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Proceedings of NRC Regulatory Info Conference on 950509-10 in Rockville,Md
	ML20211B132
Person / Time
Issue date:	05/09/1995
From:	; NRC
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i FOREWORD r

This document is a compilation of abstracts, copies of l slides, and summaries of papers to be presented at the l NRC Regulatory Information Conference at the Crowne l Plaza Hotel, Rockville, MD on May 9 and 10,1995.
l These documents have been complied to provide a basis l for meaningful discussion and information exchange during the course of the meeting.
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i
NRC REGULATORY INFORMATION
CONFERENCE
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l j May 9-10,1995 l The Crowne Plaza j Rockville, Md l
l CONFERENCE PROGRAM l i
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' Conference Chairman William T. Russell l Office of Nuclear Reactor Ret- v.lon, U.S. NRC l
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! TABLE OF CONTENTS
Tuesday, May 9,1995
Page A. MORNING PLENARY SESSION 1 Regulatory Trends 2
1. SafetyTrends 3
! 2. NRR Regulatory Data 13
3. Significant Completed Actions 39
4. Priority Actions 45 f
5. Reactor Regulation Reform 60 i
B. MORNING BREAKOUT SESSIONS 89
! 1. On-line Maintenance and Maintenanco Rule 71 l 2. Steam Generator issues 81 l
3. Probabilistic Risk Assessment Policy and 91 !
l Implementation Plan l
4.10 CFR Part 54 Ucense Renewal 113
{
Rulemaking and 10 CFR Part 51 -
Environmental Protection Rulemaking
! For ucense Renewal C
! C. AFTERNOON PLENARY SESSION 129 i
j Regional Administrator Panelissues
1, inspection Planning, Oversight, and Follow-up 130
2. Cost Reduction and Safety
3. Feedback Report on Inspector Professionalism
! 4. Plant Material Condition i 1 1
Page 137 D. AFTERNOON BREAKOUT SESSIONS Regulatory Trends
1. Outage Planning and Shutdown Risk 2.10 CFR Part 52 - Advanced Reactors / Design Certification 145
3. Regulatory Process improvements 155 (Commitment Management and Cost Beneficial Ucensing Actions)
4. Bolling Water Reactor Intemals Cracking 193 WEDNESDAY, MAY 10,1995 E. MORNING PLENARY SESSIONS 217
1. NRC/Ucensee Interface and Communications, Region i
2. NRC/Ucensee Interface and Communications, Region 11
3. NRC/Ucensee Interface and Communications, Region Ill
4. NRC/Ucensee Interface and Communications, Region IV F. MORNING BREAKOUT SESSIONS 221
1. Reactor Vessel MaterialIssues 223
2. Spent Fuelissues/ Dry Cask Storags/ 233 Independent Spent Fuel Storage Installations / Palisades / David Besse Experience
3. New Source Term (Design Certification 275 Application and Future Applications to Operating Ucenses)
4. Securit" Issues 283 11
1 Page G. AFTERNOON BREAKOUT SESSIONS 293
1. New Approach to Assessing Performance Through inspection-The Integrated Performance Assessment Process (IPAP, formerly CIPP)
i
2. Self Assessment (Inspection 301 Procedures and Lessons Leamed) l
3. Standard Technical Specifications 315
4. Enforcement Policy Changes 331
5. Notice of Enforcement Discretion 341 I 6. Allegations i
H. CLOSING PLENARY SESSION
! Summary / Closing i !
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PROGRAM AGENDA NRC 1995 REGULATORY INFORMATION CONFERENCE Thesday, May 9,1995 Opening: 8:30 a.m. 9:15 a.m. Plaza Ballrooms I,11, and til my ~.
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f* e nv r Dhececr.,0fBoe of Nuclear Reactor Regulation (NRR), NRC j e, _ _ - . _ . . . ,,
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%._ano m u_um-cu Regulanion" Morning Plenary Session: 9:15 a.m. 10:30 a.m. Plaza Ballrooms I,11, and 111 l
Regulatory Trends . ................... ........ ............. .. . .................... William T. R ussell, Director, NR R/NR C Coffee Break: 10:30 a.m. 10:45 a.m.
Breakout Sessions: 10:45 a.m. - 12:15 p.m.
1. On Line Maintenance and Maintenance Rule ......, ..... . ..... ... .. .... . .... .. .. . .... ...Roy P. Zimmerman (Plaza Ballrooms 11 and 111) Associate Director for Projects (ADPR).NRR/NRC R. Lee Spessard Director, Division of Technical Support (DOTS), NRR/NRC Edward J. Butcher Chief Probabilistic Safety Assessment Branch Division of Systems Safety and Analysis (DSSA), NRR/NRC Tony Pietrangelo Project Manager, Nuclear Energy institute (NEI)
E.C. "Hert" Simpson Vice President, Nuclear Support Arizona Public Service Company
2. S team Generator issues ..... ........... ....................... .... . ....... . ..... .............................. B ria n W. S hernn (Regency Room) Director, Division of Engineering (DE), NRR/NRC Jack R. Strosnider Chief, Materials and Chemical Engineering Branch, DE/NRR/NRC Mark Marchi Manager, Nuclear Business Group Wisconsin Public Service Corporation Alexander Marion Manager, Engineering, NEl
3. Probabilistic Risk Assessment Policy .. ... . ............. . . ... ... . .............. .. ....... . ..... Ashok C. Thadani i and implementation Plan Associate Directar for Technical l (Plaza Ballroom 1) Assessment (ADT), NRR/NRC
! Gary M. Holahan 1
Director, Division of Systems Safety and Analysis (DSSA), NRR/NRC (A Question-and-Answer Period Will Follow Each Session Each Day.)
i iv I
2 hesday, May 9,1995 (Continued)
Charles E. Rossi Director, Safety Programs Division, Office for Analysis and Evaluation of Operational Data (AEOD' NRC David R. Helwig Vice President, Power Division, PECO Energy Company Ra3 mond Ng Manager, Licensing and Performance. Based Regulation, NEl 4.10 CFR Part 54 License Renewal . ......... ....... ................................... ...... ... ... .. .. Scott F. New berry Rulemaking and 10 CFR Part 51 - Dnector, License Renewal and Environmental Environmental Protection Review Project Directorate, Associate Directorate for Rulemaking for License Renewal Advanced Reactors and License Renewal (ADAR), NRR/NRC (Conference Theater) Donald P. Cleary Senior Task Leader, Regulations Development Branch Office of Nuclear Regulatory Research (RES), NRC Douglas Walters Project Manager, NEl Lunch: 12:15 p.m. - 1:30 p.m. Atrium' Gazebo IPoiST.LulYCN81fWpSPE5EERl
!Cmendsdener Kemure C.'Aegers5
. ?h30p.m. - 2:00p.m.h Q h2feas As@maslKam(4f.i.d Afternoon Plenary Session: 2:00 p.m. 3:30 p.m. Plaza Ballrooms 1,II, and III Regional Administrator Panel Issues .......... ................ ................ William T, Russell, Director, NRR/NRC and Regional Administraton Inspection Planning, Oversight, and Followup . ... .... .. J. Callan, Regional Administrator, REG IV/NRC Cost Reduction and Safety ........................... .............. S. Ebneter, Regional Administrator, REG II/NRC Feedback Report on Inspector Professionalism.... ...... ...T. Martin, Regional Administrator, REG I/NRC Plant Material Condition ............... . ........... ............... J. Martin, Regional Administrator, REG lil/NRC Coffee Break: 3:30 p.m. 3:45 p.m.
Breakout Sessions: 3:45 p.m. - 5:15 p.m.
1. Outage Planning and Shutdown Risk .... ... ... .... ................................. .
.. .. .. Gary M. Holahan (Plaza Ballrooms 11 and III) Director, DSSA/NRR!NRC Tony Pietrangelo Project Manager, NEl Mike Millen Senior Nuclear Engineer, Safety Evaluation Group Wisconsin Electric Power Co.
2.10 CFR Part 52 Advanced Reactors /
Design Certification .... .. ..... . .... . .. ... ...... . ...... ......................... .... .............. Denals M. Crutch field (Regency Room) Associate Director for Advanced Reactors and License Renewal (ADAR), NRR/NRC Theodore R. Quay Director, Standardization Project Directorate, ADAR/NRR/NRC (A Question and. Answer Period Will Follow Each Session Each Day.)
