactor inspection oregram particularly as between older operatirg plants and plants under construction.

2. The Director, IE ensure the development of evaluation criteria necessary to assess the effectiveness of the recional offices' implementation of the IE inspection progran at reactors under construction; and

3. The Director, IE, direct that future CAT inspections include an assessment as to whether the regional offices' inplementation of ir.spection program recuirer:ents has been effective, especially in the areas that CAT team intcectinr. has found const ructinr. deficiencies.

.4 The ED0 and Regional Administrators review the policies for the inspecticn programs for operating reactors ard reactors under constructior that affect the allocation of inspection resources, to ensure that corstruction inspection program requirements can be performed as required and notify the Conmission of any shortfall in budget resou rces .

Status of Recommendations All recommendations are currently open; however, a follow-up review is scheduled to be completed before June 30, 1985.

1 i

i l

ATTACHMENT X Report Title "0IA Review of the Office of Inspection and Fnforcenent's Progran Assessment Function" Recommendations We recommend that the Director, IE, ensure that the planned assessments of IE's major inspection program areas, power reactor corstruction and operations, are sufficiently comprehensive to adequately establish the program requirements and regional performance level in order to produce valid ob.iective measures of a region's implementatior.

We believe consideration should be given to regional assessment on a cyclical basis to better utilize the resources available for this effort.

We reconrend that the Director. IE, consider usir.g regier.a1 section chiefs or other well cualified persens with current inspectior earerience to assist Headquarters personnel in perforning assessments at other regional of fices.

Such regional professional personnel should be able te provide a perspective on current implementation and interpretation of inspection progrars and pro-among theasregional cedures, well asoffices.

helping to " cross pollinate" inspection progran insights We believe this would enhance efforts at unifore implementation of the inspection programs, provide a reasure of peer review, and increase regional the validity and acceptance of the assessments in the eyes of personnel.

Status of Recommendaticns Both recommendations are currently open; however, a follow-up review is scheduled to be completed by June 30, 1985.

l

ATTACHMENT Y l

l Report Title "0IA Review of the Operating License Review Process for Power Reactors" Recommendations In order to improve the effectiveness of NRC's reactor licensing program and to better assure the public health and safety, we recommend that the Director, NRR:

1. Direct DL to institute a formal policy whereby inexperienced PMs are assigned to work under the guidance of senior PMs until such time as they are prepared to accept full PM responsibility.

I 2. Direct OL to immediately publish the PM Handbook, or at least provide PMs with a current draf t, and assure that PMs are carrying out their respon-sibilities in accordance with the Handbook.

3. Direct DL to use CFP estimates in scheduling license reviews consistent with Commissicn and EDO guidance.

4 Institute a system to track and control all open issues centained in SERs and, in coordination with IE, establish responsibility for resolving these issues.

5. Direct the staff to discontinue the practice of converting open to con-firmatory issues unless utility management has documented such commit-ments to NRC.

We also recommend that the EDO

6. Direct the Director, NRR, in coordination with the Directors, Offices of Nuclear Material Safety and Safeguards, IE, and the Division of Organiza-tion and Personnel, and other organizations as appropriate, to develop a unified plan for handling staff reductions within NRR.

Status of Recommendations All recommendations are open.

l I

l l

l l

%TTACHMdNT Z Report Title "0!A's Review of NP.C's Policies and orocedures Relating to Di ffering Professional ,

Opinions" Recommendations We recommend that tne EDO:

1. Revise the proposed OPC policy statement to:

a. establish criteria for the appointment of peer review grcups;

b. require an employee to discuss a potential DP0 with his/her management chain up through the division director before submitting a formal DP0 and indicatino the results of these discussions in any OP0 subsequently filed;

c. establish a format for the DP0 which will ensure that all of the information necessary to determine the nature of and evaluate the DP0 is available;

d. require RM to assign a control number for each OPO for better control purposes; and

e. require that dccumentation for each DP0 be held centrally in each cognizant office. .

2. Annually appoint a special review panel to review the OP0 program, and disseminate the results of the panel's review and any recommendations as required in the Manual Chapter.

3. Distribute the recommendations of the 1982 Special Review Panel to revise the MC to the public and NRC employees, i

4 Establish new procedures to review allegations of retaliation by manage-  :

ment against an individual for tubmitting a DPO.

5. Require the Headquarter's and regional personnel offices to include an cierview of the DP0 program in the orientation for new employees.

Status of Recommendations All recommendations are open.

ATTACHME'4T AA Report Title

" Federal Managers' Financial Integrity Act" Recommendations We recommend that the Chairman, ICC:

1. Ensure that an internal control directive consistent with OMB guidance is issued.

To accomplish the objectives of the FIA, we recomend, the Chaiman ICC:

2. Delegate as many of the ICC's activities to NRC managenent as possible so management can become more involved in the internal control process, and assure that adeouate resources are dedicated to the process so the objectives of 1985 can be met.

3. Reevaluate the segmentation of the agency into assessable units and ensure all agency corponents are covered, the process is well documented and the un.its are of a size and composition tc provide meaningful vulner-at'ility assessments.

4 Recuest that updates of assestable urits be previded, as necessary, by each office's internal certrol coordinator.

5. Ensure that the questic- aires are reviewed ca*1y in 1985.

6. Recuest all office directors to designate individuals for training on how to conduct internal control reviews and assign responsibility for con-

ducting internal control reviews to cognizart office directors.

7. Develop, document and implerent policies and procedures for tracking and following-up on internal control weaknesses identified in vulnerability assessments, internal control reviews, audit reports, and similar studies.

8. Follow through with the plan to develop art validate a complete inventory of the agency's accourting systems.

9. Ensure that all accourtino systems which are identified are evaluated in accordance with OMB ouidelines and a determination is made as to whether they comply with the Comptroller General's principles and standards,

10. Require responsible offices to provide the ICC with plans for corrective action on deficiencies identif-fed in prior years' evaluation process.

Status of Recommendations All recommendations are open.

AITACMMENT B3 Report Title

" Review of the Office of Inspection and Enforcement's Materials Inspection Program

• Recommendations We recommend that the Director IE:

1. Establish a time table for acquiring the necessary data and completing a study with the objective of developing a specific profile for materials inspections leading to:

a. developing realistic factors for determining resource requirements for budget purposes; and

b. establishing achievable goals for materials inspection activities of

the Regional Offices.

2. Require that periodic (at least yearly) meetings of Materials Inspection Program first line supervisors be held for the purpose of discussing mutual problems and concerns related to the naterials inspection program.

i Status of Recommendations All recommendations are open.

4 i

i

CVESTION 4: PLEASE PROVIDE THE FOLLOWING INFORMATION V'!TH RESPECT TO THE OFFICE OF POLICY EVALUATION I

(OPE):

A. THE SIZE OF THE OPE STAFF AND BUDGET PER FY FOR j -

EACH OF THE PAST TWO YEARS AND PROPOSED STAFFING AND BUDGET FOR THE NEXT TWO FYS; ANSWER:

1 THE REQUESTED STAFF AND BUDGET FIGURES FOR OPE ARE:

FY 1983 1984 1985 1986 (ACTUAL) (ACTUAL) (EST.) (EST.)

STAFF 16' 17* 18 17 1

BUDGET 3 21 50 65

($ IN THOUSANDS)

• PERSONNEL CE! LING FOR FY 83 AND FY 84 = 18 FTE l

l l

i QUESTION 4 (CONTINUED) GUESTION: B. THE RESPONS!BILITIES OF OPE AND PROFESSIONAL i

STAFF POSITION JOB DESCRIPTIONS.

l l .

ANSWER:

S. '(1) A DESCRIPTION OF OPE'S RESPONS!BILITIES AND FUNCTIONS FROM NUREG-0325 (JANUARY 2, 1985) IS ATTACHED.

(2) OPE POSITION DESCRIPTIONS FOR 11 PROFESSIONALS ARE ATTACHED.

NUMBER OF  ;

PROFESS!0 Hats NRC Joe CODE TITLE 3 1301 GENERAL PHYSICAL SCIENCES 4 840 NUCLEAR ENGINEERING

_q 345 PROGRAM ANALYSIS 11 - TOTAL MARKEY/0PE

• --___-___-____-_-_-_.__-___;M_____--___--_____._

l

i  !

1

! l'Skl

• s

! lja j i aid},,,

tj .l

!! sil)5 l

li I?!! I

+

i 11 IL F llai a l

g i

g 2 Lg inmi

.2 3

-q 1"

j 8

aih:

a 11 i'lla 1

- g il i 1 h l }i}l'} -

• ! i'l i -

r 8

ill{il I:

3 l lil s suru't'!

i .

5:1111!'

i t

JI!!jdl}i i y si 1,1!{Itu5 11 3 ill I - Cu 2 85 23 1 - -- a

                                  ]g         5211     l
                                        !*53i]I ij            3   i lj lih!!i[lj. i jlilli!

iijli!1 ljdiati1 _ 1 l

                    }l j                p!!'1!

Nil . i t

        ! lgy ce}lij  s

{ 1 l :Pisill n k V;,! 3

   !         idiihi!        .

I i i . l

                           =.                      .        ~     - - , - _ . . - .                   s _       ._,   a-      x                        -

l [ ,  ! - 1301 Senior Policy Analyst, Nuclear Facility Safety Office of Policy Evaluation GG-15 FUNCTIONAL STATEMENT As a Senior member of the Office of Policy Evaluation, perfonns, at the request of the Assistant Directors or Director, OPE, or the Commissioners, independent, in-depth, technical analyses of policy issues and regulatory programs, particularly in the area of nuclear facility safety, under consideration by the Conunission, develops alternatives and reconsnendations. REGULAR DUTIES Performs, individually or as part of a team or task force, analyses of technical aspects of NRC responsibilities and practices, especially in the areas of nuclear facility safety licensing, inspection and research. Provides to the Assistant Directors and Director, OPE, and to the Commissioners technical advice in examining or developing recommendations and alternatives in a wide range of scientific areas affecting nuclear facility safety, particularly power reactor safety. Provides to the Connission, in conjunction with the Office of the General Counsel, independent technical and policy evaluations of cases reaching the l Commission for adjudication. Carries out special assignments from OPE l management and the Commission. Identifies to the Director of the Office of ' Policy Evaluation, through the Assistant Director for Technical Review, l l policy issues which may require analysis and for which options should be developed for Connission consideration. Reviews independently the

2-technical content of proposed rules and other policy alternatives suggested by the NRC staff or agencies outside NRC. These analytical activities may include the preparation, under the general supervision of the Assistant Director for Technical Review, OPE, of reports and presentations to the Comissioners that highlight technical considerations, involve policy trade-offs and recomend alternative courses of action, considering all pertinent factors that would aid the Commissioners in making policy decisions. Once Commission decisions are made, may prepare and coordinate Connission guidance to the NRC staff, working closely with the staff in developing implementation plans and procedures. . - BASIC SKILL Degree in the sciences, with a comprehensive knowledge of the principles, theory and practices of nuclear facility safety. Full understanding of major system functions in comercial nuclear facilities, including familiarity with operational and radiological aspects. Experience (regulatory or non-regulatory) in design, construction 1 ~ or operational' considerations of such facilities. Thorough knowledge of NRC policies, practices and regulations relating to

    ^

the assurance of safety in the siting, design, construction, and operation of such facilities. 1

o - Demonstrated skill in acquiring necessary technical data for analysis from a variety of sources both within and outside the NRC, evaluations and l analyses of technical issues and problems which set precedent or establish } } policy. i ! Demonstrated ability to make clear, concise and convincing written and oral

presentations to the Consissioners and top management of NRC in a form that l facilitates decisionmaking.

i l j Knowledge and experience with the programs, organizations and authorities l j involved in the licensing and regulation of nuclear facilities pursuant to

the Atomic Energy Act of 1954, as amended, and the Energy Reorganization

Act of 1974.

1 ! CONTACTS i Frequent contacts with NRC Assistant Directors and Branch Chiefs and their I staff to discuss technical ' problems and issues; secure technical data; and j obtain concurrence on proposals, methods of analysis, and evaluation

 ^

d criteria. Must be persuasive, articulate and professional in these ~ contacts to demonstrate the validity of conclusions, but must display proper regard for problems, responsibilities and prerogatives of line ! management officials. i l Frequent contacts with the Commissioners, through the Director of the f Office, and with Conmissioner Assistants to discuss analyses and defend proposals. f ! f i

l l Occasional contacts with representatives of other Federal, state and local agencies to discuss NRC policy positions and to coordinate and resolve problems of common interest. Occasional contacts with representatives of industry to discuss and evaluate licensee requirements, problems and proposals. RESPONSIBILITY FOR DECISIONS Supervision Received Assistant Director for Management and Program Review General Supervision Guidelines are supervisory guidance on basic policy issues under study which involve policy recommendations. There are few guidelines for this position since it involves basic policy formulation, but overall NRC and office policies and program apply. High professional standards of conduct and performance are expected in accomplishing studies. Independent Action Recommends basic policies, programs and projects to the Director of the Office of Policy Evaluation and the Assistant Director for Technical

        ' Review.                                                                                            j i

Reconnends action on proposed changes in policies and programs such as the i initiation of new programs or projects and acceleration or expansion of existing ones. Identifies policy issues requiring analysis. l Work Accomplished Without Review Develop baselines of technical study projects that are undertaken individually or as part of a team effort. These inputs are basic to the decision process of senior management and have impact far beyond the initial input. In perfonning this work, the incumbent: Selects appropriate study bases and ground rules for projects. Assigns proper weight to qualitative and intangible factors.

      -      Selects appropriate comparative cases to demonstrate the relative advantages and disadvantages of alternatives.

Schedules work effort to accomplish the study task within established time frames. i SUPERVISION None. WORKING CONDITIONS No mal office conditions.

l ' o 6- . EFFORT Greater than nomal administrative effort. l i l l ( l l l l i l l O O I I t i

1 . t 8 :.0 Senior Policy Analyst, Nuclear Facility Safety Office of Policy Evaluation GG-15 FUNCTIONAL STATEMENT l As a Senior member of the Office of Policy Evaluation, perfoms, at the l request of the Assistant Directors or Director, OPE, or the Comissioners, independent, in-depth, technical analyses of policy issues and regulatory programs, particularly in the area of nuclear facility safety, under consideration by the Comission, develops alternatives and recomendations. REGULAR DUTIES Perfoms, individually or as part of a team or task force, analyses of technical aspects of NRC responsibilities and practices, especially in the areas of nuclear facility safety licensing, inspection and research. Provides to the Assistant Directors and Director, OPE, and to the l Commissioners technical advice in examining or developing recommendations and alternatives in a wide range of engineering areas affecting nuclear facility safety, particularly power reactor safet/. Provides to the Comission, in conjunctit n with the Office of the General Counsel, independent technical and policy evaluations of cases reaching the Comission for adjudication. Carries out special assignments from OPE management and the Comission. Identifies to the Director of the Office of Policy Evaluation, through the Assistant Director for Technical Review, policy issues which may require analysis and for which options should be developed for Comission consideration. Reviews independently the

2- - technical content of proposed rules and other policy alternatives suggested by the NRC staff or agencies outside NRC. l l These analytical activities may include the preparation, under the general supervision of the Assistant Director for Technical Review, OPE, of reports and presentations to the Connissioners that highlight technical considerations, involve policy trade offs and recommend alternative courses of action, considering all pertinent factors that would aid the Connissioners in making policy decisions. Once Connission decisions are made, may prepare and coordinate Connission guidance to the NRC staff, working closely with the staff in developing implementation plans and procedures. BA5!C SKILL Degree in engineering, with a cceprehensive knowledge of the principles. l theory and practices of naclear facility safety. . Full understanding of major system functions in connercial nuclear facilities, including familiarity with operational and radiological i aspects. Experience (regalatory or non-regulatory) in design, construction or operational considerations of such facilities. i

       .           Thorough knowledge of NRC policies, practices and regulations relating to
               'the assurance of safety in the siting, design, construction, and operation of such facilities.

1

l 3 . l Demonstrated skill in acquiring necessary technical data for analysis from a variety of sources both within and outside the NRC, evaluations and analyses of technical issues and problems which set precedent or establish policy. Demonstrated ability to make clear, concise and convincing written and oral l presentations to the Comissioners and top management of NRC in a fom that facilitates decisionmaking. Knowledge and experience with the programs, organizations and authorities involved in the licensing and regulation of nuclear facilities pursuant to the Atomic Energy Act of 1954, as amended, and the Energy Reorganization Act of 1974 CONTACTS Frequent contacts with NRC Assistant Directors and Branch Chiefs and their staff to discuss technical problems and issues; secure technical data; and obtain concurrence on proposals, methods of analysis, and evaluation criteria. Must be persuasive, articulate and professional in these contacts to demonstrate the validity of conclusions, but must display proper regard for problems, responsibilities and prerogatives of line management officials. l l l Frequent contacts with the Comissioners, through the Director of the Office, and with Comissioner Assistants to discuss analyses and defend proposals. 1

4 l Occasional contacts with representatives of other Federal, state and local agencies to discuss NRC policy positions and to coordinate and resolve problems of comon interest.  ; Occasional contacts with representatives of industry to discuss and evaluate licensee requirements, problems and proposals. t c RESPONSIBILITY FOR DECIS!0NS Supervision Received Assistant Director for Technical Review I General Supervision

• Guidelines are supervisory guidance on basic policy issues under study which involve policy recomendations. There are few guidelines for this ,

posttion since it involves basic policy fonnulation, but overall NRC and office policies and program apply. High professional standards of conduct  ; and performance are expected in accomplishing studies. , r Indecendent Action Recomends basic policies, programs and projects to the Director of the  ! Office of Policy Evaluation and the Assistant Of rector for Technical l

   ' Review.

1 1

Reconmends action on proposed changes in policies and programs such as the initiation of new programs or projects and acceleration or expansion of existing ones. Identifies policy issues requiring analysis. Work Accomplished Without Review Develop baselines of technical study projects that are undertaken individually or as part of a team effort. These inputs are basic to the decision process of senior management and have impact far beyond the initial input. In perfoming this work, the incumbent:

     -     Selects appropriate study bases and ground rules for projects.

Assigns proper weight to qualitative and intangible factors.

     -     Selects appropriate comparative cases to demonstrate the relative advantages and disadvantages of alternatives.
     . Schedules work effort to accomplish the study task within established time frames.

SUPERV!5!0N None. WORKING CON 0!TIONS ( Nomal office conditions.

EFFORT Greater than normal administrative effort. I 9 I I l

345 Senior Policy Analyst Office of Policy Evaluation GS-15 . Functional Statement As a senior member of the Office of Policy Evaluation, performs independent, in-depth, technical analyses of policy issues and regulatory programs under consideration by the Comission, particularly in the area of managerial, organizational or institutional policy issues. Develops, independently or at the request of the Assistant Directors or Director, OPE, or the Comissioners, policy alternatives and recommendations. Regular Duties , Performs, individually or as part of a team or task force, analyses of NRC responsibilities, especially in the area of policy formulation at the Comission level. Reviews the content of proposed rules and other policy alternatives suggested by the NRC staff or agencies outside NRC. These, .

 - activities may include the preparation, under general supervision of the Assistant Directors, OPE, of reports and presentations to the Comissioners that highlight considerations,. involve policy trade-offs and recomend alternative courses of action, considering all pertinent factors that would aid the Comissioners in making policy decisions. Once Comission decisions are made, may prepare and coordinate Comission guidance to the NRC staff, as well as work closely with the staff in developing implementation plans and procedures.

Provides advice to the Assistant Directors and Director, OPE, and to the Comissioners in examining or developing policy recomendations and alternatives in a wide range of areas affecting regulatory policy. Iden-tifies to the Director, OPE through the Assistant Directors, policy issues which may require analysis and for which options should be developed for Comission consideration. Provides independent technical and policy evaluations of cases reaching the Comission for adjudication. Part of this function can include providing support to the Office of the General Counsel on policy issues. Basic Skills Advanced degree in liberal arts or social sciences, with a comprehensive knowledge of the principles, theory and practices of policy formulation at the Comission level. l Thorough knowledge of NRC policies, practices and regulations.

Demonstrated ability to present effectively complex policy issues to the Commission both orally and in writing. Demonstrated skill in acquiring and presenting necessary data for analysis from a variety of sources both within and outside NRC, evaluations and analyses of important issues and problems whicn set precedent or establish Commission policy. Knowledge and experience with the programs, organizations and authorities involved in the licensing and regulation of nuclear facilities pursuant to the Atomic Energy Act of 1954, as amended, and the Energy Reorganization Act of 1974 Contacts Frequent contacts with NRC senior management and Commissioners and their staff to discuss management problems and issues; secure relevant data; and obtain concurrence on proposals, methods of analysis, and evaluation crite- l ria. Must be persuasive, articulate and professional in these contacts to l demonstrate the validity of conclusions, but must display proper regard for problems,' responsibilities, and prerogatives of line-management officials. Frequent contacts with the Commissioners through the Director, OPE and with Commissioner's staff to discuss analyses and defend proposals. i Occasional contacts with representatives of other Federal, state and local agencies to discuss and defend NRC policy positions and to coordinate and resolve problems of common interest. Occasional contacts with representatives of industry to discuss and evaluate licensee requirements, problems and proposals. Resoonsibility for Decisions Suoervision Received Deputy Director, Office of Policy Evaluation General Suoervision l Guidelines are supervisory guidance on basic policy issues under study which involve policy recommendations. There are few guidelines for this position since it involves NRC and office policies and programs. In accomplishing tasks, high professional standards of conduct and performance are expected. Indeoendent Action

Recommends basic policies, programs and projects to the Director and the

Assistant Directors, OPE.

Recommends action on proposed changes policies and programs such as the initiation of new programs or projects and acceleration or expansion of , existing ones. Identifies policy issues requiring analysis and the develop-ment of options for Commission consideration. Work Accomolished Without Review Develop baselines of technical study projects that are undertaken individual- , ly or as part of a team effort. This input is basic to the decision process of senior management and has impact far beyond the initial input. In performing this work, the incumbent: Selects appropriate study bases and ground rules for projects. Assigns proper weight to qualitative and intangible factors. Selects appropriate comparative cases to demonstrate the relative advantages and disadvantages of alternatives. Schedules work effort to accomplish the study task within established time frames. --. .. Suoervision ,.. None. Workinc conditions Normal working conditions. Effort Greater than normal administrative effort. i f

                            . _ , - ,~             ._                  . _ .--       ,      .- _ _ . _ _    ._ _-.

QUESTION 4 (CONTINUED) - QUESTION: C. A LISTING BY DATE AND SUBJECT OF ALL ANALYSES, REPORTS AND MEMORANDA PRODUCED BY OPE SINCE 1983. PLEASE NOTE WHICH DOCUMENTS WERE GENERATED IN PESPONSE TO A REQUEST AND WHO THE REQUESTOR WAS; ANSWER: C. THE REQUESTED NATERIAL IS ATTACHED. MARKEY/0PE 4/5/85

M Y w Y Z C M W O W Z w O W W o

      -+

w w Z Z E E E 4. 4 O w w >= = = M ( aC . 'lt! E-w E en E A ( v W W A O - 8 s 8 s 8 s 8 s E 3 = 3 3 3 w o w w w '"J M

         =

G m 8 N M w

         ==                  8                 M      to E      E v

w ( E w w w A e e-o g 6 O

                                               >=

V t-= V

         -         m       -       -           e      e u
                   -       =

e g m m w S . w w

         -         =       a       a.

W W >= >=

         ==        M       E       1A          (      (

w E == m . . C (

• O c c .

A CE E >=

                   >=              U W                 C.=

e 4 >= '

         >=        t.1     m            E M         E       ="           tema

( == W E w

                                               >=

s

                                                      >=

a 3 >= w W O >= ( ( X w ( >= >= } ( E M m

                                        >=

a 4A w w >= w

         =J        E       haJ       e         E      E .=. E                               Q v                 E             >                >= W                               E l

3E C.= u w N U s== w.e x E == t EC M > @ == 0 8w w Q

     *         ==  M       ==      T     w     ==     ==>=   >-=                             w LaJ M     ==      >=        0  C      E      E      4                               W
         ==                u       N    A      p.-    >= w   >=                              v
         >= U              h.J     CiG                    >  M                               C w           6         4     J   &      E ==                      E            E w ll2     U       6       >=   4      Q      C >=   >=                 w            A C                 w       W    C      w      6(     O                  C w   Q               w    C                 E  ==                 3            w
         >= U      ha a    W       M           E      E(     a                 C             W W2        EM      >=            >     W      w      Q                               E CW        Q       (       6     >=    Q      Q      &                  >=           w AQ         =J             O     w      m      E          en            E            O E ==      W       ==

Qe ." w O CU M ( ==

         == w                   Ps 3     y      O      O w

O A 3 M

                                                                                >=

M 6 E E 6 0 kmJ gn wC C O == wE wE C o w C t-- av == cc > c >= c >= c 6 O z y V CD 3 4 w w 6 == 6 == >= Q m w == LaJ a >= E to eC (M ( to W == beJ

""J      M >=       .had
                      ==      8 W        ===    g e-=  M ==  w    >=      4          I       >=

3 M LA 3m == w W > QU OU h M >= e== W 3 Q( w EM A w wW ww ( C C E 4 M A3 E >= w O CK cm Q mo in u o >= 3 E E E. E E E.a E E.=

          ==        E.=
                    .       .=     .-    =      =      E=

N N N

                                                                                ==           .

N N N N N eM M iM M M M E E M

         .          ==     .M=     .     ==     ==     ==    to.=

m g g .M.= == Ci

-         m         m       m      m     m       m     m      m   (        (    m            m                 ,

4 E = . a3 m so m e a e a m- a m C 3 3 3 M CE M M E E E E 2 km.a w w w Ma b w w w w w h.J w h N N N N N N N N N N N N  % e N N O N N N O N N N N N G3 CC G3 C CD CO G3 S S W CC G3 e e J e e e a e e a a a N @ 40 P% P% C == s== N w W , ca C == === e== Ps.

                                                                                 =            ==

haJ1 f rM Q a Ca n C a _n M n e a e e t i

E E N N l Y I i K T 5 S S L N L e E I E S L S S I S - A G A

                           )                                                        )

C C G G _ 0 0

                           /                                                        /

W W ( ( Y T G C N N N E S I E D E& R T G F I L T E A R F C A AN W R E A C I RE O E M T T A T L PM N E N S R YL NN E E R A TA OS G N D T O P I NS O I F J F C2 R C A A DO I0 RF A N C R M R R0 OO E O A D AN TB F L I A OO C S C S R  ; BI EY SE U I O ) F T LB TI N C J N O GA E NT E A A NR E EI E D M L Y IE NO MT D P T SP I D EN R L A I NO RA E A M L E YR I U V I R A I N CR TO UQ 5 T + 0 R B O IE IF Q O6 I l G A I LW R EA L - N O B S O AD RL A3 I Y R O I DP PE U P8 T T P R C N SR NM - F L - I P E AL I A OR OY A A L S D L DP IO TC R I I R 3 E YU E TF E D T . B O 8 H S TF1 ER C DS - R4 . A T 9 T S E 4 HP EG E E A7 B C 1 E FO - T TN T - R P - O A N N AT3 - OI A 3 - R F , O E S 8 F RS L3 N ,8 ._ O P 2 V D - OS PS E 8 - - NM 1 T I CEY E E RD I 9Y p N TC SI LS N S 6C _ AU T I NA _ O MD Y E C MAE IT AS I E M OLS SI CO O C 8S I N UN HA (R R A U M O E F F TE AR - YL LI I P S I S2

                                                                            , E D

A L - [ O N C E AT YS I A - M AM A 2N3 NU . HE C , E ) M 2E J E E 8O A C PE E1 C f1 O 6M P T 9IT CN S D N O - C 4 F O A 1SI NII N S E I _

      /S        0           I          I N   AR               E   LT          D       WM                  _

E 2T F D ,C U T , 6C AI I ET - P 6N M O E 3E CN 5I I N F I( O 4E U M DD :EO 4L TU N V

        - M     D     N     M     R       R  TLT           -      I           O       EG         6 R     2E        N     O     I     El     .O  REL        2R         NN         C       RN E     8R        A     I           BAF        O        I  8O       IO                       I H         I     R     S     l     MI R       PGM              T         I     E       lN T     YU        O     I        -  ETE        ENA         YC        BT         T         - N R     CQ        M     V     I      VIT       ROH        CA         LA         S       I    A U     EE        E     E     H     ONA              M    EE         ST         A       HL I     SR        M     R     T      NIW       AA&        SR         AS          W      TP N     N                N     N     N          N          N         N           N      N O     O               O     O      O         O           O         O          O       O I          I       I I     I          Y     I    I      I         I           I S     S          K     S    S      S         S           S         S          S       S S     S         S      S     S     S          S          S         S           S      S I          I       I I     I          N     I     I     I          I          I M     M         I      M     M     M         M           M         M           M      M M    M          L     M     M     M          M          M         M           M      M O     O         I      O     O     O          O          O         O           O      O              .

C C G C C C C C C C C E E E E E E E E E E E = l B B B B B B B B B B = R i R R R R R R R R R R E E E E E E E E E E F Z Z Z 7 Z Z Z Z Z Z Z W 3 3 3 3 3 3 3 3 3 3 3 . 8 8 8 8 8 8 8 8 8 8 8 8 9 0 4 7 8 2 3 5 6 2 f $ $ 1 3 1, l 2 1 l {'2 > >

D-83 llRDE COMMISSION PROBABillTIES OF A MAJOR ACCIDlNT AT LICENS[D OPERATING ASSELSilHE REACTORS 0-83 ZERBE AllEARNE STATUS ON SEVERAL OPEN ITEMS AHEARNE 0-83 ZERBE AHEARNE POLICY TO REDUCE ENRICHMENT AT DOMESTIC RESEARCil AND AHEARNE TEST REACTORS J-83 ZERBE COMMISSION SECY-83 NUCLEAR PLANT RELIABILITY DATA SYSTEM (NPRDS) AllEARNE ])-83 ZERBE AHEARNE UTILITY USE OF NUCLEAR CAPAC11Y AllEARNE D-83 ZERBE COMMISSION DRAFT STAFF REQUIREMENTS MEMORANDUM ON SECV-83-4: NPRDS AHEARNE 3-83 ZERBE C0PetISS10N Supt 4ARY OF WRITTEN RESPONSES 10 PARTICIPANT QUESTIONS IN THE COMMISSION NFS-ERWIN HEARING 9-83 ZERBE AllEARNE PEER REVIEWS AHEARNE l-83 ZERBE PALLADINO AGENCY ACTIONS CONCERNING TMI-l (W/0GC) PALLADlH0 2-83 ZERBE COMMISSION ADDITIONAL SUGGESTED QUESTIONS FOR NFS-ERWIN HEARING Q-83 ZER8E C0te(ISSION C0tellSS10N HEARING ON NFS-ERWIN COMMISSION D-83 ZERBE COMMISSION DISPOSITION OF THE WATEREORD 3 CONTENTIONS COMMISSION 1-83 ZERBE AllEARNE BACKFITTING COSTS: ilADDAM NECK AND MILLSTONE 1 AllEARNE 6 e ,oe

'04-83 = ZERBE COMMISSION REVISED DRAFT OF WAST,E CONFIDENCE DECISION AND RATIONALE m05-83 2ERBE C0PetISSION CLARIFICATION REGARDING PALO VERDE NUCLEAR GENERATING PALLADING STATION COOLING WATER SYSTEMS =05-83 ZERBE COMISSION PALO VERDE 1 MEDIATE EFFECTIVENESS DECISION AND REVIEW 0F (W/0GC) ALAB-713 - SECY-83-125 ,=07-83 ZERBE COMISSION SECTION 208 REPORT TO THE CONGRESS ON ABNORMAL OCCURRENCES AHEARNE/GILINSKY FOR OCTOBER-DECEMBER 19tl2; MEDICAL MISADMINISTRATION INCIDENT DESCRIBED IN ENCLOSURE 3 - SECY-83-92 , 83 ZERBE COMMISSION SECY-83 MATERIAL CONTROL AND ACCOUNTING ktQUIREMENTS AHEARNE FOR FACILITIES POSSESSING FORMULA QUANTITIES OF STRATEGIC SPECIAL NUCLEAR MATERIAL 83 ZERBE COMISSION OPE POSITION ON SRO IN POWER PLANT CONTROL ROOMS (SECY-83-52A) COMISSION 83 ZERBE PALLADINO RESPONSIBILITIES FOR STUDYING REGIONALIZATION PALLADINO '14-83 - ZERBE COMMISSION TMI-I IMMEDIATE EFFECilVENESS DECISION (M.M#

                                                                                                                                                )

(SECY-83-138) LIS-83 ZERBE COMISSION ASLB PARTIAL INITIAL DECISION RELATED 10 THE CLINCH RIVER BREEDER REACTOR LIMITED WORK AUTHORIZATIONS (FEBRUARY 28,1983) 1-26-83 ZERSE COMISSION IMI MANAGEMENT CHANGES SINCE THE IMI-2 ACCIDENT PALLADINO l-29-83 ZERBE COMMISSION IMI MANAGEMENT CHANGES SINCE THE TMI-2 ACCIDENT AHEARNE/PALLADING e .- O m__ . _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ __ _ __ ___ _ _ _ _ _ _ _ _ _ _ _ _ _

W Z Z M C C 4 C

       =                                Z               w                                             Z w       M                                =               %                                            =

Z M Q < Q M = < w w E a a a E < % Q < A < v A A U C C 3 w M 3 Z m M Z Q Q 6C e > L 6-4 M M <>= 3 Q

• M cA ><M Z A MM MQw Q = Q

= WC W ZW * = w M M M AZw= M M W MW QQ M & = Z WM a U C W = U C MW G

CW =WM

• 4 H & MM Q W ZZ < M > a W 64 M M (W *EWW mM=Q 4

3 C M A VA w M E M M4 NCE < a @N QM "C MQ 6MJ J M > Cm =4 w a ya JZ-4 a A y N s Z M Cw ==WA < w w em Q> w C > Ms M= u W M N@ wu > Ow A O M w a Z = Z> Ww > Z Q = WQ MZ

                  <CM=

6wmM

                          =AZ   Z Q          $        9         QW W

ZC wM W w W WQ QaMA Z M EM Ew 6 < M WW Q M C QE 6 Y ZQ N= 4 = W = I Zw w = QZ MMM M Z C M w 6 444 W cm = W Q =^ E6 W = M = MEMM U > M u> (C W W WMM 3CDU w = A WZ < Q MZw M= Q W Q4 Q> = Z QW QMC6 U Z A wu O w 6-= aMZO J w Q MZ MZ Q 65% U-4 < w = Q Ow E M <<v ZE & = 6 W =MW 43 E < WQ WZMZ W W < Q WM QC Mw

                                                                                                         =

Q MZZ QMw = 3 W c wc= QWWE Z W J Uw AM 6 Z C W W Q (A Q

                                =
                                      ^

W

                                         <^ > W 4

W wg M I 6 >

                                                                                                          =

Q w ZWCJ J@ =@ W =L E ZWQ Q WW <@ Q@ M Q M < W 3 Qw =gMW> == w= U < 4 MW m M Z w =MJ W 5 0 E t = 3 6 w = W < (owc MM EM > QC eMW

>            UA   WZM            <@      =@              M          Z                  A WM            ==   =<ZZ           A t           0         <     3=            M
                                                                             @ "Q       =

MW MEU 6McQ > => w w w> sZu - Z CMZ QA MU B U W W == MwM i W4 La w== ZWM "QEMC wwZ ww MM

                                          =w EM M

v 3

                                                               >C W=

WAw WAM Z QA =MA EMC <w Ww M Z Md M<W W Z Z Z Z Z Z Z Z Z Q Q Q Q Q Q Q Q Q

         =         =             =        =       =            =             =                             =
=

M M M M M M W M @ @ M M M M M M Z M M M

                                 ~

5 5 5 Q 5Q 5

                                                         =

5Q 5Q 5Q Q Q W W v v v v v v < W W w W W W W W W W W

 @       Q         C              C       Q        @     O      Q             O                              @

M M M M M M M M M M w w w w w w w W W W N N N N N N N N N N e M M M M M M M M M M

@        @         @              @       @        @      E     @             @                               @

• 0 0 0 t 0 6 8 9 9 0 O @ N M W W W M M N Q Q Q *
• N N Q Q Q e e e e e e e e e e

W W M M M M M M M M m-n

• F Q Q Q Q Q C C 83 ZERBE COMMISSION REGIONALIZATION MEETINGS ROBERIS L20-83 ZERBE AllEARNE BACKFIT COSTS AllEARNE 83 ZE R'BE COMMISSION OPE CON 4ENTS ON PRICE-ANDERSON REPORT TO CONGRESS (SECV-83-176)

.-26-83 ZERBE GILINSKY ASSESSMENT Of MCGUIRE-2 EQUIPMENT QUALIFICATION REVIEW GILINSKY 83 ZERBE COMMISSION NUREG PUBLICATION AND SUPPLEMENT OF BNL STUDY OF LER ALTERNATIVES 83 ZERBE C0fMISSION *dRITTEN COMENTS ON INDIAN POINT SHUTDOWN (W/0GC) r27-83 ZERBE GILINSKY $110REllAM GILINSKY 83 ZERBE ComISSION INDIAN POINT OPTIONS - (SECY-83-207) (W/0GC) >-01 ZERBE PALLADINO MANAGEMENT CONTROL OF TMI-1 RESTART PALLADINO H01-83 ZERBE AllEARNE INFORMATION FOR DATA BOOK AllEARNE i-03-83 ZERBE PALLADINO VIEWS ON STATUS OF HYDROGEN SAFETY RESEARCH FROM OPE PALLADINO CONSULTANT STREllLOW PALLADIN0 PALLADINO $03-83 ZERBE QUESTIONS ON INDIAN POINT REGARDING OGC/0PE MEMORANDUM 0F MAY 27, 1983

$-07-83 ZERBE COMMISSION FUTURE OPE WORK DN REGIONALIZATION CllAIRMAN- $-08-83 ZERBE AllEARNE QUESTIONS ON INDIAN POINT AllEARNE $-13-83 ZERBE ROBERTS SECY-83-62(10 CFR PART 35) ROBERTS j-14-83 ZERBE AllEARNE OPERATOR REQUAllflCATION PROGRAM AHEARNE i-16-83 ZERBE COMMISSION DOE REPORT: THE FUTURE OF ELECTRIC POWER IN AMERICA: ECONOMIC SUPPORT IOR ECONOMIC GROWTH $-17-83 ZERBE COMMISSION OPE COMMENT ON TECllNICAL ASSISTANCE TO SUPPORT INSPECTION PALLADINO ANDENFORCEMENTPROGRAMS(CONTRACTNO.NRC-05-82-249) $-17-83 ZERBE COMMISSION OPE CO MENTS ON SECY-83-221 PRIORITIZATION OF GENERIC SAFETY ISSUES i-17-83 ZERBE COMMISSION CONTRACTOR WORKER ACCESS TO LICEhSED POWER REACTORS $-20-83 ZERBE C0mlSS10N ED0'S MEMO OF JUNE 7, 1983 REGARDING COMPLETION OF Com ISSION THi-l RESTART REVIEW $-20-83 ZERBE AHEARNE OPE CONSULTANT REVIEW OF TMI HYDROGEN BURN REPORT AND AHEARNE DRAFT TEST PLAN FOR EPRI NTS HYDROGEN COMBUSTION AND CONTROL PROGRAM $-22-83 ZERBE COMISSION CO MENTS ON SECY-83-232 - REVISION OF 10 CFR PART 71,

                            " PACKAGING 0F RADIDACTIVE MATERIAL FOR TRANSROT AND TRANSPORTATION OF RA010 ACTIVE MATERIAL UNDER CERTAIN CONDITIONS" 9 9 mw

222-83 ZERill COMMIS$10N REVIEW OF CPU V. B&W TRIAL TRANSCRIPT, OF $1AFF REPORT (W/0GC) COMMISSION ON TRIAL RECORD, AND DF COMMLNTS OF PARTIES T0 lilE THI-l RESTART PROCEEDING ON TilAT REPORT - (SECY-83-245) [23-83 ZERBE COMISSION NUCLEAR SAFETY AND lilE PUBLIC UTILITY ll0LDING COMPANY GILINSKY ACT 227-83 ZERBE COMMISSION SECY-83-243 - FINAL 10 CFR 50.73, LICENSEE EVENT REPORT SYSTEM LETTER FROM OPE CONSULTANT STREllLOW ON EFFICACY OF AllEARNE =29-83 ZERBE AllEARNE GLOW PLUGS FOR llYDROGEN CONTROL IN PWRS 83 ZERBE ColetISSION DIABLO CANYON -- INTERRELATIONSillP OF ENFORCEMENT AND (W/0GC) A0 JUDICATORY PROCEEDINGS - (SECY-83-260) TENTATIVE THI-I DECISION MILESTONE CilART PALLADING m30-83 ZERBE COMMIS$10N '01-83 - ZERBE COMMIS$10N OPE REVi[W 0F ACRS COMMENTS ON TliE FY 85-86 SAFETY RESIARCil PROGRAM BUDGET ' 01-83