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'Ibesday, May 9,1995 (Continued)
R, William Borchardt Chief, inspection Program Branch, Directorate for Inspection and Support Programs (DISP), NRR/NRC R. Patrick Mcdonald Executive Director Advanced Reactor Corporation Ronald L. Simard Director, Advanced Reactor Programs, NEI
3. Regulatory Process improvements .................. ... ..................... ... ............................... Eugene V. I mbro Commitment Management and Director, Regulatory Review Group /
Cost Beneficial Licensing Actions (CBLA) Cost Beneficial Licensing Actions (Plaza Ballroom I) (RRG/CBLA) Programs ADPR/NRR/NRC Martin J. Rowling Manager, Nuclear Licensing and Programs, Virginia Powcr E. C, "Bert" Simpson Vice President, Nuclear Support Arizona Public Service Company Tim flope Regulatory Compliance Manager, TU Electric Richard M. Kacich Director, Nuclear Planning, Licensing and Budgeting, Northeast Utilities Stephen D. Floyd Director, Nuclear Economics, NEl
4. Boiling. Water Reactor Intemals Cracking .................... .. . ................ - Steven A. Varga (Conference Theater) Director, Division of Reactor Projects-1/11 (DRPE), NRR/NRC Gus C. Lainas Deputy Director, DE/NRR/NRC Robert A. Hermann Chief, Chemical Engineering and Metallurgy Section Materials and Chemical Engineering Branch, DE/NRR/NRC Robin L. Dyle Project Engineer, Southem Nuclear Operating Company, Inc.
Dinner: 6:30 p.m. 8:30 p.m.
Plaza Ballrooms I,II, and III
,s -
. L r'""E. Gallde Manque i
,. a 8.Mp.m.)- 8:30p.an.
. l.MataBallroomt1,11, Andtil
Risk Analysis and Ar Rennrn so CommonSense" (A Question-and. Answer Period Will Follow Each Session Each Day.)
vi
1 4
Wednesday, May 10,1995 Breakout Sessions: 8:00 a.m. 10:00 a.m.
1. NRC/ Licensee Interface and Communic tions, REGION 1.. ............. ........ ............. Thontas T. Martin (Plaza Ballrooms 11 and III) Regional Administrator, Region 1/NRC Frank J. Miraglis Deputy Director, NRR/NRC George T. Jones Vice President, Nuclear Engineering Susquehana, Pennsylvania Power & Light company
2. NRC/ Licensee Interface and Communications, REGION 11.................... ... ........... Stewart D. Ebneter (Regency Room) Regional Adm.'nist ator, Region ll/NRC SteSen A. Valga j Director, DRPF/NRR/NRC !
i' Roy A. Anderson VP, Brunswick Project
3. NRC/ Licensee Interface and Communications. REGION Ill .. ............. ....... J ohn B. Martin l
(Plaza Ballroom 1) Regional Adrninistrator, Region lil/NRC Roy P. Zimmerman ADPR/NRR/NRC Robert A. Fenech Vice President, Nuclear Operations Consumers Power Company
4. NRC/ Licensee Interface and Communications, REGION IV .... ................................. L. Joseph Callan (Conference Theater) Regional Adrninistrator, Region IV/NRC Elinor G. Adensam Acting Director. Division of Reactor Projects lil/IV (DRPW), NRR/NRC Ross P. Barkhurst Vice President-Operations Waterford 3 Entergy Operations,Inc.
Coffee Break: 10:00 a.m. - 10:15 a.m.
Breakout Sessions: 10:15 a.m. 12:00 p.m.
1. Reactor Vessel Material issues ..... .. ..... .. ..... ...... .. .................. ...... ...., , .... ....... Ellnor G, Adensa m (Plaza Ballrooms 11 and 111) Acting Director,DRPW/NRR/NRC Jack R. Strosnider Chief, Materials and Chemical Engineering Branch DE/NRR/NRC David L. Morrison Director, RES/NRC Matthew Kupinski Manager. Nuclear Engineering Services Northeast Utilities (A Question.and. Answer Period Will Follow Each Session Each Day.) _
vii
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Wednesday, May 10,1995 (Continued)
2. Spent Fuel issues / Dry Cask Storage / ........ ............................... .... Carl J. Paperkllo independent Spent Fuel Storage Director, Of6ce of Nuclear Material Installations / Palisades / Davis.Besse Experience Safety and Safeguards (NMSS), NRC (Regency Room)
Charles J. Haughney Chief, Storage and Tranportat;on Systems Branch Division ofIndustrial and Medical Nuclear Safety (IMNS) NMSS/NRC Martin J. Virgilio Deputy Director, DSS A/NRR/NRC William D. 'IYavers Director, Spent Fuel Program NMSS/NRC Jeffrey R. Williams Director, Engineering Division ;
Ofnce of Waste Acceptance Storage and Transportation U.S. Department of Energy Eileen Supko Senior Consultant Energy Resource Intemational,Inc.
Bob Rasmussen Senior Engineer, Nuclear Engineering D ake Power Company Kurt M. Haas Plant Safety and Licensing Director Consumers Power Company Getachew Tesfaye Senior Engineer . Licensing Baltimore Gas & Electric Company
3. New Source Term (Design Certincation Application ...................... ... ...................... Ashok C. Thadant and Future Applications to Operating Licenses) ADT/NRR/NRC (Plaza Ballroom I) Charles L. Miller Chief. Emergency Preparedness and Radiation Protection Branch DOTS /NRR/NRC M. Wayne Hodges Director, Division of Systems Technology RES/NRC Richard L. Emch, Jr.
Chief, Radiation Protection Section Emergency Preparedness and Radiation Protection Branch DOTS /NRR/NRC Leonard Soffer l SeniorTechnical Advisor Division of Systems Technology, RES/NRC Stanley Ritterbusch Manager, Standard Plant Licensing ABB Combustion Engineering, Nuclear Power (A Question and Answer Period Will Follow Each Session Each Day.)
viii
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i Wednesday, May 10,1995 (Continued)
Ray Crandall Supervisor, Radiological Engineering, Northeast Utilities Alexander Marlon l Manager, Engineering, NEl l i
4, Security i s s u e s ........ ...... ............ ....... ....... ......... ..................... .....R. Lee Spessard (Cnnference Theater) Director, DOTS /NRR/NRC LeMoine J. Cunningham Chief Safeguards Branch, DOTS /NRR/NRC Robert J. Dube Deputy Chief, Safeguards Branch, DOTS /NRR/NRC Neil S. " Buzz" Carns President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation David J. Modeen Manager, Operations and Management, NEl Lunch: 12:00 p.m. 1:15 p.m. AtriunVGazebo
'POSih]NCHEONSPEAKER '
. . JamesM.13rylor ;
ExecadwDirecear)6r Operations 4
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l Breakout Sessions: 2:00 p.m. - 3:30 p.m.
1. New Approach to Assessing Performance Through .............. .... . .... ..... ..... .. . ... . Frank P. Gillespie Inspection- the Integrated Performance Director for inspection and Assessment Process (IPAP, formerly CIPP) Support Programs (DISP), NRR/NRC (Plaza Ballrooms 11 and III)
Michael R. Johnson Chief, Performance Evaluation and Assessment Section Inspection Program Branch, DISP /NRR/NRC Loren R. Plisco Chief, Operating Reactor and Construction Inspection Programs Section Inspection Program Branch, DISP /NRR/NRC
2. Self Assessment (Inspection Procedures ....... ..... . ... . ... .. . . .. ... .. . . .... .. ... . Bruce A. Boger and Lessons Learned) Director, Division of Reactor Cont ols (Regency Room) and Human Factors (DRCH) NRR/NRC L. Joseph Callan Regional Administrator, Region IV/NRC Edward L. Jordan Director, AEOD/NRC David F. Powell Section Manager, Mechanical Engineering Systems, American Electric Power Martin J. Bowling Manager, Nuclear Licensing and Programs Virginia Electric and Power Company (A Question and.An.nver Period Will Follow Each Session Each Day.)
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7 Wednesday, May 10,1995 (Continued)
3. StanJard Technical Specifications .............................. ................. ..... .......................... Brian K. G rimes (Plaza Ballroom I) Director, Division of Project Support (DOPS). NRR/NRC Christopher I. Grimes Chief Technical apecification. Branch, DOPS/NRR/NRC Michael J. Meisner Director, Nuclear Safety and Regulatory Affairs j
Entergy Operations, Inc.
George J. Wrobel Manager, Nuclear Safety and Licensing Rochester Gas & Electric Corperation Peter E. Katz Manager, Nuclear Engineering Department Baltimore Gas & Electric Company
4. En forcement Policy Changes ................ .................. ... ................. ......... ............. ....J a mes Lie berma n
, Director, Office of Enforcement, NRC Notice of Enforcement Discretion ....... . . .............. ........ ... ......... ...... Stewart D. Ebneter Regional Administrator, Regian il/NRC Roy P. Zimmerman ADPR, NRR/NRC Allegations ......... ................ ....................... ....... ... . ... . ....... ......... .... ..... .... .... Fra nk P. G illes pie
, (Conference Theater) DISP, NRR/NRC Coffee Break: 3:30 p.m. - 3:45 p.m.
Closing Plenary Session: 3:45 p.m. 4:30 p.m. Plaza Ballrooms I, II, and III
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Please mark your calendars for the 1996,1997, and 1998 NRC Regulatory information Conferences.
which will be held at the Capitol Hilton Hotel, Washington, DC:
, April 10 and i t,1996
} April I and 2.1997 April 14 and 15.1998 (A Question and. Answer Period WillFollow Each Session Each Day.)
X
May 9,1995 Morning Plenary Gession 9:15 a.m. - 10:30 a.m. ;
Regulatory Trends 1
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I Regulatory Trends William T. Russell Director Office of Nuclear Reactor Regulation
1. Safety Trends
11. NRR Regulatory Data 111. Significant Completed Actions IV Priority Actions V. Reactor Regulation Reform 2 l
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m ' n< x ( %e e p o w e;: x%ATAw 9 64 = hs:4 w ~, % nca ..
Q.
4 N O CD w 4 N O l v- v- v-8
EQUIPMENT FORCED OUTAGE RATE Outages per 1000 Commercial Critical Hours 1.2 1.1 ZME 1 2: '?
0.9 gi vp !$g O.8 h$ ff) 0.6 e 0.6 !! M4 ne
!b$,N Nbb ey- 0,4 o,4 0,4 0,4 ElyrA 85 86 i llHim:
87 88 89 90 Year 91 92 93 94
' ! t l
E 7 0 4 R 2y 9
,r U 3 ,-
3 S 4 2 9 O
P 7 6 2 9
X 2 E
g 5 i' 5 '
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I T r 3
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e r
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e L a n 7 5
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I
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. $?f - 8 A 7 ;,
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7 6 3 e .W[K+s4 8
t n
e 2 c ,, t@yf ,h ,.f 6 r 6 .
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5 ,
8 e mj q1-i 6
I P
0 0 0 0 0 0 0 8 6 4 2 1
l
WATCH LIST PLANTS l { CATEGORY 2 AND 3}
Number of Units 20 -
16 16 15 -- -- --- ----
m4 2
z l
/ --- h, 10 ,
g---- -- -- - -
o--
g 5 --- --- ---- -- -- - -- --- --- -
86 87 88 89 90 91 92 93 94 95 Year
l l l
l w
Q D
O w
CD G
E CC QC 2
. i 13
LICENSING ACTIONS INVENTORY TRENDS 1,400
= i 1,200 -- - --------- -
-;-- l < '---------^--

n---- i-1,000 -- -- ------------ -- -------- -------- ------- ---------- ------

800 ------ - - ------- --------- --
600 --- ----- -- - - -- ---- ----- ---- - - -------
400 ------ - --- --- --
a 200 ---- -----
0 1 2 3 4 1 2 3 4 1 2 l 93 l 94 l 95 l TOTAL 1,113 1,152 1,187 1,233 1,255 1,284 1,293 1,330 1,242 1,217 P-S 1,018 1,075 1,128 1,186 1,197 1,239 1,265 1,310 1,228 1,204 I + TOTAL I PLANT-SPECIFIC ONLY Source: WIGP, data as of 4/18/95 by Quarters APRIL 17,1995 !
PLANT SPECIFIC LICENSING ACTIONS, 1989 - 1995 i
INVE!6 TORY LEVELS COMPLETED BY NRC t
i 2-%
}
u 1 13 .-
- .9 - _ . . - . . . . . ' ' ...
. . . y,. .......... N.n. i 1.000 --------*------------.- it t
I O
' 19 90 91 92. es 94 95 89 9. 91 92 93 94 95 ;
4
= = - = rvio em
, %w ,
Ul MEDIAN TIME TO COMPLETION MEDIAN AGE OF INVENTORY t
asssume a 9; i
i s - ------------------------- TC - +--**-------*.-......--
7
. . . . a.r. . . . .. . ------ " ---------- ------
e.e es ,
6 '----------- g ..-
4 ......................... . .
2 - * * - - * * - - * -'- a **-*----*--***- '
2 --------- 2 ------.------. v i
2 e.. ., . . o i I
Source: WISP, data date 4/19/95
MULTIPLANT ACTIONS i
l MAWR M%s0?EN MULTIPLANT LICENSING REQUIREMENTS l MPAs TENTACS IMPOSED ON UCENSEES, FY 88-94 1
SBSMICOlWJRCA110N,(SOUG) 61 y
USI A-46 6' 2 !
wo ............................
g

INDMDUAl.RANTEVALUATIONS(IPE) 70 soo .. ..--~~~~~~~~~~- - -------
~2 '
414 429 400 ----- --- -- -------- ---
g .... ......................
THERM 0lAGRREBARRIERS 80 y ............................ ?
, ROSEM0 M S N 17 100 ------~~- -------------------
1 0 i
800CONTROLSYSTEMFA' LURE 17 88 M 90 91 92 93 94 ascALYEARS I e CORESHROUDCRACIONG 17 D2a Dae.- 4/195
, INSPECTION TRENDS
Total inspection Hours Between 1992 and 1994 Have Remained i Relatively Stable, Varying By Only 2.5 %
e Total inspection Hours at a Site Can be influenced By:
o N + 1 Exemptions '
o Watchlist Status ,
o Reactive inspections o Major Team inspections o Regional Initiative inspections ;
i
MEAN INSPECTION EFFORT PER UNIT Regional and Total Hours, FY88 - 95 Thousands 6
4.989
! 5 - 4.772 - - - - 4,701 - - - - - - - - ---- -- ---------- --------------
e,. 05 '
4.245 4.279
. 3.987 4 -
~
~ 3.'023! i3.O65L . .
i 3 L E - :- '- *: 8 -! + -
Ub8[#! -- -
L2.755: -
2.78l . -
!2.7 :2.828: . .
.. __;7ie __ _. -:.e_i _
_ 2.m4.
2 - - . . .
1 - - - - -
~
O 1988 1989 1990 1991 1992 1993 1994 1995
...m..
Regions Only :i NRC HQ/ Regions l
PLUS PREP / DOC 04/12/95 ,
l l
1 TOTAL INSPECTION EFFORT FOR SINGLE UNIT SITES FY 1994 (9/19/93 - 9/18/94)
TOTAL MEDIAN PLANT tiQLI.R_H HOURS MONTICELLO 3,488.5 HOPE CREEK 1 3,564.4 CALLAWAY 3,837.3 KEWAUNEE 3,873.6 4,043.9 INDIAN POINT 2 4,214.1 HARRIS 1 4,329.6 1
GRAND GULF 1 4,387.5 BIG ROCK POINT 4,529.3
! GINNA 4,817.1-l MAINE YANKEE
' 4,801.3 SUMMER 4,81 0.3 WOLF CREEK 1 4,813.6 4,833.2 HADDAM NECK 4,852.8 THREE MILE ISLAND 1 5,012.1 DAVIS-BESSE 5,115.8 CUNTON 5,506.8 DUANE ARNOLD 5,522.3 WATERFOF1D 3 5,729.9 SEABROOK 1 5,747.9 VERMONT YANKEE 6,017.0 OYSTER CREEK 6,204.4 6,204.4 CRYSTAL RIVER 3 6,230.5 PILGRIM 1 6,403.4 FORT CALHOUN 1 6,546.1 FITZPATRICK 6,805.9 RIVER BEND 6,950.2 PALISADES 7,850.9 ROBINSON 2 8,019.8 COOPER 8,083.8 8,115.4 WASHINGTON NUCLEAR 2 8,147.0 FERMI 2 8,438.8 t PERRY 1 8,889.4 INDIAN POINT 3 9,744.3
/
r-l l
TOTAL INSPECTION EFFORT FOR DUAL UNIT SITES FY 1994 (9/19/93 - 9/18/94)
TOTAL MEDIAN P_LANT HOURS HOURS
BYRON 1,2 4,647.7
ST LUCIE 1,2 4,798.3
DRAIDWOOD 1,2 4,916.3
DIABLO CANYON 1,2 4,925.7 5,055.9
NORTH ANNA 1,2 5,186.0
PRAIRIE ISLAND 1,2 5,371.3
SUSQUEHANNA 1,2 5,391.1
LIMERICK 1,2 5,488.8
TURKEY POINT 3,4 5,781.1 ;
POINT BEACH 1,2 5,798.0 i SURRY 1,2 6,145.7 i FARLEY 1,2 6,353.9 6,366.7 COMANCHE PEAK 1,2 6,379.5
COOK 1,2 6,460.5 PEACH BOTTOM 2,3 6,721.1 VOGTLE 1,2 6,898.8 CALVERT CLIFFS 1,2 7,023.5 ARKANSAS 1,2 7,025.1 HATCH 1,2 7,294.3 ZION 1,2 7,311.5 7,319.1 NINE MILE POINT 1,2 7,326.6 SAN ONOFRE 2,3 7,447.5 DRESDEN 2,3 7,856.2 MCGUIRE 1,2 8,170.9 CATAWBA 1,2 8,894.0 LASALLE 1,2 8,726.9 BEAVER VALLEY 1,2 8,876.3 SALEM 1,2 9,469.2 9,664.4 QUAD CITIES 1,2 9,859.5 BRUNSWICK 1,2 10,607,6 SEQUOYAH 1,2 11,730.8 SOUTH TEXAS 1,2 15,374.2 l'
' Site with N+1 exemption.