-      ZERBE  COMMISSION  OPE REVIEW OF SECY-83-248 - GENERIC ACTIONS IN RESPONSE TO SALEM ATWS EVENT

' 01-83

-       ZERBE C0ffilS$10N SECY-83-241 - SUtttARY REPORT ON COMMENT LETTERS RECEIVED ON DRAFT DOE GUIDELINES FOR RECOMENDATION OF SITES FOR REPOSITORIES; 48 FR 5670 1-07-83  ZERBE  C0m lSS10N JULY 8 C0mlSSION MEETING Willt ACRS e                                                                        ,

2 OPE COMMENT ON lilE STATUS Of Tite CilARLESTON EARilfQUAKE GILINSKY 27-83 ZERBE COMMISSION ISSUE PRELIMINARY COMMENIS ON PROPOSED FY 1985-1986 NRC BUDGET PALLADINO 08-83 ZERBE PALLADINO 11-83 ZERBE COMMISSION SECY-83-256 - FINAL RULE ON IMMEDIATE NOTIFICATION OF SIGNIFICANT EVENTS AT OPERAllNG REACTORS, 10 CFR 550.72 AUTOMATIC DATA PROCESSING (ADP) ORGANIZATION GILINSKY 12-83 ZERBE GILINSKY IMI-I RESTART - IIARDWARE/ DESIGN, SEPARAil0N OF UNITS 1 COMMISSION 13-83 ZERBE COMMISSION AND 1 AND EMERGENCY PLANNING ISSUES REVIEW OF PROPOSED CONTRACT ON STRUCTURAL INTEGRITY OF COMMIS$10N 13-83 ZERBE COMMISSION LIGlii WATER REAC10R B0UNDARY COMPONENTS -- II COORDINATING REGULATORY REQUIREMENTS (SECY-83-183) PALLA0lNO 21-83 ZERBE COMMISSION 83 ZERBE COMMISSION WASTE CONFIDENCE:

SUMMARY

OF PUBLIC COMMENTS ON THE PROPOSED DECISION AND PROPOSED AMENDMENTS 1010 CFR PARTS 50 AND S1 83 ZERBE' CGMMISSION COMMENTS ON SECY-83-288 -- PROPOSED RULE ON PRESSURIZED Tif[i?.AL Sil0CK (P15) 83 ZERBE COMH15510N SECY-83-293: AMENDMENTS 10 10 CFR 50 RELATED 10 ANTICIPATED TRANSIENTS Will100T SCRAM (ATWS) EVENTS 83 ZERBL COMMISSION YAKIMA PETITION FOR RULEMAKING ON COMMISSION CONCURRENCE IN DOE REPOSITORY SITING GUIDELINES - (SECY-83-300) O

l l h04 '23 ZERBE E0petISSION DRAFT ORDER -- ALA8-698 (TMI RESIART EMfRGENCY PLANNING) (W/0GC) (SECY-83-318) 13-83 ZERBE C0pellSSION SECY-83-211 - IINAL RULE TO MODIFY THE RLQUIREMENT THAT PALLADINO i POWER REACIOR LICENSEES MAINTAIN PROPERTY DAMAGE INSURANCE l ZERBE C0petISSION REVISED OPE CONSULTANT REVIEW OF IMI HYDROGEN BURN REPORT hil-03 )-15-83 ZERBE COMMISSION QUALITY ASSURANCE PROGRAM PLAN plS-83 ZERBE C0petISSION C0000ENTS ON THE AUDIT OF THE OfflCE OF POLICY EVALUATION l )-15-83 ZER8E COMMISSION YAKIMA PETITION FOR RULEMAKING ON C0pellSSION CONCURRENCE (W/0GC) PALLADINO IN DOE REPOSITORY SITING GUIDELIE S - (SECY-83-3008) )-17-83 ZERBE COMMISSION

SUMMARY

OF COMMENTS 8Y ISSUE ON THE COMMISSION'S PROPOSED WASTE CONFIDENCE DECISION AND THE RELATED PROPOSED AMEN 0MENTS 1010 CFR PARTS 50 AND S1 )-23-83 ZER8E C0petlSSION SCHEDULING ORDER FOR ORAL PRESENTATIONS ON C00911SSION (W/0GC) CONCURRENCE IN DOE REPOSITORY $1 TING GUl0ELINES (YAKIMA PETITION) - SECY-83-300C >26-83 ZERSE C0petISSION SECY-83-311 (PROPOSED INSIDER SAFEGUARDS RULES): INIERIM ACTION )-30-83 ZERBE ROBERTS CR-83-l?8 (SENAIOR MITCHELL LETTER ON LICENSING REFORM ROBERTS LEGISLATION)

                                                                     -n

>30-83 ZERBE COMMISSION SECY-83-343 -- FINAL. RULE ON TEMPORARY OPERATING LICENSING AUTHORITY N06-83 ZER8E COMMISSION EMERGENCY PLANNING EXERCISES AT INDIAN POINT ZERBE COPMISSION SCHEDULE FOR IMI-I RESTART CHAIRMAN f09-83 >09-83 ZERBE C009tlSS10N DRAFT DIA8t0 CANYON LICENSE SUSPENSION l L12-83 ZER8E C0fMIS$10N NRC PLAN FOR THE MANAGEMENT OF PLANT-SPECIFIC PALLADINO BACKFITTING OF OPERATING POWER REACTORS (SECY-83-371) hl4-83 ZER8E C0tmlSSION WASTE CONFIDENCE - SIGNIFICANT LEGAL ISSUES; (SECV-83-376) (W/0GC) L16-83 ZERBE PALLADING DRAFT RESPONSES CONCERNING TMI-2 LEAK RATE CALCULATIONS COMMISSION (CR-83-139) bl6-83 ZERBE COMMISSION C0pWENTS ON STAFF GUIDANCE FOR SELECTION OF MEDICAL MISADMINISTRATION EVENTS FOR ABNORMAL OCCURRENCE REPORTING (SECY-83-302) E20-83 ZER8E GILINSKY CRITICALITY CONSIDERATIONS REGARDING THE BIG ROCK POINT GILINSKY i SPENT FUEL POOL (SECY-83-310) 1 h23-83 ZER8E C00mISS10N NATIONAL RESEARCH COUNCIL PROPOSAL FOR STUDY RELATED TO C0AL AND NUCLEAR RISKS (SECY-83-381) l 623-83 ZERBE COPMISSION TMI-l RESTART DECISIONMAKING PROCESS (SUPPLEMENT TO OPE PALLADIN0 SEPTEMBER 9, 1983 MEMORANDUM ON SCHEDULE FOR TMI-l RESTART) l

                                                                             ~

26-83 ZERBE COMMIS$10N CO MENTS ON TORREY PINES ZIMMER REPORT PALLADINO >28-83 ZERBE COMMISSION AMEN 0MENTS 1010 CFR PART S0 RELATED TO HYDR 0 GEN CONIROL * (SECV-83-357) 430-83 ZERBE ComISSION ADDITIONAL COMENTS ON PROPOSED INSIDER SAFEGUARDS RULES (SECY-83-311 and SECf-83-311A) 430-83 ZERBE C0mlSS10N COMENTS ON FITNESS FOR DUTY RULE (SECY-83-339) 03-83 ZERBE COMMISSION WASTE CONFIDENCE - SECY-83-405 (W/0GC) 03-83 ZERBE COMISSION REVIEW OF ALAB-729 (METROPOLITAN EDISON COMPANY) (W/0GC)

                                   - SECY-83-406 04-83          ZERBE COMMISSION   AT'.lS RULE, ADolil0NAL OPE Co mENTS 05-83          ZERBE COMMISSION   REVIEW 0F ALAB-738 (METROPOLITAN EDISON COMPANY)           (W/0GC)
                                   - SECY-83-408
>06-83          ZERBE COMMISSION   EMERGENCY PLANNING: NRC POLICY ON PREDISTRIBUTION OR STOCKPILING OF POTASSIUM IODIDE FOR THE GENERAL PUBLIC 211-83          ZERSE COMMISSION   DETERMINATION OF PARTICIPANTS IN THE ORAL PRESENTATIONS    (W/0GC)

ON COMISSION CONCURRENCE IN DOE WASTE REPOSITORY SITING GUIDELINES - SECY-83-3000 226-83 ZERBE COMMISSION DIABLO CANYON LICENSE SUSPENSION - SECY-83-438 a &

                                 =                                        ,

e a w e,

10-26-R3 ZERDE PALLADINO POLICY AND PLANNING. GUIDANCE - 1984 PALLADINO 10-27-83 ZERBE COMMISSION ALTERNATIVE APPROACHES TO THI-l MANAGEMENT INTEGRITY PALLADINO DECISIONMAKING 00-28-83 ZERBE COMISSION GENERIC HEALTH EFFECTS RULEMAKING (SECY-83-426) 10-28-83 ZERBE COMMISSION PRICE-ANDERSON REPORT TO CONGRESS (SECV-83-1768) 11-01-83 ZERBE COMMISSION COORDINATION OF PROPOSED 10 CFR PART 50.54(bb) WITH THE DECOMISSIONING RULE 11-02-83 ZERBE COMISSION DRAFT ADDENDUM TO COMISSION WASTE CONFIDENCE DECISION POLICY AND PLANNING GUIDANCE (PPG) - 1984 PALLADING 11-14-83 ZER8E PALLADING CHRON0 LOGY OF THI-l MANAGEMENT PROCEEDING 'BERNTilAL 11-17-83 ZERBE BERNTHAL 11-17-83 ZERBE COMISSION REGULATORY POLICY FOR ADVANCED REACTOR DESIGNS 11-17-83 ZERBE COMISSION BRIEFING ON BWR PIPE CRACK ISSUES l

11-18-83 ZERBE PAlLADING SECLC11Y , PALLADINO 11-22-83 ZERBE C0mlSSION RESPONSE TO THI-l STAFF REQUIREMENTS MEMORANDUM (M8311088) 00mlSS10N 1]2-02-83 Z'RBE E COMMISSION TMI STEAM GENERATOR REPAIR PROGRAM NO SIGNIFICANT liAZARD CONSIDERATION DETERMINA110N (SECY-83-474) D2-14-83 ZERBE COMMISSION EVALUATION Of GPU JUNE 10, 1983 PROPOSAL ON THI-l MANAGEMENT IN PALLADINO LIGHT OF ONG0ING INVESTIGA110NS PALLADINO OPTIONS FOR DEFINING "lHIEGRITY" AT IMI (W/0GC) PALLADINO D2-14-83 ZERBE 12-14-83 IERBE COMMISSION Zi mER COURSE OF ACTION -- STAFF APPROVAL (W/0GC) 12-14-83 ZERBE ASSELSTINE SEGREGABLE INTEGRITY ISSUES AT THI (W/0GC) ASSELSTINE 12-16-83 ZERBE COMMISSION RECOMMENDED SCHEDULE FOR COMMISSION CONSIDERATION OF DOE'S GENERAL GUIDELINES FOR RECOMENDATION OF Si1ES FOR NUCLEAR WASTE REPOSITORIES 12-27-83 ZERBE C0mlSS10N OPTIONS FOR DEFINING " INTEGRITY" AT TMI (W/0GC) COMISSION 12-30-83 ZERBE C0m IS$10N PUBLIC HEARINGS ON NRC'S CONCURRENCE IN DOE'S REPOSITORY SITING GUIDELINES PALLADINO POLICY AND PLANNING GUIDANCE PALLADINO '12-30-83 ZERBE 4 4

                                                     * -=am e men.           --,e   em ,    e, - - -
                                                                                                                    ,,,     ameuse                      ,

I?-30-83 ZERBE COMMIS$l0N REVISED GENERAL STATF, MENT Of POLICY AND PROCEDURE FOR ENf0RCEMENT *

• ACTIONS (SECY-83-487) t
• 6 e ema m 6"

_m ___ - -- - - ___ _ _ _ _ _ - - - - - - - - - -

DA1E FROM 10 SUBJECT JOINT PAPERS REQUESTOR 01-05-84 ZERBE COMMISSION COMMISSIONER GILINSKY'S DRAFT OPINION ON THI-l RESTART (W/0GC) PAllADINO 31-06-84 Z'RBE E COMMISSION PROCEDURAL GUIDANCE FOR PIPE REPLACEMENTS AT BWRS 01-09-84 ZERBE COMMISSION DIABLO CANYON REQUEST FOR CRITICALITY LOW POWER AUTil0RIZATION 31-09-84 ZERBE PALLADINO LIST OF INTEGRITY ISSUES IN THI-l RESTART PROCEEDINGS (W/0GC) PALLADINO 21-10-84 ZERBE COMMISSION NRC RESPONSE 10 ACCIDENTS OCCURRING DURING Tile TRANSPORTATION OF RADIDACTIVE MATERIAL, A STATEMENT OF POLICY (SECV-83-514) 21-17-84 ZERBE COMMISSION CLARiflCATIONOFPilVSICALPROTECTIONREQUIREMENT(SECV-83-500) 21-24-84 ZERBE COMMISSION INDUSTRY AND INTEREST GROUP CONCERNS ABOUT NRC REGULATIDN PALLADIND 11-25-84 ZERBE COMMISSION COMMERCIAL LICENSED OPERATOR EXPERIENCE OF DIABLO CANYON LICENSED OPERATORS 01-25-84 ZERBE COMMISSION DRAFT FINAL COMMISSION DECISION ON WASTE CONFIDENCE AND DRAFT FINAL AMENDMENTS 10 10 CFR PARIS 50 and 51 01-25-84 ZERBE COMMISSION TMI-! RESTART: DRAET MEMORANDUM TO PARTIES ON RESOLUTION OF (W/0GC) ROBERTS MANAGEMENT ISSUES - SECY-84-37) - LIMITED DISTRIBUTION e

              --            .                        . _.      . . _ -  --   ..                  _      . . ~ . . _ . . - -       . . ..

26-84 ZERBE A5SELSilNE tlSE OF POTASSIUM IOUIDE FOR TitVR010 BLOCKING (SECY-83-362) ASSELSTINE 26-84 ZERBE COMMIS$10N REGULATORY POLICY FOR ADVANCED REACTORS BERNillAL 26-84 ZERBE COMMISSION COMPARISON OF LEAK RATE TESTING AT VARIOUS B&W REACTORS BERNillAL 27-84 ZERBE COMMISSION DIRECTOR'S DENIAL OF 2.206 RELIEF (IN Tile MATTER OF COMUMERS (W/0GC) POWER COMPANY) - SECY-84-42 31-84 ZERBE COMMISSION REDUCING FUEL ENRICllMENT AND UPGRADING PilVSICAL PROTECTION AT COMISSION NON-POWER REACTORS 31-84 ZERBE COMISSION REVIEW 0F ALAB-724 - IN Tile MATTER OF METROPOLITAN EDISON (W/0GC) COMPANY - SECY-84-48 08-84 ZERBE C0mlSS10N PROPOSED DRAFT REQUIREMENTS MEMORANDUM TO STAFF REGARDING CONMISSION NON-POWER REACTORS 13-84 ZERBE COMMISSION STAFF CUIDANCE FOR SELECTION OF MEDICAL Mi$ ADMINISTRATION EVENTS FOR ABNORMAL OCCURENCE REPORTING - REVISED (SECY-84-50) 13-84 ZERBE C0 mlSS10N THI-l RESTART: CONSIDERATIONS FOR TEMPORARILY SEPARATING BERNTilAL ADDITIONAL INDIVIDUALS FROM NUCLEAR DUTIES - LIMITED DISTRIBUTION 02-84 ZERBE COMMISSION INDIAN POINT SPECIAL PROCEEDING: Su m ARY OF LICENSING BOARD OPINION AND RESPONSES TiiERET0 05-84 ZERBE GILINSKY ARKANSAS POWER AND LIGili COMPANY, GENERAL IMPRESSION OF GILINSKY a g e ,,. e- g-+=m ,, . -e- e .. - . --*en-e*= e4---e . ,,,

4 - m ae m, . A -r_ _44 _ .,u ,e 42,a 4 _ _,,. ,__m A_ c 4_4 ..m. . _ ___. . --_* - W 03-14-84 ZLittif COMMISSION UCS M0ll0N TO ESTABl.lSil CR11LRIA FOR JUDGING (W/0GC)

                                          " REASONABLE PROGRESS" AT THI-I - (SECY-84-ll3)

STATUS OF MARBLE lillL NUCLEAR POWER PLANI GILINSKY 03-21-84 ZERBE GILINSKY 03-22-84 ZERBE COMISSION DIABLO CANYON ISSUES EOR CLARIFICATION 03-23-84 ZERBE COMISSION FliNESS FOR DUTY RULE (SECV-83-339A) UTILITY MANAGEMENT CAPABILITY AND NUCLEAR SAFETY BERNillAL 03-27-84 ZERBE BERNTHAL i 03-28-84 ZERBE C0f911SS10N N011FICATION POLICY (SECY-84-97) 03-29-84 ZERBE C0fttlS$10N REDRAFT OF MILLER LETTER (CR-84-21) REGULAICRY FOLICY FOR ADVANCED REACTORS BERNillAL 03-30-84 ZERBE C009tiSSION 03-30-84 ZER8E C0f9tlSS10N QA REPORT TO CONGRESS (SECY-84-124) I r

        $       e' 1                                                                                                                                                             j
                                                                                                                                     -w-        ,. ,

t 04-0?-84 ZERSE C0m lSS10N OPE ComENTS ON SECV-84-124 REPORT 10 CONGRESS ON IMPROVING QUALITY AND THE ASSURANCE Of QUALITY IN THE DESIGN AND CONSIRUCTION Of Co mERCIAL NUCLEAR POWER PLANTS (FORD AMENOMENT) 04-04-84 ZERSE C0mlSS10N OPE ComENTS ON INTEGRATED SAFETY ASSESSMENT PROGRAM 04-11-84 ZER8E C0mlS$10N TMI-l RESTART DECISION: DRAFT SCF DULE PALLADINO i 04-12-84 ZERSE BERNTHAL REACTOR LICENSE AMEN 0 MENT PROCESS BERNTHAL  ! l ! 04-12-84 ZERSE C0mlSSION CHARACTERIZATION OF INSPECTION AND CERTIflCATION ACTIVITIES Of BER'tIHAL SONE OTHER FEDERAL AGENCIES l 04-16-84 ZERSE BERNTHAL V00R REQUEST OF APRIL 12, 1984 BERNIHAL . 1 04-19-84 ZER8E ComlSSION DRAFT LETTER ON USE Of POTASSIUM IODIDE (SECV-84-161) l 05-03-84 ZERSE C0mlSS10N ACRS REC 0 MEN 0ATIONS 10 ELEVATE AE00 TO A CopellSSION-LEVEL OFFICE l l 05-04-84 2ERSE C0f9tlSS10N TMI-I RESTART REComENDATIONS FOR TEMPORARY SEPARATION OF l ADDITIONAL INDIVIDUALS FROM NUCLEAR DUTIES l 05-04-84 ZERSE ComISSION TMI-l RESTART: DRAFT MANAGEMENT DECISION - SECY-84-186 (W/0GC) PALLADINO i LIMITED DISTRIBUTION I i t

l hC7-84 llRBL CONtI55 ION $1AFF APPROACH I") CRANilNG REQUL51510R EXIMPIIUlls FROM (W/0GC) REQUIZMENTS FOR 51Alf AND LCIAL PARTICIPA110N IN ANNUAL EMERGENCY PREPAREDNESS EXERCISES - SECY-84-171A 6-09-84 7ERSE CONtl5510N TECWIICAL ANALYSIS OF SAFETY ISSUES SURRGUv40lleG OPERATION OF SHOREHAM AT LOW POWER W11HOUT OltSITE QUALIFIED EMERGENCY DIESEL GElIERA10R$ 1 6-10-84 ZERBE SE RNTHAL SPEECH MATERIAL BERNIHAL 6-11-84 ZERSE SERNTHAL PLAlli DELAYS DUE TO HARDWARE-RELATED PROBLEMS 8ERNTHAL l 3-16-84 ZERSE BERNTHAL 1ALKING P0lNTS FOR EEI SPEECH BERNIHAL 1 6-17-84 ZERSE Comfl5510ft POLICY ALTERIIATIVES FOR DISPOSITION OF SHOREHAM CERTIFIED QUESTION ** l ON TERMS SAFE 1Y RELATED AND IMPORIAlii 10 SAFETY - ALA8-769 D-18-84 KElmeEKE CONT!SSI0li iMI ACTION PLAN. CHAPTER V PALLADINO ZERSE CONel5510lt IMI-l RESTART PROCEEDIIIG: ANALYSIS Of PARTIES' C0f0ENTS 018 (W/0GC) h23-84 LIST OF INTEGR11Y ISSUES - SECY-84-186A z[R8E CONil5510N REGULATORY PHil0 SOPHY, PRELIMIIIARY STUDY PALLADINO $22-84 ZERBE CON 41551001 NORTHEASTERN SEISMIC RESEARCH PROGRAM COIITRACT FOR IIORTHEASTERN PALIADINO %31-84 SEl5M0 GRAPHIC IIL1 WORK All0 CAleADIAlt C00PERA11VE SEISMIC AGitEEMENT C00lTRACT i G l l l t .-

p31-84 ZERGE C0 fell 5510N 1:1-1: DRAFT ORDIR ASKileG IUR PARTIES' C0petECis ON LIIIING (L'/0GC) IpetIDIATE EffECTIVEN(55 CJ 1979 SHUIDOWN ORDLR t 11-84 2[RSE C0fetI5510N TMI-l RESTART: REVIEW Of ALA8-129 HARDWARE ISSUES - SECY-84-232) (W/0GC) l >l3-84 2ERSE C0fetl55104 DIABLO CAleVolf STATUS i 'l4-84 > JERBE 8ERNTHAL NRC POLICY ON REACTOR CONTAINMENT BERNIHAL 19-84 ZEP8E C0 fell 5510N STATUS Of ISSUES EOR GRAND GULF FULL POWER LICENSE PALLA0!NO 20-84 ZERSE C00et155101 WATERFORD: STATUS Of LICENSING ISSUES PALLA0lNO l p20-84 ZERSE C0 fell 551001 SHOREHAM: STATUS Of ISSUES REQUIRIIIG RESOLUTION PRIOR TO PALLA0lNO l LICENSIIIG >22-84 ZERSE Colotl5510N POSSIBLE APPROACHES 10 A TMI-l OECI51001 p28-84 ZERSE C0 fell 551001 TMI-l RESTART LICENSE CON 0!TI0015 (SECY-84-221) PALLADINO 1 ' 03-84 2ENSE C08911551088 C08911551011 VOTE 011 SECY-84-232; MERITS REVIEW Olt TMI-I MmW l OECI51001(AtA8-729) 84 ZERSE C0fet!5510N OGC/0PE EVALUATION AND REC 0petENDATI0fts C000CER81181G LICEllSilIG (W/0GC) BOARD DEC151001 ON INUIAll POINT SPECIAL INVESTIGATORY PROCEE0lleG" (SECY-84-271)

m. as @w , 4 gm W -9' O eh w. eq -W h 6e

PALLADINO C7-12-84 ZERSE Co m 15510N P0551'3E APPROACHES 101:1-1 DECISION 07-12 94 ZERBE Com !SSION Co m ISSION DECISION ON WASTE CONflDENCE AND AMEN 0MENTS 10 10 CIR PARTS 50 AND 51 SERNTHAL 01-17-84 ZERSE SERNTHAL REVIEW Of JUNE 24. 1984 PHILADELPHIA INQUIRER ARTICLE 07-17-84 Z[RBE C0pell5510N C0fetf MTS ON DIABLO CANVON LICENSE CONDITION REQUIRING SEISMIC REEVALUATION C0pell5SION ROBERIS C7-17-84 ZERBE COMANCHE PEAK: STATUS Of LICENSING ISSUES C7-18-84 ZERSE C0pell5510N PROPOSED RL5PONSE TO CONGRESSMAN M00 RHEA 0 08-01-84 ZERSE C0petl5510N INDIAN POINT KEY ISSUES IOR C0fetISSION RESOLUTION SERNTHAL 08-07-84 ZERSE C0fetI5510N BACKGROUND mal [ RIAL 5 ON PLANT DELAYS DUE 10 BY HARDWARE-RELATED PN08tEMS PALLADING 08-09-84 ZERSE C0fel!5510ft SU MARY Of PARTY Coset [Nis ON TMI-l RESTART FOR ORAL ARGIstENT Cosell5510N IMI-l RESTART: LICENSEE REQUEST FOR STAY Of ALAS-772 (MANAGEMENT (W/0GC) 08-09-84 ZERSE DECISION) AND INI REQUEST 10 LIFT STAY OF ALA8-738 (MARTIIAll) C0 fell 5510N TMI-1 RESTART: REVIEW Of ALA8-774 - (SECY-84-323) (W/0GC) 08-13-84 ZERSE 6 O _ _ - , , ... -- ..m

l-14-84 ZERBE COMMISSION El-1 OSTART: RIVIEW OF A1 AB-112 & 138 - (MANAGEMENT & ilARTMAN) (W/0GC) (SECY-84-330) 1-17-84 Z[RBE C0fttl5510N TMI-l RESTART AND EMIRGENCY PREPAREDNESS DIFICIENCIES (W/0GC) l-28-84 ZERBE C0pell5510N FINAL RULE - 10 CFR PART 51 APPEND 11 8. EXPLANATORY NARRATIVE FOR TABLE 5-3 (SECY-84-149) l-29-84 2ERBE C0tetI5510N FOLLOWUP INFORMATION ON Tite INDIAN POINT MEETING PALLADIN0/BERNTilAL l-29-84 ZERBE COP 9tl5510N REVISION: REVIEW OF ALAB-772 (Tile MANAGEMENT DECl5 ION IN Tile TMl-1 (W/0GC) lie 51AkT PROCEEDING) AND ALAB-738 (REOPENING ON liARTMAN ALLEGATIONS) (SECY-84-330A) 1-29-84 ZERBE C0tetI5510N NEAR-TERM NEED FOR OL ItttEDIATE EFFECTIVENESS REVIEWS C0ttil5510N THI-1: WilETHER TO LIFT IPt4EDIATE EFFECTIVENESS Of TIIE 1979 (W/0GC) PALLADINO s-31-84 ZERBE SHUIDOWN ORDERS ZECil CHRONOLOGY Of THI-I MANAGEMENT PROCEEDING ZECil 9-04-84 ZERBE 9-07-84 ZERBE C0ttil5510N STAFF LONG RANGE PLAN FOR DEALING WITil STRESS CORROSION CRACKING IN BWR PIPING (SECY-84-301) 9-18-84 ZERBE Cottil5510N  !!EU TESTIMONY 0-02-84 ZERBE C0 Feil 5510N OPE COP 9 TENTS ON ISSUANCE OF A IULL-POWER OPERATING LICENSE FOR CALLAWAY

 *03-84                ZERSE                    BERNTHAL       N01ES FOR SPEECH       ,                                                                                                          BERNTHAL F05-84                ZERBE                    COMMISSION     AAMODT MOTION FOR INVESTIGATION OF THI-2 ACCIDENT RELEASES           (W/0GC)

(SECY-84-322A) l 505-84 ZERBE COMISSION OPE /0GC C0f# TENTS ON SECY-84-366: RESOLUTION OF CLEAN AIR ACT (W/0GC) IMPLEMENTATION ISSUES P05-84 ZERBE C0fMISS10N REVIEW OF PROPOSED POLICY STATEMENT ON SEVERE REACTOR ACCIDENTS REGARDING IUTURE DESIGNS AND EXISTING PLANTS 610-84 ZER8E C0petISSION DIVERSIFIED DATA REPORTING SYSTEM PALLADINO w12-84 ZER8E COMMISSION REC 0p# TENDED C000tiSS10N DECISIONS IN CONTINUING CONSIDERATION OF PALLADINO QA REPORT TO CONGRESS F17-84 ZERBE BERNTHAL NRC: PREPARING FOR THE FUTURE - ADVANCED REACTORS AND SEVERE BERNTHAL ACCIDENT POLICIES 417-84 ZERBE ASSELSTINE RADIATION OVEREXPOSURES FROM INDUSTRIAL RADIOGRAPHY ASSELSTINE hl7-84 ZERBE COMMISSION LETTER FROM CONGRESSMEN PATTERSON & PANETTA RE: DIABLO CANYON >l8-84 ZERBE COP 9tlSS10N PROPOSED RULEMAKING ON EARTHQUAKE EFFECTS ON EMERGENCY PLANNING (SECY-84-394) )-23-84 ZERBE C0pellSSION DIRECTOR'S DECISIONS ON UCS PETITION ON TMI-1 EMERGENCY FEEDWATER (W/0GC) SYSTEM UNDER 10 CfR 2.206 (IN THE MATTER OF GPU NUCLEAR CORPORATION) o

(SECY-84-378A) , 224-84 ZER8E COMISSION TMI-l RESTART: EMERGENCY FEEDWATER ILOW INDICATION - SECY-84-414 (W/0GC)

 >29-84    ZER8F   COMISSION   OPE ComENTS ON SECV-84-3SS, " FINAL POLICY STATEMENT ON ENGINEERING EXPERTISE ON SHIFT, AND SECV-84-106, " PROPOSED RULEMAKIIIG CONCERNING REQUIREMENTS FOR SENIOR MANAGERS 84 ZER8E   COMISSION   TMI-l RESTART: HEARINGS ON ACCURACY OF DIECKAMP MAILGRAM AND      (W/0GC)

ADEQUACY OF LICENSEE'S TRAINING PROGRAM - SECY-84-431

 ,09-84    ZERSE   COMISSION   INDIAN POINT SPECIAL PROCEEDING - DRAFT MEMORANDUM AND ORDER      (W/0GC)

IO9-84 ZERBE' COMISSION PROPOSED FITNESS FOR DUTY RULE (SECY-84-348), SENIOR MANAGER RULE COMISSION (SECY-84-106) AND TRAINING RULES (SECV-84-76. -76A AND -768) L13-84 ZERBE C0f911SSION INDIAN PolNT SPECIAL PROCEEDING - (SECY-84-437) (JOINT PAPER W/0GC) 614-84 ZERBE C00941SSION LOW-ENRICHED URANIUM (LEU) REFORM AMEN 0MENTS (SECY-84-362)

>l9-84     ZERSE   C0f9tISSION C0fetENTS ON SECV-84-433 221-84     ZERSE   COMNISSION  TMI-1: PATH TO A DECISION ON LIFTING lietEDIATE EFFECTIVENESS OF                 PALLADINO                 !

l SHUTDOWN ORDER 226-84 ZER8E C009tISSION OPE C0f94ENTS ON SEVERE ACCIDENT POLICY STATEMENT (SECY-84-370) r ..

d3-84 ZLRHE CumlSSIC'1 CATAWHA NUCLEAR STAT (ON UNITS 1 AND 2 84 - ZERBE C0fellSS10N REGULATORY POLICY FOR ADVANCED REACTORS - (SECY-84-453) BERNillAL 84 ZERBE C009tlS$10N AMEN 0MENTS TO 10 CIR PART 50 RELATED 10 HYDROGEN CONTROL .

>10-84      ZERBE  COMMISSION  EMERGENCY PLANNING EXERCISE AT INDIAN P0lNT
>10-84      ZERBE  ZECH        SECV-84-430 - OIA REVIEW OF THE LICENSING REVIEW PROCESS FOR           ZECH POWER REACTORS 213-84       ZERBE  C0fellSS10N CHRONOLOGY OF 1MI-I MANAGEMENT PROCEEDING                              C0ftllSS10N

>18-84 ZERBE C0fetIS$10N INI-I RESTART: l#4 ETHER FURTHER HEARINGS ARE WARRANTED ON (W/0GC) ISSUES OTHER lHAN TRAINING & MAILGRAM - SECV-84-475 126-84 ZERBE COMMISSION 1MI-I RESTART: DECIDING WHETHER 10 LIFT EFFECTIVENESS WHILE (W/0GC) PALLADINO HEARINGS ARE ONG0ING - SECV-84-480 4

         .*-e                                           ,              =    -                            e

SUBJECT JOINT PAPERS RFQUESTOR DATE FROM 10 PALLADINO 01-09-85 ZIRBE PAL LADINO REVIEW Of WASTE CONflDENCE DECISION 01-15-85 ZIDBE COMISSION POLICY STATEMENT ON 1 RAINING AND QUAllFICATIONS OF NUCLEAR POWER PLANT PERSONNEL (SECY-85-1) COMLZ-85-5; DIRCKS MEMORANDtM - JANUARY 10, 1985 PALLADINO 01-18-85 ZERBE PALLADINO 01-22-85 ZERBE C0mlSS10N REVISED DRAFT POLICY AND PLANNING GUIDANCE 01-30-85 ZERBE C0m !S$10N ERRATA FOR REVISED POLICY AND PLANNING CUIDANCE 01-30-85 ZERBE C0mlSSION PROPOSED NEW 10 CFR PART 39 FOR WELL-LOGGING OPERATIONS (SECY-85-il) 02-04-85 ZERBE C0mlSS10N POLICY STATEMENT ON FITNESS FOR DUTY OF NUCLEAR POWER PLANT PERSONNEL (SECV-85-21) 02-04-85 ZERBE COMMISSION SECY-84-473--lMPLEMENTATION OF CONVENTION ON PHYSICAL PROTECTION ASSELSTINE 02-04-85 ZERDE C0mlSS10N OPE COMENTS ON SECY-84-462: MEMORANDUM OF UNDERSTANDING BETWEEN NRC AND FEMA RELATING TO RADIOLOGICAL EMERGENCY PLANNING AND PREPAREDNESS SECY-85 IMEDIATE EFFECTIVENESS REVIEW OF (W/0GC) 02-04-85 ZERBE COMISSION OCTOBER 29, 1984 LICENSING BOARD ORDER AUTHORIZING GRANT OF EXEMPTION FROM GDC-17 FOR PHASES Ill AND IV 0F LOW POWER TESTING 9 .-

t C

                                                               .E C

aC e

                                                               =J eC L

e O c O N 3 w m E o

                                                        ==           n 2                   C       3            H MC                       w       Cz3          ==
                       = >=                     >=      ==           E w ==                     ==      K            3 CM                       E       >

coL E == M E M S -,J == CQ 6w heJ C === w Qg w w e > >= g 4/5 CI: O aC aC 3a E gE w >= a C ww w .o >= Mw w

                       == >       U       Ms            ==                 5
                       >w         ==
                                             *g
                                                >=      E            CE           ME wJ         =.J                   ==           *C 6         EC M e                cllh E        =.J          LaJ C        C ==         M
                            =     M       C3            w            a            ==>=         Cz:

Wc w CC U >= lll3 E

                                                                                  >=aC         C
                                                                                               >=
                . L.J  = ==       aC        ew             a                      en E U

v >= = == ME Ew w aC Z K CO == CB: E 3J aC w aC Cw w w cM Cy A o 2= >= EJ C ca: M M z

                  ==   = >=       aC      O aC          E            CW           C haJ 3    E          E       == E          Q      th    6M           >=           Q w

c EE >= O c KM w aC C !lI: *C == =* Z w aC W> U c Jw Q U >= e == >= M .-. X Z A 6' = = = = === >= aC C E >= aC e == a L.J 6C E W 3E C *C > , Z J > =c >= w aC A CI: C N. E *3 >= >* aC E 6 no CI: e aC aC CC == C C CE w *C CD w Tw J K

• w >= Q 2 X er &

A e= == c M E c == == C Mu QZ == h.J = MQ . 6 c cc M (E.3

                                  -=      CE =           >     E     2= >aC a

• ww E e M aC Q w w MW 6 M CO >

aug >E E O 64 cz; o E == M woa v vC C CD haJ aC wQW aC C=:>* ==

                  >    w ===      CL            v          e    E    u 3 .3       >= c u       a
            =     u    in M        M         eo                aC    = -3 M       M cz: w      C
                  ==        ==    w .'"

• EE *C E JQM AM A

                  =.J  Ev         CE N    $aO             n                aC ==  2         w C    Qw              a  w         ===  P'm    CE   CI:          Oc a         C        J e  m E >=         v     C     w6J               2F      Cx:

M e aC M e C :l3 e w Q aC M == e O C >= >= E == CC M == cn e v >= 2 m >= w E u as; ve CC >= = CD aC M == Z2 *C M wwX Z> e 4 C3: e C e2E h.J L.4 LhJ =J 3c aC U = > E a>= v =J 3

                  >         cO     Ew     >E Uh       >A    U      6sJ                    Z 4E3   0 w         gE     == M   haJ m ===      w      c     =.4 3 >=aC6 U.J      Q aC    w CK   WAA         6w     MwQ            M      aC    6 M >=      U U >=       CK e

E E E E E E E E C C O O.a C o m .o o.= Ce

                  .    ==          ==      =             .      Z                              .