20 k
TOTAL INSPECTION EFFORT FOR TRIPLE UNIT SITES FY 1994 (9/19/93 - 9/18/94)
TOTAL MEDIAN l PLANT HOURS HOURS i BROWNS FERRY 1,2,3 8,346.0 OCONEE 1,2,3 10,063.W 10,836.0 PALO VERDE 1,2,3 11,208.0 MILLSTONE 1,2,3 15,783.8 i
r t
. 21
i 1994 WATCH LIST CATEGORY 2 AND TRENDING PLANTS BY INSPECTION HOURS QUARTILE
i
\
! INSPECTION HOURS
! QUARTILE WATCHLIST TRENDING L !
i FIRST 0/0 0/0 0
l SECOND 0/0 0/0 l
THIRD 0/1 0/0 FOURTH 1/1 1/2 l
SINGLE UNIT / DUAL UNIT
_ . _ _ _ _ _. i
1989 WATCH LIST CATEGORY 2 PLANTS BY INSPECTION HOURS QUARTILE INSPECTION HOURS QUARTILE 1992 1993 1994 FIRST 0/0 0/1 0/0 U
SECOND 0/1 0/2 0/3 THIRD 1/1 1/2 1/2 FOURTH 0/3 0/0 0/0 SINGLE UNIT / DUAL UNIT
TREND IN NUMBER OF TEAM INSPECTIONS
REGION FY 94 FY 95 (THROUGH MARCH)
I 21 9 i
11 14 9 i
lil 19 5 l
l l IV 24 14 1
37 l
Total 78
Inctudes a11 Major Activities during 4 ich 20 or more statf-deys of onsite effort are empended uithin a 5-dey perlod.
l MEAN LICENSING EFFORT PER UNIT, FY 89 - 95 Hours i 3,000 l 2,544
2,500 #
2,31s. s s 2,2s7 j 2,1 38, , N ,- 8 s 2,000
%sg
~,
J,,,
,,g e ,
! 1,500 iU 1,000 500 i
j 0 : : : : :
1989 1990 1991 1992 1993 1994 1995 I
PROJECTED Fiscal Year l
Source: NRR l
3/27/94 i
TOTAL EFFORT FOR SINGLE UNIT SITES FY 1994 (9/19/93 - 9/18/94)
TOTAL MEDIAN PLANT HOURS HOURS MONTICELLO 5,290.8 HOPE CREEK 1 5,634.8 KEWAUNEE 0,570.7 CALLAWAY 6,766.8 6,901.0 WOLF CREEK 1 7,035.1 GRAND GULF 1 7,386.0 THREE MILE 'SLAND 1 7,404.6 BIG ROCK POINT 7,51 6.5 lNDIAN POINT 2 7,529.9 HARRIS 1 7,566.2 CLINTON 8,097.6 SUMMER 8,153.0 8,178.6 GINNA 8,204.1 MAINE YANKEE 8,570.8 DAVIS-BESSE 8,695.2 HADDAM NECK 8,899.3 WATERFORD 3 8,749.7 DUANE ARNOLD 9,551.9 FORT CAL;'OUN 1 9,949.3 VERMONT YANKEE 9,982.7 SEABROOK 1 10,349.3 10,349.3 OYSTER CREEK 10,361.3 COOPER 10,941.3 FITZPATRICK 10,992.5 RIVER BEND 11,287.6 ROBINSON 2 11,546.8 PILGRIM i 11,547.8 CRYSTAL RIVER 3 12.123.3 FERMI 2 12,851.9 13,396.8 PERRY 1 13,941.7 PALISADES 13,995.4 INDIAN POINT 3 14,014.0 WASHINGTON NUCLEAR 2 14,569.5 26
(
l l
TOTAL EFFORT FOR DUAL UNIT SITES !
FY 1994 (9/19/93 - 9/18/94) j 4
TOTAL MEDIAN PLANT HOURS HOURS
BYRON 1,2 7,457.8
DIABLO CANYON 1,2 7,722.2
ST LUCIE 1,2 8,232.5
NORTH ANNA 1,2 8,069.4 8,803.6 1
PRAIRIE ISLAND 1,2 8,937.7 I SURRY 1,2 9,308.7
COOK 1,2 9,835.6 >
FARLEY 1,2 9,915.4
BRAIDWOOD 1,2 10,008.7 COMANCHE PEAK 1,2 10,030.1
TURKEY POINT 3,4 10,123.7
LIMERICK 1,2 10,627.9 10,689.4 PEACH BOTTOM 2,3 10,750.8
POINT BEACH 1,2 11,219.6 ZION 1,2 11,251.8 DRESDEN 2,3 11,454.6 MCGUIRE 1,2 11,686.6
SUSQUEHANNA 1,2 12,171.4 LASALLE 1,2 12,217.1 ARKANSAS 1,2 12,329.6 12,370.8 NINE MILE POINT 1,2 12,411.9 SAN ONOFRE 2,3 12,599.3 l BEAVER VALLEY 1,2 12,654.8 HATCH 1,2 12,720.8 i
CATAWBA 1,2 13,026.0 CALVERT CLIFFS 1,2 13,740.2 BRUNSWICK 1,2 14,251.9 VOGTLE 1,2 14,329.0 14,816.7 QUAD CITIES 1,2 15,304.4 SALEM 1,2 15,692.0 SEQUOYAH 1,2 16,210.3 SOUTH TEXAS 1,2 25,592.5 OSite with N+1 exemption.
27
i
\
TOTAL EFFORT FOR TRIPLE UNIT SITES FY 1994 (9/19/93 - 9/18/94) e TOTAL MEDIAN PLANT HOURS HOURS BROWNS FERRY 1,2,3 14,020.9 PALO VERDE 1,2,3 18,056.1 18,088.6 OCONEE 1,2,3 18,121.0 MILLSTONE 1,2,3 27,744.1 l
I l
28
BULLETINS ISSlJED thru MARCH 31,1995
- Number issued -
60 50 - --- ~~~~~~ - '* '-48---- ------- ------~~ ---------- --- -- -- -*
40 --------:-' ' ------ - - - '37-'----------------'---------'--------------
@ 39 . . . . .............. ... ................................. ... ....
20 . . . . . . ...
....... ... . . . . . . . . . . . . . . . . . .....1.9.....................
.15
.11 10 g
0 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95
- Year -
NOTE -- Total issuances for the year include new (numbered and lettered) issuances, revisions, and supplements.
GENERIC LETTERS ISSUED thru MARCH 31,1995
- Number issued -
140 120 --------222-:--------------------------------------
.. m .z . . . . . . ..... .. ........ ...........
300 .~.....
80 - C-- - - - - -: g- -~-4 +-- '--- - --- ----- - ----- - # *- -- ----
w O -----~------------------------------------------
60 -i -:- --- - - - - =
47 42i l3 . . . . - . . . . . - ......
= . .:
4o 37 20 --- - -
- i'7 T16 *
- -' 8 N* - - - - - - - - - - - -
0 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95
- Year -
NOTE - Total issuances for the year include new (numbered and lettered) issuances, revisions, and supplements.
Administrative Letters issued -- 5 in 93,17 in 94, and 3 in 95 r- - - - - -
INFORMATION NOTICES ISSUED j thru MARCH 31,1995 1
i - Number issued -
140 120 - ----- ------- - ------- 443--
101 .104 '103 .107 1 m l 100 - --- -------------~~-
i 80 --------"--- -
2 -- - -
60 -
--L----~----- - - - - - - ----
39 f 381... _ _
20 - - - - - - - -
79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95
- Year -
NOTE -- Total issuances for the year include new (numbered ~
and lettered) issuances, revisions, and supplements.
EVENTS ANALYSIS AND FOLLOWUP, 1989-1995 l
i EVENTS REVIEWED EVENTS REQUIR;NG FOLLOW-UP Evesite 500 3.500 *'
SAas an

---- 400 - - - -- ----- - -- --- -

3,000 w-------
2,500 - -----
'** * * * * * - -- --- ---- 2 sco 2.000 - --- *-- --- --
1.500 - - - -------- --------- --- 200 9,000 . ---- ...--------.. --..--
100 - - - -
- ---------- + -*---------
500 0
0..
RoomBVeer ,temme 11 mar y Cd N SIGNIFICANT EVENTS AUGMENTED INSPECTION TEAMS
.-. e 100 25 38 '
80 - - ------------- --------- 29 -- - ------= --
- - -------------- -------.- 15 ' - - - - - - '
60 -
11
" -*- ------ ~ ~~ ~ ~~~******'"~ * * * '

10 40 ----

2' D - Sb 5 -- -- -- - -------------
' 20 -- ----- --- .
r- - - - Nte
=
= = ..
Source: NRR 4/17/95
' l' y];=ri M
ls;i e, :i !
i s
5 g A= .xr g ii j
g Nm+gwsg3;nMi; i
s
= ?Mw i
in a
4 r t-
- =+ c g 6 mf;h_
=
0 w y,=M=s# = M 7 0
= =;j = =-
s r
9 5 05 a; W
= ;L i q s>
=f9 S
ij s*
~
6 6 y$E = =
R s=M F s;g =a
= 1
= 4 l_ * +={;_Wg_E u!9=; 1 N 5 .-
r=. 5
=z_
seg; E a R.- %
_J =
m- a+ 35
~
r 5
= =
O 0 0
=
Q ==3 ]=e;_=:=M s 5 :
=iEw
=
=
~: 9 5 0 5
=
E =is b g ii i
- r 9 5 5 f; 3 - ;;
1 y3=3E =
w
_ 7 I E
+=4==M x
2 E = W i TR n'
= l
== ~
=
nW xe= e= g 7 ire P-1 E 1
= i l
=
e =;
AAE lf =
= ;
wfg sH ni W C ;u+
i Mr "s
_ 4 m= s==
s 7= 1 1 2
?
?
.,w i _
i 9 1 6 7
9
=e _~
NYL i
5 1 6 a n r-pa 3eQEMgCm+=_e i==c[t p= = h g = 1 S
1 Ei=*
I = :
f
= _
5 g*mg=;E g ;= g
= s s
=
T s x= g7 +*__'5c ye=mM=M;.=h{
=
A - ;g n
MC 4=
o
=3 y 1 3 7 wa.g i
, g~j i;m*=__^~
g r
f-
@#;W==nQ -
9 6 1 5 3 2 t
c a 5 ASF Yi
=
m9 := 9 5, e
==M 5

I
=
g;ig = ~ 1 6 9 1 j
e =-
K+r- == u m= em= ip g
n;5
~
e gE s =
r XY e
i;M:
=
en==fWM==r p
i s-i n =
gs i n
i; ==
=
ti M #" = = '
e e= =
EB y]5E] a z -
=; w= r==G
=
=-
r "Z
I =_F=_==
=
o
=
=
=
=
=
=
=+#
2
_. 2 9
9 7
1 0 8 8 7 2 4
6, 6 r
a m*;g_T;gs~_= 6 m l a -r =- - e =r 1 1 9 C
~
- m -
7 9
+ s ==
_ i =
-+ Z E 1 t
i
=..
- n :
2. -
?= = = =
=
y p;=_.9s- e iI s d R
t 9= 1 n
w=. = ;,=(jsMa+g-i=-
6 7 i '
s :
a
=
r= ~?_
1 9 1 0 1 a 0_
E W=
=~
-5 g 9 1 N 2, 9, 5 -
h~ == " E g= 2 m= Z E== E

. 7 e
5 =+=
7.- # 1 1 1 9
a. =;
y;=M=
w= s; i 9
%s=_==y=
=:
s=
fi i +-
i
=
J!: Z i == + 1 0 0 0 0 O K r
0 0 0 0
= '
' o 5, 0, 5, 0 5 l f
2 2 1 1 a s r
ui e l
a qa i
t i
et o b n
iRT m u
ww N
ALLEGATIONS 1 Reactors: 1989-1994 Number of Allegations 1,000 -- -
800 [ -
600
\{ -
W ! \
i 4oo x ;l< :
N_
h-x 200 ,
b l s\ ,
0 - -- - - - - - -
1989 1990 1991 1992 1993 1994 Fiscal Year i E H&l A Received _ Substantiated 88 Closed Numbers are approximate
ALLEGATIONS Vendors: 1989-1994 Number of Allegations 50 40 1b9 j
bb0 l
19b1 1bb2 Fiscal Year 1b3 1
1hb4 E H&l A Received [ Substantiated M Closed Numbers are approximate
NRR COMPARABILITY -- HQ and REGIONS Streamlining impact, FY 93 - FY 99 971 971 '
9e r- . . +- - - - t ,
o .
I I
ggg ......................................l.............................
I 852 I 850 831 b - - 4. .822 823 . 8b
.g.- . .
$. - - - $. . 817 O 800 -------,-------------------------c:-------------------------
I 7s3
' 4 719 G) 723 c) 718'-
709 701 7 = 'A
- - - . . . . . . . . . sos . . . . . . i. . . . . . . . 7i 4 os 700 ,
...s ,es. ...sss
. + . ...s
.o 894 644 8
67 641 O I 6:!4 I i 1
600 i i
tHQ I
& Regions '
500 95 96 97 98 99 85 86 87 88 89 90 91 92 9,G 94 i STREAMLINING >
Note: FTE are budgeted per FY
NRR STREAMLINING PLAN Total NRR Managers FTE 140 -
,128 120 -
106 98 100 -
~_
(As of 03/31/95) ~
80 -
$ _ 69 60 -
40 -
20 -
0 i i i i i i 1993 1994 1995 1996 1997 1998 1999 Fiscal Year
NRR STREAMLINING PLAN Total NRR Overhead
FTE 350 -339 r
46% 297 300 -
i 41% 251 250 -
~~ _
36% ~ '
(As of 03/31/95) ~ ,
200 - -
g ~ _ 156
~.
150 -
25%
100 -
50 -
0 . . . . . .
1993 1994 1995 1996 1997 1998 1999 Fiscal Year
M:nagers, Secretaries, Licensing Assistants, Technical Assistants, and Program Assistants.
-_.-.hu-%_ ..a_w.__ a.-_m+ -,__._m -.__~.a _ _--2mA.x A %-.-_hAa:____,%A_,A a e ,m4. - .Jn A..-._A JA%a._____s_-m4_a-~___eh-h_a 4__,.m._aAA---_ ..aJ j
)
i n
i 1
i i
C O
I
'5
O i 4 i t e
l -
F l 6
O u
C i M O
i C
.G .
O m
m m
39 e__ _ ____ _. -
Significant Comoleted Actions: NRR Licensing OPERATING REACTORS e Completed 1520 Licensing Actions During Fiscal Year 1994 e Completed 3 Requests for CP-OL Recapture (Peach Bottom 2 & 3, Turkey Point 3 & 4, Diablo Canyon 1 & 2)
, , e Completed Conversion of Hatch 1 & 2, Clinton, and Grand Gulf 1 to Standard Technical Specifications o Reduces LCOs by ~40 %
o improves Consistency o Enhances Bases-e issued Power Uprate License. Amendments for Peach Bottom 2, Limerick 2, and Susquehanna 1 & 2 e NRC Approved Final Part 54 Rule.
Significant Comoleted Actions: NRR Licensing ADVANCED REACTORS
Issued GE ABWR and CE System 80+ Final Design Approvals and Proposed Rules c
Issued AP-600 DSER t
Issued EPRi p;ssive Utility Requirements Document FSER
Significant Completed Actions: Generic Safety issues I
j l f e issued Generic Letter on Thermal-Hydraulic Instabilities in Boiling Water i Reactors o Long-term Solutions
! o Upgrade of Interim Operating Recommendations !
e issued Generic Letter on Intergranular Stress Corrosion Cracking of Core Shrouds in Boiling Water Reactors t
t e issued NRC Bulletin on Potential Fuel Pool Draindown Caused by inadequate Maintenance Practices i
t
^^ +4 -- - _ g-__ _ _
4 .4 . . .
T Significant Completed Actions: Regulatory Reform e Completed 32 of 71 Regulatory Review Group implementation Plan (SECY-94-003) Items e issued'CBLA Administrative Letter 95-02 e Approved 87 CBLAs for $410 Million Savings (Based on Licensee g Estimates) e issued Revised Fire Protection Guidance (GL 86-10, Supplement 1) e Revised Safeguards Requirements / Deleted Unnecessary Reporting Requirements
Completed Transition to Operator Licensing Requalification Program inspection Process L _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ . _ .
Significant Comoleted Actions: Regulatory Reform .
t e Published Proposed Revision to 10 CFR 21 - Reporting of Defects and Noncompliance i
e Completed Commitment Management Program Pilot inspections i
i e initiated Public Responsiveness initiative
$ o Public Petitions (10 CFR 2.206) o Licensing Actions o Management of Allegations 0 Emergency Preparedness 0 Electronic Information Exchange l
i
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Priority Actions i
1) On-Line Maintenance and Maintenance Rule *
2) Steam Generator issues *
3) 10 CFR Part 54 - License Renewal Rulemaking and -
l 10 CFR Part 51 - Environmental Protection Rulemaking for License Renewal * !
4) Outage Planning and Shutdown Risk *
5) 10 CFR Part 52 - Advanced Reactors / Design Certification *
(SBWR Testing SER/AP-600 FSER)
6) Boiling Water Reactor Internals Cracking *
7) Reactor Vessel Material Issues *
8) Decommissioning *
9) New Source Term (Design Certification Application and Future Applications to Operating Licenses) * !
10) Fire Barriers ;
11) Motor Operated Valves ;
12) Other Technical items *
Breakout Session Topics
On-Line Maintenance and Maintenance Rule
On-Line Maintenance e increased Preventive Maintenance of Equipment While at Power - Can flesult in Significant increase in Risk '
e Some Licensees Are Not Adequately Planning and Controlling Multiple '
Equipment Unavailabilities e Shift Operators and Maintenance Planners Generally Not Familiar With 3 Plant Specific Risk Insights e NRC Actions - NRC Tl 2515/126 Licensee On-Line Maintenance ,
Maintenance Rule e Verification and Validation of Draft inspection Procedure is Complete - Pilot inspections Performed at Nine Sites e NRC Public Workshop on Pilot inspections and Final Inspection .
Procedure to be Held June 27,1995, (St Louis, MO) with NEl Workshop Following
Breakout Session Topic
t Steam Generator issues
e Steam Generator Degradation increasing i
e NDE Technology improving ,
e Regulatory implications S
e Regulatory Actions '
o Generic Letter - Circumferential Cracking of Steam Generator Tubes o Proposed Generic Letter - Steam Generator Voltage-Based Repair Criteria - 6/95 o Steam Generator Rulemaking - 6/96 1
1
Breakout Session Topic i
i
10 CFR Part 54.- License Renewal Rulemaking and 10 CFR Part 51 - Environmental Protection Rulemaking for License Renewal *
Draft License Renewal Regulatory Guide for Comment and Workshop - 12/95
Final Part 51 Rulemaking - 7/95 s
Complete Reviews of Industry (Owners Groups) Technical Reports o Requests for Additional Information - 3 Months o Draft SER - 9 Months o Final SER - 15 Months
Breakout Session Topic
Outage Planning and Shutdown Risk
i o -Issued Proposed Rule - iO/94 e Received Significant Cornments on the Proposed Rule e Major Revision Based Upon Comments o Performance Based Rule (No Technical Specifications) j o o Fire Protection Aspects Deleted (To be Addressed as Part of. Revision :
to Fire Protection Rule) -
t
Held Public Meeting to Discuss Staff Resolution of Public l Comments - 4/95 i i
e issue New Proposed Rule for Comment - 12/95 l
Breakout Session Topic !
I
___ . _ _ _ . _ . . ..~ _ _ _ _ . _ . _ _ - _ _ . _ _ _ _ _ . _ _ . _ . . _ _ _
4 !
10 CFR Part 52 - Advanced Reactors / Design.
Certification (SBWR Testing SER / AP-600 FSER)
e Staff's Final Evaluation of the SBWR Test and Analysis Program Description (TAPD) Expected by the End of 1995 i
e DSER. Supplement Addressing AP-600 Test Program - 10/95 9
FSER on the AP-600 Design - 8/96 i t
Breakout Session Topic
Boiling Water Reactor internals Cracking
l l
Cracking Observed in Several BWR Reactor Vessel internals Components o Core Shrouds o Jet Pump Hold Down Beams o Manway Cover Welds o Support Assemblies ,
en
NRC Required Core Shroud inspections for All BWRs (Except Big Rock Point) at Next Refueling Outage
Core Shroud Cracking Evaluated to Date Acceptable for Continued Operation o Required inspection at Subsequent Outage L o Repairs Implemented to Reduce Subsequent Inspections
I l
l l
l Boiling Water Reactor Internals Cracking
i I
Several Licensees are Proposing Preemptive Shroud Repair Rather Than inspections i
a e BWR Owners Group Aggressively Addressing Internals Cracking :
ta i
i i
Breakout Session Topic !
Reactor Vessel Material issues * .
I i
Generic implications of Palisades Evaluation o New Information on Reactor Vessel Weld Chemical Properties and Variability for Combuction Engineering Fabricated Reactor Vessels '
o Several Reactor Vessels May Reach PTS Screening Criteria Before EOL ai
Information Submitted in Response to Generic Letter 92-01 May Not be
Complete j
Licensees Must Obtain and Evaluate All Relevant Data in Evaluation of Their Reactor Pressure Vessels
Annealing Rule 10 CFR 50.66 !
O Comments on. Draft Rule Being Evaluated ;
o Final Rule - Fall 1995 .
PTS Rule 10 CFR 50.61 May Need to be Revised
Breakout Session Topic "
L
Decommissioning
e Decommissioning Efforts Proceeding (Trojan, Yankee Rowe, Rancho Seco) e NRR/NMSS Realignment of Decommissioning Plans Approved - NRR to Retain Plants Until Fuel Removed From Wet Spent Fuel Storage E e issuance of Proposed Rule Streamlining Decommissioning Process Expected in Summer 1995 e Staff Will Revise Regulatory Guidance for Preparation and Review of t
Decommissioning Submittals e Spent Fuel issues / Dry Cask Storage / Independent Spent Fuel Storage installations *
Breakout Session Topic K
New Source Term
e, New Physically-Based Accident Source Term Used on CE System 80+
and AP-600 Design Certification Reviews e Policy On Use of New Source Term for Operating Reactors Being Developed E e. Industry Must Take Lead Responsibility for Scope and Technical Basis for Application of New Source Term for Operating Reactors
Staff Will Review industry Proposals
Breakout Session Topic
l
. Fire Barriers
NEl Thermo-Lag Application Guide - Pilot Evaluations Underway
Staff Performed Site Visits to Four Lead Plants ,
t e Staff Issued 50.54(f) Followup Letters (9/94,12/94) .
0
Staff is Reviewing Plant-Specific Submittals :
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Motor Operated Valves 1
e Most Licensees Making Satisfactory Progress on Completion of MOV Testing o NRC Reviewing Schedule Extensions (GL 89-10, Supplement 6) o Many Valves Required Modifications to Meet Design Basis Requirements e Proposed Generic Letter on Pressure Locking / Thermal Binding was
= issued For Public Comment o NRC Staff Review of the Topical Report on EPRI MOV Performance Prediction Program Scheduled for Completion by Fall 1995 e Staff is Working with ASME on a Long-Term Program to Provide Assurance for Continued Capability of MOVs
l Other Technical items '
t e Security issues
i o Guidance on 10 CFR 50.54 (p) - Changes to Security Program Without Prior Staff Approval i
e Digital I&C Retrofits and 10 CFR 50.59 o Proposed Generic Letter issued for Public Comment i E
e BWR ECCS Strainer Blockage ,
o Proposed Bulletin - 6/95 e Appendix J Revision ;
o Final Rule - 10/95

Breakout Session Topic i
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Reactor Regulation Reform i
11 Licensing *
2) Managing Generic. Issues
3) Rulemaking
4) Probabilistic Risk Assessment Policy and g implementation Plan *
5) Inspection *
6) Enforcement
f l
Breakout Session Topics i ;
Licensing
i
Commitment Management and Cost Beneficial Licensing Actions
e Standard Technical Specification (STS) Conversions
e Line-Item improvements to Technical Specifications 0
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Breakout Session Topics
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63
Rulemaking ,
l 4
Revised Process for Petitions for Rulemaking
Revised Regulatory Analysis Guidelines e improved Internal Management of Reactor Rulemaking
, o Formal Action Plans
o Monthly Status Reports to Director, NRR s
Probabilistic Risk Assessment Policy and i implementation Plan * ,
e Conducted Public Workshop on PRA implementation Plan
Interacted With industry and NEl - Commented on NEl PSA Applications Guide i
$ e Trial Use of NEl PSA Application Guidelines l e Piloting Applications (MOVs, ISI/IST, Graded QA) i e Developed Risk Profiles at Pilot Facilities t
e Publishing Final PRA Policy Statement
Breakout Session Topic
inspection
l l
e Licensee Self Assessments (NRC Inspection Procedure 40501)
l 0 , Cooper SET e Superior Performer Program l e Plant Performance Reviews (PPRs) o New Approach to Assessing Performance Through inspection - the
Integrated Performance Assessment Process (IPAP)
t e Use of Risk insights in Inspections e Resident inspection Program improvements o Resident / Senior Resident inspector Development Programs o Senior Reactor Analyst (SRA) Development Program l
Breakout Session Topics
Enforcement
e NUREG 1525 - Assessment of the NRC Enforcement Program o Mitigation for Licensee identification and Satisfactory Corrective Action o Focus on Current Safety Performance O Provide More Predictability o Simplify Internal' Agency Reviews o Enforcement Conferences Normally Open to the Public e Notice of Enforcement Discretion (NOED) Policy and implementation Review i
e Allegation Program initiatives
Breakout Session Topic i
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i May 9,1995
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Morning Breakout Sessions j 10:45 a.m. - 12:15 p.m.