M M M M M == M M M to e M M c M

                                                                                  .M M
                  .M   =.=         =       e-o           ==     aC    ==                       .

v v v v v A v v v w w w w w w w w w cz3 cm cc a:n c:3 CE3 cz2 cz3 cE3 Ex: CK CE  % 2 CK z z 64 64 64 64 had C.K bJ had had bed N N N N N N N N N i I M M Ln 6n M M M M M ' CC CC cc CO CQ CC CD CC CC *  ! s e e e e e e e e c N Cc cc == N - == N l C C C C ** *=* N N N

• e e e e e e e e e

                                                                                                          -                          j

__ A ____ W _________%t_____ K _ ___ R _ R _ K _____ ] __ e

l

                                                                        .           l l

l 02-26-85 ZERBE COMMISSION SECY-84-453A - REGULATORY POLICY FOR ADVANCED REACTORS l

@3-04-85                         2ERBE     COMMISSION   IMPOSITION OF CIVIL PENALTIES ON FEDERAL AGENCIES G3-04-85                         ZERBE     COMMISSION   TMI-l -- AAMOOT MOTION FOR RECONSIDERATION AND                     (W/0GC)

REOPENING OF THE RECORD - SECY-85-74

@3-05-85                         ZERBE     COMMISSION   SECY-85-60: FINAL PRESSURIZED THERMAL SHOCK (PTS)

RULE

'G3-08-85                        ZERBE     ZECH         OPE 

SUMMARY

OF CSNI SPECIAL TASK FORCE ON SOURCE TERM ZECH MEETING, FEBRUARY 26-28, 1985 - LIMITED DISTRIBUTION '33-11-85 ZERBE COMMISSION COMMENT ON PROPOSED REVISION OF 10 CFR PART 35,

                                                        " MEDICAL USE OF BYPRODUCT MATERIAL" (SECY-84-485)

G3-14-85 ZERBE COMMISSION ANALYSIS OF THE TRAINING RECORD AT TMI-l (W/0GC) ZECH LIMITED DISlRIBUTION 33-14-85 ZERBE PALLADING MANAGEMENT OF NRC RESOURCES G3-19-85 ZERBE COMMISSION LLW DISPOSAL CAPACITY -- SECY-85-83 13-19-85 ZERBE COMMISSION SECY-85-100 - INDIAN POINT SPECIAL PROCEEDING - (W/0GC) DECISION l . 4

 - * * - -   * ' ' *

• e MM N -= a w. m - ew eme>

e e, ,e NN ewe -e MNh

                                                                           -4 0-20-85                          ZERBE COMISSION     DIABLO CANYON UNIT 2 LICENSING SCHEDULE -

NEED FOR EFFECTIVENESS REVIEW 0-20-85 ZERBE COMIS$10N ANALYSIS OF DIECKAMP MAILGRAM HEARINGS -- (W/0GC) PALIADINO 1MI-! RESTART 421-85 ZER8E C0f0tlSS10N PETITION FOR REVIEW OF ALA8-788 (IN THE MATTER (W/0GC) 0F LONG ISLAND LIGHTING COMPANY) - (LILCO) 0-22-85 ZERBE C0f011SS10N CHRONOLOGY OF THI-! MANAGEMENT PROCEEDING KAMERER )-29-85 ZERBE C0fetISSION TMI-l RESTART PROCEEDING: DECIDING WHETHER TD (W/0GC) LIFT EFFECTIVENESS BEFORE ISSUANCE OF LICENSING BOARD DECISION ON TRAINING AND DIECKAMP MAILGRAM me e+ e - - _ _ - _ _ - - - _ _ - -_ - - - - -- a

     .. .       -       ..  -.           - ~ _ -          -          -_    . _. -- -
                                ~

j_ OVEST10N 4 (CONTINUED) ' l QUESTION: E. THE RECOMMENDATIONS OF THE 1983 OIA AUDIT OF OPE AND WHAT IS THE STATUS OF IMPLEMENTATION OF THOSE RECOMMENDATIONS. l ANSWER:

          ~ E. THE RECOMMENDATIONS OF OIA, THE COMMISSION'S VOTE ON THE RECOMMENDATIONS, THE OPE RESPONSE TO THE RECOMMENDATIONS, AND A 

SUMMARY

OF THE CURRENT STATUS IS ENCLOSED. THE OIA j MADE 11 RECOMMENDATIONS, OF WHICH 5 WERE DIRECTED AT THE COMMISSION. SUBSEQUENTLY, THE COMMISSION VOTED ON THESE f FIVE RECOMMENDATIONS AS INDICATED IN THE MEMORANDUM FROM THE SECRETARY TO THE COMMISSION, SAMUEL J.CHILK, TO THE i ACTING DIRECTOR OF OIA DATED DECEMBER 14, 1983. 4

                      ~

, 'AS FOR THE SIX RECOMMENDATIONS DIRECTED AT OPE, THE OFFICE HAS ACTED ON ALL OF THEM EXCEPT FOR THE FOLLOWING: { -A) OPE'S SECTION OF THE NRC MANUAL HAS NOT BEEN UPDATED. THIS ACTION IS CONTINGENT ON THE COMMISSION ISSUING GUIDANCE TO OPE ON OPE'S ROLES AND FUNCTIONS WHICH HAS l NOT YET BEEN DONE. B) OPE HAS NOT PREPARED ANY ANNUAL OPERATING PLANS SINCE l THE COMMISSION DECIDED AGAINST THIS RECOMMENDATION. Y

QUESTION u. (CONTINUED) .. QUESTION: F. THE REASON WHY THE SERVICES OF OPE WERE NOT USED TO PREPARE THE JANUARY 23, 1985 REPORT TO THE

                  ~

t COMMITTEE ON APPROPRIATIONS ON THE ROLE OF THE NRC CHAIRMAN INSTEAD OF HIRING AN OUTSIDE CONTRACTOR. ANSWER:

                        ~

i THE MEMBERS OF THE STUDY GROUP APPOINTED BY THE CHAIRMAN TO REEXAMINE THE CHAIRMAN'S AUTHORITY UNDER REORGANIZATION PLAN - NO. 1 0F-1980 WERE THREE NRC OFFICIALS: THE EXECUTIVE DIRECTOR FOR OPERATIONS, THE ASSISTANT SECRETARY OF THE COMMISSION, AND THE DIRECTOR (AND CHIEF COUNSEL) 0F THE REGULATIONS DIVISION, 1

             ' 0FFICE 0F THE EXECUTIVE LEGAL DIRECTOR, AND A-CONSULTANT TO THE
                                ~
           ^

EXECUTIVE DIRECTOR FROM OUTSIDE THE AGENCY. THUS, THE STUDY TEAN WAS A REPRESENTATIVE GROUP WHICH INCLUDED THE HIGHEST MANAGEMENT OFFICIAL IN THE AGENCY'S STAFF, A SENIOR COMMISSION i 0FFICIAL, A SENIOR LEGAL OFFICER, AND A KNOWLEDGEABLE MANAGEMENT CONSULTANT. 4

              ' IT WOOLD NOT HAVE BEEN APPROPRIATE FOR THE CHAIRMAN TO USE THE l         ~ : OFFICE OF POLICY EVALUATION (OPE) TO PREPARE THE STUDY REPORT.

t i OPE WAS INITIALLY ESTABLISHED TO PROVIDE POLICY ADVICE TO ALL 10F THE COMMISSIONERS AND IT HAS CONTINUED TO PERFORM THIS FUNCTION. WHILE OPE MAY PERFORM STUDIES FOR INDIVIDUAL

                              '~
                    ^ ~

MARKEY/0PE

CUESTTON 4, (CONTINUED)  !

                                      ~
  -                                      COMMISSIONERS UPON REQUEST, THESE TYPICALLY DEAL WITH POLICY ISSUES WHICH CONCERN THE CCMMISSION AS A COLLEGIAL BODY.

MORE0VER, CONGRESSMAN BEVILL'S LETTER REQUESTING THE STUDY WAS DIRECTED TO THE CHAIRMAN ALONE AND WAS BASED ON THE CHAIRMAN'S SINGULAR EXPERIENCE AS THE LONGEST-SERVING CHAIRMAN IN NRC HISTORY. HENCE, IT WAS NATURAL TO USE THE AGENCY'S SENIOR MANAGEMENT OFFICIALS (WHO SERVED DIRECTLY UNDER THE CHAIRMAN) TO CONDUCT THE STUDY. SINCE THE STUDY GROUP'S REPORT FOCUSED ON PROBLEMS RESULTING FROM POLICY FORMULATION AND INDEPENDENCE

                   ~

PRACTICED BY THE OTHER COMMISSIONERS AND RECOMMENDED A SINGLE

           -                             ADMINISTRATOR AS THE PREFERRED OPTION, IT WAS CLEARLY THE CHAIRMAN'S REPORT.

l 4 i i

                                            ~

MARKEY/0PE

1 QUESTION 5. DOES THE COMMISSION BELIEVE THAT THE AGENCY IS COMPLYING WITH REQUESTS MADE PURSUANT TO THE FREEDOM OF INFORMATION ACT (FOIA) IN A TIMELY AND COMPLETE FASHION AS REQUIRED BY LAW, REGULA-TIONS AND INTERNAL POLICY? HAS THE WORKLOAD OF THE FOIA BRANCH OF THE DIVISION OF RULES AND RECORDS CHANGED SIGNIFICANTLY OVER THE PAST SEVERAL YEARS AND IF SO, WHAT STEPS HAVE BEEN - TAKEN TO RESPOND TO ANY SUCH CHANGES? i ANSWER, IHE NRC IS COMPLYING WITH ALL OF THE SUBSTANTIVE LEGAL AND PROCEDURAL REQUIREMENTS OF THE FREEDOM OF INFORMATION ACT (FOIA) EXCEPT THAT, BECAUSE OF THE INCREASING NUMBER AND COMPLEXITY OF THE REQUESTS RECEIVED, IT HAS NOT BEEN ABLE TO COMPL'Y FULLY WITH THE TIME LIMITATIONS SPECIFIED IN THE ACT. THE FOLLOWING CHART SHOWS THE ACTUAL F0IA RESPONSE TIMES IN 1984: i .f

  'a--  , - - - + - - - - - - - - _ - _ - . - - - - - - - - - - - - - - _ - - - - - - - , _ - - - - - - - - . -               --.  - - - -  ---a            - -- - - - - - - - - - - - - - - - . - - - , , - - - - . - - -

QUESTION 5 (CONTINUED) RESPONSE TIME NUMBER PERCENTAGE

       ~

_. (WORKING DAYS) COMPLETED COMPLETED 1 - 10 212 23% 11 - 20 231 24% OVER 20 505 53% TOTALS 948 100% THE NRC'S F0IA WORKLOAD HAS INCREASED FROM 539 F0IA CASES IN 1981 TO 1036 CASES IN 1984. DURING THIS PERIOD,'THE NUMBER OF PENDING CASES HAS ALSO CONTINUED TO GROW, AND AVERAGED ABOUT 200 CASES THROUGHOUT 1984. THE COMPLEXITY OF THE FOIA WORKLOAD ALSO HAS INCREASED, AND THE NRC EXPECTS THAT THIS TREND WILL CONTINUE FOR THE NEXT SEVEPAL YEARS. TO HANDLE THE INCREASED WORKLOAD, THE FOIA BRANCH HAS TAKEN A NUMBER OF POSITIVE ACTIONS. MOST IMPORTANTLY, THE YEARLY PRODUCTION OF EACH PROFESSIONAL STAFF MEMBER HAS INCREASED FROM ABOUT 90 CASES PER YEAR IN 1981 AND 1982 TO 122 CASES IN 1984, NEW WORD PROCESSING EQUIPMENT HAS BEEN INSTALLED, AND A NEW MANAGEMENT INFORMATION SYSTEM HAS BEEN DEVELOPED TO TRACK THOSE ACTIONS STILL NECESSARY TO BE ACCOMPLISHED TO COMPLETE THF PROCES' SING OF INDIVIDUAL FOIA RECUESTS. IN ADDITION, IN LATE 1984 TV!O PROFESSIONAL STAFF MEMBERS AND A SECRETARY WEPE ADDED TO THE F0IA BRANCH,

1 i

  ~

1 QUESTION 6. PLEASE ENUMERATE WHAT PROCESS AND STANDARDS ARE i USED BY THE COMMISSION TO DETERMINE LICENSEE i COMPETENCE AND LICENSEE INTEGRITY IN CASES WHERE

                ~

THE NRC HAS DETERMINED THAT LICENSEES HAVE MADE , MATERIAL FALSE STATEMENTS. ANSWER, 1 IF A MATERIAL FALSE STATEMENT IS DISCOVERED, ITS BEARING ON THE ~ q NRC'S OvEPALL EVALUATION OF WHETHER THERE IS REASONABLE ASSURANCE i THAT THE LICENSEE WILL OPERATE ITS FACILITY WITHOUT UNDUE RISK TO 1 THE PUBLIC HEALTH AND SAFETY IS CONSIDERED AND TAKEN INTO ACCOUNT

fN LICENSING AND ENFORCEMENT DECISIONS. NOT ALL MATERIAL FALSE

. STATEMENTS HAVE A BEARING ON LICENSEE INTEGR!TY.

i l {

                   ~ ~

~~THE COMMISSION APPLIES THE TERM " MATERIAL FALSE STATEMENT" TO BOTH INTE'NTIONAL AND UNINTENTIONAL STATEMENTS AND OMISSIONS. THE

           ~

i 0FFICE OF INVESTIGATIONS (01) REVIEWS MATERIAL FALSE STATEMENTS I

AND, IF EVIDENCE SUGGESTS THAT A STATEMENT WAS MADE INTENTIONALLY, l

I INVESTIGATES THE CIRCUMSTANCES SURROUNDING THE STATEMENT TO DETERMINE WHETHER THE VIOLATION WAS WILLFUL. Ol'S CONCLUSIONS ARE ,

l

!   CONSIDERED IN SUBSEQUENT DECISIONS REGARDING POSSIBLE LICENSING OR ENFORCEMENT ACTION.                                                                                                              f 1

l IN ADDITION TO THE LICENSEE'S CANDOR AND TRUTHFULNESS IN THE CASE. 1~ i OF A PARTICULAR INTENTIONAL FALSE' STATEMENT, A NUMBER OV OTHER ' l i i

l l I CUESTTON 6 (CONTft4UED)  ! FACTORS ARE CONSIDERED IN ASSESSING A LICENSEES INTEGRITY, THE3E l INCLUDE ITS GENERAL CANDOP AND ATTITUDE TOWARD ITS RESP 0ft-l l SfBILITIES, ITS HISTORY OR PECORD OF WILLFUL NON-COMPLIANCE WITH NRC REQUIREMENTS, AND ITS ACTIONS TO DEAL WITH INSTANCES OF MIS-CONDUCT OR WRONGDOING ON THE PART OF ITS STAFF. DETERM!t!ATIONS OF LICENSEE INTEGRITY ARE, NECESSARILY, SUBJECTIVE AND DO NOT LEND THEMSELVES TO APPLICATION OF SPECIFIC OBJECT!VE CRITERIA. INSTEAD, A DETERMINAT!ON MUST BE MADE BASED Oft THE TOTALITY OF THE

   ~

CIRCUMSTANCES. AN UNINTENT!0tlAL MATERIAL FALSE STATEMENT MAY HAVE MORE OF A BEARING ON COMPETENCE THAN ON INTEGRITY IF THE CIRCUMSTANCES DO NOT RAISE QUEST!CNS ABOUT CANDOR AND TRUTHFULNESS. WITH REGARD TO A LICENSEE'S COMPETENCE, Uti!NTENTIONAL MATERI AL FALSE STATEMENTS IflCLUDING THOSE MADE RECKLESSLY, flEGLIGENTLY OR WITH CARELESS DISREGARD ARE CONSIDERED ALONG WITH MANY OTHER FACTORS. THESE FACTOPS INCLUDE: THE LICEf4SEE'S ORGANIZATIONAL STPUCTURE, THE MAKEUP OF ITS OPERATING ORGANIZATION, ITS MANAGEMENT AND TECHNICAL RESOURCES, ITS TRAlti!NG PROGRAM, ITS EXPERIENCE WITH NUCLEAR OPERATIONS, AND THE EXPERIENCE AND QUALIFICATIONS OF THE LICENSEE'S PERS0flNEL. l A DETERM!flATION IN A PARTICULAR CASE THAT THE NRC HAD SUFFICIENT DOUBTS REGARDING A LICENSEE'S INTEGRITY OR COMPETENCE THAT IT COULD NO LOflGER MAKE THE REAS0tlABLE ASSURANCE FlflDING COULD LEAD TO DEN!AL OF A LICENSEE APPLICATION, THE SUSPEtlSION OR REVOCATION l

l l l QUESTI0tl 6 (CONTDlUED) j

  ' 0F A LICENSE   OR TO OTHER ACTION THAT WOULD INVOLVE THE LICENSEE ,

REORGANIZING OR HIRING NEW PERSONNEL. l l l l l I. r 6 0

I m J

OllESTION 7 PLEASE EXPLAIN THE PROCESS BY WHICH LICENSING

                             ~

i BOARD JUDGES ARE SELECTED AND REMOVED FROM OFFICE, EXPLAIN ALSO THE PROCESS BY WHICH INDIVIDUAL JUDGES ARE ASSIGNED TO OR REMOVED FROM PARTICULAR CASES. I i ANSWER, 1 l i THE SELECTION PROCESS FOR LEGAL AND TECHNICAL LICENSING BOARD JUDGES IS AS FOLLOWS. WHEN A VACANCY FOR A PERMANENT MEMBER l OCCURS, IT IS POSTED WITHIN THE AGENCY ACCORDING TO PROCEDURES ] I WHICH GOVERN ALL VACANCIES WITHIN THE AGENCY. VACANCIES IN THE PART-TIME MEMBERSHIP ARE, OF COURSE, NOT POSTED WITHIN THE AGENCY. I ADDITIONALLY, ALL VACANCIES, PERMANENT AND PART TIME, ARE PUBLISHED WIDELY IN TRADE JOURNALS AND OTHER SUITABLE PUBLICATIONS IN ORDER TO ATTRACT APPLICANTS FROM OUTSIDE THE AGENCY. - i FROM 1980 TO 1984 APPLICATIONS WERE TURNED OVER TO ONE OF TWO ADVISORY SCREENING COMMITTEES, ESTABLISHED UNDER THE ADVISORY I COMMITTEE ACT. THE TWO COMMITTEES, ONE FOR LAWYERS AND ONE FOR 4 TECHNICAL MEMBERS, WERE ESTABLISHED IN FEBRUARY 1980 AND i '

DISCONTINUED IN 1984 EECAUSE THE COMMISSION DOES NOT ANTICIPATE 1

lI HIRING ANY MORE ADMINISTRATIVE JUDGES FOR SEVERAL YEARS. NO NEW

               -JUDGES HAVE BEEN SELECTED SINCE MARCH 1982.

i I

QUESTION 7 (CONTINUED) ) !: .EACH~ O'F THE COMMITTEES CONSISTED OF SEVEN MEMBERS DESIGNATED-TO SERVE, WHEN AND AS NEEDED, FOR A PRESCRIBED TERM. THE MEMBERS OF THE COMMITTEES WERE DRAWN FROM BOTH WITHIN AND WITHOUT THE COMMISSION AND THE GOVERNMENT. THE CHAIRMAN OF THE LICENSING

    ~ BOARD PANEL (OR HIS DELEGATE) SERVED ON EACH COMMITTEE.                                                                                           IN RECOGNITION OF THE ADJUDICATORY NATURE OF THE FUNCTIONS OF THE LICENSING BOARDS, AT LEAST ONE MEMBER OF THE COMMITTEE FOR TECHNICAL VACANCIES WAS A LAWYER.

THE SCREENING COMMITTEES HAD NO RESPONSIBILITY FOR THE ! SOLICITATION OF CANDIDATES AS THEY DID NOT HAVE THE FUNCTION OF

       " SEARCH" COMMITTEES. ALL PAPERS PERTAINING TO A CANDIDATE WERE I

j SUBMITTED IN THE FIRST INSTANCE (OR IMMEDIATELY TRANSFERRED UPON RECEIPT) TO THE APPROPRIATE COMMITTEE. UNDER SUCH PROCEDURES ! DEVISED BY IT, THE COMMITTEE EVALUATED THE INFORMATION SUPPLIED BY OR ON BEH'ALF OF THE CANDIDATE, SOUGHT ANY-FURTHER INFORMATION FROM , - INTERVIEWS OR REFERENCES FROM THE CANDIDATES AS IT DEEMED I NECESSARY, AND TOOK SUCH OTHER ACTIONS AS IT DEEMED NECESSARY TO EVALUATE THE CANDIDATES. l FOLLOWIN'G THE COMPLETION OF THE SCREENING PROCESS, THE COMMITTEES l SUBMITTED THE NAMES OF THREE CANDIDATES TO THE COMMISSION FOR ITS CONSIDERATION. THE FULL FILE ON EACH OF THOSE CANDIDATES ACCOMPANIED'THE SUBMISSION. IN ADDITION, UPON COMMISSION REQUEST, THE COMMITTEE FURNISHED IT WITH THE FILES ON THE REMAINING

QUESTION 7 (CONTINUED) - CANDIDATES, TOGETHER WITH THE COMMITTEE'S EVALUATION OF THE CUALIFICATIONS OF THOSE INDIVIDUALS.

   ' THE COMMISSION THEN FILLED THE VACANCY BY THE APPOINTMENT OF ONE 0F THE THREE COMMITTEE NOMINEES, GENERAL QUALIFICATIONS                           __

ALL MEMBERS OF THE PANEL -- WHETHER LAWYERS OR SCIENTISTS -- - - SHOULD POSSESS THE FOLLOWING QUALIFICATIONS: I. OBJECTIVITY AND GOOD JUDGMENT. II. JUDICIAL TEMPERAMENT. -- 4 A HIGHLY DEVELOPED SENSE OF PROFESSIONAL III. j RESPONSIBILITY. IV. SOUND LEGAL AND/OR TECHNICAL ANALYTIC ABILITY, INCLUDING THE ABILITY TO DISCERN THE P!VOTAL ASPECTS OF COMPLEX ISSUES.

v. ABILITY TO COMMUNICATE ORALLY.

VI, ABILITY TO FUNCTION EFFECTIVELY AS A MEMBER OF A ] COLLEGIAL.DECISIONMAKER. i

QUESTION 7 (CONTINUED) .

.   .                           SPECIAL QUALIFICATIONS FOR LAWYER MEMBERS                                                                               ,

I. CONSIDERABLE LITIGATION EXPERIENCE IN THE ADMINISTRATIVE LAW AREA; FAMILIARITY WITH THE RULES OF EVIDENCE AND

                         ~

BASIC PRINCIPLES OF ADMINISTRATIVE LAW, AS WELL AS WITH FUNDAMENTAL CONCEPTS OF PROCEDURAL DUE PROCESS. . 11. MARKED ABILITY TO WRITE CLEARLY AND TO ORGANIZE

                                                                                                                                                            ~

PROPERLY THE CONTENT OF DECISIONS AND MEMORANDA. III. ABILITY TO CONTROL PROCEEDINGS IN A FIRM BUT FAIR MANNER. IV. I ~ WILLINGNESS TO ADDRESS AND MASTER SCIENTIFIC ISSUES TO . PASS AN INFORMED JUDGMENT ON THEM. I j SPECIAL QUALIFICATIONS FOR TECHNICAL MEMBERS , , , . . _ I. CONSIDERABLE AND BROAD EDUCATIONAL BACKGROUND AND VOCATIONAL EXPERIENCE IN ONE OR MORE RELEVANT TECHNICAL

                    ~
                           ~ DISCIPLINES; EXPERIENCE SHOULD NOT HAVE BEEN RESTRICTED                                                                           -

j TO RESEARCH WORK IN ONE NARROW FIELD. i II. ABILITY AND WILLINGNESS TO DEVELOP THAT DEGREE OF j EXPERTISE IN OTHER SCIENTIFIC DISCIPLINES AS MAY BE j NECESSARY TO MASTER FULLY AND TO PASS AN INFORMED 2 l

! QUESTION 7 (CONTENUED) .

                                                                             ~~
                                                                                                                                                                     ' JUDGMENT ON ALL OF THE TECHNICAL ISSUES PRESENTED IN THE                                              ,

PARTICULAR CASE -- WHETHER THE PARTICULAR ISSUE BE - l REGARDED AS RELATED TO RADIOLOGICAL HEALTH AND SAFETY OR TO THE ENVIRONMENT. III. IN THE CASE OF AN. INDIVIDUAL WHOSE TECHNICAL CREDENTIALS ARE PRIMARILY IN THE PHYSICAL SCIENCES, ONE OR MORE OF HIS OR HER AREAS OF SPECIALIZATION SHOULD - HAVE BEEN NUCLEAR-RElATED. - . XV. ABILITY TO,PRESENT IDEAS LOGICALLY AND CLEARLY IN WRITTEN FORM. l V. WILLINGNESS TO ADDRESS AND MASTER LEGAL ISSUES AND TO PASS AN INFORMED JUDGMENT ON THEM. SPECIAL QUALIFICATION FOR PART-TIME MEMBERS __ (LAWYER OR TECHNICAL) A~PART-TIME MEMBER MUST BE IN A POSITION TO' DEVOTE THE TIME NECESSARY TO DISCHARGE HIS OR HER DUTIES FULLY, EFFECTIVELY AND WITH THE REQUIRED DEGREE OF EXPEDITION. ANY PERSON WHOSE OTHER PROFESSIONAL OR PERSONAL COMMITMENTS ARE SUCH AS TO CAST REASONABLE DOUBT UPON HIS OR HER ABILITY TO MEET THAT STANDARD IS, WITHOUT REGARD TO ANY OTHER FACTORS, ELIMINATED FROM FURTHER  ; CONSIDERATION FOR APPOINTMENT TO THE PANEL. i

1 QUESTTON 7 (CONTZNUED)  : l l THERE ARE NO SPECIAL PROCEDURES ESTABLISHED FOR REMOVAL OF ADMINISTRATIVE JUDGES, AND NONE HAVE BEEN REMOVED. IN THIS CONNECTION, IT SHOULD BE NOTED THAT IN RECOGNITION OF THE FACT THAT NRC LICENSING PROCEEDINGS ARE CONDUCTED UNDER THE i ADMINISTRATIVE PROCEDURE ACT, ADMINISTRATIVE JUDGES ARE NOT SUBJECT TO PERFORMANCE APPRAISALS, AND ARE ACCORDED THE INDEPENDENCE OF ADMINISTRATIVE LAW JUDGES. 1 ASSIGNMENT / REMOVAL FOR PARTICULAR CASES JUDGES ARE ASSIGNED TO PARTICULAR CASES BY THE CHIEF 1 i ADMINISTRATIVE JUDGE OF THE ASLBP OR THE COMMISSION BY MEANS OF A NOTICE' PUBLISHED IN THE FEDERAL REGISTER. THEY ARE REMOVED BY PUBLICATION OF A NOTICE RECONSTITUTING THE BOARD WITH ONE OR MORE I NEW MEMBERS. USUALLY, THE SOLE CONSIDERATION IN THE ASSIGNMENT OF JUDGES IS AVAILABILITY AND DISTRIBUTION OF WORKLOAD. REMOVAL OCCURS ONLY WHEN A JUDGE ADVISES THAT HE OR SHE IS UNAVAILABLE. i .ONCE APPOINTED, A JUDGE WHO REMAINS AVAILABLE TO SERVE MAY BE - i REMOVED IF THE JUDGE DEEMS HIMSELF OR HERSELF DISQUALIFIED, . EITHER jjJA SPONTE OR UPON MOTION OF A PARTY. THE JUDGE'S DECISION  ; ON A MOTION TO DISQUALIFY IS SUBJECT TO APPELLATE REVIEW BY THE i

    ~

ATOMIC SAFETY AND LICENSING APPEAL BOARD AND'THE COMMISSION fTSELF. l

l l

                                                      -- -,_-___ _.____.-_.-_--_-._..i.

l l QUESTION 8. WHAT IS THE LEGAL BASIS FOR THE COMMISSION OR ~ LICENSING BOARDS DIRECTING THAT A LICENSING PROCEEDING, A PORTION OF A LICENSING PROCEEDING, OR AN AMENDMENT FROM A LICENSEE OR PERMITTEE BE HANDLED ON AN EXPEDITED BASIS? PLEASE EXPLAIN WHAT IF ANY STANDARD MUST BE MET BY PARTIES TO THE PROCEEDING, OR FINDING MADE BY THE LICENSING ~ PANEL, IN ORDER TO JUSTIFY EXPEDITING ALL OR PART OF A

            ~

PROCEEDING. ADDITIONALLY, PLEASE DETAIL WHAT

        ~     ~

STANDARDS AND GUIDELINES EXIST FOR REGULATING THE CONDUCT OF AN EXPEDITED PROCEEDING. PR0vlDE A LISTING OF ALL CASES SINCE 1983 IN WHICH.THE COMMISSION, INDIVIDUAL COMMISSIONERS, OR THE CHAIRMAN OF THE ATOMIC SAFETY AND LICENSING BOARD PANEL HAVE DIRECTED OR OTHERWISE SOUGHT TO EXPEDITE A LICENSING PROCEEDING AND THE REASON WHY. ANSWER, IHERE IS NO SPECIFIC STATUTORY AUTHORITY GOVERNING THE PACE AT - WHICH LICENSING PROCEEDINGS ARE CONDUCTED. IN 10 C.F.R. . 5 2.718(E), ISSUED PURSUANT TO THE GENERAL GRANT OF AUTHORITY - CONTAINED IN SECTION 161 (P) 0F THE ATOMIC ENERGY ACT OF 1954, AS AMENDED, THE COMMISSION HAS EMPOWERED LICENSING BOARDS TO

     " REGULATE THE COURSE OF THE HEARING AND THE CONDUCT OF THE PARTICIPANTS."     THIS AUTHORITY IS ALSO STATED IN 9 556 (C) 0F.THE -

QUESTION 8 (CONTINUED) ADMINISTRATIVE PROCEDURE ACT, IT IS EXERCISED WITH DUE REGARD FOR THE POLICY OF THE COMMISSION THAT PROCEEDINGS BE CONDUCTED EXPEDI'TIOUSLY. AS STATED IN 10 C.F.R. PART 2, APPENDIX A, THIS POLICY IS

       ... FOUNDED UPON THE RECOGNITION THAT FAIRNESS TO ALL THE PARTIES IN SUCH CASES AND THE OBLIGATION OF ADMINISTRATIVE AGENCIES TO CONDUCT THEIR FUNCTIONS WITH EFFICIENCY AND            1 ECONOMY, REQUIRE THAT COMMISSION ADJUDICATIONS BE CONDUCTED WITHOUT UNNECESSARY DELAYS.

IN 1981, THE NRC ISSUED A STATEMENT OF POLICY ON CONDUCT OF -

            ~

LICENSING' PROCEEDINGS IN WHICH IT ENCOURAGED THE LICENSING BOARDS TO EXPEDITE THE HEARING PROCESS BY FULLY USING THE PROCEDURAL DEVICES CONTAINED IN 10 C.F.R. PART 2. IT EMPHASIZED THOUGH THAT, IN EXPEDITING HEARINGS, BOARDS SHOULD ENSURE THAT THE HEARINGS ARE l FAIR, AND PRODUCE A RECORD WHICH LEADS TO HIGH QUALITY DECISIONS THAT ADEQUATELY PROTECT THE PUBLIC HEALTH AND SAFETY AND THE ENVIRONMENT. CLI-81-8, 13 N.R.C. 452.

 $N ITS POLICY AND PLANNING GUIDANCE DOCUMENTS FOR 1984 AND 1985,         ,

NUREG-0885, THE COMMISSION REAFFIRMED ITS 1981 POLICY STATEMENT AND' DIRECTED THAT ACTIONS BE TAKEN TO ELIMINATE UNWARRANTED DELAY IN REACHING LICENSING DECISIONS. POLICY AND PLANNING GUIDANCE DOCUMENTS ISSUED FOR YEARS 1982 AND 1983 CONTAINED SIMILAR STATEMENTS.

QUESTION 8 (CONTINUED)

• IHE STANDARD FOR EXPEDITION OF A PROCEEDING IS "G00D CAUSE", I.E.,

A SHOWING THAT A FAILUPE TO EXPEDITE WOULD CONSTITUTE AN

      " UNNECESSARY DELAY."   IN PRACTICE, PARTIES DO NOT REQUEST EXPEDITION OF A PROCEEDING AS A WHOLE BUT RATHER SOME DEFINABLE
   ~ SEGMENT'SUCH AS THE PERIOD ALLOWED FOR DISCOVERY OR THE TIME FOR FILING SOME DOCUMENT. THE VAST MAJ0 PITY OF TIME-RELATED REQUESTS ARE FOR EXTENSIONS RATHER THAN " EXPEDITION."

~ THERE ARE NO SPECIAL STANDARDS OR GUIDELINES FOR THE CONDUCT OF S0-CALLED EXPEDITED PROCEEDINGS. THE ADMINISTRATIVE PROCEDURE ACT AND THE COMMISSION'S. RULES OF PRACTICE REQUIRE THAT ALL PROCEEDINGS BE CONDUCTED WITH DUE REGARD FOR THE PIGHTS OF THE PARTIES AND THE OBLIGATION OF THE AGENCY TO COMPILE AN ADEQUATE

    ~ RECORD UPON WHICH TO BASE ITS DECISION. THAT REMAINS TRUE WHETHER THE HEARING PROCEEDS QUICKLY OP SLUGGISHLY.

THE CHAIRMAN OF THE ASLBP HAS NEVER DIRECTED LICENSING BOARDS TO EXPEDITE ALL OR ANY PART OF A PROCEEDING. HE HAS " SOUGHT TO EXPEDITE" PROCEEDINGS ONLY IN THE SENSE THAT HE HAS APPOINTED ADDITIONAL LICENSING BOARDS TO PRESIDE OVEP SPECIFIC SEGMENTS OF

 ~

HEARINGS WHEN ADVISED BY THE ORIGINAL BOARDS THAT THEY ARE UNABLE BECAUSE OF WORKLOAD CONFLICTS TO COMPLETE PROCEEDINGS AS SCHEDULED. THIS HAS OCCURRED SINCE 1983 IN THE CATAWBA, SHOREHAM, LIMERICK AND COMANCHE PEAK OPERATING LICENSE PROCEEDINGS.

QUESTf0N 8 (CONTINUED) u-WITH REGARD TO THE INSTANCES IN WHICH THE COMMISSION OR [NDIVIDUAL COMMISSIONERS, HAVE SOUGHT TO EXPEDITE A LICENSING PROCEEDING SINCE 1983, IT IS VIRTUALLY IMPOSSIBLE TO GIVE A COMPLETE ANSWER. REASONABLE EXPEDITION IN LICENSING PROCEEDINGS IS, AS NOTED ABOVE, A GOAL OF THE ADMINISTRATIVE PROCEDURE ACT, AS WELL AS A GOAL

  ~ }&l!CH THE CONGRESS HAS EMPHAS! ZED REPEATEDLY (SEE, FOR EXAMPLE, H.R. REP. NO. 96-1093, 96TH CONG. 2ND SESS. 1982).      MANY
   ~ SCHEDULING DECISIONS OF THE COMMISSION COULD BE CONSTRUED AS           l l

EFFORTS TO EXPEDITE A PROCEEDING. EFFORTS TO EXPEDITE LICENSING PROCEEDINGS TAKE PLACE ROUTINELY--AND APPROPRIATELY S0. IN ADDITION, AS YOU ARE AWARE, IN MARCH 1984, CHAIRMAN PALLADINO MET WITH THE l! CENSING BOARD PANEL CHA!RMAN AND OTHER NRC OFFICIALS TO DISCUSS POTENTIAL LICENSING DELAYS AT A NUMBER OF FACILITIES. AT THAT MEETING, THE POSSIBILITY OF AN EXPEDITED HEARING ON THE QUESTION OF LOW-POWER OPERATION OF THE SHOREHAM FACILITY WAS DISCUSSED, AS CHAIRMAN PALLADINO DESCRIBED IN DETAIL IN'A MEMORANDUM ISSUED BY HIM ON SEPTEMBER 21, 1984, CLI-84-20, 20 i N.R.C. 1061. 4

4 OVESTION 10. SINCE THE ORIGINAL PASSAGE OF LEGISLATION AUTHOP-I

                           ! ZING THE COMMISSION TO ISSUE TEMPORARY OPERATING LICENSES (TOLS), HOW MANY LICENSEES OR PERMITTEES l   ,

HAVE REQUESTED TOLS AND HOW MANY TOLS HAS THE COMMISSION ISSUED 7 i

ANSWER.

'SECTION 192 0F THE ATOMIC ENERGY ACT (THE ACT), AUTHORIZING '

1 ISSUANCE OF TEMPORARY OPERATING LICENSEES FOR NUCLEAR POWER i REACTOPS, WAS IN!T! ALLY ADDED TO THE ACT IN JUNE, 1972. THIS i STATUTORY AUTHOP!TY EXP! PED IN OCTOBER, 1973. A TEMPORARY l r OPERATING LICENSE WAS ISSUED TO VERMONT YANKEE NUCLEAR POWER ! STATION IN SEPTEMBEP, 1972 UNDER THIS AU'THOP!TY. 7 ON JANUARY 4, 1983, SECTION 192 0F THE ACT WAS AMENDED TO i  : AUTHORIZE THE NRC TO ISSUE TEMPORARY OPERATING LICENSES. REGU-LATIONS ADOPTED IN CONNECTION WITH THIS NEW AUTHOP!TY WERE , i ~ EFFECTIVE NOVEMBER 14, 1983. (48 Egn. Egg. 46489). THE STATUTOPY AUTHORITY EXP! RED ON DECEMBER 31, 1983. UNDEP THIS 1983 STATUTORY AUTHORITY, NO TEMPOPARY OPERATING LICENSES WERE ! DEOUESTED AND NONE ISSUED. l l

QUESTION 11, DOES THE COMMISSION AND NRC STAFF GENERALLY I CONSIDER THE CONSTRUCT!0fl COMPLET!Orl, FUEL LOAD, CRITICALITY AND COMMERCIAL OPERATION DATES SUGGESTED BY LICENSEES TO BE ACCURATE AND RELIABLE. FOR PLAflTS LICENSED SINCE THE THPEE MILE ISLAND ACCIDENT, PROVIDE A LISTING BY PIANT AND YEAR OF EACH LICENSEES' PROJECTED MILESTONES DATES, NRC STAFF PROJECTED MILESTONE DATES AND ACTUAL HISTORICAL DATES THESE MILESTONES WERE ACHIEVED OR - CURRENT EST! MATES. EXPLAIN WHICH DATES, THE NRC'S OR THE LICEflSEES'ARE USED FOR AGENCY RESOURCE PLANNING, HEARING SCHEDULES AND OTHER CONSIDERATIONS. ANSWER THE NRC GENERALLY CONSIDERS THE APPLICANT'S EST! MATED DATES FOR CONSTRUCTION COMPLET!ON AND FUEL LOAD (USUALLY SYN 0flYMOUS) TO HAVE VARYING DEGREES OF OPTIMISM. OFTEN THERE IS LITTLE OR NO C0flT!NGENCY BUILT INTO THE APPLICANT'S SCHEDULE TO TAKE CARE OF LAST MINUTE PROBLEMS WHICH MIGHT ARISE. THE NRC IS NOT INVOLVED IN THE DETER-MINATION OF A COMMERCI AL OPERATIOff DATE. DATE OF CRITICALITY IS - MAINLY USEFUL FOR HISTORICAL PURPOSES AND !$ fl0T PROJECTED BY THE NRC STAFF. ACCORDINGLY THE BULX OF THIS ANSWER WILL CONCEtlTRATE Ofl FUEL LOAD DATE. l

OVESTf0N 11 (CONTINUED) AT THE-TIME OF CONSTRUCTION PERMIT ISSUANCE, THE APPLICANT PROVIDES AN EST! MATE OF THE DATE OF FUEL LOADING, FOR WHICH HE EXPECTS AN OPERATING LICENSE. PERIODICALLY, AS NEEDED, THE DATE IS REVISED. THE NRC STAFF PERIODICALLY REVIEWS CONSTRUCTION PROGRESS AND MAY ESTIMATE A CONSTRUCTION COMPLETION DATE. NRC EST! MATES ARE ALSO REVISED FROM TIME TO TIME. ATTACHMENT 1 LISTS, FOR PLANTS LICENSED SINCE l THE TMI-2 ACCIDENT, THE APPLICANT'S FUEL LOAD DATE AT CONSTRUCTION PERMIT ISSUANCE, THE APPLICANT'S FUEL LOAD DATE AS OF FEBRUARY 1979, JUST PRIOR TO THE TMI-2 ACCIDENT, THE APPLICANT'S AND STAFF ESTIMATES AS OF DECEMBER, 1980 AND AS OF FEBRUARY, 1983, IF APPLICABLE, AND THE ACTUAL DATES FOR OPERATING LICENSE ISSUANCE PERMITTING FUEL LOAD AND COMMERCIAL OPERATION FOR UNITS LICENSED SINCE MARCH 1979. BOTH THE APPLICANT AND STAFF FUEL LOAD DATES HAVE BEEN USED FOR AGENCY RESCURCE PLANNING AND HEARING SCHEDULES. IN RECENT YEARS THE APPLICANT'S FUEL LOAD DATE HAS BEEN USED FOR PLANNING PURPOSES FOR LICENSING ACT!VITIES INCLUDING HEARING SCHEDULING. IHE NRC OFFICES OF NUCLEAR REACTOR REGULATION, NUCLEAR MATERIAL SAFETY AND SAFEGUARDS, EXECUTIVE LEGAL DIRECTOR AND THE l! CENSING BOARDS PRIMAP!LY UTILIZE THE APPLICANT'S DATE. OTHER OFFICES SUCH AS INSPECT!ON AND ENFORCEMENT AND THE REGIONS HAVE USED THE NRC PROJECTIONS. ' CURRENTLY, WHEN THE APPLICANT'S DATE AND THE STAFF DATE DIFFER BY MORE THAN'S!X MONTHS A MEETING IS HELD WITH APPLICANT MANAGEMENT TO ATTEMPT TO RESOLVE THE DIFFERENCE.

i. . .. , ,

QUESTION 11. ATTACHMENT

i. . ,

I FUEL LOAD DATE Date of ' '

    .. ,.               .           ,                                                                                                         Lic. Issuance Cowenercial At CP                       As of 12/80                                                             As of 2/83          Perini tting Operations Unit'Nane         Issuance    As Of 2/79    Applicant         Staff                                                   Applicant     Staff    Fuel Load         Date N:rth Anna 2         8/74        4/79            NA             NA                                                          NA       NA ~ >    4/80         12/80 S:quoyah:1   i       3/75        4/79            NA             NA                                                          NA       NA        2/80         7/81 Farley 2              9/76  .,    12/79           NA .   .  . . . NA i . . i i i NA                                                   NA         10/80       6/81

. Salem 2 9/72 2/79 NA NA NA NA 4/80 10/81 McGuire 1 5/75 2/79 1/81 1/81 NA NA 6/81 12/81 S:quoyah 2 11/75 12/79 3/81 7/81 NA NA 6/81 6/82 Diablo Canyon 1 4/72 2/79 1/81 1/81 2/83 2/83 11/83** 4/85* San Onofre 2 2/79 2/80 4/81 7/81 NA NA 2/82 8/83 LaSalle 1 3/75 3/79. 6/81 6/81 NA NA 4/82 1/84 Grand Gulf 1 3/79 10/80 8/81 7/82 NA NA 6/82 6/85* Susquehanna 1 5/79 5/80 6/81 3/82 NA NA *7/82 6/83- .Sunener 10/77 7/80 4/81 8/81 NA NA 8/82 1/84 McGuire 2 10/76 10/80 6/82 6/82 3/83 3/83 3/83 3/84 San Onofre 3 5/80 5/81 4/82 10/82 NA NA 11/82 4/84 St. Lucie 2 , 6/83 12/82 ~11/82 12/83 4/83 ~4/83 4/83 8/83

't.aSalle 2           8/75        3/80          '6/82           6/82                                                        9/83       11/83     12/83       10/84 WNP-2                '4/77        3/80           7/82           7/82                                                        8/83      2/84       12/83       12/84 S Estimated Date
** Operating License Ihsued 9/81,' withdrawn 11/81', reinstated 11/83

QUESTION 11. (jontinuid) ATTACIMENT FUEL LOAD DATE Date of Lic. Issuance Conenercial At CP As of 12/80 As of 2/83 Permitting Operations Unit Name Issuance As Of 2/79 Applicant Staff Applicant Staff Fuel Load Date Susqu:hanna 2 11/80 11/81 9/82 4/83 2/84 2/84 3/84 2/85 Callaway 6/81 4/82 10/82 2/83 5/84 11/84 6/84 12/84 (Proposed) Catawba 1 12/78 2/81 8/83 10/83 5/84 11/84 7/84 5/85* 3 '_imerick 4/79 10/82 11/83 11/83 8/84 11/84 10/84 11/85* Byrcn 5/80 3/81 4/83 4/83 8/83 8/83 10/84 9/85* Sh:reham 3/77 6/80 5/82 9/82 2/83 8/83 12/84 10/85* Waterford 3 6/78 5/81 7/82 10/82 5/83 8/83 12/84 6/85* Palo Vcrde 1 11/81 11/81 11/82 5/83 8/83 11/83 12/84 Late 1985 Walf Creek 10/82 10/82 4/83 12/83 11/84 11/84 3/85 5/85* Fermi 2 8/73 6/80 11'/82 11/82 8/83- 8/84 3/85 6/85*

  *- Estimated Date                            i                                                                                                     .
                         ?

I. 9 4 l 0 I f B t

QUESTION 12, LIST ALL CASES SINCE 1982 IN WHICH THE REVIEWING

                ~

COURTS HAVE RULED AGAINST NRC LICENSING, REGULATORY

                ~

OR RULEMAKING ACTIONS, PROVIDE A BRIEF DESCRIPTION

 ~:~
                  ~ ~          ~

OF THE DISPUTE AND THE REASON PROVIDED BY THE COURT FOR ITS ACTION, 1 ANSWER, THE FOLLOWING LIST INCLUDES ALL CASES SINCE 1982 IN WHICH THE REVIEWING' COURTS HAVE RULED AGAINST NRC LICENSING, REGULATORY OR l RULEMAKING ACTIONS: l i

1. GUARD V. NRC, NO. 84-1091 (D.C. CIR FEBRUARY 12, 1985)

THE COURT VACATED THE COMMISSION'S INTEF.PRETATION THAT THE ARRANGEMENTS FOR OFFSITE EMERGENCY MEDICAL SERVICES FOR

            ~

CONTAMINATED INJURED INDIVIDUALS IN CONNECTION WITH THE

         ~

FULL-POWER OPERATING LICENSE FOR SAN ONOFRE UNIT 3 WERE -

              ~          ~       ~

C0NS'ISTENT WITH 10 C.F.R. 550.47(B)(12). THE C0VRT HELD THAT THE COMMISSION DID NOT REASONABLY INTERPRET SECTION -

                                 ~

r ~50.47(B)(12) WHEN IT DECLARED THAT A SIMPLE LIST OF TREATMENT

                      'FA'CILITIES ALREADY IN PLACE CONSTITUTES SUCH ARRANGEMENTS.
                                                                                      ~
                ~ THE COURT REMANDED THE ISSUE TO THE COMMISSION FOR FURTHER CONSIDERATION,

ObESTION 12 (CONT!NUED) 2. LORION V, NRC, 712 F.2D 1472 (D.C. CIR. 1983), REV'D SUB NOM. FLORIDA POWER a LIGHT CO. V. LORION, NO. 83-703 (U.S. SUPREME COURT MARCH 20, 1985) ON FEBRUARY 8, 1982, NRC DENIED MS, LORION'S PEQUEST FOR ENFORCEMENT ACTION UNDER 10 C.F.R. 52.206 THAT TURKEY POINT UNIT 4 BE SHUT DOWN FOR A STEAM GENERATOR INSPECTION. ON JULY 26, 1983, THE D.C. CIPCUIT COURT HELD THAT THE DISTRICT COURTS NOT THE COURTS OF APPEALS HAVE SUBJECT-MATTER JURISDICTION TO INITIALLY REVIEW DENI ALS BY THE liRC OF 10 C.F.R. 52.206 REQUESTS. 4 IHIS LOSS WAS RECENTLY REVERSED BY THE SUPREME COURT, WHICH AFFIRMED THE NRC'S POSITION, AND HELD THAT THE COURTS OF APPEALS HAVE INITIAL SUBJECT-MATTER JURISDICTION CVER COMMISSION ORDERS DENYING 10 C.F.R. 82.206 CITIZEN PETITIONS.

3. NEW ENGLAND COALITION ON NUCLEAR POLLUTION, ET AL, V. NRC, _

727 F.2D 1127 (D.C. CIR. 1984) THE COURT REMANDED TO THE COMMISSION FOR FURTHER PROCEEDINGS THE MARCH 31, 1982 FINANCIAL QUALIFICATIONS RULE, WHICH ELIMINATED FINANCIAL QUALIFICATION REVIEWS FOR PUBLIC UTILITY LICENSEES. THE COURT HELD THAT THE RULE WAS NOT ADEQUATELY SUPPORTED BY ITS ACCOMPANYING STATEMENT OF BASIS AND PURPOSE. THE COURT FOUND THAT THE COMMISSION'S REASONING, IF SUPPORTED -

QUESTION 12-(CONTINUED) BY THE FACTS, WOULD APPLY GENERALLY TO ALL LICENSE APPLICANTS AND, THEREFORE, WOULD NOT SUPPORT A PULE WHICH SINGLED OUT UTILITIES FOR SPECIAL TREATMENT. ON SEPTEMBER 12, 1984 THE COMMISSION PUBLISHED A NEW FINANCIAL QUALIFICATION RULE WHICH REINSTATED THE FINANCIAL QUALIFICATION REVIEW AT THE

     ~ CONSTRUCTION PERMIT STAGE, BUT ELIMINATED PEVIEW AT THE OPERATING LICENSE STAGE FOR REGULATED UTILITIES ON THE GROUND
    ~ THAT SUCH UTILITIES WILL RECOVER ALL REASONABLE COSTS OF OPERATION THROUGH THE RATE REGULATORY PROCESS. THIS RULE IS PRESENTLY UNDER REVIEW IN THE D.C. CIRCUIT.

4. UNION OF CONCERNED SCIENTISTS v. NRC, 711 F.2D 370 (D.C. CIR. _

1983)

              ~

THE COURT VACATED THE COMMISSION'S FINAL RULE WHICH SUSPENDED BY AN IMMEDIATELY EFFECTIVE RULEMAKING THE JUNE 30, 1982 DEADLINE BY WHICH NUCLEAR FACILITIES MUST COMPLETE THE ENVIRONMENTAL QUALIFICATION OF SAFETY-RELATED EQUIPMENT. THE COURT HELD THAT THE NRC ERRED BY PROMULGATING A RULE WITHOUT PRIOR NOTICE AND OPPORTUNITY FOR COMMENT.

5. UNION OF CONCERNED SCIENTISTS V. NRC, 735 F.2D 1437 (D.C.

CIR. 1984) THE COURT VACATED THE COMMISSION'S JULY 1982 AMENDMENTS TO THE. EMERGENCY PLANNING RULES WHICH PERMITED THE ISSUANCE OF

CUESTION 12 (CONTINUED) - 4- . INITIAL LICENSING DECISIONS WITHOUT THE RESULTS OF

   ~     ~

PREPAREDNESS EXERCISES. THE COURT HELD THAT THE ATOMIC l

                                                                                 ~

' ENERGY ACT DOES NOT PERMIT THE COMMISSION TO EXCLUDE THE

~ ~

RESULTS OF EMERGENCY PPEPAREDNESS EXERCISES FROM OPERATING LICENSE HEARINGS BECAUSE THE ISSUE IS MATERIAL TO NRC LICENSING DECISIONS. i ) l i i e t 9

i* - QUESTION 13 (CONTINUED) . AS A MATTER OF PUBLIC POLICY, DOES ~7E

  ~

(B) COMMISSION BELIEVE THAT IT IS WISE TO COMMIT PUBLIC FUNDS TO REVIEW A PLAN WHOSE LEGALITY IS IN DOUBT? ANSWER. THE LAW OBLIGATES THE COMMISSION TO REVIEW A UTILITY EMERGENCY PLAN. IF A FINAL AND BINDING DETERMINATION WERE MADE THAT A UTILITY COULD NOT LAWFULLY IMPLEMENT ALL OR PART OF A PLAN NEGESSARY FOR ADEQUATE PROTECTION OF THE PUBLIC HEALTH AND SAFETY,

THEN REVIEW MIGHT LEGALLY BE DECLINED OR DISCONTINUED.

l J k I P

    . _ _ . _ _ _ _ _ _ _ _ . _ _ . _ _               __._._.______.____.__._____..________________A_.__                _ . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ . _ _ _ _ _ .   . _ . _ _ _ . _ _ _ _ _ . _ _ . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ . _

0VESTION 13 (CONTlNUED) , (C) AS A MATTER OF LAW, DOES THE COMMISSION AND

                                                                 ~

ITS OFFICE OF GENERAL COUNSEL BELIEVE THAT IT WOULD BE LAWFUL TO PARTICIPATE IN AN EXERCISE OF A UTILITY EMERGENCY PLAN THAT HAS BEEN ESTABLISHED

  ~

TO BE UNLAWFUL BY A COURT OF COMPETENT JURISDIC-TION. 4 ANSWER. IT WOULD PROBABLY NOT BE A VIOLATION OF THE ATOMIC ENERGY ACT IN i OUR JUDGMENT. BEYOND THAT, WE HAVE NO OPINION ON WHETHER OR NOT TT WOULD VIOLATE STATE LAW OR SOME OTHER FEDERAL STATUTE. COMMISSIONER ASSELSTINE NOTES THAT HE HAS REQUESTED A REVIEW BY

                          'THE.0FFICE OF THE GENERAL COUNSEL ON THE RELEVANCE OF THE RECENT
                                                                   ~

NEW' YORK SUPREME COURT DECISION TO THE ISSUE OF AN EMERGENCY PLAN EXERCISE FOR THE SHOREHAM PLANT. - - l 4 _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ .._e_

QUESTION 15. DOES THE COMMISSION AND NPC STAFF BELIEVE THE MATERIALS CERTIFICATION AND PROCEDURES BRANCH OF

         ~

THE DIVISION OF FUEL CYCLE AND MATERIAL SAFETY IS ADEQUATELY STAFFED, WHAT IS THE PURPOSEa0F THIS BRANCH AND WHAT IS THE CURRENT "IN HOUSE" BACKLOG OF PENDING REQUESTS FOR SEALED SOURCE AND DEVICE EVALUATIONS? F0F EACH YEAR SINCE 1982, WHAT HAS BEEN THE AVERAGE AMOUNT OF TIME IT HAS TAKEN TO

           .             COMPLETE DEVICE EVALUATIONS?    FOR THOSE DEVICE EVALUATIONS CURRENTLY PENDING, PROVIDE A LISTING OF THE DATE EACH EVALUATION WAS REQUESTED AND THE DATE IT IS EXPECTED TO BE COMPLETE.

ANSWER,

             ~

TH'E MATERIAL CERTIFICATION AND PROCEDURES BRANCH PRIOR 70-EARLY 1~984 HAD 1.5 STAFFYEARS BUDGETED TO PERFORM 100 EVALUATIONS PER YEAR. HOWEVER, IN 1984, WE RECEIVED ABOUT 200 CASES, RATHEP THAN - 100 PROJECTED AND THE VOLUME OF INCOMING CASES HAS CONTINUED IN

                  ~

1985. ACTUAL RECEIPTS ARE EXCEEDING PROJECTED BUDGETED RECEIPTS WHICH ARE BASED MAINLY ON EARLIER EXPERIENCE. IN JANUARY 1984, CONTAMINATED STEEL ENTERED THE UNITED STATES FROM MEXICO, THIS,' ALONG WITH OTHER LESS SERIOUS INCIDENTS LED NRC TO ASSIGN A HIGH PRIORITY TO A STUDY OF OUR POLICY ON REGULATING GAUGES AND SIMILAR DEVICES, THIS CAUSED US TO SHIFT STAFF FROM THE SOURCE AND DEVICE EVALUATIONS TO THE STUDY AND THE BACKLOG OF UNPROCESSED EVALUATIONS INCREASED,

d QUESTION 15, 2 CURRENTLY, ADDITIONAL STAFF HAS BEEN TEMPORARILY REASSIGNED TO PERFORM THE EVALUATIONS. THIS ACTION IS REDUCING OUR BACKLOG. THE ONLY WAY WE CAN CONTINUE TO REDUCE THE BACKLOG IS IF WE

                                                                               ~

CONTINUE TO APPLY THESE EXTRA RESOURCES. AT THE BEGINNING OF FY85, THERE WERE 95 SOURCE AND DEVICE APPLI-CATIONS PENDING. AT THE END OF MARCH 85, WE HAD REDUCED THAT TO

                                                                                                ~

71 APPLICATIONS. THE AVERAGE TOTAL REVIEW TIME FOR A SEALED SOURCE AND DEVICE APPLICATION, PRIOR TO 1984, WAS 30-60 CALENDAR DAYS. THE MATEPIAL CERTIFICATION AND PROCEDURES BRANCH IS RESPONSIBLE FOR THE DESIGN CERTIFICATION OF SEALED SOURCES AND DEVICES AND FOR

             ~

THE DEVEL0PMENT OF REGULATIONS AND REGULATORY GUIDES NEEDED FOR BYPRODUCT, SOURCE AND SPECIAL NUCLEAR MATERIALS LICENSING. THE MATERIAL LICENSING BRANCH IS RESPONSIBLE FOR LICENSING THE POSSESSION AND USE OF BYPRODUCT, SOURCE'AND SPECIAL NUCLEAR MATERIAL AND FOR PROVIDING TECHNICAL GUIDANCE TO THE NRC REGIONAL

 ' 0FFICES. DURING THE MONTH OF APRIL 1985, THESE TWO BRANCHES ARE BEING CONSOLIDATED TO IMPROVE THE EFFICIENCY OF. NUCLEAR MATERIALS LICENSING AND TO REFLECT THE DECENTRALIZATION OF THE LICENSING RESPONSIBILITY'TO THE REGIONAL OFFICES.

i 1

CUESTION 15, 3 4 A LISTING OF EVALUATIONS CURRENTLY PENDING IS ATTACHED. A SINGLE APPLICANT .vAY REQUEST MCPE THAN ONE PRCDUCT DESIGN EVALUATION. THEREFORE, A COLUMN HAS BEEN ADDED TO SHOW HOW MANY EVALUATIONS ARE REQUESTED BY EACH APPLICANT. PRODUCT EVALUATIONS ARE ORDINARILY PERFORMED ON A FIRST-COME/ FIRST-SERVED BASIS. THE LENGTH OF TIME REQUIRED TO PERFORM AN EVALUATION. DEPENDS ON 1) THE COMPLEXITY OF THE PRODUCT DESIGN, 2) THE INTENDED USE OF THE PRODUCT, 3) THE QUALITY OF THE APPLICATION AND'4) THE AMOUNT OF STAFF DEDICATED TO THIS WORK. THEREFORE, A SPECIFIC DATE FOR COMPLETING EACH EVALUATION CANNOT BE GIVEN. REVIEWS HAVE BEEN INITIATED FOR ALL APPLICATIONS ON THE PENDING L!ST RECEIVED PRIOR TO JANUARY 1985. THOSE FOR WHICH REVIEW HAS BEEN INITIATED ARE IN VARIOUS STAGES OF COMPLETION, E.G., PENDING RESPONSE FROM THE APPLICANT REGARDING DEFICIENCIES, EVALUATION OF APPLICANT RESPONSES TO QUESTIONS OR PREPARATION OF FINAL REPORTS. ATTACHMENT: LISTING OF EVALUATIONS CURRENTLY PENDING .

OUESTION 15, 4 _ NUMBER OF DATE OF EVALUATIONS

 .. . REQUEST .. RE0 VESTED                    NAME 04/13/84       (2)          BAUMER OF AMERICA, INC, P,0, B0x 235 435 ROUTE 202 TOWACO, NJ 07082 04/27/84       (1)          AMERSHAM CORP.

2626 SOUTH CLEARBROOK DRIVE ARLINGTON HEIGHTS, IL 60005

  ~

06/19/84 (6) BERTHOLD INSTRUMENTS 136 BRADFORD AVENUE PITTSBURGH, PA 15202 07/10/84 (1) RADIATION MONITORING DEVICES 44 HUNT STREET WATERTOWN, MA 02172 08/29/84 (9) NUCLEAR RESEARCH CORPORATION 125 TITUS AVENUE WARRINGTCN, PA 18976 08/31/84 (2) MONITOR SUGAR COMPANY 2600 S. EUCLID AVENUE BAY CITY, MI 48706 (SEE BERTHOLD ALS0) 09/12/84 (1) . YALE UNIVERSITY 20 YORK STREET NEW HAVEN, CT 06504 09/14/84 (4) DEPT, OF INTERIOR

 -                                 DENVER, CO 80225 10/01/84       (1)          BEST INDUSTRIES 2244 S. SHIRLINGTON ROAD ARLINGTON, VA 22206 10/29/84       (1)          ELLIS CONSULTANTS FOR BUCHLER GMBH 913 STATE ROAD PRINCETON, NJ 08540-1484

CUESTION 15, 5 NUMBER OF DATE OF EVALUATIONS REQUEST _ REQUESTED NAME 11/09/84 (3) AMERSHAM CORPORATION 2626 SOUTH CLEARBROOK DRIVE ARLINGTON HEIGHTS, IL 60005 11/13/84 (1) 10N TRACK INSTRUMENTS 109 TERRACE HALL AVENUE

  .                            BURLINGTON, MA 01803 11/30/84       (1)         LIxI, INC, 1438 BROOK DRIVE DOWNERS GROVE, IL     60515 11/30/84       (2)         AEONIC SYSTEMS, INC.

45 MANNING ROAD BILLERICA, MA 01821 12/04/84

       ~

(1) FAG BEARING CORP, 118 HAMILTON AVENUE, B0x 811 STAMFORD, CT 06904 12/06/84 (1) DEPT, OF THE ARMY ROCK ISLAND, IL 12/11/84 (1) E. S INDUSTRIES 8 SOUTH MAPLE AVENUE MARLTON, NJ 08053 12/21/84 (1) H0CHIKI-AMERICA CORP, 5415 INDUSTRIAL DPIVE I HUNGTINGTON BEACH, CA 92649 01/07/85 (1) TVA 1040 CHESTNUT STREET, TOWER 1 CHATTANOOGA, TN 37401 01/09/85 (1) DEPT, OF THE INTERIOR BUREAU OF RECLAMATION 1917 MARSH ROAD YAKIMA, WA 98907-1749 01/24/85 (1) OSTE 0N, INC. P.O. BOX 430 WASHIAWA, HI 96786

QUESTION 15, 6 NUMBER OF DATE OF EVALUATIONS .... REQUEST . PEQUESTED NAME 01/25/85 (2) SENTEX, INC. 553 BROAD AVENUE RIDGEFIELD, NJ 07657 01/25/85 (2) THE TIMKEN COMPANY 1836 DAEBER AVENUE, SW CANTON, OH 44706 01/25/85 (4) AMERSHAM CORP. 2636 S. CLEARBROOK DRIVE ARLINGTON HEIGHTS, IL 60005 01/25/85 (1) AMERSHAM CORP. 2636 S. CLEARBROOK DRIVE ARLINGTON HEIGHTS, IL 60005 01/28/85 (I) MPSI 240 ARCH STREET YORK, PA 17403 01/29/85 (2) REUTER STOKES R6 HOLDINGS 18530 S. MILES PARKWAY CLEVELAND, OH 44128 02/06/85 (1) TWIN CITY SHIPYARD 1303 RED ROCK ROAD P.O. B0x 43032 ST. PAUL, MN 55164 02/11/85 (2) 3M 225-583M CENTER ST. PAUL, MN 55144 02/15/85 (1) ATOMIC ENERGY OF CANADA 413 MARCP ROAD KANATA, CNTARIO CANADA 02/22/85 (1) BRANDHURST, INC. 87 SAND PIT ROAD DANBURY, CT 06810 i

l I QUESTION 15, 7 NUMBER OF DATE OF EVALUATIONS REQUEST _ REQUESTED NAME 02/22/85 (2) NEN PRODU' 'S 331 TRELL' COVE ROAD NORTH BILLcRICA, MA 02/25/85 (1) McLINS MACHINE CO. 3900 CAROLINA AVENUE P.O. B0x 16C08 RICHMOND, VA 23222 02/26/85 (1) DEPT OF ENERGY SAVANNAH RIVER OPERATION P.O. B0x A AIKEN, SC 29802 03/05/85 (1) AMERSHAM CORP. 2636 CLEARBROOK DRIVE ARLINGTON HEIGHTS, IL 60005 03/05/85 (1) AMEPSHAM CORP.

           .               2636 CLEARBROOK DRIVE ARLINGTON HEIGHTS, IL   60005 03/05/85         (1)      AMERSHAM CORP.

2636 CLEARBROOK DRIVE ARLINGTON HEIGHTS, IL 60005 03/12/85 (1) AMERSHAM COPP. 2636 CLEARBROOK DRIVE ARLINGTON HEIGHTS, IL 60005 03/12/85 (1) SEAMAN NUCLEAR OAK CREEK, WS 53154 03/20/85 (1) THE 5-4-3 COMPANY MORGANTOWN, WV 65006 03/27/85 (1) COALSCAN YORK, PA 17403 03/28/85 (1) STATE PROGRAMS FOR THE STATE OF FLORIDA 1

1 l 1 CUESTION 16. (A) REGARDING PEACTOR FIRE PROTECTION AND THE

       ~~

ASSOCIATED RULEMAKING, PLEASE INDICATE THE ~ ~ ~ DATE THE PROBLEM WAS FIRST IDENTIFIED, ITS SAFETY SIGNIFICANCE, ANY DEADLINES (S) FOR - COMPLIANCE AND ALL PLANTS NOT IN COMPLIANCE AT THE TIME OF THE DEADLINE (S). ANSWER: THE BASIC REQUIREMENT FOR PLANTS TO BE DESIGNED TO INCORPORATE

                                                                             ~

FIRE PROTECTION FEATURES WAS FIRST CODIFIED IN 1971 IN GENERAL DESIGN CRITERION 3 IN 10 CFR PART 50. FOLLOWING THE FIRE AT THE BROWNS FERRY PLANT IN MARCH 1975, THE OFFICE OF INSPECTION AND ENFORCEMENT SENT SPECIAL BULLETINS TO ALL LICENSEES OF OPERATING REACTORS ON MARCH 24, 1975 AND APRIL 3, 1975. WTTH RESPECT TO SAFETY SIGNIFICANCE FIRE FROTECTION IS A PROGRAM WHICH INCLUDES PASSIVE FEATURES SUCH AS BARRIERS AND SEPARATION, ACTIVE FEATURES SUCH AS DETECTION AND SUPPRESSION, ADMINISTRATIVE PROCEDURES, TRAINING, AND QUALITY ASSURANCE. THERE IS M0 IN- - DZYIDUAL ITEM IN THE FIRE PROTECTION GUIDELINES DISCUSSED BELOW THAT BY ITSELF HAS A SIGNIFICANT SAFETY SIGNIFICANCE--BECAUSE THE FIRE PROTECTION PROGRAM IS' BASED ON " DEFENSE-IN-DEPTH." ALTHOUGH ALL PLANTS HAVE NOT IMPLEMENTED COMPLETELY THE NECESSARY FIRE PROTECTION PROGRAM, EACH AND EVERY PLANT HAS MADE MODIFICATIONS

   'WHfCH SIGNIFICANTLY IMPROVED THE LEVEL OF FIRE PROTECTION.      IN

QUESTION 16(A) (CONTINUED) '

          ' VIEW 0F THE ADDITIONAL IMPROVEMENTS IN FIRE SAFETY MADE IN
       ' -OPERATING POWEP PLANTS SINCE THE BPOWNS FERRY FIRE, THE INTER!M
         ~ PRECAUTIONS TAKEN SUCH AS INSTITUTING FIRE WATCHis AND EMCCCENCY PROCEDURES, COUPLED WITH THE CURRENT FIRE PROTECTION ACTION PLAN,
         . ASSURE THAT PLANTS CAN CONTINUE TO OPERATE WITHOUT UNDUE RISK TO i            THE PUBLIC HEALTH AND SAFETY.

1 IN MARCH 1976, THE NRC ISSUED IMPROVED GUIDELINES FOR FIRE

   ~

PROTECTION FOR NEW PLANTS IN THE FORM OF BRANCH TECHNICAL POSITION (BTR) APCSB 9.5-1. IN AUGUST 1976, FIRE PROTECTION GUIDELINES F'R OPERATING PL' ANTS WERE ISSUED IN APPENDIX A TO BTP APSCB 9.5-1, AND

       ~ NRC INITIATED A REVIEW OF FIRE PROTECTION PROGRAMS AT ALL OPERATING PLANTS.- AS A PESULT, THE LICENSEES PROPOSED FACILITY i            MODIFICATIONS TO MEET THE NRC GUIDELINES.      OUR ORIGINAL SCHEDULE WAS TO COMPLETE THE NRR STAFF-REVIEW OF THE UTILITY RESPONSES TO
          .THE 1976~ GUIDELINES BY APRIL 1979 AND HAVE THE LICENSEES COMPLETE l ~~       THEIR COMPLIANCE WITH THE IMPROVED GUIDELINES BY OCTOBER 1980.

THE STAFF DID COMPLETE THEIR EVALUATION OF THESE PROPOSED MODIFICATIONS BY THE END OF 1979. AT THAT TIME, 15 FIRE b PROTECTION ISSUES REMAINED UNRESOLVED WITH SEVERAL LICENSEES. 4 THE NRC'S REQUIREMENTS TO RESOLVE THESE ITEMS WERE PUBLISHED AS  : APPENDIX R TO 10 CFR 50, WHICH BECAME EFFECTIVE IN FEBRUARY 1981. l

          'IHE SCHEDULE FOR IMPLEMENTING THESE REQUIREMENTS WAS SPECIFIED IN SECTION 50.48 0F 10 CFR 90. THIS SCHEDULE ALLOWED TIME TO COM-         )

PLETE THE REQUIRED ACTIONS ACCOPDING TO THE FEATURE REQUIRING ) l s- _

QUESTTON 16(A) (CONTINUED) ' CHANGE,' FOR EXAMPLE, THE FULE REQUIRED ONLY 30 DAYS TO IMPLEMENT ADMINISTRATIVE CONTROLS. ON THE OTHER HAND KEY FEATURES SUCH AS

 ' - AL'TERNATIVE SHUTDOWN CAPABILITY WERE ALLOWED UNTIL THE FIRST

SUBSEQUENT SHUTDOWN OF SUFFICIENT DURATION WHICH COMMENCES MORE THAN 180 DAYS AFTER STAFF APPROVAL, A NUMBER OF LICENSEES ARE CONTINUING TO EVALUATE AND IMPROVE PLANT THE FIRE PROTECTION FOR SHUTDOWN CAPABILITIES. IHE PRESENT SCHEDULE CONTEMPLATES THAT-THE LICENSEE AND STAFF REVIEWS WILL BE COMPLETED BY THE END OF 1985. MANY PLANTS WILL REQUIRE SOME ADDITIONAL MODIFICATIONS TO COMPLETE COMPLIANCE WITH APPENDIX R, lE.G., FIXED FIRE SUPPRESSION 3YSTEM, FIRE BARRIERS BETWEEN REDUNDANT SHUTDOWN SYSTEMS AND ALTERNATIVE SHUTDOWN SYSTEMS IN SOME LOCATIONS, SUCH MODIFICATIONS MAY REQUIRE UP T. SEVEPAL YEARS TO COMPLETE IN AN ORDERLY FASHION, AS NOTED ABOVE, COM-PENSATORY MEASURES WILL REMAIN IN EFFECT DURING THIS PERIOD.

OUR CURRENT SCHEDULE IS BASED ON LICENSEES' REQUEST FOR SCHEDULAR RELIEF.AS PERMITTED BY THE RULE, OF THE 68 PLANTS AFFECTED BY I PARAGRAPH 50,48, APPROXIMATELY 38 UNITS HAVE NOT MET THEIR - ORIGINAL SCHEDULES, l l l l l l

l l I QUESTION 16B. LIST SEPARATELY THOSE PLANTS THAT ARE IN FULL COMPLIANCE WITH APPLICABLE FIRE PROTECTION REG-ULATIONS (E.G., APPENDIX R), AND THOSE THAT ARE

   ~

NOT. FOR THOSE PLANTS NOT'IN FULL COMPLIANCEi LIST ANY RESULTING ENFORCEMENT ACTIONS AND EXPLAIN THE TECHNICAL BASIS FOR CONTINUED OPERATION. ADDITIONALLY, PLEASE ENUMERATE BY - ~ ~ PLANT AND DATE ALL AMENDMENTS OR EXEMPTIONS REQUESTED OR GRANTED. ANSWER.

                 ~

A REACTOR PLANT IN COMPLIANCE WITH APPENDIX R WOULD HAVE COMPLETED ALL NECESSARY MODIFICATIONS, PROCEDURAL CHANGES AND ASSOCIATED TRAINING, AND WOULD HAVE RECEIVED APPROPRIATE CONFIGURATIONAL - EXEMPTIONS. REACTOR FICILITIES LICENSED PRIOR TO JANUARY 1, 1979 ARE SUBJECT - TO 10 CFR 50, APPENDIX R AS SPECIFIED IN 10 CFR 50.48. THESE PLANTS HAVE UNDERGONE DETAILED STAFF PEVIEW 0F THEIP SUBMITTALS SHOWING' COMPLIANCE WITH APPENDIX R AND HAVE HAD THE OPPORTUNITY TO REQUEST EXEMPTIONS. IN MANY CASES EXEMPTIONS FROM THE REQUIRE-

           ~   ~

MENTS 0F APPENDIX R HAVE BEEN GRANTED BASED UPON A SHOWING THAT DUE TO' PLANT SPECIFIC DESIGN, THE REQUIRED MODIFICATION WOULD NOT 1 l l

QUESTION 16B. (CONTINUED) ' - ENHANCE FIRE PROTECTION SAFETY IN THE FACILITY OR THAT SUCH MODI-FICATIONS.MAY BE DETRIMENTAL TO OVERALL FACILITY SAFETY. WHEN SAFETY EVALUATION REPORTS HAVE BEEN ISSUED AND REQUIRED PLANT MODIFICATIONS HAVE BEEN COMPLETED, COMPLIANCE INSPECTION SITE VISITS ARE CONDUCTED. TEN (10) SUCH INSPECTION SITE VISITS HAVE BEEN CONDUCTED SINCE 1982: D.C. COOK 1/2, FT CALHOUN, TROJAN, DAVIS-BESSE, FT. ST. VRAIN, VERMONT YANKEE, SALEM 1, CALVERT CLIFFS 1/2, MAINE YANKEE AND NINE MILE POINT 1. - 4 l RESULTS OF THE REGIONALLY CONDUCTED INSPECTIONS HAVE VARIED. .

i. OF THE TEN INSPECTED PLANTS THAT HAD RECEIVED THEIR LICENSE PRIOR TO 1979 TWO (2) FACILITIES WERE FOUND TO BE IN FULL COMPLIANCE WITH APPENDIX R. THESE WERE CALVERT CLIFFS 1/2 AND NINE MILE l

i POINT 1. IN ADDITION, MAINE YANKEE HAD ONLY ONE CONFIGURATION THAT REQUIRED ADDITIONAL MODIFICATION TO ACHIEVE COMPLIANCE. -AT EACH OF THE REMAINING SEVEN (7) REACTOR FACILITIES, THE INSPEC-T10NS RESULTED IN SOME FINDINGS-OF NONCOMPLIANCE OR LISTS OF OPEN ITEMS. SECY-84-77 0F FEBRUARY 14, 1984'(ATTACHED) DISCUSSES THE ] RESULTS OF THE FIRST SEVEN INSPECTION SITE VISITS. . WITH REGARD TO 8 PPE-1979 FACILITIES NOT IN FULL COMPLIANCE, DEFICIENCIES OR - NONCOMPLIANCES WERE FOUND IN PARTICULAR AREAS. IN THE MAIN, HOWEVER, EACH OF THESE FACILITIES HAD IMPLEMENTED MAJOR PORTIONS - l 1 l i l

                               ._     -          _  _ . , . . . ~ .      ___ ._

QUESTION 16B. (CONTINUED) - 0F THE FIRE PROTECTION RULE OR WERE OBTAINING EXEMPTIONS FOR SPECIFIC SITUATIONS.

     - IT IS BECAUSE OF THESE VARYING PRE-1979 LICENSE INSPECTION RE-SULTS THAT THE NRC CONDUCTED A SERIES OF POST-FIRE SAFE SHUTDOWN WORKSHOPS FOR ALL LICENSEES. IN THESE OPEN MEETINGS THE NRC STAFF PROVIDED INFORMATION TO ASSIST LICENSEES IN THEIR EFFORTS TO ACHIEVE THE POST-FIRE SAFE SHUTDOWN CAPABILITY REQUIRED BY APPENDIX R.

FOR TWO PRE-1979 FACILITIES INSPECTED, ENFORCEMENT ACTION WAS TAKEN' BASED UPON THE RESULTS OF THE INSPECTION. PORTLAND GENERAL EL5CTRIC WAS FINED $50,000 FOR VIOLATIONS IDENTIFIED AT TROJAN. A NOTICE OF VIOLATION WAS ISSUED FOR SEVERITY LEVEL ~IV VIOLATIONS

       ' IDENTIFIED AT FORT CALHOUN. FOR FIVE OTHER CASES, ENFORCEMENT a        ACTION IS STILL UNDER CONSIDERATION AND WILL FOLLOW ISSUANCE OF            -

THE' ADDITIONAL CLARIFYING GUIDANCE ON IMPLEMENTATION OF APPENDIX R. THE TECHNICAL BASIS FOR CONTINUED OPERATION ~IS THE DEFENSE IN - DEPTH AS DISCUSSED IN RESPONS TO QUESTION 16(A).

QUESTION 16B. (CONTINUED) ~ THE FOL' LOWING FACILITIES WERE LICENSED SINCE THE TMI ACCIDENT.ON THE BASIS THAT THEY MEET APPENDIX R. SEQUOYAH 1/2 NORTH ANNA 2 FARLEY 2 MCGUIRE 1/2 SAN ONOFRE 2/3 LASALLE 1/2 _ GRAND GULF 1 SUSQUEHANNA 1/2 SUMMER ST. LUCIE 2 WNP-2 DIABLO CANYON 1 CALLAWAY l LIMERICK 1 BYRON 1 CATAWBA 1 SHOREHAM WATERFORD 3 PALO VERDE 1 WOLF CREEK FERMI-2

QUESTTON 16B, (CONTINUED) .

 ' REACTOR PLANTS LICENSED AFTER JANUARY 1, 1979 FALL INTO TWO CATE-GORIES:   THOSE FACILITIES INSPECTED AS NT0LS (PRIOR TO ISSUANCE OF THEIR OPERATING LICENSE), AND THOSE INSPECTED SUBSEQUENT TO 4
  -lSSUANCE OF THEIR OPERATING LICENSE. FOURTEEN NTOLS HAVE BEEN INSPECTED TO DATE,    FIVE FACILITIES ARE CURRENTLY IN FULL COMPLI-ANCE WITH THE FIRE PROTECTION REQUIREMENTS OF THEIR OPERATING LfCENSES. FOUR FACILITIES ARE NOW OPERATING UNDER SHORT TERM LlCENSE CONDITIONS REQUIRING INTERIM COMPENSATORY MEASURES UNTIL MODIFICATIONS HAVE BEEN COMPLETED,      FIVE FACILITIES REMAIN IN AN 1

NT0L STATUS AND WILL REQUIRE REINSPECTION TO VERIFY COMPLIANCE WITH FIRE PROTECTION REQUIREMENTS, 4 FOUR OPERATING POST-1979 LICENSEES HAVE BEEN INSPECTED TO DATE. TWO FACILITIES ARE IN FULL COMPLIANCE. OF THE TWO FACILITIES NOT IN FULL COMPLIANCE, ONE IS CURRENTLY BEING CONSIDERED FOR

 ~ ENFORCEMENT. THE OTHER FACILITY RECENTLY UNDERWENT ITS INSPEC-TION SITE VISIT, AND WAS NOT FOUND TO BE IN FULL COMPLIANCE,

> THEREFORE, ENFORCEMENT ACTION IS A POSSIBILITY, WE ARE DEVELOPING A LIST ENUMERATING BY PLANT THE DATE EACH EXEMPTION WAS GRANTED AND THE DATE EXEMPTIONS WERE REQUESTED FOR EXEMPTIONS STILL UNDER REVIEW. WE WILL PROVIDE THIS LIST AS SOON AS POSSIBLE. l l

CUESTION 16 (C). (C) STATE WHAT REQUIREMENTS APPLY TO PLANTS LICENSED AFTER JANUARY 1979,

                                     ~
                            -                                                     AND IF DIFFERENT THAN PLANTS LICENSED
                              ~'

BEFORE THIS DATE, EXPLAIN THE TECHNICAL BASIS FOR THIS POLICY. ANSWER. PLANTS LICENSED PRIOR TO JANUARY 1, 1979 ARE SUBJECT TO A BRANCH POSITION (APPENDIX A TO BRANCH TECHNICAL POSITION APCSC 9.5-1) AND TO 10 CFR 50 (APPENDIX R), FOR THESE PLANTS, APPENDIX R APPLIES AS A REGULATION. PROVISION IS MADE IN 10 CFR 50.48 FOR EXEMPTIONS TO BE GRANTED FOR FEATURES REQUIRED BY APPENDIX R THAT WOULD EITHER NOT ENHANCE FIRE PROTECTION SAFETY OR WOULD BE DETRIMENTAL TO OVERALL FACILITY SAFETY. PLANTS LICENSED AFTER JANUARY 1, 1979 ARE SUBJECT TO ESSENTIAL-LY THE SAME TECHNICAL REQUIREMENTS AS PLANTS LICENSED BEFORE 1979. HOWEVER, THE FIRE PROTECTION PROVISIONS IN THE BRANCH POSITION

                                   ~

AND IN APPENDIX R HAVE BEEN INCORPORATED INTO ONE DOCUMENT--THE . STANDARD REVIEW PLAN (SRP) SECTION 9.5.1. FOR THESE PLANTS, WHERE DEVIATIONS FROM THE SRP GUIDELINES ARE REQUESTED, ADEQUATE JUSTIFICATION MUST BE PROVIDED FOR STAFF REVIEW TO ESTABLISH AN EQUIVALENT LEVEL OF PROTECTION AS PROVIDED BY THE SRP. _ - - - _ - _ - - - - - - - ---------_____--_------__----------_-__1-_ _ - _ _ _ - - - - - - _ _ - _ - - _ _ - - - - _ - _ - _ _ _ -

i i l QUESTION 16 (C) (CONTINUED) .- . . - - 2 THE STAFF REVIEW IS INTENDED TO ESTABLISH AN EQUIVALENT LEVEL j OF SAFETY FOR EITHER SET OF PLANTS. APPENDIX R TO 10 CFR 50 WAS ISSUED TO RESOLVE OPEN ITEMS IN THE REVIEWS BEING PERFORMED BY THE STAFF USING THE GUIDANCE IN APPENDIX A TO THE EPANCH i j' TECHNICAL POSITION, AND PROVIDES DETAILED ACCEPTANCE CRITEPIA FOR CERTAIN FIRE PROTECTION FEATURES SPECIFIED IN APPENDIX A. DURING THE RULEMAKING PROCESS, THE COMMISSION CONSIDERED MAKING APPENDIX R APPLICABLE TO ALL PLANTS AS A REGULATION AND LATER

!      CONSIDERED ISSUING A MORE COMPREHENSIVE RULE FOR NEW PLANTS.