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I 69
l ON-LINE MAINTENANCE I
4 AND MAINTENANCE RULE 4
i i
l AGENDA:
o Opening Remarks Spessard
! o NRC Presentation Black i
i dn-Line Maintenance Maintenance Rule

NEl Presentation Pietrangelo
- l
Open Discussion
! 1 l
70 l
ON-LINE MAINTENANCE
NRC Concern is That Risk Can Significantly increase During Periods When Multiple Redundant Or Diverse Systems Are Unavailable Due To Maintenance
NRC Took Actions To Address This Concern Letters To INPO And NEl Developed And Implemented Temporary Instruction For NRC Resident inspectors At Each Plant To Evaluate Licensee Perforrnance in This Area Pilot Maintenance Rule Inspections included Evaluation Of Licensee Approach To On-Line Maintenance
ON-LINE MAINTENANCE 2.00E-04 .
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ON LINE MAINTENANCE Preliminary Feedback From inspections Conducted in Accordance With Tl 2515/126
- Significant Amounts Of On-Line Maintenance Performed With An increasing Trend
- On-Line Maintenance Coordinated To Minimize Out Of Service Time And Maximize Availability I - PRA Insights incorporated When Scheduling And Planning On-Line Maintenance
- Tools Used By Licensees Vary Widely In Approach j And Sophistication
- Training And Awareness Of Risk insights Varies Greatly Within And Between Licensees ON-LINE MAINTENANCE
Pilot Maintenance Rule Inspections Found That
, Licensees Have Developed, Or Are Developing, Methods And Procedures For Evaluating The Risks Of 4
Performing On-Line Maintenance
Results Of Entire Pilot inspection Program To Be Shared in A NUREG Document And Public Workshop To Be Held in June 1995
Staff And Industry Plan To Revise Implementation Guidance On Basis Of Inspection Findings 73
l ON LINE MAINTENANCE
)
Although implementation is incomplete, It Appears That Industry is Resoting Positively To The NRC's Concerns With Performing On-Line Maintenance l
Maintenance Rule Requires Balancing Unavailability For Maintenance Against Equipment Reliability l
Maintenance Rule Requires An Assessment Of Total Plant Equipment That is Out Of Service To Determine Overall Effect On Performance Of Safety Functions MAINTENANCE RULE - BACKGROUND
Maintenance Rule is Agency's First Major Performance-Based Rule
Effective July 10,1996
Requirements Are Contained in 10 CFR 50.65
Staff Has Provided An Acceptable Method For Compliance With The Maintenance Rule In Regulatory Guide 1.160, Which Endorses Industry Guidance Document NUMARC 93-01
Licensees May Propose An Alternative Method To That in NUMARC 93-01
Draft inspection Procedure Provides Approach NRC Will Take in Evaluating Compliance With The Maintenance Rule 74
MAINTENANCE RULE - PILOT PROSRAM Pilot Program Evaluated Draft Inspection Procedure
- Nine Sites Volunteered To Participate
- All Pilot Inspections Have Been Completed o degree of implementation varied between sites o all sites but one elected to follow guidance in RG 1.160 and NUMARC 93-01 l
Major Problem Areas identified In Pilot Program
- Scope Of SSCs Within Rule
- Goal-Setting
- Applying Maintenance Rule To Structures MAINTENANCE RULE - PlLOT PROGRAM, REMAINING ACTIVITIES Lessons-Learned Report (NUREG) is Being Drafted, Will Be issued In Summer 1995
Puolic Workshop To Be Held in June 1995
Commission Briefing Scheduled For June 1995 75
)
MAINTENANCE RULE - ADDITIONAL PRE-lMPLEMENTATION ACTIVITIES I
Regional Training On How To Evaluate Licensee Compliance With The Maintenance Rule Will Be Conducted From Fall 1995 Through Spring 1996
Proposed TTC-Based Maintenance Rule Course To Provide Continued Training After Initial Training 76
)
4 l On-Line Maintenance and Maintenance Rule i
I
Tony Pietrangelo j Nuclear Energy Institute l May 9,1995 4
Maintenance Rule implementation i
1 Proceeding smoothly - a few concerns identified
- non-safety related SSCs that could cause scrams
- shadowing" beyond the train level l Industry workshop conducted in Baltimore last year i
l NEl has participated in all NRC pilot inspections i
i NEl is continuing to conduct assist visits Industry workshop will follow NRC meeting in St. Louis NEI
! 77
Importance of Maintenance Rule
Provides a model for regulation where risk-based and performance-based approaches are applied
. Risk insights are used to help establish the risk significance of systems within the scope of the rule
Performance monitoring provides reasonable assurance that SSCs are capable of fulfilling their intended functions Several industry initiatives designed to build on maintenance rule implementation model On-Line Maintenance
Addressed in section a(3) of the rule
- In" performing monitoring and preventive maintenance activities, an assessment of the total plant equipment that is out of service should be taken into account to determine the overall effect on performance of plant safety functions."
Concern raised by NRC last year that licensees appear I to be increasing on-line maintenance activities without a l
complete understanding and evaluation of potential impacts on safety
Further information on licensee practices gathered by resident inspectors through Tl 2515/126 NEI 78
_ _ _ - _ _ _ _ - . _ - - . . . - . -_ _ ~ . - - - - ._ . _ .
Benefits of On-Line Maintenance Increased system and unit reliability Reduction of plant equipment and materiel condition deficiencies that could impact plant operations More focused attention when fewer activities are competing for specialized resources Reduction of outage work scope On-Line Maintenance Practices
' For compliance with 50.65 (a)(3), most utilities are planning to use matrices that pre-analyze the impact on safety of taking key equipment out of service Some utilities are developing automated matrices or risk / safety monitors as a tool for planning and scheduling on-line activities General conclusion that PSA can provide valuable insights that aid in operational decisions NEl 79 3
-- j
Industry Actions i
- INPO has issued industry guidance on managing i
maintenance during power operations
- Issuance ofindustry's PSA Applications Guide 8
- Industry workshops on maintenance rule implementation, the PSA Applications Guide, and others
- NEl will continue to provide industry interaction with NRC NEI
STEAM GENERATOR ISSUES l
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Brian W. Sheron, Director Division of Engineering Office of Nuclear Reactor Regulation 81
/
I
! TRENDS IN STEAM GENERATOR l DEGRADATION l I
l
Forms of Degradation Have Changed
!