SUBSEQUENTLY, THE COMMISSION DECIDED THAT THE FIRE PROTECTION GUIDANCE FOR PLANTS LICENSED AFTER JANUARY 1979 SHOULD REMAIN IN THE SRP TO GIVE THE STAFF AND APPLICANTS FLEXIBILITY IN SELECTING ALTERNATIVE MEANS OF MEETING THE NRC'S FIRE PRO-TECTION OBJECTIVES (SECY-84-24), 4 I i i i l i i l i 4

QUESTION 17. (A) REGARDING REACTOR ENVIRONMENTAL QUALIFI- ~ CATION PLEASE INDICATE THE DATE THE PROBLEM

   ~

WAS FIRST IDENTIFIED, ITS SAFETY SIGNIFICANCE, ANY DEADLINE (S) FOR COMPLIANCE AND ALL PLANTS

 '     ~

NOT IN COMPLIANCE AT THE TIME OF THE DEADLINE (S). ANSWER, THE BASIC REQUIREMENT FOR EQUIPMENT TO BE QUALIFIED FOR THE ENVIRONMENTAL CONDITIONS ASSOCIATED WITH ACCIDENT CONDITIONS WAS

             ~  ~

FlRST C0DIFIED IN 1971 IN GENERAL DESIGN CRITERION 4 IN 10 CFR 50. [N RESPONSE TO A NOVEMBER 4, 1977 PETITION FOR EMERGENCY AND REMEDIAL ACTION BY THE UNION OF CONCERNED SCIENTISTS, THE COMMISSION DIRECTED THE STAFF TO REVIEW AND EVALUATE THE ENVIRONMEtlTAL QUALIFICATION OF ALL CLASS IE ELECTRICAL EQUIPMENT. - THE NRC STAFF INITIATED THAT REVIEW BY REQUESTING LICENSEES TO DETERMINE THE ADEQUACY OF EXISTING DOCUMENTATION ON EQUIPMENT QUALIFICATION. CIRCULAR 78-08 AND IE BULLETINS 79-01 AND 79-01B WERE ISSUED TO REQUEST THE NECESSARY INFORMATION. STAFF'S REVIEWS OF LICENSEES' SUBMITTALS IN RESPONSE TO 79-01 AND 79-01B LED TO

   .THE DISCOVERY OF EQUIPMENT FOR WHICH QUALIFICATION HAD NOT BEEN ESTABLISHED.

1 BY COMMIS'SION MEMORANDUM AND ORDER, CLI-80-21, ISSUED ON MAY 23, l 1980r THE COMMISSION DENIED A SUBSEQUENT UCS PETITION, FINDING l

QUESTION 17(A) (CONTINUED) THAT " CURRENT COMMISSION REQUIREMENTS , , , AND THOSE ACTIONS WE ORDER TODAY PROVIDE REASONABLE ASSURANCE THAT THE PUBLIC HEALTH AND SAFETY'IS BEING ADEQUATELY PROTECTED DURING THE TIME NECESSARY

 . FOR CORRECTIVE ACTION "     AMONG THE ACTIONS ORDERED BY THE COMMISSION WERE: (1) THE ESTABLISHMENT OF MORE SPECIFIC ENVIRONMENTAL QUALIFICATION CRITERIA; AND (2) THE ESTABLISHMENT OF A JUNE 30, 1982 DEADLINE FOR COMPLETION BY THE LICENSEES OF THE ENVIRONMENTAL QUALIFICATION PROGRAM.

THE~ VOLUME OF THE SUBMITTALS BY THE LICENSEES SHOWED THAT THE EXTENT OF THE EFFORT NECESSARY EITHER TO ESTABLISH THE 00hLIFI-CATION OF EQUIPMENT OR TO REPLACE UNQUALIFIED EQUIPMENT HAD BEEN - UNDERESTIMATED AND THAT THE JUNE 30, 1982 DEADLINE WOULD NOT BE MET. THE COMMISSION PROPOSED TO EXTEND THE DEADLINE IN THE NRC'S PROPOSED RUL'E ON ENVIRONMENTAL QUALIFICATION PUBLISHED FOR COMMENT ON JANUARY 20, 1982. IN THE RULE THE COMMISSION PROPOSED TO CCDIFY THE' ENVIRONMENTAL QUALIFICATION REQUIREMENTS SET 0UT IN THE EXISTING ORDER, CLI-80-21. IN LATE MAY OF 1982-IT BECAME CLEAR TO THE COMMISSION THAT, DESPITE EFFORTS BY THE STAFF, THE FINAL RULE WOULD NOT BE PROMULGATED BEFORE THE JUNE 30, 1982 DEADLINE. ACCORDINGLY, ON JUNE 30, 1982, THE COMMISSION ISSUED AN IMMEDIATELY EFFECTIVE RULE SUSPENDING THE JUNE 30, 1982 COMPLIANCE DEADLINE INCORPORATED IN EACH OPERATING LICENSE (0L) THEN IN - FORCE, _.1 -_w

QUESTf0N 17(A) (CONTINUED) ON JANUARY 6, 1983 THE COMMISSION PPOMULGATED A FINAL RULE ON

          ~

ENvI'RONMENTAL QUALIFICATION OF ELECTRICAL EQUIPMENT IMPOPTANT TO SAFET'Y, 10 CFR 50.49. THAT RULE ESTABLISHED GENERAL QUALIFICATION REQUIREMENTS AND NEW DEADLINES FOR COMPLIANCE. THE NEW DEADLINES ' ~ WERE ESTABLISHED AS THE SECOND REFUELING OUTAGE AFTER MARCH 31~, 1982 OR MARCH 31, 1985, WHICHEVER IS EARLIER. THE RULE

            ~

ALSO STATES THAT THE DIRECTOR OF THE OFFICE OF NUCLEAR REACTOR REGUL'ATI~0tf MAY GRANT EXTENSIONS TO NOVEMBER 30, 1985, AND THAT THE

        ~

C0MMISSION ITSELF MAY GRANT EXTENSIONS BEYOND NOVEMBER 30, 1985. ~ ON JUNE 30, 1983, THE UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT INVALIDATED THE COMMISSION'S JUNE 30, 1982 ACTION DELETING THE JUNE 1982 DEADLINE FOR FAILURE TO PROVIDE PRIOR NOTICE AND AN OPPORTUNITY TO COMMENT. UNION OF CONCERNED SCIENTISTS V. NRC, 711 F.2D 370 (D.C. CIR. 1983). ON MARC'H 7, 1984, THE COMMISSION PUBLISHED A POLICY STATEMENT IN WHICH IT DECLARED THAT BECAUSE THE JUNE 1982 DEADLINE HAD SERVED fTS PURPOSE OF ASSURING DILIGENT LICENSEE ACTION RELATIVE TO -

            ~

EQUIPMENT GUALIFICATION, THE JUNE 1982 DEADLINE WOULD NOT BE ENFORCED PENDING COMPLETION OF A SIMULTANEOUSLY INITIATED RULEMAKING TO DELETE THAT DEADLINE. ON NOVEMBER 19, 1984, THE l~ COMMISSION' AMENDED THE JANUARY 1983 FINAL RULE BY THE ADDITION OF A SENTENCE SPECIFICALLY STATING THAT THE JUNE 30, 1982 DEADLINE, OR ANY OTHER PREVIOUSLY IMPOSED DATE, FOR ENVIRONMENTAL QUALIFICATION OF ELECTRIC EQUIPMENT CONTAINED IN CERTAIN NUCLEAR POWER OPERATING LICENSES IS SUPERSEDED BY THE SCHEDULE GIVEN IN

QUESTION 17(A) (CONTINUED) THE FINAL RULE, THIS ACTION ALSO HAS BEEN CHALLENGED IN LITIGATION NOW FENDING IN THE DISTRICT OF COLUMBIA CIRCUIT. UNION OF CONCERNED SCIENTISTS V. NRC, NO, 841549 (D.C. CIR. FILED N0v, 5, 1984), ~ COMMISSIONER ASSELSTINE ADDS: ESTABLISHING THAT ELECTRICAL EQU~IPMENT IMPORTANT TO SAFETY WILL CPERATE IN HARSH ENVIRONMENTS IS NECESSARY TO ENSURE THAT DESIGN BASIS ACCIDENTS DO NOT PROGRESS 1 TO ~A SITUATION IN WHICH UNACCEPTABLE RADI ATION DOSES TO THE PUBLIC ' OCCUR, AS DEFINED BY 10 CFR PART 100. UNFORTUNATELY, LIKE FIRE PROTECTION THIS IS ANOTHER EXAMPLE OF WHERE THE COMMISSION IS NOT VIGOROUSLY ENFORCING ITS REGULATIONS, IT IS WORTH NOTING THAT THE COMMISSION'S FIRE PROTECTION AND ENVIRONMENTAL QUALIFICATIONS REQUIREMENTS, TOGETHER WITH THE TMI LESSONS LEARNED, ARE THE PRINCIPAL SOURCES OF PLANT BACKFITS WHICH ARE THE SOURCE OF CURRENT INDUSTRY OBJECTIONS, CHAIRMAN PALLADINO ADDS: I BELIEVE THAT THE NRC IS, IN FACT, ENFORCING ITS ELECTRICAL EQUIPMENT GUALIFICATION REGULATIONS. AT A RECENT COMMISSION MEETING THE STAFF INFORMED THE COMMISSION - THAT 39 PLANTS HAD COMPLETED ENVIRONMENTAL QUALIFICATION BY MARCH 30, 1985, FURTHERMORE, THE REMAINING 53 PLANTS HAD - COMMITTED TO FINALIZING ENVIRONMENTAL QUALIFICATIONS PRIOR TO THE 10 CFR 50,49 DEADLINE OF NOVEMBER ?l, 1985, OF THESE 53 PLANTS, 7 HAVE A' LARGE NUMBER OF OUTFTP );" ITEMS. THE STAFF MET WITH LICENSEE MANAGEMENT FOR THESE PLAN.S AND FORMAL COMMITMENTS WERE

QUESTION 17(A) (CONTINUED) - 5-RE'CEIVED' TO COMPLETE ENVIRONMENTAL QUALIFICATION SY N0vEMBER 30, i 1985.~ THE COMMISSION IS CONSIDERING VARIOUS ENFORCEMENT ACTIONS

              ~

FOR USE~IN THE EVENT THESE COMMITMENTS ARE NOT MET. I PROF 0SE

       ~THAT THE COMMISSION ADVISE LICENSEES OF COMMISSION INTENTIONS IN
      ~ THE NEAR~ FUTURE. THUS, LICENSEES WOULD HAVE SUFFICIENT ADVANCE   _

NOTIFICATION OF THE COMMISSION'S INTENDED ACTI'ONS. l l k

QUESTION 17 (CONTtNUED) I QUESTION 17. (B) SPECIFICALLY WHAT PLANTS WILL NOT MEET THE r COMMISSION'S MARCH 31, 1985 DEADLINE. LIST

                      ~

SEPARATELY THOSE PLANTS, BOTH OPERATING AND _ THOSE UNDER CONSTRUCTION, THAT ARE IN FULL COMPLIANCE WITH APPLICABLE ENVIRONMENTAL )

    ~~

QUALIFICATION REQUIREMENTS AND STANDARDS AND THOSE THAT APE NOT.

       +

ANSWER. . OUT OF A TOTAL 93 OPERATING REACTORS: 42~ PLANTS HAVE MET THE MARCH 31, 1985 DEADLINE FOR COMPLETION OF ENVIRONMENTAL QUALIFICATION, OR DID NOT REQUEST AN EXTENSION, 6 PLANT HAVE BEEN LICENSED WITH A NOVEMBER 30, 1985 DEADLINE, AND ' 45 PLANTS HAVE BEEN GRANTED AN EXTENSION BEYOND THE MARCH 31. 1985 DEADLINE TO NOVEMBER 30, 1985 FOR SPECIFIC PIECES OF' EQUIPMENT. i EVEN THOUGH EXTENSIONS TO THE DEADLINE HAVE BEEN GRANTED, ALL PLANTS ~.

   . 'ARE IN COMPLIANCE WITH APPLICABLE ENVIRONMENTAL QUALIFICATION
   ~

REQUIREMENTS. AN EXTENSION FOR COMPLETION IS SPECIFICALLY ALLOWED

                                                                                  ~

BY 10 CFR 50.49, THE FINAL RULE ON ENVIRONMENTAL QUALIFICATION. L

QUESTION 17 (CONTINUED) .

WLTH THE POSSIBLE EXCEPTION OF 2 PLANTS, HADDAM NECK AND

   ~ ~

MILLSTONE 1, ALL LICENSES ARE SCHEDULED TO COMPLETE ENVIRONMENTAL QUALIFICATION BY NOVEMBER 30, 1985. THE STAFF REVIEW IS FOCUSING ON THOSE PLANTS WITH THE LARGEST NUMBER OF COMPONENTS TO BE QUALIFIED,

.                THE PLANTS THAT HAVE MET THE MARCH 31, 1985' DEADLINE FOR COMPLETION ~
   ~-

0F ENVIRONMENTAL QUALIFICATIONS, OR DID NOT REQUEST AN EXTENSION, ARE: ARKANSAS 1, 2 BRUNSWICK 1 BP.0WNS FERRY 1, 2 CATAWBA 1 4 CRYSTAL RIVER 3 DAVIS-BESSE 1 DIABLO CANYON 1 DRESDEN 2 DUANE ARNOLD FARLEY 2 FITZPATRICK FORT ST, VRAIN GINNA INDIAN POINT 2 KEWAUNEE

00ESTf0N 17 (CONTINUED) . l LACROSSE j LIMERICK 1 MAINE YANKEE MCGUIRE 1, 2 1 MILLSTONE 2 OCONEE 1, 2, 3 . PRAIRIE ISLAND 1 QUAD CITIES 2 2

RANCHO SECO i ROBINSON l SALEM 1, 2 i SAN ONOFRE 2, 3

, ST. LUCIE 1, 2 I ' SUMMER 1 i ! SURRY 2 TURKEY POINT 3, 4 ~ YANKEE R0WE  : j ZION 1 I I i 4 I i

QUESTTON 17 (CONTINUED) _ . THE PLANTS FOR WHICH AN EXTENSION TO NOVEMBER 30, 1985, OR AN

                ' EARLIER DEADLINE AS SHOWN, HAS BEEN GRANTED FOR SPECIFIC PIECES OF EQUIPMENT ARE:

BEAVER VALLEY l BRUNSWICK 2 CALVERT CLIFFS 1 (APRIL 5 AND 30, 1985) CALVERT CLIFFS 2 (APRIL 30, 1985) COOK 1, 2 DRESDEN 3 FARLEY l HATCH 1, 2 INDIAN POINT 3 NINE MILE POINT l' PALISADES POINT BEACH 1, 2 (JUNE 7, 1985) - CUAD CITIES 1 SAN ONOFRE 1 SEQUOYAH 1, 2 TROJAN VERMONT YANKEE ZION 2 BIG ROCK POINT BROWNS FERRY 3 A__.___m- _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ e .

0 QUESTION 17 (CONTINUED) ' CALLAWAY l COOPER FORT CALHOUN GRAND GULF 1 HADDAM NECK LASALLE 1, 2 MILLSTONE 1 MONTICELLO 1 NORTH ANNE 1, 2 OYSTER CREEK PEACH BOTTOM 2, 3 PILGRIM PRAIRIE ISLAND b, SURRY l SUSQUEHANNA 1, 2 THREE MILE ISLAND 1

WNP-2 (APRIL 30 AND N0vEMBER 30, 1985) .

i THE EXTENT OF CONFORMANCE OF PLANTS UNDER CONSTRUCTION IS DETERMINED ON AN INDIVIDUAL BASIS BY REVIEWING THE QUALIFICATION

            ~

PROGRAM FOR THESE PLANTS AS PART OF THE LICENSING PROCESS, PRIOR TO ISSUANCE OF AN OPERATING LICENSE EACH APPLICANT MUST DEMONSTRATE CONFORMANCE TO ALL APPLICABLE REGULATIONS. i

l

                                                                                                  ~

OVESTION 17 (CONTINUED) l FOR THOSE PLANTS NOT IN FULL COMPLIANCE, PLEASE (C)

         -    -        LIST ANY RESULTING ENFORCEMENT ACTIONS AND EXPLAIN

! THE TECHNICAL BASIS FOR CONTINUED OPERATION. l l ANSWER. ._ L AS OF THIS TIME NO ENFORCEMENT ACTIONS HAVE RESULTED. IN i FIVE~ INSTANCES SCHEDULAR RELIEF REQUESTS WERE RECEIVED BY THE . !' STAFF AFTER A LICENSEE'S SCHEDULAR DEADLINE HAD EXPIRED. THE STAFF IS IN THE PROCESS OF DEVELOPING APPROPRIATE PROPOSED ENFORCEMENT OPTIONS FOR CASES INVOLVING FAILURE TO MEET EQUIPMENT QUALIFICATION DEADLINES. THE CONTINUED OPERATION OF PLANTS NOT IN FULL COMPLIANCE IS BASED ON THE' SUBMITTAL AND STAFF REVIEW OF AN ACCEPTABLE JUSTIFICATION FOR CONTINUED OR INTERIM OPERATION FOR EACH EQUIPMENT ITEM NOT FULLY QUALIFIED l THE ACCEPTABILITY OF THE JUSTIFICATION FOR THE MAJORITY - 0F OPERATING PLANTS IS BASED ON THE FOLLOWING CONSIDERATIONS: . A. THE SAFETY FUNCTION CAN BE ACCOMPLISHED BY SOME OTHER DESIGNATED EQUIPMENT THAT IS QUALIFIED, AND: FAILURE OF THE - PRINCIPAL EQUIPMENT AS A RESULT OF THE HARSH ENVIRONMENT WILL~ NOT DEGRADE OTHER SAFETY FUNCTIONS 07 MISLEAD THE OPERATOR.

QUESTION 17 (CONTINUED) B .~ ^ PARTIAL TEST DATA, ALTHOUGH INSUFFICIENT TO DEMONSTRATE FULL QUALIFICATION, PROVIDE A BASIS FOR CONCLUDING THE EQUIPMENT WILL PERFORM THE REQUIRED SAFETY FUNCTION. IF AVAILABLE' PARTIAL DATA ARE INSUFFICIENT TO DEMONSTRATE THAT AN ITEM OF

       ~

EQUIPMENT WILL REMAIN FUNCTIONAL, AFTER PERFORMING THE - REQUIRED SAFETY FUNCTION, THE PRESUMED FAILURE MUST NOT RESULT IN SIGNIFICANT DEGRADATION OF ANY SAFETY FUNCTION OR PROVIDE MISLEADING INFORMATION TO THE OPERATOR. I C. PERFORMANCE OF THE REQUIRED SAFETY FUNCTION CAN BE ASSURED BY LIMITED USE OF ADMINISTRATIVE CONTROLS OVER EQUIPMENT THAT HAS NOT BEEN DEMONSTRATED TO BE FULLY QUALIFIED. FOR ANY EQUIPMENT ASSUMED TO FAIL AS A RESULT OF THE ACCIDENT ENVIRONMENT, THAT FAILURE MUST NOT RESULT IN A SIGNIFICANT DEGRADATION OF ANY SAFETY FUNCTION OR PROVIDE MISLEADING INFORMATION TO THE OPERATOR. THE'ABOVE CRITERIA CONTAIN ESSENTIALLY THE $AME ELEMENTS THAT ARE REQUIRED BY 10 CFR 50.49(I), WHICH APPLIES TO LICENSE a APPLICANTS. FOR THOSE OPERATING PLANTS THAT WEPE LICENSED-SUBSEQUENT TO THE EFFECTIVE DATE OF 10 CFR 50.49, AND FOR'SOME

 ~0PERATING PL.4NTS LICENSED PRIOR TO THAT DATE, THE JUSTIFICATIONS ARE BASED ON THE CONSIDERATIONS OF 10 CFR 50.49(I),

i ___________u________._____________________________.

QUESTION 17 (CONTfNUED) ' (D) PLEASE ENUMERATE BY PLANT AND DATE ALL AMENDMENTS REQUESTED AND OR GRANTED, ANSWER, WE ARE DEVELOPING A LIST ENUMERATING SY PLANT THE SCHEDULAR -- EXTENSIONS REQUESTED,- THE DATE OF THE REQUEST, THE LENGTH OF

                                                                      ~~

EXTENSION IF GRANTED, AND THE DATE THE EXTENSION WAS APPROVED._ WE WILL PROVIDE THIS LIST AS SOON AS POSSIBLE. l o

OVESTION 17 (CONT!NUED)  ; -

                    ~(E)  ADDITIONALLY, EXPLAIN WHAT ASSURANCE NRC HAS THAT ALL EQUIPMENT WITH THE POTENTIAL TO BE EXPOSED GP
    .:                    EFFECTED BY A HARSH ENVIRONMENT HAS BEEN
                                      ~

I IDENTIFIED. ANSWER. 1 10 CFR 50.49 (B) DEFINES THE CATEGORIES OF EQUIPMENT THAT MUST BE INCLUDED IN THE ENVIRONMENTAL QUALIFICATION PROGRAM. THE i DEVELOPMENT OF THE EQUIPMENT LISTS BY THE LICENSEES WAS BASED ON i THEIR REVIEWS OF THE FINAL SAFETY ANALYSIS REPORT (FSAR), THE TECHNICAL SPECIFICATIONS, EMERGENCY OPERATING PROCEDURES, PIPING l AND INSTRUMENTATION DIAGRAMS (P8 IDS), AND. ELECTRICAL DISTRIBUTION DIAGRAMS. THE STAFF PERFORMED A SYSTEMATIC REVIEW OF THE METHODS

• USED BY THE LICENSEES FOR EACH TYPE OF EQUIPMENT COVERED BY THE RULE.

THE CRITERIA USED FOR THIS EVALUATION REQUIRED THAT THE POSTULATED EVENTS LISTED IN THE APPROVED FSAR BE USED AS THE - ! BASIS TO IDENTIFY SYSTEMS THAT HAVE A SAFETY-RELATED FUNCTION OR SUPPORT A SAFETY-RELATED FUNCTION. FURTHER ASSURANCE THAT THE i, LfCENSEE ESTABLISHED A COMPLETE LISTING OF EQUIPMENT AS REQUIRED f BY-10 CFR_50.49 WAS OBTAINED BY COMPARING A STAFF-GENERATED GENERIC MASTER LIST OF REQUIRED SYSTEMS AGAINST THE LICENSEE'S ~ GENERATED LIST OF SYSTEMS REQUIRED FOR ACCIDENT MITIGATION. . r

CUESTTON 17 (COMTINUED) _ . _, IN ADDITION, THE LICENSEES WERE REQUESTED TO COMPARE THE LIST OF 4

      -SYSTEMS IN THEIR QUALIFICATION PROGRAM WITH THE COMPREHENSIVE
  - - LIST ~OF SAFETY-RELATED SYSTEMS FOUND IN THEIR FSAR AND JUSTIFY
  - -AulY OMISSION FROM THE QUALIFICATION PROGRAM.          THE STAFF ALSO               :
    ' REVIEWED ~THE TOTAL NUMBEP AND TYPES OF COMPONENTS AND EQUIPMENT                   i i         AS COMPARED WITH OTHER PLANTS OF SIMILAR DESIGN AND VINTAGE.       IN j        -VIEW 0F THE METHODS USED BY THE LICENSEES TO ESTABLISH THESE LISTS AND THE REVIEW BY THE STAFF, THAT INCORPORATED MULTIPLE LAYERS OF' ASSURANCE AS DESCRIBED ABOVE, THE STAFF BELIEVES THAT 1 -       THERE IS'A HIGH DEGREE OF ASSURANCE THAT ALL EQUIPMENT WITHIN THE l

SCOPE OF 10 CFR 50.49 HAS BEEN IDENTIFIED. l a e a t

OVESTION 18, WHAT IS THE CURRENT STATUS OF THE TMI ACTt0N PLAN?

 ~

SPECIFICALLY: HOW MANY ACTION PLAN ITEMS ARE N0'

            ~

FULLY IMPLEMENTED; WHICH PLANTS ARE NOT CURRENTLY ! IN FULL COMPLIANCE WITH ALL APPLICABLE ACTION PLAN ITEMS; AND BY WHAT DATE DOES THE COMMISSION EXPECT THAT ALL ACTION PLAN ITEMS WILL BE FULLY IMPLEMENTED A7 ALL PLANTS? l ANSWER. THE TMI ACTION PLAN WAS DEVELOPED TO IMPROVE THE REGULATION AND OPERATION OF THE NUCLEAR POWER PLANTS. NUREG-0660, "NRC ACTION PLAN DEVELOPED AS A RESULT OF THE TMI-2 ACCIDENT," INCLUDED ALL l THE ACTIONS BEING CONSIDEPED FOR IMPLEMENTATION AND WAS ISSUED IN l MAY 1980. ! SUBSEOUENTLY, NUREG-0737, " CLARIFICATION OF TMI ACTt0N PLAN REQUIREMENTS," DATED NOVEMBEP 1980, INCCPPORATED AS A SUBSET 1 l THOSE NUREG-0660 !TEMS WHICH WERE APPROVED BY THE COMMISSION FCR IMPLEMENTATION AND ISSUED TO THE INDUSTRY AS REQUIREMENTS. SUPPLEMENT 1 TO NUREG-0737 WAS ISSUED DECEMBER 17, 1982 TO PROVIDE CLARIFICATION OF CERTAIN ITEMS IN NUREG-0737. THE ITEMS IN SUPPLEMENT 1 TO NUREG-0737 ARE ALSO REQUIREMENTS. THOSE TMI ACTION PLAN ITEMS WHICH WERE APPROVED FOR

   ~!MPLEMENTATION ARE BEING TRACKED FOR THE 65 REACTORS THAT WERE

4pM- -. +4_ 1,_-* 1,e-.- M4- - --Wha 2,. .._c--- -_J-++ _h3- _- -- LT-.u_4-uss-----+-+- e '

• 4

                                                                                                                                                                                                                                                                          -     _h  4-.- -

b+d-- --.+4 - ( i QUEST!0N 18 (CONTINUED) - 2-i i OPERATIONAL AT THE TIME OF THE TMI ACCIDENT. THE ACTION PLAN STEMS WERE SUBDIVIDED INTO 131 INDIVIDUAL LINE ITEMS WHICH ARE ~ BEING REVIEWED AGAINST ONE OR MORE FACILITIES. .THE PROGRESS OF IMPLEMENTATION OF THE 131 INDIVIDUAL LINE ITEMS IS REPORTED IN I TABLE Z OF NUREG-0748, "0PERATING REACTOR LICENSING ACT10NS l~

SUMMARY

." A REVIEW OF THE DATA CURPENTLY IN OUR TRACKING SYSTEM TNDICATES THAT APPROXIMATELY 95% OF THE NUREG-0737 ACTION PLAN ITEMS (EXCLUDING SUPPLEMENT 1) ARE COMPLETE FOR ALL PLANTS. MOST OF THE REMAINING EFFORT INVOLVES THE ITEMS WHICH RELATE TO THE l EMERGENCY RESPONSE CAPABILITY IDENTIFIED IN SUPPLEMENT 1 TO NUREG-0737. SCHEDULES FOR ALL REMAINING !TEMS HAVE BEEN  ; l NEGOTIATED WITH THE LICENSEES WITH COMPLET!ON DATES EXTENDING 2 INTO 1988. i i THOSE ISSUES STILL IN THE DEVELOPMENTAL PROCESS AS PART OF [ NUREG-0660 ARE DISCUSSED IN QUESTION 20.D WHICH ADDRESSES THE f HISTORY;"AND STATUS OF RESOLVED SAFETY ISSUES AND GENERIC SAFETY , ISSUES. i i i

i 2 OVESTION 19. WHAT IS THE CURRENT STATUS OF IMI CLEAN-UP AND !~ WHAT ARE THE COMMISSION'S VIEWS ON THIS SUBJECT? ] i { ANSWER.

DURING THE PAST YEAR, SEVERAL SIGNIFICANT CLEANUP ACTIONS WERE ACCOMPLISHED. FOLLOWING THE REFURBISHMENT AND LOAD TESTING OF i THE POLAR CRANE, THE REACTOR PRESSURE VESSEL HEAD WAS REMOVED ~

AND' SAFELY STORED IN THE REACTOR BUILDING. WITH THE REACTOR i' HEAD REMOVED, A DETAILED INSPECTION OF THE PLENUM WAS CONDUCTED. END FITTINGS, FUEL RODS AND OTHER DEBRIS ATTACHED ,

 ;       TO THE UNDERSIDE OF THE PLENUM AS A RESULT OF THE ACCIDENT-i        WERE REMOVED IN DECEMBER 1984.          THE PLENUM WAS SUCCESSFULLY
            ~

JACKED UPWARDS APPROXIMATELY SEVEN INCHES INDICATING THAT THE A VISUAL AND l PLENUM WAS NOT WEDGED IN THE REACTOR VESSEL.

                                                                                             ~

RADIOLOGICAL' EXAMINATION OF THE HIGHLY CONTAMINATED REACTOR j BUILDING BASEMENT WAS PERFORMED BY A REMOTELY OPERATED SURVEY VEHICLE. SAMPLES OF CORE DEBRIS HAVE UNDERGONE ANALYSIS AND A I VIDEO CAMERA INSPECTION INSIDE THE LOWER VESSEL HEAD AREA WAS

        'MADE TO ASSESS CORE DAMAGE.         AN AGGRESSIVE DOSE REDUCTION
]

i PROGRAM IS PROCEEDING TO REDUCE THE GENERAL AREA RADIATION LEVELS AND THEREBY REDUCE THE TOTAL-DOSE TO CLEANUP. WORKERS FOR THE REMAINING CLEANUP ACTIVITIES. l l

OUESTION 19 (CONTINUED) - i i ALTHCUGH SIGNIFICANT PROGRESS HAS BEEN MADE, MOST OF THE

                                                                                              ~

DIFFICULT AND COMPLEX WORK LIES AHEAD. IHE FOLLOWING IS THE LICENSEE'S SCHEDULE FOR THE REMAINDER OF THE CLEANUP. WE

                    ' UNDERSTAND THAT THIS SCHEDULE WILL BE UPDATED IN LATE APRIL i                                                1985, a                                                                                                                REACTOR PLENUM REMOVAL         MAY 1985 START REACTOR FUEL REMOVAL     JULY 1985 COMPLETE FUEL REMOVAL          3RD QUARTEP 1986 FROM ORIGINAL REACTOR VOLUME STAR r REACTCP FLEL SHIPPING   IST CUARTER 1986    -

i COMPLETE IN-VESSEL 4TH GUARTER 1986 i FUEL REMOVAL I ~ COMPLETE FUEL REMOVAL 3RD QUARTER 1987 FROM REACTOR PLANT SYSTEMS I COMPLETE FUEL SHIPPING IST GUARTER 1988 PROGRAM ENDPOINT 2ND QUARTER 1988 I

i QUESTION 19 (CONTINUED) THE CURRENT TOTAL ESTIMATED COST OF THE CLEANUP IS $987 ] M I L L'I ON'. THE AMOUNT SPENT BY THE LICENSEE THROUGH THE END OF CALENDAR YEAR (CY) 1984 WAS $500 MILLION. THEREFORE, THE AMOUNT NEEDED TO COMPLETE THE CLEANUP IN CY85 AND BEYOND IS

                            $487 MILLION.                                                                                                      THE LICENSEE'S PROJECTED TOTAL SPENDING IN 1985

! IS $120 MILLION. i THE LICENSEE'S PROPOSED SOURCES OF FUNDS FOR THE PEMAINDER OF THE CLEANUP (CY85 AND BEYOND) ARE AS FOLLOWS: SOURCE $ in MILLIONS 4 CUSTOMER REVENUES 164 ! GPU INTERNALLY GENERATED FUNDS 81 i FEDEPAL AND STATE GOVERNMENT 77 INDUSTRY 150 JAPANESE CONSORTIUM 15 ! TOTAL 487 l i

 ~

ALTHOUGH THE COMMISSION HAS BEEN DISAPPOINTED ~BY THE EARLIER I PACE OF.THE CLEANUP, THE COMMISSION BELIEVES THAT THE LICENSEE IS NOW MAKING REASONABLE PROGPESS TCWARD ACCOMPLISHING CLEANUP OBJECTIVES AND THAT THE FUNDING SITUATION IS NOW AS ASSURED AS ?

QUESTION 19 (CONTINUED) '

                     REASONABLY POSSIBLE.                         THE COMMISSION WILL CCNTINUE TO MONITOR:

i

                     ' ~ CLOSELY BOTH THE LICENSEE'S PROGRESS IN COMPLETING THE CLEANUP AND THE FUNDING SITUATION.       SHOULD CONDITIONS CHANGE IN A l

! MANNER THAT COULD SIGNIFICANTLY IMPACT THE PACE OF THE CLEANUP, THE COMMISSION WILL PROMPTLY RECONSIDER THE-NECESSITY I 0F TAKING WHATEVER ACTION IS DEEMED APPROPRIATE TO ENSURE ADEQUATE PROTECTION OF THE PUBLIC HEALTH AND SAFETY. e i 9 D ( ' l

j i 00ESTION 20. THE V.S. GENERAL ACCOUNTING OFFICE RECENTLY j REPORTED TO CONGRESS CN THE STATUS OF UNRESOLVED

' '~ GENERIC SAFETY PROBLEMS IN A STUDY ENTITLED,

                   ~
                              " MANAGEMENT WEAKNESSES AFFECT NUCLEAR REGULATORY
            ~

r COMMISSION EFFORTS TO ADDRESS SAFETY ISSUES COMMON TO NUCLEAR POWER PLANTS." AMONG ITS

      ' '            ~~

FINDINGS, THE GAO STATED THAT A NUMBER OF GENERIC SAFETY ISSUES POSE EQUAL OR GREATER RISK THAN f PROBLEMS FORMALLY CLASSIFIED AS UNRESOLVED SAFETY ISSUES (USIS). CONSEQUENTLY, THESE GENERIC } SAFETY ISSUES AND NRC'S PROGRESS IN RESOLVING THEM ARE NOT PEPORTED TO CONGRESS AS ARE USIS UNDER SECTION 210 0F THE ENERGY REORGANIZATION ACT OF 1974, AS AMENDED, ACCORDING TO THE GA0 THESE GENERIC SAFETY ISSUE DO NOT RECE!VE THE SAME DEGREE OF MANAGEMENT ATTENTION AT NPC As DO USIS. (A) WHAT GENERIC SAFETY ISSUES DOES NRC BELIEVE I TO BE OF EQUAL OR GREATER SIGNIFICANCE IN TERMS OF RISK AT THE AFFECTED PLANTS AS

   ~

USIS? WHAT, IF ANY, STUDIES OR' ANALYSES

            ~

i HAVE BEEN PREPARED ON THIS SUBJECT? 7 i . . i a t

4 OUESTION 20(A). (CONTINUED) 4 ANSWER. i

  - ~ SUBJECT TO THE IMPRECISION OF THE UNDERLYING QUANTITATIVE                                                      L ANALYSES AND MODIFYING FACTORS, WE BELIEVE THAT USIS AND l      GENERIC SAFETY ISSUES THAT HAVE BEEN ASSIGNED A HIGH I      PRIORITY RANKING SHOULD BE RESOLVED WITH THE GENERALLY j ~ EQUIVALENT PRIORITY.             THE ASSIGNMENT OF THIS PRIORITY IS A
  ' ' BALANCE JUDGMENT THAT IS NOT LIMITED TO ONLY QUANTITATIVE ESTIMATES OF RISK (E.G. POPULATION EXPOSURE OR CORE MELT FREQUENCY), BUT THE EVALUATION OF OTHER RELEVANT FACTORS SUCH

] AS THE POTENTIAL FOR OCCUPATIONAL RADIATION EXPOSURE OF 3

WORKERS; THE COST ASSOCIATED WITH IMPLEMENTING THE ISSUE; THE UNCERTA'INTY, CONCERN AND CONTROVERSY ATTACHED TO THE ISSUE; THE

! EFFECT ON DEFENSE-IN-DEPTH; THE RESOURCES ALPEADY SPENT AND THE

                                ~

i CONSEQUENCES OF DELAY OR DEFERMENT. THUS. WE'HAVE NOT MADE AN ! EXPLICIT COMPARISON OF THE RISK AMONG USIS AND HIGH PRIORITY GENERIC SAFETY ISSUES, BUT HAVE JUDGED EACH ISSUE ON ITS l RELEVANT FACTORS. , f QUANTITATIVE ANALYSES OF THE RISK AND COSTS OF ONLY NINE f UNRESOLVED SAFETY ISSUES (USIS) WERE CALCULATED BY A CONTRACTOR I

!      (BATTELLE PACIFIC NORTHWEST LABORATORY).                          THE GAO FINAL REPORT INCORRECTLY IDENTIFIED THESE CALCULATIONS AS "NRC RANKINGS."                                   -

THESE CALCULATIONS WERE DONE AS AN INPUT TO THE PRIORITIZATION 2

r i 4

l QUESTION 20(A), (CONTINUED) ~

         ~

OF ALL GENERIC SAFETY ISSUES THAT WAS REFCPTED IN NUREG-0933. - HOWEVER, NRC DID NOT ADOPT THE CALCULATIONS FOR RANKING USIS, l OF THE NINE USIS EVALUATED, SIX USIS (A-43, A-44, A-45, A-47, l j A-48 AND A-49) HAD CONTRACTOR CALCULATED VALUES OF CHANGES [ !N RISK (MAN-REM) OR CORE-MELT FREQUENCY OR BOTH THAT NOMINALLY - I WOULD'BE A HIGH PRIORITY RANKING, ONE OF THE USIS EVALUATED BY i . PNL (A-1, WATER H,'MMER) WHICH HAS SUBSEQUENTLY BEEN RESOLVED WOULD' NOMINALLY BE PANKED AS MEDIUM PRIORITY, THE CONTRACTOR CALCULATED VALUES FOR TWO USIS (A-40 AND A-46) NOMINALLY WOULD BE A DROP PANKING. ALL OF THESE CALCULATIONS INCLUDE SIGNIFICANT UNCERTAINTIES AND DO NOT CONSIDER ALL OTHER RELEVANT FACTORS, f THE UNCERTAINTIES ASSOCIATED WITH SEISMIC DESIGN (A-40 AND A-46) j ARE PARTICULARLY GREAT. l i t 4 f 5 i f 1 4

l' .. i QUESTION 20. (B) DOES THE COMMISSION PLAN TO RECLASSIFY HIGH PRIORITY GENERIC SAFETY ISSUES, THAT ARE AS SEPIOUS IN TERMS OF RISK AS USIS, TO BE MADE PART OF THE

                    ~

OFFICIAL USI LIST, AND, DOES THE COMMISSION PLAN TO  ! INFORM CONGRESS OF THESE SAFETY PROBLEMS UNDER SECTION 2107 i i ANSWER, THE PROCEDURES OF THE OFFICE OF NUCLEAR REACTOR REGULATION FOR 1 i IDENTIFYING, PRIORITIZING, AND TRACKING THE RESCLUTION OF GENERIC t ', SAFETY ISSUES INCLUDE A REV!EW OF EACH ISSUE IDENTIFIED AS A i ' HIGH-PRIORITY GENERIC SAFETY ISSUE TO DETERMINE IF THE ISSUE j ! MEETS THE CRITERIA FOR A USI, ISSUES THAT MEET THE CRITERIA ARE

   ' SUBMITTED TO THE COMMISSION FOR APPROVAL.         THE LATEST LIST OF CANDIDATE USIS WAS SUBMITTED TO THE COMMISSION ON DECEMBER 3, 1

1984,' IN SECY-84-458, ONE !SSUE WAS PROPOSED AS A USI, BUT WAS l ~

                                                                          ~

NOT APPROVED BY THE COMMISSION.  ; i I I i 4 i 4 i r ,

OllESTION 20. (C) WHAT ACTIONS HAS THE COMMISSION TAKEN IN - RESPONSE TO THE GAO REPORT?

                                                                                               ~

ANWSER, . ' THE'

COMMISSION WILL, BEGINNING WITH THE 1984 ANNUAL REPORT, REPORT

ANNUALLY TO THE CONGRESS ON THE STATUS OF GENERIC SAFETY ISSUES, INCLUDING USIS,

l CUESTION 20. (D) PROVIDE A LISTING OF ALL UNRESOLVED SAFETY ISSUES AND HIGH PRIORITY GENERIC SAFETY ISSUES l INCLUDING THE DATE THE PROBLEM WAS FIRST IDENTIFIED, THE DATE THE PROBLEM WAS

                             " RESOLVED," THE DATE THE PROBLEM WAS j
                             "!MPLEMENTED," OR THE DATE THE PROBLEM IS EXPECTED TO BE " RESOLVED" AND "!MPLEMENTED."           7 l                           PLEASE INCLUDE A DETAILED DEFINITION OF ALL l
 ;                           TERMS USED IMCLUDING " RESOLVED" AND j                             "!MPLEMENTED."

i i ANSWER. l ! ENCLOSED ARE TABLES 1, 2, 3, UA, 4B, AND 4C OF THE GENERIC ISSUE MANAGEMENT CONTROL SYSTEM (GIMCS), WHICH SHOW THE STATUS OF i RESOLUTION. (ENCLOSURE A FOR QUESTION 20.) WE ALSO ENCLOSE A TABLE SHOWING THE STATUS OF LICENSING ACTIONS l . TAKEN IN FURTHERANCE OF IMPLEMENTATION OF RESOLVED FORMER

   " UNRESOLVED SAFETY ISSUES" (USIS) (ENCLOSURE B FOR QUESTION 20),                 j BASED ON NUREG-0748, "0PERATING REACTOR l! CENSING ACTION 

SUMMARY

(ORLAS). IN ADDITION, WE ENCLOSE A LICENSING ACTIONS STATUS AND SCHEDULE

SUMMARY

ON ALL MULT!-PLANT (GENERIC) ISSUES (TABLES J AND K FROM NUREG-0748), (ENCLOSURE C.) 1 4 s e

   . -.-. . _ . .   -_ -   - -    = .      - _ _ - -     .    .   - - . -   - . -- --
                                                                                           \

l l OVESTION 20(D) (CONTINUED) i l MANY GENERIC-ISSUE LICENSING ACTIONS BEING TRACKED VIA ORLAS AND { l THE SUBSEQUENT IMPLEMENTATION ACTIONS BY LICENSEES AND SELECTIVE i I VERIFICATIONS BY INSPECTION CURRENTLY ADDRESS ISSUES WHOSE j RESOLUTION PRECEDED THE FULL DEVELOPMENT OF THE PRESENT GIMCS, i l WHICH TRACKS THE ISSUES TO RESOLUTION. EFFORTS ARE UNDERWAY TO 1 i ' j IMPROVE THE COORDINATION OF TRACKING BETWEEN THE RESOLUTION, j LICENSING, AND IMPLEMENTATION PHASES. 1 i } AN ISSUE IS CONSIDERED PFSOLVED WHEN A NEW REGULATORY REQUIREMENT HAS BEEN ESTABLISHED (BY RULE, STANDARD REVIEW PLAN CHANGE, OR E0V! VALENT) OR A DETERMINATION HAS BEEN MADE THAT THERE IS NO.NEED l TO CHANGE REGULATORY REQUIREMENTS. I i i I ! NEW GENERIC REQUIREMENTS BECOME THE SUBJECT OF LICENSING ACTIONS [ IMPOSING THE NEW REQUIREMENT ON EACH AFFECTED PLANT. PLANT- l: 1 -

!      SPECIFIC INFORMATION TAKEN INTO ACCOUNT IN LICENSING ACTIONS MAY                  l I

t INCLUDE FURTHER INFORMATION REQUIRED OF LICENSEEES. i L I IMPLEMENTATION IS CONSIDERED COMPLETE WHEN THE DOCUMENTS 1 ) REFLECTING THE LICENSING ACTIONS ARE COMPLETE, ANY PHYSICAL CHANGE 1 IN PLANT OR EQUIPMENT HAS BEEN DESIGNED AND INSTALLED AND DECLAPED l l OPERABLE BY THE LICENSEE, AND ANY WRITTEN PROCEDURES OR TRAIH!NG REQUIRED HAS BEEN COMPLETED. AFTER IMPLEMENTATION IS COMPLETE, f l THE LICENSEES' IMPLEMENTATION ACTIONS REMAIN SUBJECT TO CONTINUING , l LICENSEE REPORTING REQUIREMENTS AND.NRC INSPECTION AND I , l ENFORCEMENT. ( I t t )

1 l ENCI.0SLIPE A FOR OllESTION 20 l 1 EXCERPT FROM: MEMORANDUM F00 H. DFNTON FPOM T. SPE!S, "GEPERIC ISSUE PANAGEMENT CONTOL SY? TEM: FIRST GUADTER FY-85 UPDATE," JAFUARY 18, 1985. l { 1 I I 1

LEGEND HIGH - HIGH SAFETY PRIORITY MEDIUM - hEDIUMSAFETYPRIORITY MPA - MULTI-PLANT ACTION (SEE STATUS IN NUREG-0748) US! - UNRESOLVED SAFETY ISSUE (SEE STATUS IN NUREG-0606) SRP - STANDARD REVIEW PLAN NRR-OP - 0FFICE OF NUCLEAR REACTOR REGULATION OPERATING PLAN; ISSUED ANNUALLY; REFERS TO 83 OR 84 OPERATING PLANS TBD - TO BE DETERMINEDJ SCHEDULE TO BE DEVELCPED ACA - AWAITING COMMISSION ACTION NR - NEARLY RESOLVED POSSIBLE RESOLUTION IDENTIFIED FOR EVALUATION HFPP - HUMAN FACTORS PROGRAM PLAN e

                                                                                                                                                        \

TABLE 1 l Generic Safety Issues Sclieduled for Resolution, New Generic issues asul Issue Resolved

            ~

FY-83 FY-84 FY-85 (1st Qtr.) ISSUE Gls New GIs GIs New Gls GIs New Gls IYPE Start

• Issues - Resolved = End Start
• Issues - Resolved = Emi Start
• Issucs - Resolved = End i

llSI 16 0 2 14 14 0 2 12 12 0 0 12 NIGH 24 2 0 26 26 1 1 26 26 1 0 27 KDIUM 31 2 0 33 33 4 3 34 34 0 3 31 NEARLY 20 3 4 19 19 5 9 15 15 2 1 16 RESOLVED 10TAL 91 7 6 92 92 10 15 81 87 3 4 86 Cumulative Totals FY-83 through FY-85 (1st Qtr.) ISSUE Gis New GIs TYPE Start + Issues = Totals - Resolved = Totals USI 16 0 16 4 12

                  .                   HIGl            24           4            28            1       27 MEDIUM          31           6            37           6        31 i

NEARLY 20 10 30 14 16 RESOLVED TOIALS 91 20 111 25 86 l As of First Quarter FY-85 l

TABLE 2 NUMBER OF GENERIC SAFETY ISSUES RESOLVED AND SCllEDULED FOR RESOLUTION First Quarter FY-85 , Issues Resolved Issues Scheduled for Resolution , FY-85 Quarters ISSUE ' lo De Cumulative TYPE FY-83 FY-84 1st 2nd 3rd 4th Total FY-86 FY-87 Scheduled Total USI 2 2 0 0 4 2 6 6 0 0 16 HIGli 0 1 0 3 5 2 10 13 4 0 28 HEDIUM 0 3 3 4 5 3 15 10 8 1 37 NEARLY 4 9 1 0 1 6 8 6 2 1 30 RESOLVED (NR) Total 6 15 4 7 IS 13 39 35 14 2 111 Number of New Ger.eric Issues Approved this Quarter, approved in previous FY Quarter and approved in previous years is shown on Table 1 and S. As of First Quarter FY-85

TABLE 3 GENERIC SAFETY ISSUES RE50lVfD BY FISCAL YEAR Issue Type of Date Approved Date . Number Title Priority Resolution for Resolution Resolved GENERIC SAFETY ISSUES RESOLVID FY-83 i A-11 Reactor Vessel Materials USI GL 82-26 01/79 10/82 Toughness A-16 Steam Effects on BWR Core Spray NR MPA-012 NRR-OP FY83 03/29/83 Distribution A-39 Determination of Safety USI SRP Revision 01/79 10/82 Relief Valve (SRV) Pool Dynamic Loads and Temperature Limits for BWR Containment B-53 Load Break Switch NR SRP Revision NRR-OP FY83 07/28/83 II.E.5.1 (B&W) Design Evaluation NR No NRR-OP FY83 03/21/83 Requirement IV.C.1 Extend Lessons Learned from NR No NRR-0P FY83 04/15/83 THI to Other NRC Programs Requirement GENERIC SAFETY ISSUES RESOLVED FY-84 12 BWR Jet Pump Integrity Medium No NRR-OP FY83 09/25/84

                                              .                             Requirement 20               Effects of Electromagnetic            HR          NUREG/        NRR-OP FY83       11/15/83 Pulse on Nuclear Plant Systems                    CR-3069 40***            Safety Concerns Associated            NR          MPA-865       07/18/83          12/27/83 With Breaks in the BWR Scram System As of First Quarter FY-85

Table 3 (Centinusd) GENERIC SAFETY ISSUES RESOLVED BY FISCAL YEAR Issue Type of Date Approved Date Number Title Priority Resolution for Resolution Resolved '

              '45***           Inoperability of Instruments        NR           SRP Revision 09/08/83          03/23/84 Due to Extreme Cold Weather.

i 50*** Reactor Vessel Level NR MPA-F26 07/28/83 09/06/84 Instrumentation in BWRs 69** Make-Up Nozzle Cracking in NR MPA- 12/06/83 09/27/84 B&W Plants A-1 Water llammer USI SRP Revision 01/79 03/15/84 A-12 Steam Generator and Reactor USI SRP Revision 01/79 10/83 Coolant Pump Supports B-10 Behavior of BWR Mark III liigh SRP Revision NRR-OP FY83 09/10/84 Containments B-26 Structural Integrity of Medium No NRR-OP FY83 09/27/84 Containment Penetrations Requirement B-60 Loose Parts Monitoring NR GL NRR-OP FY83 09/25/84 Systems (LPMS) I.A.1.4 Long-Term Upgrading of NR New Rule NRR-0P FY83 01/01/84 Operating Personnel II.A.1 Siting Policy Reformulation Medium No NRR-OP FY83 09/20/84 Requirement II.E.5.2 (B&W) Reactor Transient NR HUREG-0667 NRR-OP FY83 09/28/84 Response Task Force III.D.2.5 Offsite Dose Calculation Manual NR NUREG/ NRR-OP FY83 01/17/84 CR-3332 As of First Quarter FY-85 L--.--.---______ _ _______ _ ______ _____ _

4 Table 3 (Centinu d) GENEf!IC SAFETY ISSUES RESOLVED BY FISCAL YEAR - Issue Type of Date Approved Date Number Title Priority Resolution for Resolution Resolved

• GENERIC SAFETY ISSUES RESOLVED 1st QUARTER FY-85 22 Inadvertent Boron Dilution NR GL 11/05/82 10/15/84 Events A-41 Long Tern Seismic Program Medium No NRR-OP FY83 10/10/84 Requirement B-54 Ice Condenser Containments Medisun NUREG/ HRR-0P FY83 10/22/84 CR-4001 1.G.2 Scope of Test Program Medium No NRR-OP FY83 10/05/84 Requirement s

i i As of First Quarter FY Table 4A NRR GENERIC SAFE 1Y ISSUES SCllEDULED FOR RESOLUTION . . Lead Date Resolution Current Issue Division / Approved for Date as of Resolution' , Number Title Branch Priority Resolution June FY-84 Date 14 PWR Pipe Cracks DE/MTEB NR NRR-OP. 12/84+ 06/85+ 23 Reactor Coolant Pump Seal Failures DE/EQB 11 NRR-OP 07/86 07/86 29 Bolting Degradation or failures in DE/MTEB 11 NRR-0P 09/85 11/85 Nuclear Power Plants

 . 36**         Loss of Service Water (Calvert          DSI/ASB              NR      02/15/84           03/85         05/86 Cliffs Unit 1)                                                     -

48** LCO for Class IE Vital Instrument DSI/ICSB NR 10/25/83 02/86 02/86 Buses in Operating Reactors 49"* Interlocks and LCOs for Class IE DSI/PSB M 07/31/84 180 09/88 lie Breakers 51*** Proposed Requirements for Improving DSI/ASB M 06/03/83 10/86 09/88 t Reliability of Open Cycle Service Water Systems i 61** SRV Discharge Line Break Inside The DSI/CSD M 11/30/83 03/87 03/87 Wetwell Airspace of BWR Mark I &

Mark II Containments 65*** Component Cooling Water System DE/EQB 11 07/28/83 07/86 07/86 failure 66** Steam Generator Requirements DL/0RAB NR 11/16/83 09/85 09/85 68** Loss of AFWS Due to AFW Steam IIELB DSI/ASB 11 04/24/84 10/87 10/87 70** PORV and. Block Valve Reliability DSI/RSB M 05/14/84 TBD 03/85+ 4 As of first Quarter FY-85 4

Table 4A (continued) Lead Date Resolution Current issue Division / Approved for Date as of Resolution Number Title Branch Priority Resolution June FY-84 Date 77*** Flooding of Safety Equipment DSI/ASB H 09/08/83 08/86 08/86 Compartments by Back-Flow Through , Floor Drains ' 79*** Unanalyzed Reactor Vessel Thermal DE/MEB M 07/25/83 02/86 03/85+ Stress During Natural Convection Cooldown

     . 82**     Beyond Design Bases Accidents in     DSI/AEB            M     12/07/83          09/86 Spent Fuel Pools                                                                              09/86 83**     Control Room Habitability (CRH)      DSI/HTEB           NR   08/83              10/84+        07/85+

06* Long Range Plan for Dealing With DE/MTEB NR 10/01/84 TBD 05/85+ Stress Corrosion' Cracking in BWR Piping 93* Steam Binding of Auxiliary DSI/ASB H 10/19/84 TBD 08/87 Feedwater Pumps A-3, 4 Steam Generator Tube Integrity DL/0RAB USI 01/79 12/84 06/85 and 5 - A-17 Systems Interaction DST /GIB USI 01/79 03/86 03/86 A-29 Nuclear Power Plant Design for the DSI/ASB M NRR-0P 06/86 06/86 Reduction of Vulnerability to . Industrial Sabotage A-30 Adequacy of Safety Related DC Power DSI/PSB ll NRR-0P 07/85 07/85+ Supplies A-40 Seismic Design Criteria DE/SGEB USI 01/79 04/85 07/85 As of First Quarter FY-85

Table 4A (centinuid) Lead Date Resolution Current Issue Division / Approved for Date as of Resolution Number Title Branch Priority Resolution Jb..e FY-84 Date A-43 containment Emergency Sump DST /GIB USI 01/?9 _ 09/84 05/85 Performance - i A-44 Station Blackout DST /GIB USI 01/79 02/85 01/86 A-45 Shutdown Decay Heat Removal DST /GIB USI 02/81 02/86 02/86 Requirements , A-46 Seismic Qualification of Equipment DSf/GIB USI 02/81 02/85 08/85 in Operating Plants A-47 Safety Implications of Control DST /GIB USI 02/81 04/06 06/86 Systems A-48 Hydrogen Control Measures and DST /GIB USI 02/81 06/86 06/86 Etfects of Hydrogen Burns on Safety Equipment A-49 Pressurized Thermal Shock DST /GIB USI 12/81 12/85 03/86 B-5 Ductility of Two Way Slabs and DE/SGEB M NRR-0P 09/86 09/86+ Shells and Buckling Behavior of Steel Containments B-6 Loads, Load Combinations, Stress DE/MEB 11 NRR-OP 10/84+ 04/85+ Limits B-55 Improve Reliability of farget Rock DE/MEB M NRR-0P 05/85 05/85 i Safety Relief Valves B-56 Diesel Reliability DSI/PSB 11 NRR-OP 01/85 01/85+ B-58 Passive Mechanical Failures DE/EQB M NRR-OP 10/84+ ( As of First Quarter FY-85 ~

                             .               ._.     .   .    -=          .    - . .         .     .          ---    -.      _           .-    _.

lable 4A (continued) Lead Date Resolution Current Issue Division / Approved for Date as of Resolution Number Title Branch Priority Resolution June FY-84 Date , 1 B-61 Allowable ECCS Equipment Outage DST /RRAB M NRR-OP 09/87 09/87 Periods t 8-64 Decommissioning of Nuclear Reactors DE/CMEB NR NRR-0P 09/85 09/86* C-8 Main Steam Line Isolation Valve OSI/ASB H NRR-OP 12/86 12/86 Leakage Control Systems C-11 Assessment of Failure and Reliability of Pumps and Valves DE/MEB M NRR-0P 10/84+ 10['b s 1 As of first Quarter FY-85 1

Table 4B 1 NRR lHI GENERIC SAFE 1Y ISSUES SCllEDULED FOR RESOLUTION ' Lead Date Resolution Current Issue Division / Approved for Date as of Resolution Number Title Branch Priority Resolution June FY-84 Date I.A.2.2 Training and Qualifications of DilFS/LQB H NRR-dP 04/85 04/85+ Operations Personnel 1.A.2.6 Long-Term Upgrading of Training DilFS/lQB 11 NRR-OP 04/85 08/85+ (1) and Qualifications - Revise Regulatory Guide 1.8 I.A.2.6 Operator Workshops DilFS/LQB M NRR-0P 09/84 03/85 (4) I.A.2.7 Accreditation of Training DilFS/lQB H NRR-OP 01/85 01/87 Institutions I.A.3.4 Licensing of Additional Operations DilFS/LQB M NRR-OP 09/84 03/85 Personnel I.A.4.2 Review Simulators for Conformance DHFS/0LB 11 HRR-OP 04/85 04/85*

                                                                 '(4)

I . B. I.1 Organizatii>n and Management of # # # # #. Long Term Improvements I.B.1.1 Prepare Draft Criteria DilFS/LQB - - (1) I . B. I.1 Prepare Commission Paper DilFS/LQB - - (2) ' ^

                                                                  #ituman Factors Program Plan Issues No. 6.1 and 6.2 have replaced THI Issues 1.B.1.1 (1 through 4)

As of First Quarter FY-85

i Table 4B (continued) Lead Date Resolution Current Issue Division / Approved for Date as of Aesolution Number Title Branch Priority Resolution June FY-84 Date ' I . B.1.1 Issue Requirements for the DilFS/LQB - - (3) Upgrading Management and

• Technical Resources I.B.1.1 Review Responses to Determine DilFS/tQB - -

(4) Acceptability

            . IlFPP                                   Establish NRC Position on Manage-      DilFS/LQB             M     llFPP                   11/85+        04/86+

6.1 ment and Organization at Operating Nuclear Power Plants liFPP Development of NRC Assessment Mate- DilFS/LQB M liFPP 02/86+ 08/86 6.2 rials for Evaluating Management and Organization at Nuclear Power Plants I . C. 9 Long-Term Program Plan for Upgrad- DilFS/PSRB M NRR-0P 05/85+ 07/85 ing of Procedures I . D. 3 Safety System Status Monitoring DilFS/flFEB M NRR-OP 09/84+ 03/85+ II.B.6 Risk Reduction for Operating DST /RRAB 11 NRR-0P 11/84 ACA Reactors at Sites with liigh Population Densities II.C.2 Continuation of Interim Reliability DST /RRAB 11 - ACA 03/85 Evaluation Program II.E.4.3 (Containment) Integrity Check DSI/CSD 11 NRR-0P 07/84 03/85+ II.E.6.1 Test Adequacy Study DE/MEB M NRR-OP 11/86 11/86 4

              #iluman Factors Program Plan Issues 140. 6.1 and 6.2 have replaced THI Issues 1.B.1.1 (1 through 4)

As of First Quarter FY-85 i

                                                                                                                               ~

i I- Table 4B (continusd) Lead Date Resolution Currentf Issue Division / Approved for Date as of Resolution Number Title Branch Priority Resolution June FY-84 Da te' , ' III.D.2.3 Develop Procedures to Discriminate DE/EllEB NR NRR-OP 09/84 07/55 (1) Between Sites / Plants i III.D.2.3 Discriminate Between Sites and DE/EllEB NR NRR-0P 09/84 ' 07/85 (2) Plants that Require Consideration of Liquid Pathway Interdiction Techniques III.D.2.3 Establish Feasible Method of DE/EllEB NR NRR-0P 09/84 07/85 (3) Pathway Interdiction III.D.2.3 Prepare a Summary Assessment DE/EllE8 NR NRR-OP 09/84 07/85 (4) III.D.3.1 Radiation Protection Plans DSI/RAB 11 NRR-OP 03/85- 09/85 IV.E.5 Assess Currently Operating Plants DL/SEPB 11 NRR-OP 07/85 03/85 t I As of First Quarter FY-85

Table 4C NON-NRR lHI AND GENERIC SAFETY ISSUES SCllEDULED FOR RESOLUTION Lead Date Resolution Current issue Division / Approved for Date as of Resolution Number Title Branch Priority Resolution June FY-84 Date ' 3 Set Point Drift in RES/EEICB NR NRR-Ok 06/85 TBD Instrtmentation 75** Generic Implications of ATWS IE/QUAB NR 10/19/83 02/86 02/86 Events at the Salen Nuclear P.lant

  - B-17       Criteria for Safety Related            RES/flFSB         M        03/22/84         09/84+*

02/85+ Operator Actions 2 I.A.3.3 Requirement for Operation RES/DRA0/IIFSB 11 NRR-OP 12/84 06/85 Fitness I.A.4.2 Research on Training Simulators RES/DRA0/liFSB 11 NRR-0P 03/85 03/85 l (1) , j I . B.1.1 Prepare Revisions to Regulatory IE/DQASIP/QUAB M ~ NRR-OP 02/86 02/86 1 (6) Guides 1.33 and 1.8 I.B.I.1 Issue Regulatory Guides 1.33 and IE/DQASIP/QUAB M NRR-OP 02/86 02/86 (7) 1.8 i I.D.4 Control Room Design Standard RES/DRA0/IIFSB M NRR-0P 07/84 05/85 I.D.5 On-Line Reactor Surveillance RES/DET/EEICB NR NRR-0P 12/87+ 12/87+ (3) Systems l 1.D.5 Disturbance Analysis Systems RES/DRA0/IlFSB M NRR-0P 09/84t 05/85t j (5)

1. F.1 Expand QA List IE/DQASIP/QUAB 11 NRR-0 ' 09/85+ 09/85+

11.8.5 Behavior of Severely Damaged RES/DAE/FSRB 11 NRR-OP 06/85 09/85+ (1) Fuel As of First Quarter FY-85 e

Table 4C (continu2d) NON-NRR IMI AND GENERIC SAFETY ISSUES SCllEDULED FOR RES0luTION i Lead Date Resolution Current - Issue , Division / Approved for Date as of Resolution Number Title Branch Priority Resolution June FY-84 Date

                                                                                            ~

II.B.5 Behavior of Core Melt RES/DAE/FSRB ll NRR-OP 06/85 09/85+ (2) II.B.5 Effect of Hydrogen Burning and RES/DAE/CSRB M NRR-0P 09/85+ 10/85+ (3) Explosions on Containment Structure II.B.8 Rulemaking Proceeding on RES/DRA0/RAHRB 11 NRR-OP 08/84 02/85 Degraded Core Accidents II.C.1 Interim Reliability Evaluation RES/DRA0/RRB 11 NRR-OP 09/84 04/85 Program II.C.4 Reliability Engineering RES/DRA0/PRB 11 NRR-OP 12/87+ 12/87+ II.E.2.2 Research on Small Break LOCAs RES/DAE/RSRB M NRR-OP 09/86+ 09/86+ and Anomalous Transients II.F.5 Classification of Instrumenta- RES/DET/EEICB M NRR-OP 09/84+ TBD tion, Control, and Electrical Equipment 1I.11.2 Obtain Technical Data on the RES/DAE/FSRB 11 NRR-OP 06/86+ 06/86+ ' Conditions Inside the 1MI-2 Containment Structure II.J.4.1 Revise Deficiency Report IE/DEPER/EAB NR NRR-OP 12/84+ 08/85+ Requirements III.A.I.3 Maintain Supplies of IE/DEPER/EPB NR NRR-OP ACA 01/85+ (2) Thyroid-Blocalis Agent for Public , III.A.3.4 Nuclear Data Link IE/DEPER/EPB M NRR-OP 08/84+ 03/85 As of First Quarter FY-85

ENCLOSURE B FOR QUESTION 20 LICENSING STATUS OF RESOLVED USIS BASED ON NUREG-0748, VOL. 5, NO.1, "0PERATING REACTORS LICENSING ACTIONS

SUMMARY

," JANUARY 1985. (PUBLISHED MARCH 1985) AND NUREG-0606, VOL. 7, NO. 1, " UNRESOLVED SAFETY ISSUES

SUMMARY

," FEBRUARY 15, 1985. USI

• FPA
• TITLE No. OF PLANTS COMPLETED LOMPLETED ACTIVE FUTURE FY85 PRIOR FY TOTAL A-2 D-10 ASYMMETRIC 12 0 0 27 39 LOCA LOADS A-6 D-1 MARK I SHORT 0 0 0 22 22 TERM PROGRAM A-7 D-1 GE MARK I 10 0 3 9 22 CONTAINMENT EVALUATION--

LONG TERM A-9 - ATWS 0 All 0 0 All A-10 B-25 BWR FEED- 0 0 0 8 8 WATER N0ZZLE CRACKING A-24 B-60 ENVIRONMENTAL 42 0 27 7 76 QUALIFICATION A-26 B-4 REACTOR 1 0 0 11 12 VESSEL OVER-PRESSURIZATION PROTECTION A-36 C-10 CONTROL OF 9 0 11 58 78 HEAVY LOADS A-42 B-5 STRESS 0 0 O' 25 25 CORRSION-- BWR RCSPB

l - j ENCLOSURE C FOR DUESTION 20 EXCERPT PROM NUREG-0748, VOL 5, NO. 1, "0 P E P A T i t'C- PEACTnes LICENSING ACTION SUMMAPY," JANurPv 1985 (PUBLISPFD MAPCH 1985.) e e

!R-1208608-002                      TECHNICAL          ASSIGNMENT           C0NTR0L   SYSTEM                           PAGE: J-        1 B2/26/85                            MULTI-PLAHT              ISSUES      

SUMMARY

REPORT COMPL. COMPL. .

• GDE CURRENT PRIOR A-08 GENERIL351ECI ACTIVE EMIMRE FY.(851 FY Igl&L to CFR 5s.55 A(G) - ISI 0 0 0 37 37 A-02 APPENDIX I - ALARA 20 0 15 32 A-03 SECURITY REVIENS-MODIFIED AMENDMENT PLANS 67 A-04 0 0 0 t i APPENDIX J - CONTAINMENT LEAK TESTING i1 0 2 16 19 A-05 GE MARK I CONTAINMENT TECH SPECS-SNORT TERM 0 A-06 0 0 0 0 RESPIRATORY PROTECTION SYSTEM 0 0 0 0 A-07 APPENDIX G - FRACTURE TOUGHNESS 0 0 0 0 2 2 A-08 ECCS EVALUATION-GENERIC PER 50.46 COMPLIANCE A-09 O 0 0 0 0 PRES $URE VESSEL BELTLINE MATERIAL SURVEILLANCE O 0 0 0 0 A-10 CONTINGENCY PLANNING 0 A-Il

                                                            .                                    0        0            5            5 GUARD TRAINING PLANS                                                             0    0        0 A-12      VITAL AREA ANALYSIS                                                                                          8            8 A-13                                                                                       0     0        0            0            0
       . HON POWER REACTOR SAFEGUARDS PLANS                                               0    0        0 A-14       IOCFR 50.55 A(G) - INSERVICE TESTING                                                                        0            0 A-15                                                                                      10     0        0          27           37 QUALITY ASSURANCE REQUEST REGARDING DIESEL GENARATOR FUEL DIL                    0    0        0             t A-I6       QUALIFICATIONS OF EXAMINATION, INSPECTION, TESTING AND AUDIT PERSONNEL                                                    1 0    0        0            3 A-87       INSTRUMENTATION To FOLLOH THE COURSE OF AN ACCIDENT (RG 1.97)                  78     0 3

0-18 0 3 81 TECH SPECS AFFECTED BY 50.72 AND 50.73 (GL 83-43) 58 0 14 12 84 B-01 DIESEL GENERATOR LOCKOUT 0 0 0 t B-02 FIRE PROTECTION 0 i B-03 PHR MODERATOR DILUTION 0 0 t 0 0 0 0 0 B-04 REACTOR VESSEL OVERPRESSURE PROTECTION t iB-05 . 0 0 1 12 STRESS CORROSION CRACKING - BHR RCSPB 0 0

  -06     BHR RELIEF VALVE                                                                                0          25           25 O     O        o             I            :
  -07     STEAM GENERATOR FEEDWATER FLOH INSTABILITY
  -08                                                                                      0     0        0            0            0 PWR HPSI-LPSI FLDH RESISTANCE                                                    O     0
  -09                                                                                                     0            G            0 CHARGING SYSTEMS PIPE VIBRATIONS                                                 0     0        0
  -80     BURNABLE POISON ROD FAILURE - B8H                                                                            0            0 11                                                                                     0     0        0            0            0 FLOOD OF EQUIPMENT IMPORTANT TO SAFETY                                           0     0        0
  -12     STEAM GENERATOR TUBE INSPECTION                                                                              0            0 0     O                     o
  -15     FUEL ROD B0H                                                                     0 O                         0
  -14     CEA GUIDE TUBE HEAR                                                                    0        0            0            0
  -15                                                                                      0     0        0            0            0 C-E POISON ROD GROHTH                                                            0     0
  -16     EMERGENCY PLANNING AND REVISIONS                                                                0            0            0
  -17                                                                                      0     0        0            2            2 TECH SPEC SURVEILLANCE FOR HYDRAULIC SNUBBERS                                   13     0        3
  -18     HORTHINGTON RHR PUMP SHAFT INTEGRITY                                                                         6          22 19                                                                                     0     0        0            0            0 NEUTRON SHIELDING - CE REACTORS                                                  0     0        0
  -20                                                                                                                  0            0 CONTAINMENT LEAKAGE DUE TO SEAL DETERIORATION                                    0     0        0            t
  ~21                                                                                                                               I LOSS OF 125-V DC BUS VOLTAGE HITH LOSS OF ANNUNCIATOR SYSTEM                     0     0        0            0            0 22     TECH SPEC SURVEILLANCE REQUIREMENTS FOR MECHANICAL SNUBBERS                     to     0        3            7          20
  -23     DEGRADED GRID VOLTAGE                                                            2     0
  -24                                                                                                      t         17           20 VENTING AND PURGING CONTAINMENTS HNILE AT FULL PDHER AND EFFECT ON LOCA         13     0        1         41            55
  -25     BHR FEEDHATER N0ZZLE CRACKING                                                    0     0        0            8           8 26     INADVERTANT SAFETY INJECTION DURING COOLDOHN                                     0 s1                                                                                            0        0            0            0 REVIEH RESPONSES TO IE BULLETIN 78-03 (OFFGAS EXPLOSIONS)                        0     0        0            0            0
  -28     BHR JET PUMP FLOH INDICATION ELIMINATION                                         0     0
 -29                                                                                                      0            0            0 BHR FEEDWATER PUMP TRIP                                                          0     0        0 30     STEAM GENERATOR REPLACEMENT PROGRAM                                                                         0             0 0     0        0           0             0
  -31     LONG SHAFT LNSI 8 OUTSIDE RECIRC. PUMP DEGRADATION                               0     0
  -32                                                                                                     0           0             0 BLOCKED SI SIGNAL DURING COOLDOHN                                                O     O        t         17 33     IDDINE SPIKING                                                                                                          38 0     0        0           0            0

SYSTEM PAGEs J- 2 TECHNICAL ASSIOHHENT C0NTR0L t-1208608-002 ISSUES

SUMMARY

REP 0RT . D2/26/85 MULTI-PLANT COMPL. COMPL. CURRENT PRIOR ACT!VE EMIVRE FY (651 FY TOTAL o 0 0 0 0 gqDE Oft lLBIC_$URLEG 0 0 0 B-34 BHR JET PUMP INTEGRITY ASSURANCE to 0 ORIFICE ROD ASSEMBLY INTEGRITY - B8H 0 0 0 0 B-35 o O 0 0 B-36 RESISTANCE TEMPERATURE DETECTOR (RTD) RESP 0 HSE - CE O O STEAM GEHERATOR TUBE DENTING AND SUPPORT PLATE MODIFICATI0HS - CE 0 0 0 t i B-37 0 0 0 0 l-38 TENDON SURVEILLANCE - BECHTEL CONTA!HMENTS o 0 0 0 0 0 B-39 PHR PRES $URE - TEMPERATURE LIMIT TECH SPECS B-40 PIPE SUPPORT BASE PLATES 13 0 3 62 78 FIRE PROTECTIDH - FINAL TECH SPECS (INCLUDES SER SUPPLEMENTS) 0 0 0 0 0 B-41 t t Q-42 TMI FOLLOW UP - ALL PLANTS 0 0 0 PHR FEEDHATER LINE CRACKS O 0 0 B-43 O O 0 B-44 0 0 0 0 B-45 LESSONS HASH LEARHED 1400 EVENT V, IMPLEMENTATION" PRIMARY COOLANT SYSTEM PRESSURE ISOLATION0 VALVES" 0 1 2 AHALYSIS OF TURBINE DISC CRACKS o 0 0 0 0 B-46 29 B-47 ECCSs CLAD SHELLING AND RUPTURE 3 0 2 24 ADEQUACY OF STATION ELECTRIC DISTRIBUTION VOLTAGE 0 0 0 5-48 0 0 0 0 B-49 PHR CONTROL ROD MISALIGNMENT 0 0 0 AUXILIARY FEEDWATER SYSTEM EVALUATIDH 0 0 0 0 5-50 0 0 0 0 3-51 EVALUATIDH OF BULLETIN 79-06 AND 79-08 0 0 REVIEH OF SAFETY ASPECT OF IHADVERTENT SAFETY ACTIONS DURING SUR.' TEST 0 0 0 0 5-52 0 0 3 3 5-53 LESSONS LEARHED CATEGORY B (ITEMS) 0 0 0 0 B-54 LESSONS CATEGORY A. TECH SPEC 0 0 0 B80 REPORT ON BHRS 0 0 0 0 5-55 0 13 B-56 CONTROL RODS FAILURE TO INSERT. BHR 6 0 0 7 5-57 DHR CAPABILITY 0 0 0 20 20 B-58 SDV CAPABILITY 38 0 3 20 61 B-59 MASONRY HALL DESIGN 42 0 27 7 76 ENVIRONMENTAL QUALIFICATION 0 0 0 0 0 B-60 10 B-61 LOSS OF HON CLASS IE I&C P0HER 0 0 0 10 ESF RESET CONTROL DESIGH DEFICIENCY 0 0 0 3 3 B-62 0 0 B-63 INTERIM PROCEDURES FOR SHORT TERT 1 BLACKOUT 0 0 0 5-64 BSC INDUCED FLUX EPRORS 19 0 0 1 20 SAFETY CONCERHS ASSOCIATED HITH PIPE BREAKS IN BWR SCRAM SYSTEM 8 0 0 41 49 5-65 0 8 8 3-66 NATURAL CIRCULATIDH C00LDOHN 0 0 THERMAL SHOCK 0 0 0 0 0 B-67 35 37 B-68 ECCS PUMP DEADHEADING 0 1 IEB 80-4 MAINSTEAM LINE BREAK HITH CONTINUED FEEDHATER ADDITION 0 0 0 0 5-69 0 0 0 B-70 FATIGUE TRANSIENT LIMIT TS 0 0 0 120 VAC VITAL INSTRUMENT BUSSES AND INVERTER TECHNICAL SPECS. O 11 53 74 5-71 to 0 0 8 8 B-72 HUREG 0737 TECH SPECS (GENERIC L ETTER 82-16) 0 PLAHS FOR PREVEPTING EXCEEDING PTS SCREENING CRITERION 0 0 0 4 4 B-7 3 THERMAL SHIELD FOLLOH UP ANALYSIS 0 0 *0 0 0 ~ B -7 4 2 82 B-75 REVIEH OF 88H CORE BARREL BOLTS CRACKING 79 0 1 ITEM t.t - POST TRIP REVIEHs PROGRAM DESCRIPT!0'. A PROCEDURES 30 0 0 2 82 5-76 0 2 81 B-77 ITEM 2.1 - EQUIPMENT CLASSIFICATI0H & VENDOR IaTERFACE - RTS COMPONENTS 79 0 ITEMS 3.t. & 3.t.2 -POST MAINTENANCE TEST PROCEDURES & VENDOR RECOMM. 77 0 2 2 81 B-78 ITEM 3.3.3 - POST MAINTENANCE TESTING - CHANGES TO TECH SPECS - RTS COMP, 0 0 2 54 B-79 52 ITEM 4.1 - REACTOR TRIP SYSTEM RELIABILITY - VENDOR RELATED MODS 54 0 0 0 54 B-80 5 18 44 B-St ITEMS 4.2.8 & 4.2.2 -PREVENTATIVE MA!HT PROG FOR REACTOR TRIP BREAKERS 28 0 12 to 70 B-82 ITEM 4.3 - AUTOMATIC ACTUATION OF SHUNT TRIP ATTACH. 83-36 8FOR 83-37 HEST FOR&HUREG 88H 0737 48 0 22 IB-83 LECH SPECIFICATI0HS COVERED BY GENERIC LETTERS 19 1 2 0 B-84 INSPECTIDHS OF SHR STAIHLESS STEEL PIPING ACCORDING TO GENERIC LETTER 84-11 =-"= 7 . - ~ _ __w.- , _

                                                                             -   - - -        A .;.;,.       . .. ,.,_ ,_       ,    g t. % p.p .y . % g g g

R-1208608-002 iECHHICAL ASSIGHHEHT C0NTR0L 5YSTEM PAGEs J- 3 02/26/85 MULTI-PLAHT ISSUE $ $UMMARY REPORT COMPL. COMPL. l CURRENT PRIOR I

  '0DE         OCHERIC_sV11ECI                                                          ACIlyE  LHIVRE fY_(851    FY       TOTAL I-85         SALEM AlHS t.2 DATA CAPABILITY                                                I      0         0        0          7 B-36         SALEM ATHS 2.2 5-R COMPONENTS                                                 7      0         0        0          7 B-87         SALEM ATHS 3.2.1 & 3.2.2 5-R COMPONENTS                                       2      0         0        0          2 B-88          SALEM ATHS 3.2.3 T.S. 5-R COMP 0HENTS                                         0      0         0        0          0 B-89          SALEM ATHS 4.2.3 & 4.2.4 LIFE COMPONENTS                                      3      0         0        0          3 B-90          SALEM ATHS 4.3 H AND B8H T.S.                                                 3      0         0        0          3 B-91          SALEM ATHS 4.4 58H TEST PROCEDURES                                             I     O         O        0          t B-92          SALEM ATHS 4.5.1 DIVERSE TRIP FEATURES                                        5      0         0        0          5 B-93          SALEM ATHS 4.5.2 3 4.5.3 TEST ALTERNATIVES                                    3      0         0        0         3

-01 PHR SECONDARY HATER CHEMISTRY MONITORING REQUIREMENTS 0 0 0 5 5

-02 BHR-RECIRC. PUMP TRIP (ATHS) 0 0 0 0 0 C-03 QUALIFICATIONS OF RADIATION PROTECTION MANAGER 0 0 0 0 0 C-04 FILTER TECH SPECS 0 0 0 3 3 C-05 CONVER$10N TO STANDARD TECH SPECS 0 0 0 0 0 C-06 PUMP SUPPORT-LAMELLAR TEARING 0 0 0 0 0 C-07 FUEL HANDLING ACCIDENT INSIDE CONTAIHMENT 0 0 2 2 4

• C-08 BHR POST LOCA H2 CONTROL 0 0 0 0 0 C-09 PHR AUX FH PUMPS 0 0 0 t t

-to CONTROL OF HEAVY LOADS OVER SPENT FUEL POOL (PHASE ONE) 9 0 11 58 78

-It RPS POWER SUPPLY 3 0 0 to 13

-12 BORON SOLUBILITY DURING LONG TERM COOLING FOLLOHING LOCA . 0 0 0 0 0

-13 LOSS OF 0FFSITE P0HER 0 0 0 0 0

-14 AUXILIARY FEEDHATER SRISMIC QUALIFICATION 7 0 0 20 27

-15 CONTROL OF HEAVY LDADS - PHASE II (FOLLOHUP OF MPAR C-10) 81 0 0 0 81 D-Og GE MARK I CONTAINMENT EVALUATION - LONG TERM to 0 3 9 22 D-02 ECCS ZIRC CLAD MODEL ERROR-COMPLIANCE HIIH 10 CFR-46 0 0 0 0 0 3-03 PRESSURIZER HEATUP RATE ERROR 0 0 0 0 0 3-04 PHR REACTOR VESSEL CAVITY SEAL RING MISSILE POTENTIAL 0 0 0 4 4 D-05 PLANT UPI MODEL PROBLEM 6 0 0 0 6 D-06 PEAKING MODEL CHANGE FOR CE REACTOR CORE o 0 0 0 0 3-07 BHR POWER LEVEL FOR RilM' 0 0 0 0 0 3-08 DEFICIENCY IN CHEM ADDITION TO CONTAINMENT SPRAYS 0 0 0 0 0 3-09 GE ECCS INPUT ERRORS 0 0 0 0 0 3-10 ASYMMETRIC LOCA LOADS 12 0 0 27 39 D-11 FISSION GAS RELEASE D 0 0 0 0 3-12 N0H-JET PUMP BHR CORE SPRAY PERFORMANCE 0 0 0 2 2 3-83 B8H SMALL BREAK ERROR 0 0 0 0 0 3-14 REACTOR VESSEL llELD - HIRE DEFICIENCY 0 0 0 0 0

 )- 15       HIGH ENERGY LINE BREAK & CONSEQUENTIAL SYSTEM FAILURE                          o      0         0      43         43
 )-16        REVIEH OF CORPORATE MANAGEMENT CAPABILITY                                      0      0         0         t         t 3-17         DEFINITION OF OPERABLE                                                        7      0          t       8        16 3-18        HUREG 0630 CL ADDING MODEL S (88H PL ANTS)                                     0      0         0        8          8 3-19         DIESEL GENERATOR RELIABILITY TECH SPECS (GL 84-15)                          86       0         0        0        86 E-03        SPENT FUEL POOL EXPAHSIONS                                                     0      0         0        0          0 E-02        FUEL CASK DROP                                                                 0      0         0        0          0 F-03         CORE RELOADS REQUIRING PRIOR HRC APPROVAL                                      0      0         0         t         I i-04         BHR SINGLE LOOP OPERATION                                                      8      0         0        0          8 E-05         H N-t LOOP OPERATION                                                           0      0         3        1         4 E-06         CEA POSITION INDICATION FAILURES - CE                                          o      0         0        0          0 E-07         REACTOR PROTECTIDH SYSTEM LOGIC - CE                                           0      0         0        0         0
  -01        I.A.I.t SHIFT TECHNICAL ADVISOR                                                0      0        0         2         2

PAGE: J- 4 ASSIGHMEHT C0NTR0L 5 Y $ T,E M R-1.208608-002 TECHHICAL I55UES

SUMMARY

REP 0RT 02/26/85 MULTI-PLANT COMPL. COMPL. , CURRENT PRIbR FY 1gJAL

                                                                                                &Cl]VE            [MLUR[ FY s331  0             64             64 0              0 OfN[gl O URJfCl 2              53            56 CDDE                                                                                                    1              0 F-02      1.A.t.3       SNIFT MANNING                                                                                  0            t             63            7I UPGRADING OF RO AND SRO TRAINING                                                7                                           3           7t F-03      I.A.2.1                                                                                    68                0            0 F-04      I.C.t.2/3.A EMERGENCY OPERATING PROCEDURES GENERIC                     t)       TECHNICAL     O         GUIDELINES O            O               2             2 2

F-05 I.C.t.2/3.B PROCEDURES GENERATIDH PACKAGES (HUREG 0737. SUPP. t 0 0 1 83 F-06 I.C.5 FEEDBACK OF OPERATING EXPERIENCE 40 0 38 5 F-07 I.C.6 CORRECT PERFORMANCE OF OPERATING ACTIVITIES 0 4 5 82 73 F-08 I.D.t.t DETAILED CONTROL ROOM DESIGil REVIEH PROGRAM PLAN 0 0 0 63 63 SAFE 1Y PARAMETER DISPLAY SYSTEM 0 69 70 F-09 I.D.2 t 0 73 F-10 II.R.t RCS HIGH POINT VENTS 18 0 10 45 F-st 11.B.2 PLANT SHIELDIHO 0 2 51 54 F-12 II.B.3 POST ACCIDENT SAMPLING 1 0 3 26 85 TRAINING FOR MITIGATING CORE DAMAGE 56 18 18 F-t3 II.R.4 0 0 0 RV AND SV TRAINING 0 9 9 F-14 II.D.1 0 0 9 9 F-15 II.E.t.1 AFH SYSTEM EVALUATIDH O O O to F-16 II.E.1.2.1 AFH SYSTEM INITIATION O O O 10 50 F-t? II.E.t.2.2 AFH SYSTEM FLOW INDICATION 4 0 1 48 DEDICATED HYDROGEN PEHETRATION t 2 4 F-18 II.E.4.1 CONIAIHMENT ISOLATIDH DEPENDABILITY t 0 0 1 F-89 II.E.4.2 1 0 0 NOBLE GAS MOHITOR 0 9 9 F-20 II.F.t.1 10DIHE/ PARTICULATE SAMPLING . 0 0 61 62 F-28 II.F.1.2 1 0 0 F-22 II.F.t.3 CONTAIHMENT HIGH RANGE N0filTOR 0 0 61 62 t F-23 II.F.t.4 CONIAINMENT PRESSURE IHS1HUMENT 0 1 58 6I CONT AINMENT HATEF. LEVEL INSTRUMENT 2 79 F-24 II.F.t.5 0 8 9 CONTAIHMENT HYDROGEN MONITOR 62 0 0 F-25 II.F t.6 INSTRUMENTS FOR DETECTION OH IHADEQUATE CORE COOLING 0 0 0 0 F-26 II.F.2 0 0 0 0 F-27 II.K.2.9 FMEA DN ICS 0 0 0 0 0 F-28 II.K.2.10 SAFETY GRADE ARTS CONTINUED OPERATOR TRAINING AND DRILLING 0 0 0 53 53 0 F-29 II.K.2.It 0 0 0 0 THERMAL-MECHANICAL REPORT 0 0 F-30  !!.K.2.13 o 0 0 F-31 II.K.2.14 LIFT FREQUENCY OF PORVS AND SVS 1 0 0 40 41 F-32 II.K.2.16 RCP SEAL DAMAGE POTENTIAL FOR VOIDING IN RCS 0 0 0 0 43 0 F-33 II.K.2.t? 0 0 42 F-35 II.K.2.20 SYSTEM RESPONSE TO SB LOCA 1 0 0 43 43 AUTO PORV ISOLATION 0 3 F-36 II.K.3.1 1 0 0 2 II.K.3.2 REPORT OH PORV FAILURES 0 48 49 F-37 REPORTING SV AND RV FAILURES AND CHALLENGES 1 0 t t F-38 II.K.3.3 0 0 0 AUTO TRIP OF RCPS 0 2 2 F-39 II.K.3.5 PID CONTROLLER 0 0 0 0 F-40 II.K.3.9 0 0 0 F-41 II.K.3.10 ANTICIPATORY TRIP MODIFICATIONS 0 0 0 17 17 ANTICIPATORY TRIP OH TURBIHE TRIP 0 0 0 F-42 II.K.3.12 HPCI AND RCIC INITIATION LEVELS 0 0 t F-43 II.K.3.13 0 0 i ISOLATION CONDENSER ISOL AIION MODIFICATI0H O 24 F-44 II.K 3.14 0 0 22 2 ISOLATION OF HCPI AHD RCIC MODIFICATIONS 0 62 62 F-45 II.K.3.15 CHALLEHGES AND FAILURES OF RELIEF VALVES 0 0 12 24 F-46 II.K 3.16 5 0 7 II.K.3.17 ECCS OUTAGES 0 0 t F-47 ADS ACTUATION I O 17 17 F-48 II.K.3.18 0 0 0 F-49 II.K.3.19 INTERLOCK RECIRCULATIDH PUMP MODIFICATION 2 0 0 15 17 RESTART OF CSS AND LPCI 0 9 9 F-50 II.K.3.28 0 0 RCIC SUCTIDH 37 F-51 II.K.3.22 SPACE COOLING FOR HPCI/RCIC MODIFICATION 5 0 t 38 F-52 II.K.3.24 F-53 II.K.3.25 POWER Ott PUMP SEALS

                                                                                            -           .              j     .;'e      ..    .

~ ~~' ' ^

                                        '.              ,- . . _i_
                                                                     ~
                                                                       ._q X ~,     ,  ;           __ , _

R-1208604-002 TECHNICAL ASSIGNMENT C0NTR0L $YSTEM PAGE: J- 5 02/26/85 MULTI-PLANT I5 SUES

SUMMARY

REP 0RT COMPL. COMPL. CURRENT PRIOR G9C NERI [CI ACIIVE F-54 f(I .K. 3. OMMON REFERENCE LEVEL 4 FUTURE FY (8}1 0 0 FY 6 IRIAL 6 F-55 II.K.3.25 00ALIFICATION OF ADS ACCUMULATORS

• 12 0 F-56 II.K.3.29 PERFORMANCE OF ISOLATION CONDENSERS 1 9 22 0 0 0 I F-57 II.K.3.38 St LOCA METHODS 44 1

F-58 0 0 26 70 II.K.3.31 COMPLIANCE WITH 10 CFR 50.46 47 0 0 27 74 F-59 II.K.3.44 ANTICIPATED TRANSIENTS HITH SINGL E FAILURES 0 0 0 F-60 II.K.3.45 3 3 MANUAL DEPRESSURIZATION 0 0 0 24 F-61 II.K 3.46 MICHELSON CONCERNS 24 5 0 0 0 0 0 F-62 II.K.3.57 MANUAL ACTUATION OF ADS O O F-63 O O O III.A.t.2 TECHNICAL SUPPORT CENTER 71 0 F-64 III.A.I.2 OPERATIONAL SUPPORT CENTER 0 3 74 F-65 70 0 0 3 73 III.A.t.2 EMERGENCY OPERATIONS FACILITY 67 0 0 F-66 - III.A.t.2 NUCLEAR DATA LINK 6 73 0 0 0 0 0 F-67 III.A.2.1 EMERGENCY PLAN UPGRADE To MEET RULE o 0 i F-68 III.A.2.2 METEOROLOGICAL DATA UPGRADE

• 71 72 1 F-69 69 0 0 3 72 III.D.3.3 IMPLANT RADIATION MONITORING 0 0 F-70 0 0 0 III.D.3.4 CONTROL ROOM MAGITASILITY $ 0 25 F-71 I.D.1.2 DETAILED CONIROL ROOM REVIEH (FDLLOHUP TO F-8) 0 30 C-01 32 0 0 2 84 REACTOR COOLANT PUMP TRIP (0660 - II.K.3.5) 49 0 0 1 50 TOTAL GENERIC ISSUES 1,992

                                                                                     ,                            1      232         2,180       4,405 i

e I

TABLE K . K1 HULTIPLANT ACTION COMPLETION SCHEDULE FY1985 Schedule for Technical Schedule for Technical inputs to DL Actions Issued Review Performed by' Projected Remaining Hulti plant FY84 Carryover Review FY 1985 by DL In-Inputs to be FY FY IV fY House .Under Contract MPA No. Action Title (Inputs /LAs) Priority Branc h 1st 2nd 3rd 4th Total Completed FY Under 1986 1987 1985 1986 1987 Staff OL Div. A-02 Appendim 1 - ALARA 16 RA8 5 0 1 4 7 16 0 i (5 yr. old) 16 f1EID 5 4 7 0 16 0 A-04 Appendia J - 1 C58 1 0 0 0 1 2 Containment teak Testing (5 yr. old) A-14 10 CFR 50.55 A(G) - 1 REG 0 3 0 0 3 0 0 Inservice Testing 9 0 0 HE8 0 0 3 0 3 (5 yr. old) A-17 Instrumentation 84 1 IC58 0 13 16 10 39 45 45 to follow 8-05 Stress Corrosion 1 HIE 8 Cracking BWR RCSPB ~ (U5I: A-42) 8

IABLE K K2 HULTIPLANT ACil0N COMPLEll0N SCHEDULE FY1985 , Schedule for Technical Schedule for lechnical Inputs to OL Actions Issued _ Review Performed by Projected Remaining by OL In- Contract Multi plant FY84 Carryover Review FY 1985 Inputs to be FY FY FY fY FY' ilouse Under Under HPA No. Action iltle (Inputs /LAs) Priority Branch 1st 2nd 3rd 4th Total Completed 19 j 1987 1985 1986 1987 Staff OL Div. B-17 Tech Spec (15718) 2 REG 7 10 0 1 18 0 0 0 18 0 0 5 Surveillance for Hydraulic $nubbers B-22 Tech Spec (15/18) 2 REG 7 10 0 1 18 0 0 0 18 0 0 5 Surveillance Requirements for

      . Mechanical Snubbers 8-23      Degraded Grid               2           2          P58      1      1   0   0     2       0         0    0     6     1      0        4 Voltage (5 yr. old)

B-24 venting and Purging 0 1 Containments While [QB 5 7 0 0 12 0 at Full Power and . Effect Or LOCA B-41 Fire Protection 1 App. R CHEB 6 5 8 0 19 0 0 0 35 o r-- - n Adia

TABLE K K3 MULTIPLANT ACTION COMPLETION SCHEDULE FY1985 Schedule for Technical Schedule for Technical Inputs to Dt Actions Issued Review Performed by e Projected Aeeatning by DL In- Contract Multi plant FV84 Carryover Review FY 1985. Inputs to be FY FY fY FY FY House Under Under MPA No. Action iltle (Inputs /LAs) Priority Branch 1st 2nd 3rd 4th Total Completed 1986 1987 1985 1986 1987 Staff OL Div. 8-44 Adequacy of Station (3/9) 2 P58 0 1 2 0 3 0 0 0 6 3 0 7 Electric Olstribution i Voltage B-57 DHR Capability (5/6) 3 R58 2 3 0 0 5 0 0 0 6 0 8-59 Masonry Walt Design (0/26) 2 SCEB 6 2 3 3 14 12 12 0 14 12 0 1 0 11 B-60 Environmental Qual. (11/71) 1 EQ8 0 1 34 36 71 0 0 0 46 25 11

       -   (U5I;A-24)              10                     C58       0    10 0    0    10         0 1                     A58       0    1   0 0       1         0 B-65      Safety Concerns         (25/20)     1          ASB       25 0 0       0    25         0        0    0    20    0          22 Associated with                                AE8       22 0 0 0          22 Pipe Breaks in SWR Scras Systes B-66      Natural Circulation    (7/9)        2          R$8       0    3 4     0     7         0        0    0    2     7      0 Cooldown 3-68      ECC5 Pump                           Not Yet Deadheading                         Active

- b-69 PWR M5LB with (1/2) 1 C58 1 0 0 0 1 0 0 0 2 0 0 1 Continued Feed-water Addition 4 0 0

TABLE K K4 MULTIPLANT ACTION COMPLETION SCilEDULE l FYI985 l Schedule for Technical

• l Schedule for Technical Inputs to DL Actions Issued Review Performed by Projected Remaining by DL In- Contract Multi plant FY84 Carryover Review FY 1985 Inputs to be FY FY FY FY FY House Under Under MPA No. Action Title (Inputs /LAs) Priority Branch 1st 2nd 3rd 4th Total Completed 1986 1987 1985 1986 1987 Staff DL Div.

I 1 8-72 HUREG 0737 15 2 REG 17 19 19 19 14 0 0 0 40 34 0 54 (e20 in RII) i 8-75 Cracking of Core 1 MIE8 Barrell l I 8-76 Salen ATV5 Iten 1 LQB 0 0 81 0 81 0 0 0 0 0 3 81 1.1 Post Trip Rev.

 '8-77        Equip. Classification                             ICSB       0 0 0 0            0        131      131   0    0      0     0
              & Vendor Interface 8-78         Post Maintenance Test     N/A          1          Regions           HEGollATING Procedures
 *8-79        Post Maintenance Testing N/A           1          IC58              NEGOTIATING IDAll0 CONTRACT 8-80         Trip System Rellability N/A            1          Regions           NEG0!!ATING        .

8-81 Preventive Maintenance 1 EQB 0 29 25 0 54 54 0 0 0 0 0 0 54 Program for Reactor Trip Breaker 8-82 Item 4.3 in Generic Letter (20/33) 2 ICSB 11 2 4 3 20 0 33 29 4(051) 83-28 8-83 8-84

 *zchedule to be established in 3rd quarter of FY85.

s l l l i M-4.m . . ~ . m ,_e. . 3_........ m 2 ,_ ,;,. _ g g...:g ., .. n ,. ., .d - rdis,ryphkhM

                                                                                                                                          }                  v     v v

TABLE K K5 MULTIPLANT ACTION COMPLETION SCHE 0utE FY1985 Schedule for Technical l Schedule for Technical inputs to DL Actions Issued . Review Performed by Projected Remaining by DL In- Contract' l Multi plant Fys4 Carryover Review FY 1985 Inputs to be FY FY FY FY FY House Under Under MPA No. Action Title (Inputs /LAs) Priority Branch 1st 2nd 3rd 4th Total Completed 1986 1987 1985 1986 1987 Staff OL Div. C-07 Fuel Handling (2/2) 2 0R8#5 2 0 0 0 2 0 0 0 2 0 0 2 Accident Inside ' Containment C-10 Control of Heavy (16/19) 1 A58 1 10 4 1 16 0 0 19 5 toads Over Spent Fuel (USI:A-36) C-11 RP5 Power Supply (3/3) 1 P58 0 0 3 0 3 0 0 0 3 0 0 3 0 C-13 Loss of Of fsite Power Complete C-14 Auuillary Feedwater ORAS 4 5 0 0 9 5elsmic Qualificatten (7/21) A58 0 1 0 6 7 0 0 0 21 0 21 C-15 Phase 11 Heavy Loads 2 A5B 0 81 0 0 81 0 0 0 0 0 0 0-01 GE Mark I Containment (4/2) 1 MER 0 2 2 4 8 6 6 0 16 6 0 0 8 Evaluation Long Ters (U51:A-7) , 4 IC58 0 0 3 1 4 0 0 0-05 Plant UPI Model (6/6) 3 RSS 6 0 0 0 6 0 0 6 6 Probles a

u TA8tE K HutilPL ANI AC110N COMPLEllOr4 SCHEDULE fvi985 Schedule for Technical Review Performed by Schedule for Technical loputs to DL Actions issued Remaining _ J _ot In- contract Projected IV FY House Under Under Review FY 1985 Inputs to be FY fv lY Staff OL Div. . Multi plant fv84 Carryover Priority Branch 1st 2nd 3rd 4th lotal Completed 1986 19n1 1985 1986 1987 MP3 No. Action Title (Inputs /LAs)' 4 4 8 11 0 0 0 11 17 2 Mf8 1 D-10 Asymmetric LOCA (1657) Loads (U51:A-21) 0 11 2 0 0 O 11 1 2 ORA 884 0 2 6 5 13 , D-17 Definttlen of (3/3) Operable D-19 R58 E-04 BWR Single Loop ORABf2 Operation IC58 0 9 9 0 0 10

            .      (5 yr. old)                                                   CP8       0 0      1   0         1 (10/10) 0         0         0 0                3             R58       0    0 0 0
   'E-05           W N-1 Loop Operation                                           gcss     o o o o              o          3         3 se                                            3 HFE8 0          2         2 2                              A58       0 0 0 0                                   0 0 0 0 0             0          0 CP8 4     0       0       4 0 0 0        4       4 1.A.2.1 Upgrade              (4/4)              Past       . REG f-03 Training             ,

l.A.2.1.4 Modify Trng LS8 - A; views will be scheduled as licensee subalttals are received. ' CPS schedule to be deteralped by Lead PM. 6 I - "*

                                                                                                                                                                         "Y0'.

mg'~ , ~ '- . ( ) "1 "Y?' t T 'e D hi fl bk'Yi'Y h[, .? fYs k , h.l .

1 I I k I

   'l 5{I

• r 4 . t 3 l' h $=

J 43 ed e>. V=

     .I N

9 e = O W CO M S b C. es

      $ ,l                                 Q C b y)                             a= h        C &
                                 @ g b         u     Q .J
  'h i
              .                  euo                 co mg
   #                             >4 3 hue w an=          Gh
                                    >= D        f Wh es    C3 e m == ~0 ed
                                                    .m. to
        ..')                                             N V         lb= (D b e            w Cp O3                  me.

tim e a - e -s C he 3* we VC > M

                                     & C 43 4 ==

a w ed @ t to u > CD Q ( een O eo d:

   .y                                                    ~

U . > CD CO b CB

   %                                                .~
   .3                                       a

b. O >= e. -O g tem e M@

o - en W

  " *

• 43 me V I *@4 3 C,

On O e i w= C wC ** *e* l hh m J t. .C .de e n @N * [g w 9 9 D E E AC

    =&**                     =.e         W     eCU r

3 e a == , O C ) l W- w 4 .

                             =

4,,a v -

    ==                                   6                               @h                     mmNN m          >=               .m*              mh C

Z b >=

   '.*[]

3 w O.e O 2

                                                                                                                          )

g e-h

                                                   @ en                   @@                    OmMn a-                    tas          6         &w
                            =a         -           cn
  -yQ'at t         nd G.            3        M V                                                                     I E          t                6               e@                     OOOO
  ;-                    wO               e         >= m au              r.,       ta.

a3 v 7 885 42 m C til

• MCOO

                        >= O                            N
                           ==
                            *=                          en               m u                           *                *O

( a OO"O

                           ==

M Z 32

                            <                      wv
                            .4                    === CC                 CD ED      CD          ED (D CD CD C6                      D glm                 MM         M
                           ==                                                                   MMMM
     .' >f                 tus G bpA                 %rt to     to          4A go na go      e4d a

E G364 b Gm Go b & Gm On == M. ' >

c. en w

• k

            **                                          O                ** ed                                   ea
                                                       *                  = =

• 6 @W W e
• OO n= t. &.

h b O

              ,                                        bi                Q Gm                   4 4. A 4.        b f,
            ==                                     b ee D d UO(

wb . G M en Mu3 O C, mw t= w C OO mM

                                             & G me
       ,                                         >=w                m                      a=%

w N N *

            -*                                                      M                   em M                    ==
                                                                 *N                     eN wO                                              O On o CO
                                                                                       == e                      e 9Q                     s= Q                      u as w                   e i.e                     C
          *4                                     *J p
                                                       &        wW                     DM                        g .
          'e*,                                                  4       E              === 3                     E ed C **          4. $3 Z   end             3Z                       b u 4*                    to             Q
                                                 ==p=        *C       e

• O4

                                                                                                                ==

4 6 0m ee D>M b C6 e C b == e= ee u es C

                                                 == 0        3 ed .

es as- V e en em eC . G.== b te,4 == es a= ed e* ed & t= ik O to D QB CL 98, 3 W W W Ch @4 eb .b g K4 O C 3 m W @a 3 ye

          ',d'"

b & 4A M. N. E 4A

• CL Gm Q %me 8"94'1 N had quia Q tadG3 u m) ) had me O 1

e i Z

                                                           @                      w                             ps 4 O                         O b     o                      e                            O, 5%                          %                             %

TABLE K K8 MULTIPLANT ACTION COMPLETION SCHEDulf FY1985 Schedule for Technical Inputs to DL Schedule for Technical e Projected Actions issued Review Performed by Multi plant FY84 Carryover Remaining by DL Review FY 1985 In- Contract MPA No. Action Title e_(Inputs /tAs) Inputs to be FY FY FY FY FY llouse Under Under F-08 I.D.1 Control Room Priority Branc h 1st 2nd 3rd 4th Total _ Completed Design Review ( /6}) HfE8 2 13 8 10 33 1986 1987 1985 1986 1987 Staff Dt Div. 19 11 33 19 11 (Suppl., 1. NUREG-0737) F-09 1.D.2 Safety Parameter itFEB 3 27 23 7 60 Display System 71 2 (Suppl. 1, NUREG-0737) IC58 8 19 20 12 59 12 12 S w j j

l [ TABLE K K9 MULTIPLANT ACTION COMPLETION SCHEDULE FY1985 Schedule for Technical Schedule for Technical Inputs to DL Actions Issued Review Performed Uy Projected Remaining by DL Hulti plant FY84 Carryover Review In- Contract fY 1905 Inputs to be fY FY fY FY fY llouse Under Under HPA No. Action Title (Inputs /LAs) Priority Branch 1st 2nd 3rd 4th Total Completed 1986 1987 1985 1986 1987 f-11 11.8.2 Plant Shielding (1/1) Post REG 0 0 Staff OL Div. 1 0 1 0 0, 0 1 0 0 1 i 11.8.2.2 Modifications F-12 II.B.3 Post Accident Sampilng 11.8.3.2 Upgraded Post CE8 15 8 5 6 34 35 35 0 34 35 0 34 System F-13' 11.8.4 Training for (4/4) Post REG 0 0 0 4 4 Mitigating Core 4 0 0 4 Damage F-14 II.D.1 RV & SV Testing (15/17) BWR EQB 4 4 5 2 15 (BWR) 17 15 II.D.1.1 BWR Test Report Post- [QB 4 6 7 7 24 28(PWR) 28 20 32 II.D.I.2.a BWR Plant Unique Analysis , II.D.1.2.b PWR Test (52/52) Pre Hf8 Report 11.D.1.3 PWR Plant Pre HE8 Unique

TABLE K K10 HULilPLANI ACil0H COMPLEi!ON SCHEDULE FV1985 Schedule for Technical Schedule for Techn M 1 Inputs to DL Actions Issued Review Performed by Projected kemaining by DL In- Contract . Multi plant FY84 Carryover Review FY 1985 Inputs to be FY FY fY If FY House Under Under (Inputs /LAs) Priority Branch 1st 2nd 3rd 4th Total Completed 1986 1987 1985 1986 1987 Staff DL Olv. MPA No. Action Title Ibbpnd iy , 1 F-20 II.F.1.1 Noble Gas (0/1) Post ETSB 1 1 1 Monitor F-21 II.F.1.2 lodine /Partic Post ETSB Monitor . Post 6 5 0 11 F-23 II.F.1.4 Cont Press (0/11) CSB Monitor II.F.1.5 Cont. H y0 Post 6 5 0 11 F-24 (0/11) CSB Level Monitor II.F.1.6 Cont. H y0 Post 0 0 0 0 6 5 0 11 F-25 (1/11) CSB 1 1 Monitor

  . .s ,ry . v y, .           _- . .                             , , . , _ .
 ..t 2'     .          '.

• I  ! ,

bh 4 b %b '

• 5k" f., f h , f

                                              -,       , ,               . . vm                          -
                                                                                                                                                                                                                        -------R g    . , ,;' t: ..          :

TABLE K Kil MULTIPLANT ACTION COHPLET!ON SCHEDULE FY1985 Schedule for Technical Schedule for Technical Inputs to DL Actions Issued _ Review Performed by Projected Remaining by DL In- Contract FY84 Carryover Multi plant Review FY 1985 Inputs to be FY fY HPA No. FY FY FY House Under Under Action Title (Inputs /tAs) Priority B ranch 1st 2nd 3rd 4th intal Completed 1986 1987 1985 1986 1987 Staff OL Div. F-26 II.F.2 Inadeq. Core PWRa 1 0 4 5 10 42 16 16 8 16 16 Cooling (45/35) CPB 2 3 2 3 10 35 35 (45/35) ICSR 2 3 2 3 10 35 35, II.F.2.2 Water Level (28/28) Post CP8 28 28 0 28 0 F-36 II.K.3.1 PORV Isolation (0/1) Post IC58 0 1 0 F-37' II.K.3.2 Rpt on PORV (0/1) Post RRAB 0 0 0 0 0 0 0 1 0 F-38 II.K.3.3 Rpt SV/RV (0/1) Post ORBf3 0 0 0 0 0 0 0 1 Failures F-46 II.K.3.16 Chall/ Fall (0/22) Post R58 22 0 0 0 22 0 22 0 22 0 0 of RVS Report F-48 II.K.3.18 A05 Actuation II.K.3.18a Study (0/22) Complete 22

• II.K.3.18b Design 30 Post ICSB it.KU.18eModifications 5 Pre R58 6 0 0 0 6 0 0

hedul2 dependent ett outcome of R58 review of new Owners' Group submittal.

w

o K12 TABLF K HULTIPLANT ACTION COMPLETION SCitfDULE FYI985 Schedule for Technical . Actions issued Review Performed by Schedule for Technical inputs to OL by DL In- Contract Remaining Under Under Projected fy fy fy itouse Review FY 1985 Inputs to be FY TV Staff DL Div. Multi-plant FYB4 Carryover Completed 1986 p 87 1985 1986 1987 (Inputs /LAs)_ Priority Branch 1st 2nd 3rd 4th Total MPA No. Action Title 0 1 0 1 0 0 0 0 1 0 1 Post RSS 0 F-49 II.K.3.19 Interlock RCPs (1/1) 8 8 12 8 2 1 5 4 12 Post EQB F-55 II.K.3.28 Qual, of A05 Acc 0 50 3 3 (53/28) Pre R58 0 50 0 F-57 II.K.3.30b SB LOCA Methods 53 53 Pre R58 F-58 II.K.3.31 Compt w/10 CFR 50.46 Post Reg /IE Regions will issue audit reports which will complete action. F-63 Ill.A.1.2 Tech Supp. Ctr. Post Reg /IE Regions will issue audit reports which will complete action. F-64 III.A.I.2 Ops Supp. Ctr. . Post Reg /IE Regions will issue audit reports which will complete action. rp.65 Ill.A.I.2 Emergency AIB 1 0 0 0 1 HS Operations Facility 1 RAB Post AEB 1 0 0 0 1 F-67 III.A.2.1 Emerg Plan to Upgrade Rule "lE still develop additional review schedules.

                                                                                                                                                                                                               . gh'f             gg Map                   fh   f I:

• Iha I #

A ,, i

• h . .' , ; * ,
• e i

                                                                                                         ..~,.,a..~
                                                                                                            . .            sc l

e_*** p g, - ( ' ' . '

                                                                        )

K13 TABLE K HULilPLANT ACTION COMPLETION SCitfDULE FY1985 Schedule for Technical Schedule for Technical Inputs to DL Actions issued Review Performed by Remaining by DL ~ I n- Contract ~ Projected House Under Under FY84 Carryover Review FY 1985 Inputs to be FY FY FV FY FY Hulti plant Completed 1986 1987 1985 1986 198F Staff Dt Div. HPA No. Action iltle (Inputs /LAs) Priority Branch 1st 2nd 3rd 4th Total 0 IBD IBD 72 Post Reg. 0 0 0 0 0 72 IBD IBD

                  *F-68                  Ill.A.2.2 Het Data                  (72772)

HEIB F-70 III.D.3.4 CR Habibility Post 0 2 0 0 2 4 4 0 10 III.D.3.4.1 Design (6/10) AEB 49 4 4 0 45 3 0 51 RCP Trip (53/48) 1 R$8 0 31 0 18 G-01 TOTALS (/) .

            *IBO - to be determined.

S e

                                                                                                                    .e

QUESTION 21. (A) WHAT DOES THE COMMISSION AND NRC STAFF BELIEVE THE LIKELIHOOD OF.A SEVERE CORE MELT ACCIDENT TO BE IN THE NEXT TWENTY YEARS FOR THOSE REACTORS NOW OPERATING AND THOSE EXPECTED TO OPERATE DURING THAT TIME?

ANSWER, THE STAFF HAS AVAILABLE TO GUIDE ITS JUDGMENT ON THIS MATTER CLOSE TO TWO DOZEN PLANT- AND SITE-SPECIFIC PROBABILISTIC RISK ASSES 5MENTS (PRAS). THE MOST COMPLETE AND RECENT PRAS SUGGEST CORE-MELT FRE00ENCIES IN THE RANGE OF 10-3 PER REACTOR YEAR TO 10-4 PER REACTOR YEAR. A TYPICAL VALUE IS 3 X 10-4 . WERE THIS THE INDUSTRY AVERAGE, THEN IN A POPULATION OF 100 REACTORS 1

OPERATING OVER A PERIOD OF 20 YEARS, THE CRUDE CUMULATIVE PROBABILITY OF SUCH AN ACCIDENT WOULD BE 45%. COMMISSIONER ASSELSTINE ADDS THE FOLLOWING: THE PRA ESTIMATES GIVEN ABOVE HAVE SUBSTANTIAL UNCERTAINTIES THAT SPAN A FACTOR OF ABOUT 10 ABOVE AND BELOW THE PEPORTED VALUES. I BELIEVE IT IS MANDATORY THAT CONSIDERATION OF THESE UNCERTAINTIES BE FACTORED INTO ANY APPLICATION OF SUCH POINT ESTIMATES. THUS, THE CUMULATIVE PROBABILITY OF A CORE MELTDOWN ACCIDENT IN THE NEXT 20 YEARS, BASED ONLY ON PRA ESTIMATES AND THEIR UNCERTAINTIES, RANGES ANYWHERE FROM 0.99 TO 0.06.

4 . QUESTION 21(A) (CONTtNUED) .

ACTUARIAL EXPERIENCE WITH REACTOR ACCIDENTS INDICATES THAT THE -

b INDUSTRY AVERAGE CORE MELTDOWN FREQUENCY IS NOT AB0VE PER 10-3 REACTOR YEAR, CORE MELTDOWN ACCIDENTS INVOLVE MULTIPLE FAILURES AND A PROGRESSION OF EVENTS THAT MAKE CLOSE CALLS SOMEW' HAT EDENTIFIABLE, IF THE INDUSTRY AVERAGE OF THE CORE MELTDOWN ' FREQUENCY WERE AS HIGH AS 10-3 PER REACTOR YEAR, ONE WOULD EXPECT MORE CLOSE CALLS ON CORE MELTDOWNS THAN APPEAR TO HAVE OCCURRE'D WETHIN THE MORE THAN 800 REACTOR YEARS OF U.S. NUCLEAR POWER EXPER.IENCE.

                                                                                      ~

) IN RESPONSE TO CUESTION 21(G) REGARDING THE TECHNICAL BASIS FOR . THE COMMISSION'S CONCLUSION THAT THE RISK TO THE PUBLIC FROM CORE i MELTDOWNS IS CURRENTLY ACCEPTABLE, THE COMMISSION OFFERS AS AN ANSWER PAGES 85-131 0F NUREG-1070 "NRC POLICY ON FUTURE REACTOR DESIGNS: DECISIONS ON SEVERE. ACCIDENT ISSUES IN NUCLEAR POWER PLANT REGULATION", OCTOBER 1984. IN THAT NUREG, ON PAGE 106, IS l THE FOLLOWING STATEMENT RELATED TO THIS QUESTION (QUESTION 21(A)):

     "THERE IS A DISTINCT POSSIBILITY OF ONE OR MORE ADDITIONAL SEVERE REACTOR ~ACC'IDENTS, BEYOND THE ONE AT THREE MILE ISLAND, IN THE REMAINING SERVICE LIFE OF THE PLANTS NOW IN OPERATION OR UNDER t

CONSTRUCTION, UNLESS THE ESTIMATED ACCIDENT FREQUENCY DECLINES SHARPLY WITH MODIFICATIONS, OR HAS BEEN SIGNIFICANTLY OVERESTIMATED IN CURRENT PRA'S AND ACTUARIAL INFERENCES " ! CHAIRMAN PALLADINO ADDS THE FOLLOWING: i

                                   -QUESTION 21(A) (CONTINUED)                                                                     

TT SHOULD BE NOTED THAT ONLY A SMALL FRACTION OF S0-CALLED CORE-MELT ACCIDENTS WOULD HAVE MAJOR OFF-SITE CONSEQUENCES, FOR EXAMPLE, THE PROBABILISTIC RISK ASSESSMENTS PERFORMED TO DATE

 ~

INDI'CATE THAT THE RISK TO INDIVIDUALS FROM AN ACCIDENT IS MUCH S'MALLER THAN 3 X 10~ CORE-MELT ACCIDENT FREQUENCY STATED ABOVE -- 0FTEN BY SEVERAL ORDERS OF MAGNITUDE. THIS IS BECAUSE ONLY THOSE EVENTS WHICH INVOLVE FAILURE OF PEACTOR CONTAINMENT COULD RESULT IN SIGNIFICANT OFF-SITE RELEASES WHICH COULD HARM THE PUBLIC. i m E

QUESTION 21 (CONTfNUED) .

           ~

(B) WHAT IS THE RANGE OF ESTIMATED FREQUENCIES FOR SEVERE CORE DAMAGE OR CORE MELT ACCIDENTS PER

REACTOR YEAR ACCORDING TO PROBABILISTIC RISK

               ~

ASSESSMENTS AND ACCIDENT PRECURSOR STUDIES UNDERTAKEN BY THE COMMISSION AND WHAT IS THE DEGREE 0F CONFIDENCE IN SUCH ESTIMATES? ANSWER, THE RANGE OF CORE DAMAGE FREQU5NCY ESTIMATES IN THE LIBRARY OF ^ CURRENT PRAS COVERS ALMOST TWO ORDERS OF MAGNITUDE, ABOUT 10-5 pgg

  . YEAR TO 4X10-4 PER YEAR,       (PRAS HAVE ESTIMATED CORE MELT
                        ~

FREQUENCIES AS HIGH AS 6X10-3 PER YEAR BEFORE PRA-INSPIRED fMPROVEMENTS WERE MADE, BUT NONE REMAIN SO HIGH TODAY.) I A STUDY WAS MADE OF ALL LICENSEE EVENT REPORTS (LERS) FROM l 1969-1979 (THE PRECURSOR STUDY). THE LERS THAT APPEARED TO HAVE SOME RISK SIGNIFICANCE, GIVEN OCCURRENCE OF'THE EVENT, WERE EVALUATED USING PROBABILISTIC TECHNIQUES TO ESTIMATE THE LfKELIHOOD OF CORE MELT (lX10-3 TO 4x10-3 PER YEAR), INSIGHTS FROM THIS STUDY ARE NOT MUCH DIFFERENT FROM~THOSE OBTAINED FROM. PLANT SPECIFIC PRAS, IF ONE CONSIDERS IMPROVEMENTS THAT HAVE BEEN i IMPLEMENTED TO ADDRESS THE TMI ACCIDENT, THE BROWNS FERRY FIRE, THE RANCHO SECO TRANSIENT, AND THE AUXILIARY FEEDWATER l t i l

GUESTION 21 (CONTlNUED) IMPROVEMENTS REQUIRED AFTER THE IMI ACCIDENT. A SIMILAR PRECURSOR STUDY FOR THE 1980-1981 PERIOD (WHICH HAD ABOUT 60 PERCENT FEWER LERS) INDICATED A LOWER CORE MELT FREQUENCY (ABOUT 3X10~ PER YEAR) THAT COULD POSSIBLY REFLECT THE FIXES AFTER THE TMI

  ~

ACCIDENT.

BOTH PRA AND PRECURSOR-BASED ESTIMATES OF SEVERE CORE DAMAGE OR MELT ACCIDENT FREQUENCIES ARE SUBJECT TO SUBSTANTIAL UNCERTAINTIES. BOTH METHODS HAVE PESSIMISTIC (CONSERVATIVE)

BIASES. THE ESTIMATES ARE THOUGHT TO BE WITHIN A FACTOR OF 10 0F THE ACTUAL FREQUENCY. NOTE THAT IF THE INDUSTRY' AVERAGE SEVERE CORE DAMAGE FREQUENCY WERE 10-3 PER YEAR OR ABOVE, WE WOULD HAVE SEEN FAR MORE CLOSE CALLS THAN WE HAVE, S0.THIS IS AN ACTUARIAL UPPER BOUND ON THE AVERAGE. 4 Y 4 h

                   -             -                    -   ,           -~   ,

T - CUESTION 21 (CONTINUED) - 6-(C) WHAT, IF ANY, NUMERICAL RELIABILITY OR FAILURE RATE REQUIREMENTS EXIST FOR COMPONENTS AND SYSTEMS RELATED TO SAFETY AND HOW ARE ANY SUCH REQUIREMENTS

 ~

MONITORED AND ENFORCED?

ANSWER. j VERY LITTLE USE IS BEING MADE OF NUMERICAL RELIABILITY REQUIREMENTS. THE STANDAP.D REVIEW PLAN FOR DIESEL GENERATOPS ESTABLISHES A RELIABILITY G0AL OF 0.99 AND AN ACCEPTABLE 1 4 QUALIFICATION TESTING PROGRAM. THESE GUIDELINES ARE USED IN THE 1 ' OPERATING LICENSE REVIEW AND START UP TESTING. FOR PLANTS LICENSED AFTER 1978, GUIDANCE FOR PERIODIC TESTING OF THE DIESEL GENERATORS IS PRESENTED IN REGULATORY GUIDE 1.108, " PERIODIC i TESTING OF DIESEL GENERATOR UNITS USED AS ONSITE ELECTRIC POWER SYSTEMS AT NUCLEAR POWER PLANTS," WHICH IS REFERENCED IN THE f ' STANDARD TECHNICAL SPECIFICATIONS FOR THE PLANT. THIS GUIDANCE REFLECTS RELIABILITY GOALS FOR THE DIESELS. REGULATORY GUIDE 1.108 CONTAINS EXPLICIT ACCEPTANCE CRITERIA AND/OR DIESEL GENERATOR TEST FREQUENCIES BASED ON THE FAILURES OBSERVED. THESE REQUIREMENTS ARE ENFORCED AS PART OF THE IMPLEMENTATION OF THE TECHNICAL SPECIFICATIONS. THE STANDARD REVIEW PLAN FOR AUXILIARY FEEDWATER SYSTEMS IN PRESSURIZED WATER REACTORS CONTAINS AN UNRELIABILITY CRITERION THAT HAS BEEN IMPLEMENTED DURING THE OPERATING LICENSE REVIEWS t m _ ,v----m--- - ---.- , ,. -- . - - , . - - . - - - ~ . - v

QUESTION 21 (CONTfNUED)  : SINCE 1981. COMPLIANCE WITH THE UNRELIABILITY CRITERION IS BASED

ON'A STYLIZED ANALYTICAL PROCEDURE TO PROVIDE CONSISTENCY AMONG THERE IS NO FOLLOW-UP ACTIVITY TO MONITOR THE s - THE REVIEWS'.

AUXILIARY FEEDWATER SYSTEM UNRELIABILITY AFTER THE STAFF HAS MADE A DETERMINATION THAT THE SYSTEM MEETS THE ACCEPTANCE CRITERION. e e e i 4 e 1

QUESTION 21 (CONTINUED) f

                        ~(D) FOR EACH OPERATING REACTOR INDICATE THE EXTENT TO 1

WHICH IT COMPLIES WITH THE COMMISSION'S PROVISIONAL 4

  ~     ~~

j SAFETY GOALS. I. . i [ ANSWER. 4 i AT PRESENT, THERE IS NO COMPARISON BETWEEN ALL OPERATING REACTORS AND THE PROVISIONAL SAFETY GOALS BECAUSE PROBABILISTIC ASSESSMENTS l HAVE NOT BEEN PERFORMED FOR MOST PLANTS. RECENTLY WE HAVE MADE A LIMITED COMPARISON USING INFOPMATION FROM 16 PLANT SPECIFIC STUDIES AND SUPPLEMENTED WITH GENERIC SOURCE TERM WORK WHERE APPROPRIATE. THE 16 PRAS DIFFER IN SCOPE, METHODS, PURPOSE, COMPLETENESS, CURRENCY, AND ACCURACY. THESE ESTIMATES USE SOURCE TERM l ASSUMPTIONS FROM THE REACTOR SAFETY STUDY AND DO NOT REFLECT OUR I CURRENT UNDERSTANDING OF IMPROVED CONTAINMENT CAPABILITY. THIS ' i MAKES IT DIFFICULT TO DRAW CONCLUSIONS ON SAFETY GOALS FROM THEM. . i HOWEVER, THE COMPARISON SUGGESTS THE FOLLOWING RESULTS: l i l EIGHT OF THE 16 INDICATE AN EARLY FATALITY RISK BELOW THE [ CORRESPONDING SAFETY GOAL, WHILE THE REMAINING EIGHT HAVE

    ' UNCERTAINTY BANDS WHICH STRADDLE THE EARLY FATALITY GOAL.

j ALL 16 ARE WELL BELOW THE LATENT CANCER SAFETY GOAL. 1 1

QUESTION 21 (CONTINUED) - 9- ~ ~ ALL 16'HA'VE AN UNCERTAINTY BAND ON CORE MELT FREQUENCY THAT ST'RADDLES THE CORRESPONDING SAFETY GOAL, 10 " PER UNIT VEAR, NONE ARE UNAMBIGUOUSLY ABOVE OR BELOW THE GOAL, ALTHOUGH.SOME, BEFORE PRA-INSPIRED IMPROVEMENTS WERE MADE WERE WELL ABOVE THE GOAL, W e e o e e

L QUESTf0N 21 (CONTINUED)  ; I (E) INDICATE THE MANNER IN WHICH THE NRC STAFF AND COMMISSION RELIED ON NEW SOURCE TERM

  .                            INFORMATION IN DEVELOPING AND OR APPROVING THE NRC POLICY ON SEVERE ACCIDENTS.

1 ANSWER. i THE STAFF DID NOT USE A REDUCTION IN THE SOURCE TERM AS A BASIS l

;     FOR THE SEVERE ACCIDENT POLICY STATEMENT.                       THE POLICY WAS DEVELOPED, FOR THE MOST~PART, USING THE MANY RISK ASSESSMENTS DONE BY AND SUBSEQUENT TO THE REACTOR SAFETY STUDY (WASH-1400, NOW i

DESIGNATED NUREG-75/014). ESSENTIALLY ALL OF THESE USED OLDER, MORE PESSIMISTIC MODELS OF FISSION PRODUCT TRANSPORT. ONLY A FEW 1 LIKE ZION AND INDIAN POINT INCLUDED MORE CURRENT MODELS OF

IMPROVED CONTAINMENT PER-FORMANCE. THEREFORE, IT CAN BE FAIRLY l SAID THAT THE STAFF DID NOT DEPEND ON NEW SOURCE TERM INFORMATION l IN DEVELOPING THE POLICY. AS OF THIS DATE THE COMMISSION HAS NOT i

i VET GIVEN ITS FINAL APPROVAL OF THE SEVERE ACCIDENT POLICY: AN ! AFFIRMATION VOTE IS SCHEDULED AFTER INCORPORATION OF' CHANGES THAT 1 { HAVE BEEN IDENTIFIED BY THE COMMISSION. , t i COMMISSIONER ASSELSTINE HAS THE FOLLOWING COMMENT: ! AS WITH MANY COMMISSION DECISIONS, IT IS HARD TO PIN DOWN WHAT WAS AND WAS NOT RELIED UPON TO REACH A DECISION, I 0FFER THE

FOLLOWING COMMENTS THAT WERE MADE BY THE NRC STAFF ON OCTOBER 9, i

QUESTION 21 (CONTINUED) ' 1984 DURING THE LAST COMMISSICN MEETING ON THE SEVERE ACCIDENT

  ~

POLICY STATEMENT: MR. BERNER0: "AND THE LAST ITEM HERE, WE ANTICIPATE SOME REGULATORY CHANGES ARISING FROM THE SEVERE ACCIDENT

SOURCE TERM PROGRAM.

l'D LIKE TO EMPHASIZE HOW IMPORTANT IT IS THAT THE SEVERE ACCIDENT RISK JUDGMENTS WE'RE SPEAKING OF HERE,

                                                                                  ~

WHETHER FOR A NEW PLANT OR AN EXISTING PLANT, THAT THOSE BE BASED ON THE BEST AVAILABLE DATA WE HAVE ON SOURCE TERMS.

                  ~ WE'RE VERY TIGHTLY LINKED TO THE SOURCE TERM CONSIDERATIONS IN THE ASSESSMENT OF SEVERE ACCIDENT RI.SK.
              .      NOW, SOME REGULATORY CHANGES THAT WOULD EVOLVE FROM THAT GROUP WOULD BE OF AN ADMINISTRATIVE NATURE, OTHERS WOULD BE VERY SUBSTANTIVE.

~ BUT IT'S IMPORTANT THAT WE NOTE THAT SEVERE ACCIDENT

                   ~

[- RISK DECISIONS ANTICIPATED IN THIS POLICY STATEMENT WOULD TAKE ADVANTAGE OF THE PROPERLY REVIEWED SOURCE TERM INFORMATION DEVELOPED IN RECENT YEARS." d J

l L GUESTf0N 21 (CONTINUED) - (F) TO THE EXTENT THAT THE NRC STAFF AND COMMISSION RELIED ON NEW SOURCE TEPM INFOR-  ;

          ~

MATION IN DEVELOPING AND OR APPROVING ITS POLICY ON SEVERE ACCIDENTS, SPECIFY HOW AND TO WHAT EXTENT THE UNCERTAINTIES IN ,

       ~

NRC'S KNOWLEDGE OF ACCIDENT SOURCE TERMS, l I AS HIGHLIGHTED BY THE RECENT REPORT OF THE AMERICAN PHYSICAL SOCIETY, WERE TAKEN INTO ACCOUNT. ANSWER, t AS NOTED ABOVE, THE STAFF DID NOT RELY ON NEW SOURCE TERM INFORMATION IN DEVELOPING ITS PROPOSED POLICY ON SEVERE ACCIDENTS.  ! I

 ~

COMMISSIONER ASSELSTINE ADDS: I COMMISSIONER ASSELSTINE'S COMMENT TO QUESTION 21(E) APPLIES HERE AS WELL. l l l l

QUESTTCN 21 (CONT!NUED) (G) IS THERE A TECHNICAL BASIS FOR CCNCLUDING THAT THE RISK TO THE PUBLIC FROM SEVERE I ACCIDENTS INCLUDING CORE MELTDOWN AT EXISTING REACTORS IS CURRENTLY ACCEPTABLE? ANSWER. YES. IMPORTANT ASPECTS OF THE TECHNICAL BASIS FOR REACHING THE CONCLUSION THAT THE RISK TO THE PUBLIC FROM SEVERE ACCIDENTS INCLUDING CORE MELTDOWN AT EXISTING REACTORS IS CURRENTLY ACCEPTABLE IS PROVIDED IN NUREG-1070, CITED ABOVE. MOST OF THIS BASIS IS DESCRIBED IN THE EIGHT CHAPTERS 0F APPENDIX A (PP. 85-131), THAT COLLECTIVELY DESCRIBE " CURRENT INFORMATION BEARING ON THE NEED FOR GENERAL DESIGN CHANGES OR FURTHER REGULATORY CHANGES AFFECTING NUCLEAR POWER PLANTS."

 'lN PARTECULAR, PART IV 0F APPENDIX A ON " PERSPECTIVES ON THE NEED TO REDUCE SEVERE ACCIDENT RISK DRAWN FROM PROBABILISTIC RISK ASSESSMENT" PROVIDES USEFUL INSIGHTS ON THE UPPER LIMITS CF RISK TO THE PUBLIC. A VARIETY OF PESSIMISTIC ASSUMPTIONS DESCRIBED THERE ALL SHOW THAT THE EXPECTED NUMBER OF CASUALTIES PER REACTOR YEAR MUST BE VERY LOW.

THE COMMISSICN CONCLUSION THAT EXISTING PLANTS POSE NO UNDUE RISK TO THE PUBLIC IS A CONDITIONAL JUDGMENT REQUIRING ORDEPLY

OVESTION 21 (CONTINUED) - lu - l

     ' CONCLUSION OF SEVERE ACCIDENT WORK AS DESCRIBED IN CHAPTER 4 0F NUREG-1070 AND ELSEWHERE.
   ~
 ~

COMMISSIONER ROBERTS ADDS: ON THE BASIS OF CURRENTLY AVAILABLE INFORMATION, INCLUDING NRC AND INDUSTRY-SPONSORED RESEARCH AS WELL AS DATA ARISING FROM CONSTRUCTION AND OPERATING EXPERIENCE, COMMISSIONER ROBERTS CONCLUDES THAT EXISTING PLANTS POSE NO UNDUE RISK TO PUBLIC SAFETY AND' PROPERTY. HE SEES NO PRESENT BASIS FOR IMMEDIATE ACTION'ON - GENERIC RULEMAKING OR OTHER REGULATORY CHANGES FOR THESE PLANTS BECAUSE OF SEVERE ACCIDENT RISK. COMMISSIONER ASSELSTINE ADDS: THE COMMISSION'S RESPONSE BOILS DOWN TO THE!P JUDGEMENT THAT PLANTS ARE SAFE ENOUGH BECAUSE A CORE MELT ACCIDENT CAUSING PROMPT OFFSITE FATALITIES IS UNLIKELY TO OCCUR. THE COROLLARY OF THIS

                                                                                                              ~

i JUDGEMENTISTHECONCLUDIONTHATLITTLESHOULDBEDONETOPgEVENT j THOSE MORE LIKELY ACCIDENTS, INCLUDING ACCIDENTS SIMILAR TO THE TMI ACCIDENT. THE COMMISSION SHOULD CONTINE ITS EFFORTS TO PREVENT'SUCH ACCIDENTS AND TO MITIGATE THEIR POTENTIAL CONSEQUENCES. MORE0VER, THERE ARE ENORMOUS UNCERTAINTIES IN THE l ESTIMATED CORE MELTDOWN RISKS TO THE PUBLIC. SCIENTIFICALLY I ACCEPTED DATA AND METHODOLOGY ARE NOT IN HAND TODAY TO SUBSTANTIALLY REDUCE THOSE UNCERTAINTIES. THUS, I BELIEVE IT IS MANDATORY TO CONSIDER FORTHRIGHTLY THOSE UNCERTAINTIES !N REACHING ANY CONCLUSION ON THE ACCEPTABILITY OF THE CORE MELTS 0WN RISKS. l

 ,                                                                                                                                                                                                          1 i           QUESTION 21 (CONTINUED)                                                                                                                                                                                                                                                                                              t 5
           .THE COMMISSION HAS YET TO FORMULATE A COHERENT APPROACH TO ADDRESSING THE UNCERTAINTIES.                                                                             UNTIL THIS IS DONE, I BELIEVE THERE 1

IS NO JUSTIFIABLE TECHNICAL BASIS FOR CONCLUDING THAT THE CORE I MELTDOWNRISKSAR$ACCEPTABLEFORTHELONGTERM.

t J I I l 1 1 1 t i I i a i 1 -t i l 3 1 I- . .

QUESTION 21 (CONTfNUED) , . . m

                                                                         ~

(H) WHAT IMPACT WILL THE CONCLUSION THAT THE RISK TO

              ~:   

THE PUBLIC FROM SEVERE ACCIDENTS INCLUDING ~ CORE " ~ '

                 -        MELTDOWN AT EXISTING REACTORS IS CURRENTLY ACCEPTABLE HAVE UPON THE MERITS OF AND REGULATORY RESPONSE TO UNPESOLVED SAFETY ISSUES AND GENERIC SAFETY ISSUES?

ANSWER. SAFETY CONCERNS CAN HAVE A WIDE RANGE OF DEGREES OF SERIOUSNESS. A CONCERN MAY BE SERIOUS ENOUGH THAT IN DUE PRUDENCE A PLANT MUST NOT BE ALLOWED TO OPERATE, EVEN FOR A SHORT TIME, BEFORE THE CONCERN IS RESOLVED, BY PLANT OR OPERATIONAL CHANGES OR BY DEVELOPMENT OF INFORMATION SHOWING THE SERIOUS CONCERN TO BE UNWARRANTED. HOWEVER, PLANTS ARE ALSO SUBJECT TO SAFETY CONCERNS THAT, THOUGH WARRANTING INTENSIVE ATTENTION AND EFFORTS TO RESOLVE, REPRESENT RISKS AND UNCERTAINTIES MODERATE ENOUGH TO BE CONSISTENT WITH ACCEPTABILITY OF THE OVERALL RISKS OF OPERATION. SAFETY RISKS OF REACTOR OPERATION ARE NOT SUBJECT TO PRECISE MEASUREMENT AND A RIGID DEMARCATION LINE BETWEEN SAFE ENOUGH AND DEMANDING SAFETY IMPROVEMENT. THOUGH THE COMMISSION IS CURRENTLY ATTEMPTING TO DEVELOP EXPLICIT SAFETY GOALS THAT WOULD ENHANCE THE COHERENCE OF JUDGMENTS AS TO SAFETY ADEQUACY, SUCH JUDGMENTS ARE NOT MATTERS OF CERTAINTY, BUT OF STRIVING FOR RECOGNITION OF SIGNIFICANT ISSUES AND THEIR COST-EFFECTIVE RESOLUTION.

CUESTION 21 (CONTINUED) ,

I i

      'IN VIEW'0F THE ABOVE CONSIDERATIONS, THE COMMISSION'S EFFORTS TO RESOLVE-UNRESOLVED SAFETY ISSUES AND GENERIC SAFETY ISSUES WILL
                                                                                 ~

l' NOT DIMINISH SY VIRTUE OF ITS GENERAL CONCLUSION ABOUT THE ACCEPTA'BILITY OF CURRENT SEVERE ACCIDENT PISKS. SHOULD THE RESULTS OF THESE RESOLUTION EFFORTS WARRANT, SEVERE-ACCIDENT. SAFETY REQUIREMENTS MAY BE STRENGTHENED OR RELAXED. MORE0VER, SAFETY ISSUES ARE SCREENED FOR ANY CONCERN SEVERE ENOUGH TO 1 , REQUIRE PROMPT ACTION; SUCH ACTION, WHERE INDICATED, IS TAKEN IN A i TIMELY MANNER, WITHOUT AWAITING RESULTS OF LONGER-TERM EFFORTS. COMMISSIONER ASSELSTINE ADDS: l THE ' CORE MELTDOWN RISK IS THE FOREMOST RISK TO THE PUBLIC. FROM THE OPERATION OF NUCLEAR REACTORS. I BELIEVE THE COMMISSION'S SEVERE ACCIDENT POLICY STATEMENT AND ITS DECISION ON THE INDIAN POINT SPECIAL PROCEEDING SEND A MESSAGE TO THE STAFF THAT THE COMMISSION l ' BELIEVES THE EXIST!NG REACTORS ARE FINE AS THEY ARE. GIVEN THESE DECISIONS, I SUSPECT NOT MUCH WILL COME.0UT OF THE " RESOLUTIONS" 0F THE USI'S OR THE HIGH PRIORITY GENERIC SAFETY ISSUES, BUT I 4 HOPE THAT THE STAFF CONTINUES ITS DILIGENT SEARCH FOR RISK

REGULATION MEASURES.

4 I i l

QUEST 10N 22. THE U. S. GEOLOGICAL SURVEY HAS INFORMED THE NRC OF INFORMATION CONCERNING SE!SMIC RISK IN THE EASTreN UNITED STATES BASED ON REVIEW OF THE CHARLESTON, SOUTH CAROLINA EARTHQUAKES IN THE 1800s. PLEASE PROVIDE THE FOLLOWING INFORMATION: 1

    .            (A)  THE PLANT SITES POTENTIALLY AFFECTED; ANSWER.

WE ASSUME THAT THE "!NFORMATION" REFERRED TO BY THE SUBCOMMITTEE fS THE LETTER OF NOVEMBER 18, 1982, FROM JAMES F. DEVINE, OF THE UNITED STATES GEOLcGICAL SURVEY (USGS) TO RCBERT E. JACKSON OF THE

NRC IN WHICH THE LETTER STATED

      "BECAUSE THE GEOLOGIC AND TECTONIC FEATURES OF THE CHARLESTON REGION ARE SIMILAP TO THOSE IN OTHER REGIONS OF THE EASTERN SEABCARD, WE CONCLUDE THAT ALTHOUGH THEPE IS NO RECENT OR HISTORICAL EVIDENCE THAT OTHER REGIONS HAVE EXPERIENCED STRONG EARTHQUAKES, THE HISTORICAL RECORD IS NOT, OF ITSELF, SUFFICIENT GROUNDS FOR RULING OUT THE OCCURPENCE IN THESE OTHER REGIONS OF STRONG SEISMIC GROUND MOTIONS SIMILAR TO THOSE EXPERIENCED MEAR CHARLESTON IN 1886. ALTHOUGH THE PROBABILITY OF STRONG GROUND MOTION DUE TO AN EARTHQUAKE IN ANY GIVEN YEAR AT A PARTICULAR

QUESTION 22 (CONTINUED) t LOCATION IN THE EASTERfl SEABOARD MAY BE VERY LOW, DETEPMINISTIC

               ~

AND PROBABILISTIC EVALUAT!CNS OF THE SEISMIC HAZARD SHOULD BE MADE FOR INDIVIDUAL SITES IN THE EASTEPN SEABOARD TO ESTABLISH THE SEISMIC ENGINEERING PARAMETERS FOR CRITICAL FACILITIES." THE PLANT SITES POTENTIALLY AFFECTED INCLUDE THOSE IN THE APPALACHIAN PIEDMONT AND ATLANTIC COASTAL PLAIN (AS THE EASTERN SEABOARD IS DEFINED IN THE USGS LETTER). THE SPECIFIC SITES ARE LISTED IN THE TABLE IN THE RESPONSE TO QUESTION 228. l 9 i

                                                                                            . _ _ __._. _ _ _ _ _ ~ . _ .

QUESTION 22 (CONTINUED) ' ~ B. A LIST OF ALL PLANT SITES INCLUDING (1) THE OBE (2) THE SSE, (3) THE TYPE OF FOUNDATION, (4) THE ~ l ESTIMATED FREGUENCY OF PECURRENCE FOR THE OBE AND t

        .                                           SSE, AND (5) THE MAXIMUM ESTIMATE OF GROUND MOVEMENT FOR THE SITE.      TH!S LIST SHOULD ACCOUNT                               i

~ ~ FOR THE NEW INFORMATION'AND EXPLAtN NRC'S DEGREE OF CONFIDENCE IN THESE ESTIMATES. ANSWER. . , i THE FOLLOWING TABLE RESPONDS TO POINTS (1), (2) AND (3), i p P P h l l I l 1 f

QUESTION 22 (CONTINUED) SEISMIC DESIGN BASES FOR U. S. NUCLEAR POWER PLANTS

      -                                         EASTERN SEABOARD A. -0PERATING REACTORS PLANT                                SSE**         .QE*

• FOUNDATION -

1. BRUNSWICK 0.16G 0.08G S0IL .

2. CALVERT CLIFFS 1 a 2 0.15G 0.08G S0IL

3. CATAWBA 1 & 2 0.15G 0.08G ROCK

4. CRYSTAL RIVER 0.10G 0.05G ROCK

5. FARLEY 0.10G 0.05G ROCK

6. HADDAM NECK

• 0.17G NONE ROCK (CONNECTICUT YANKEE) l 7. HATCH 1 & 2 0.15G 0.08G S0ll

8. INDIAN POINT 2 8 3 0.15G 0.10G ROCK l

l 9. LIMERICK 0.15G 0.075G POCK

10. MAINE YANKEE 0.10G 0.05G ROCK

11. MCGUIRE 1 a 2 0.15G 0.08G P0CK l

12. MILLSTONE l' O.17G 0.07G ROCK MILLSTONE 2 0.17G 0.09G ROCK l 13. NORTH ANNA 1 8 2# 0.12G 0.06G ROCK l

0.18G 0.08G SOIL l 14. OCONEE 1-3# 0.10G 0.05G ROCK 0.15G 0.05G S0IL .

15. 0YSTER CREEK

• 0.22G - 0.11G S0!L

16. PEACH BOTTOM 1-3 0.12G 0.05G ROCK  !

17. PILGRIM 1 0.150 0.08G S0IL l l 18. ROBINSON 2 -0.20G 0.10G S0IL

        - ~ ~_                 _____________                ___x          _             - ____ - -_____

OUESTION 22 (CONTINUED) l l PLANT SSE** OBE" FOUNDATION

20. ST LUCIE 1 8 2 0.10G 0.05G S0Il

21. V. C. SUMMER # 0.15G 0.10G ROCK 0.25G 0.15G S0ll 22 ~ SUPP.Y 1 8 2 0.15G 0.07G S0ll

23. THREE MILE ISLAND 0.12G 0.06G ROCK 182 l 24. TURKEY POINT 1-3 0.15G 0.05G ROCK

25. VERMONT YANKEE 0.14G 0.07G ROCK

! 26. YANKEE R0WE' BUILDING NONE S0ll CODE POST CONSTRUCTION PERMIT

27. HOPE CREEK 1 8 2 0.20G 0.10G S0ll

28. MILLSTONE 3 0.17G 0.09G ROCK l

29. SEABROOK 0.25G 0.13G ROCK

   ?0. SHEARON HARRIS            0.150      0.08G      ROCK

31. SHOREHAM 0.20G 0.10G S0ll i

32. V0GTLE 1 8 2 0.20G 0.12G S0IL THESE PLANTS UNDERWENT SEISMIC REEVALUATION AS PART OF NRC SPONSORED SYSTEMATIC EVALUATION PROGRAM.

SSE AND OBE ARE HORIZOMTAL PEAK ACCELERATION VALUES, VARIOUS DESIGM RESPONSE SPECTRA WERE ANCHORED TO THESE VALUES.

   # PLANTS.WITH TWO DESIGft VALUES TO REFLECT BOTH POCK AND S0IL     -

C0f!DIT10NS AT THE SITE.

CUESTION 22 (CONTINUED) (4) THE ESTIMATED FRECUENCY AND RECURRENCE FOP THE OBE AND SSE BASED UPON SEVERAL LIMITED STUDIES THE AVERAGE FREQUENCY OF RECURRENCE OF THE SSE AT THE NUCLEAR POWER PLANT SITES LISTED ABOVE IS ESTIMATED TO BE ON THE ORDER OF ONCE IN A THOUSAND YEARS TO ONCE IN TEN THOUSAND YEARS. SIMILARLY THE AVERAGE FREQUENCY OF RECURRENCE OF OBE AT THESE PLANTS IS ESTIMATED TO BE ON THE ORDER OF ONCE IN HUNDREDS OF YEARS. ESTIMATION OF

                                                                    ~

RECURRENCE FREQUENCIES IS UNCERTAIN AND IS NOT A LICENSING REQUIREMENT. THEPEFORE, SOME OF THE PLANTS LISTED MAY BE ASSOCIATED WITH SHORTER OR LONGER RECURRENCE INTERVALS. A SYSTEMATIC PROBABILISTIC PROGRAM AIMED AT ESTIMATING FREQUENCY OF EARTHOUAKE RECURRENCE AT NUCLEAR POWER PLANTS IS DESCRIBED IN RESPONSE TO QUESTION 22C. (5) THE MAXIMUM ESTIMATE OF GROUND MOVEMENT FOR THE SITE THE SSE PEAK ACCELERATION VALUES LISTED ABOVE AND THEIR ASSOCIATED DESIGN RESPONSE SPECTRA REPRESENT THE MAXIMUM EARTHQUAKE VIBRATORY GROUND MOTION USED IN THE DESIGN OF EACH NUCLEAR POWER PLANT. SINCE THEY ARE DETERMINISTIC ENGINEERING DESIGN VALUES THEY DO NOT NECESSARILY REPRESENT MAXIPUM POSSIBLE GROUND MOTIONS FROM AN EARTHQUAKE OF ANY SIZE. RANGES OF MAXIMUM POSSIBLE GROUND MOTIONS MAY BE ESTIMATED IN PROBABillSTIC STUDIES SUCH AS THOSE DESCRIBED IN RESPONSE TO QUESTION 22C.

         .9 QUESTION 22 (CONTINUED)                                                                                  l l

l (C) A DESCRIPTION OF THE ACTIONS THE NRC HAS TAKEN TO RESPOND TO THIS ISSUE AND WHAT RESEARCH PRCGPAMS ARE CURRENTLY UNDERWAY, ANSWER. IN A COMMISSION PAPER DATED FEBRUARY 5, 1982 (SECY-82-53), THE STAFF INFORMED THE COMMISSION OF THE POSSIBILITY OF MODIFICATIONS IN THE USGS POSITION AND IN A MEMORANDUM DATED NOVEMBER 19, 1982, I THE USGS CLARIFICATION WAS FORWARDED TO THE COMMISSION ALONG WITH A STAFF ASSESSMENT OF ITS SIGNIFICANCE AND A PRELIMINARY PLAN TO ADDRESS IT. THIS PLAN WAS DISCUSSED WITH THE COMMISSION IN ITS NOVEMBER 19, 1983 MEETING AND A COMPREHENSIVE PROGRAM PLAN WAS DEVELOPED, THE PLAN CONSISTS OF A PROBABILISTIC PROGPAM THAT HAS AS ITS CORE A LAWRENCE LIVERMORE NATIONAL LABORATORY (LLNL) ESTIMATION OF SEISMIC HAZARD AT ALL NUCLEAR POWER PLANT SITES EAST OF THE ROCKY MOUNTAINS, AND A DETEPMINISTIC PROGRAM TO DETERMINE THE CAUSES'0F LARGE EARTHOUAKES, SUCH AS THE CHARLESTON EARTHOUAKE, IN THE EASTERN SEABOARD, THE PURPOSE OF THE PROBABILSITIC PROGRAM IS TO IDENTIFY PLANTS (IF ANY) IN THE EASTERN SEABOARD AT WHICH THE PROBABILITY OF EXCEEDING DESIGN LEVEL GROUND MOTION IS SIGNIFICANTLY GREATER THAN HAS BEEN ASSUMED AT OTHER LOCATIONS, SUCH AS THE CENTRAL

                                                                     ~

GUESTION 22 (CONTINUED) STABLE REGION OR THE GULF COASTAL PLAIN. IN ADDITION, THE UTILITY INDUSTRY, THROUGH THE ELECTRIC POWER RESEARCH INSTITUTE (EPRI), HAS UNDERTAKEN AN EXTENSIVE PARALLEL PROGRAM TO DEVELOP A METHODOLOGY FOR CALCULATING SEISMIC HAZARD. l THE PURPOSE OF THE DETERMINISTIC PRCGRAM IS TO STUDY AREAS OF l RELATIVELY HIGHER SEISMICITY, AS PRIMARILY IDENTIFIED BY SEISMIC - NETWORKS, IN THE EASTERN SEABCARD TO DETERMINE IF TECTONIC FEATURES AND PROCESSES RESPONSIBLE FOR THE SEISMICITY CAN BE IDENTIFIED AND CORRELATED. THIS IS BEING PURSUED BY CRUSTAL STUDIES, AT DEPTHS AT WHICH EARTHQUAKES OCCUR, TO DETERMINE IF THERE IS A CORRELATION BETWEEN CRUSTAL STRUCTURES AT THESE DEPTHS AND EARTHQUAKE LOCATIONS. IN ADDITION, STUDIES TO IDENTIFY GEOLOGIC EVIDENCE OF PREHISTORIC EAPTHOUAKES ARE UNDERWAY. MOST - SIGNIFICANTLY, SEVERAL TEAMS OF INVESTIGATORS, MAINLY FUNDED BY NRC, HAVE FOUND SUCH EVIDENCE (PALE 0 LIQUEFACTION) IN THE CHARLESTON AREA. THIS IS THE FIRST GECLOGIC EVIDENCE THAT MAY INDICATE THE OCCURRENCE OF LARGE TO MODERATE EARTHQUAKES IN THE l EASTERN SEABOARD IN PREHISTORIC TIMES. IT IS POSSIBLE THAT A SEISMIC RECURRENCE INTERVAL FOR LARGE EARTHOUAKES IN THE CHARLESTON AREA MAY BE DEVELOPED AND THAT A DETERMINATION CAN BE MADE AS TO WHETHER OR NOT THIS AREA IS SEISMICALLY UNIQUE. THESE CONCLUSIONS AWAIT FURTHER INVESTIGATIONS AND ASSESSMENT.

QUESTION 23. ACCORDING TO THE AMERICAN NUCLEAR SOCIETY (ANS), ITS SEPTEMBER 1984 REPORT ON NUCLEAR ACCIDENT SOURCE TERMS WAS PREPARED WITH THE ASSISTANCE OF NRC FUNDS (NRC-G-04-81-001). (A) PLEASE INDICATE THE AMOUNT OF THE INITIAL

  ~

GRANT, ALL SUBSEQUENT AMENDMENTS, TOTAL EXPENDITURES AND THE SERVICES RENDERED FOR

  ~

EACH. PLEASE PROVIDE ALL DOCUMENTS IN THE GRANT FILE. ANSWER,

             .                                                                I IN JANUARY 1980 THE NRC AND THE IEEE SPONSORED A CONFERENC    ON THE UTILIZATION OF ADVANCED PRA TECHNOLOGY IN REACTOR SAFETY.      AS A RESULT O'F THAT CONFERENCE,.IT WAS DECIDED BY THE NRC TO AWARD A GPANT'TO THE IEEE TO DEVELOP A PRA PROCEDURES GUIDE. SUBSEQUENT
      'DISCUSSICNS DEVELOPED THE NECESSITY TO BRING A NUCLEAR REACTOR
                                                                            ~

TECHNOLOGY PERSPECTIVE TO AUGMENT THE ENGINEERING PERSPECTIVE OF IEEE AND IT WAS DETERMINED THAT THE ANS WOULD PROVIDE THAT PE'RSPECTIVE, DISCUSSIONS WERE THEN INITIATED TO PROVIDE GRANTS TO BOTH IEEE AND ANS, ON JANUARY 26, 1981, RES PROVIDED A $228K GPANT TO ANS FOR'THE PREPARATION OF A PRA PROCEDURES GUIDE. THIS GRANT WAS SUBSE-QUENTLY INCREASED TO ABOUT $305K DURING THE PERIOD OF AUGUST 1981

QUESTION 23(A). (CONTINUED) . TO JANUARY 1982. THE ANS GRANT WAS IN CONJUNCTION WITH A GRANT OF $258K TO THE IEEE FOR JOINT WORK ON THE PRA PROCEDURES GUIDE. IHE PRA PROCEDURES GUIDE (NUREG/CR-2300) WAS COMPLETED BY ANS AND PUBLISHED IN JANUARY 1983. BOTH ANS AND IEEE MADE MAJOR CONTRIBUTIONS TO THE GUIDE. ON JULY 15, 1982, ANS REQUESTED A NO-COST EXTENSION AND MODIFI-CATION TO THIS GRANT TO PERFORM PERIODIC REVIEWS OF NUREG/CR-2300 AND TO DEVELOP A WHITE PAPER ON THE DETERMINATION AND USE OF ACCIDENT RELATED RADIOLOGICAL SCURCE TERMS. THE SOURCE TERM

 ~(CONTAINMENT EVENTS) CHAPTER OF NUREG/CR-2300 WAS A SOURCE OF SOME CONTROVERSY AT THAT TIME BECAUSE OF THE CHANGING STATE OF SOURCE TERM RESEARCH.                                             -

TOTAL FUNDING FOR THE ANS WHITE PAPER ON SOURCE TERMS WAS PROVIDED BY EPRI, DOE, AND NRC (THE NRC INCREMENTAL FUNDING TOWARD THIS EFFORT FROM THE GRANT WAS $138K). THE ANS WHITE PAPER WAS PUBLISHED IN SEPTEMBER 1984 AS A " REPORT OF THE SPECIAL

                                                          ~

COMMITTEE ON SOURCE TERMS." A COPY OF THE GRANT FOR ANS IS ATTACHED. i l

I i QUESTION 23(A). (CONTINUED) i

     ' DOCUMENT'CHRON0 LOGY FOLLOWS FOR THE ANS GRANT:

MOD DATE NUMBER PURPOSE

     -01/26/81   BASIC GRANT      DEVELOPMENT OF PROCEDURES GUIDE AWARD 08/05/81  MOD #1           ADDED FUNDS /NO WORK SCOPE CHANGE 01/04/82  MOD #2           ADDED FUNDS /NO WORK SCOPE CHANGE 4

08/12/82 MOD #3 EXTENDED PERIOD OF THE GRANT 10/28/82 MOD #4 WORK SCOPE CLARIFICATION AND CHANGE (ADDED SOURCE TERM WHITE PAPER) 02/15/85 MOD #5 EXTENDED PERIOD OF T.,E GPANT TO ALLOW COST CLOSE0VT ON THE COMPLETED WORK m S 9

l

           *Aopendix G of SECY-85-48 dated 2/7/85,                                                                         l Status of' Audit Reports Over Six Months Old                Acrendix G,                                         i Pa.ge 1 o' 2                                       '

Survev o# the Of# ice e' Colicv EvaluP*ior __ _ . . _ . . _ _ . Th.it- report was issued on July 26, 1983, and containad 11 recomendations. it wes not transmitted in-draft to the Office n' policy Evaluation (PE) *nr coments bacause of CI A's shcrt deadline te have the report to the Cm-ission. Five of the 11 recce,erdations recuired action by the Crmission. The Ccmicsion vcted on the #ive recomendations ard the majority enreed tn ie;31erent twc recomendat ons. Acccrdingly, we are closine the other th ree i recomeadations. directed to the Comission. Mcwever, en Aucust 13, 1983, the Director, PE, respended to 01A's recomerdatiers directed to PE. Follow-up work-will-be cerforred in the future to ascertain the status of the eicht noen recermendaticns. Comission Directed Recorrendations . ._ . _ . . . _ _ _ Provide PE with a statement of the rnie and " unctions desired of PE. We~ suggest usino the 1979 point paper as a starting point. ~ Reconsider the 1980 rotation onlicy in licht of PE's hich turnover rate and either reaffim, ecdify or rescind the policy and advise accropriate NQC officials of its decision. PE Directed Recomendations . 1 We recomend that PE, using the Commission's guidelines on PE's role and functions, update the appropriate sections of the NRC Manual and the Code o#~ ' Federal Regulations, as needed, and prepare forral operating procedures to carrf out PE's functions. We suggest that a copy of the procedures be provided to the Comission. PE Resoonse _. The Director, PE, stated that he was prepared to ievise the aporopriate

       . sections of the NRC manual and prepare formal operating procedures to carry                                       1
      - out PE's functions based on any new guidance the Comissinr tray give on PE's                                       '

role and functions. He pointed out PE's priorities have been changing as work related to the safety goal and the waste confidence proceeding has been winding down. He said the office now has more rescurces to allocate to the review of the Commission papers and is doing so and PE will continue to respond to Comissioner requests in a timely manner. . . Recomendation , We recommend that PE prepare and submit to the Comission for aporoval, annual operating plans for PE's activities, and reevaluate the plans at least semi-annually and provide a cooy of the updated . plans to the Comission. PE Resoonse

  - :    The Director, PE, stated that he was prepared to do this if the Commission so desired.
                                           ,4

Aappadir G - 1

• Page 2 n# 2 /

Decerre-?ation

      . Ins-itt'e a #nrrel record keerino systen tha . will 71'0w DE to accurulate th?

7.rcunt of tien stent nn the various carecories ^# verk, e.g., Cernissier recuests, sta#f caner reviews, arc imredia'e cf#ectiveness reviewe. This de'e

        <bruid be beneficial in orecaring PE's annual oceratino plans.

D5 Reccense . The-Director, PE, said he was prepared to institute e #crral record keepine

      -systen te accumulate the arount o# tire spent en the various categories c#'

work as reccrrended by the auditors. Rocerneadation _ lie reconnend that PE cc,nsult with officials in the Division o# Technical Informatico and Document Control on PE's present systen of recordt naintenance anc cbtain their advice on what recneds and files PE should naintain. PE Resconse The Director, PE, said PE was improving their filing systen and intended to censult with the Division of Technical Infornatien and Document Centrol to

      .obtain their. advice as to what additional records and files PE should main-tain.

P.ecommendation We-recommend that PE, in con,iunction with the Division of Organization and

    - Personnel, update PE employees' position descriptions, as needed.

PE Resconse ,

- ihe Director, PE, said PE had already reviewed the'non-managerial professional positions with the Division of Organization and Personnel and they are in the process of formally revising them. -

Recommendation We reconrend that PE comply with the work hours policy in Manual Chapter 4136

      .by either adoptino one of the flexitime options or requiring the PE staff to work the agency hours of 8:15 am to 5:00 cm.

PE Comments , The Director, PE, agreed to adopt an appropriate work hours policy in com-pliance with Manual Chapter 4136. m% , _}}