Older US SGs are Expenencing an increasing Amount of Degradation e
Most Prevalent Forms are ODSCC at TSPs, PWSCC within Tubesheet, and ODSCC and PWSCC at Roll Transition i
Degradation of Sleeved Tubes May Be an Emerging j issue I
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CHANGES IN NDE TECHNOLOGY
More Sensitive NDE Techniques Available
Data Acquisition and Analysis Capabilities Have Improved
- Large amounts of data can be analyzed and tracked
" Hindsight" review of data provides insight into procedure improvements and growth rates CONSEQUENCES OF THE CURRENT SITUATION Economic Imolications for Industry
increased Forced Outages
increased Plugging / Sleeving and Associated Costs
Potential for Power Reduction as SG Plugging increases Shortened Operating Life of Sgs/ Continued Facility Viability Can Become a Major Concern 84 u -_ _ _ _ _ _ _ - _ _ _. - - - - - - . - - --._--J
l REGULATORY IMPLICATIONS '
1
Current Conservative Technical Specification Repair Criteria were Developed About 20 Years Ago and Don't Reflect Current Technology or Operating Problems
Staff is Regulating on a Ad Hoc Basis / Unstable Regulatory Environment
Drain on Staff Resources
- Increased requests for TS amendments
- Staff involved with mid-cycle inspection outages / reviewing associated inspection plans (e.g.--
l Palo Verde, ANO-2, Maine Yankee, Braidwood Unit 1, Byron Unit 1)
~
REGULATORY IMPLICATIONS (CON'T)
W and EPRI Have Previously Estimated up to 30 Different Alternate Repair Submittals are Possible Within the Next 1-2 Calendar Years
Need for a Generic Approach to Address Current Problems: l
- Performance-based
- Adaptable
- Providing incentives
- Integrated - systems, materials, radiological i
85
PROPOSED GENERIC LETTER STEAM GENERATOR VOLTAGE-BASED REPAIR CRITERIA
GL Applicable Only to Axially-Oriented ODSCC at Tube Support Plate (TSP) - Issue in May 1995
Voltage Repair Limits (Based on Current Data)
Lower Limit' Upper Limit' 3/4 inch tubes -- 1.0 volts 3.0 volts 7/8 inch tubes -- 2.0 volts 5.5 volts
- current values, but allowed to vary if data supports
Acceptance Criteria:
- Conditional burst probability < 1 X 10 2
- Leakage < applicable 10 CFR Part 100 guidelines PROPOSED GL SG VOLTAGG-BASED REPAIR CRITERIA
Enhanced Inspection Guidance includes:
- 100% bobbin coilinspection of TSP intersections with ODSCC
- Selected follow-up rotating pancake coilinspection
- Additional controls on probe calibration, probe wear, analyst qualification, and noise
Implementation of GL Requires Acquisition of Tube Pull Data
! - Two tubes initially (minimum of four intersections) l
- One tube thereafter on 2nd or 3rd RF outage frequency
GL Requires Implementation of Reduced Operating Leakage (Primary-to-Secondary) Limit 150 GPD 86
PROPOSED CL S'3 VOLTAEE BASED REPAIR CRITERIA
GL has Applicability to Approximately 30 Plants (Having W SGs with Drilled-Hole TSPs)
lssued for Public Comment August 12,1994, Comment Period Expired September 12,1994
Comments Received from NEl (Coordinated Industry Comments), W, Duke Power, State of Illinois, NUSON, John Frewing (PGE)
Two Meetings Held with Industry on Nov 3,.1994 and ;
Jan 24,1995 to Discuss Specific Comrnants in More '
Detail
Final GL in Concurrence (including RES concurrence). l Meeting with ACRS and CRGR in May Time Frame.
Objective to issue Final GL in May 1995 l
l STEAM GENERATOR RULEMAKING
= lssued Advanced Notice of Proposed Rulemaking Soliciting Public Comments on September 19,1994
Public Comment Period Expired December 5,1994
Staff Schedule for SG Rulemaking:
- Draft rule / regulatory guide for public comments 12/95
- Final rulo/ regulatory guide 6/96
- Schedule is very tight with no margin for delays 87
.J
SO TUBE SLEEVINS ISSUES
Overall, Experience with Sleeves in US Has Been Good to Date
Cracking of Joints in Sleeved Alloy 600 Tubes !
Emerging issue, Especially for Heavily Sleeved Plants Without Plans for SG Replacement
industry Attempt for Circumferential Flaw Sizing / Acceptance Denicd Unreliable ECT, Flaw .
Growth Analysis, and Structural Integrity Data
EPRI Study of Sleeve Performance Under Review by NRC i
GENERIC LETTER CIRCUMFERENTIAL CRACKING OF SG TUBES
Reliable Detection and Sizing of Circumferential Cracks has been Identified as a Technical Concern by Both NRC and Industry
GL Under Development to Request Licensees to Inspect SG Locations Susceptible to Circumferential Cracking with a Technique Capable of Detecting the Degradation 88
\
TUBE SUPPORT PLATE LOCKING
In February 1995 Commonwealth Edison Submitted an Application to Use Higher ECT Voltage Limits than Currently Endorsed by the Proposed Generic Letter on ODSCC at Tube Support Plate Intersections Staff Met with Commonwealth Edison on February 23,1995 Staff Identified Significant Concern That Proposed Leakage Model Will Result in Unacceptable Leakage Values with Respect to Part 100 Commonwealth Edison Undertaking Test Program to Validate Leakage Model STEAM GENERATOR ISSUES
Industry Needs to Take Proactive Action to Expand Data Bases Used to Support Proposed Actions on SG's
- i.e., Data to Support Acceptance Criteria for Tube Circumferential Cracks at Sleeves.
i
Industry is Responsible for Assuring That SG Degradation is Reliably Detected Using Proper Equipment and Methods. Failure to Detect Degradation is a Violation of Appendix B.
69
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yt.gR REgg PROBABILISTIC RISK ASSESSMENT POLICY AND l>MPLEMENTATION PLAN REGULATORYINFORMATION CONFERENCE May 9,1995 I 91
PRA POLICY AND IMPLEMENTATION PLAN MAJOR ACTIVITIES TO DATE Public workshop on PRA Implementation Plan
Applications guidelines and decision criteria
PRA pilot applications
Maintenance Rule pilot site visits
Integrated Performance Assessment Process (IPAP) inspections 1
PRA POLICY AND IMPLEMENTATION PLAN MAJOR ACTIVITIES (continued) _
Insights from IPE
Training program and new courses for PRA
Draft reliability data reporting rule
Risk assessment for medical devices
High-level waste and Low-level waste performance assessment activities 1
92
)
PRA POLIOY STATEMENT AND IMPLEMENTATION PLAN PUBLIC OMMENTS ON POLICY AND PLAN Generally supportive of plan and policy statement
PRA method should compliment deterministic approach
Any risk-based regulations should avoid an addlilonal layer to the existing deterministic approach l l PRA Methods should be applied consistently by the NRC and by the industry
Implementation plan needs more near term I
activities l
1 PRA POLICY STATEMENT AND IMPLEMENTATION PLAN NEl PSA APPLICATIONS GUIDE l Staff reviewed NEl Draft PSA Applications ;
Guide l l
Guide accepted as a high level conceptyal l basis to begin pilot applications l
Details of guide to be evaluated in conjunction with pilot applications 93
PRA POLICY STATEMENT AND IMPLEMENTATION PLAN PRA PILOT APPLICATIONS
Priority pilot applications
-IST
- MOV testing
- Graded QA
Risk ranking methodology a central issue
- Dynamic vs. static methodology issues
being addressed
- Working meetings with industry groups and individual licensees to discuss issues are ongoing
Active discussions with potential volunteer licensees; pilots expected to start June /
July 1995
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i j PRA POLICY STATEMENT AND IMPLEMENTATION PLAN
IPE/IPEEE REVIEWS AND INSIGHTS
!
Accelerating IPE reviews
Focusing staff involvement on l l i
understanding and using insights I
RES/NRR will conduct presentations l In each Region to disseminate insights to inspection staff
IPEEE reviews and insights studies
- Just beginning
- Similar elements to IPE activities l l
l 1
PRA POLICY STATEMENT AND IMPLEMENTATION PLAN PRA STAFF TRAINING
Concept of three PRA KSA Levels c Four new courses based on JTAs
- Systems modeling techniques
- Risk Assessment in event evaluation
- Accident Progression j - Accident Consequence analysis l
l TWo new courses based on student and management feedback
- PRA insights into an IPE
- Advanced IRRAS l
PRA training focus group established to ensure training milestones ate met 96
(
s
' PRA POLICY STATEMENT AND IMPLEMENTATION PLAN RELIABILITY DATA NEEDS
PRA Plan
- currently, generic data unverified or outdated
- currently, plant-specific data sparse, inefficient
- Increased PRA role will increase data need
- PRA plan recognizes need for credible data from current experience for NRC and industry use l'
PRA Policy Statement j" - Enhance collection of equipment and human reliability data
- Make data available to public
W
- _ ~
Proposed Rule for Reporting Equipment Reliabilit: Data Charles E. Rossi, Director Safety Programs Division Office for Analysis and Evaluation of Operat lonal Data In August 1994, the staff presented the Comission with a proposed probabilistic risk assessment (PRA) policy statement. The proposed policy was published for coment in the Federal Reaister on December 8, 1994 (59 FR 63389). Among other things, the proposed policy statement indicates that NRC will expand the use of PRA techhology in all regulatory matters to the extent
supported by the state-of-the-art in terms of PRA methods and
data. It also indicates that this implies the staff must significantly enhance the collection of human and equipment
, reliability data.
The Nuclear Regulatory Comission (NRC) is proposing to amend its regulations to require that licensees for comercial nuclear power reactors report to the NRC sumary reliability and availability data for risk-significant systems and equipment. The proposed rule would also require licensees to maintain ensite, and to make available for fiRC inspection, records and documentation that provide the basis for the sumary data reported to the NRC. This information would improve the NRC's ability to make risk effective regulctory decisions consistent with the. proposed policy statement. The systems and equipment for which data would be provided am : mbset of the systems and equipment within the scope of b ts*4 tenance i rule.
l The proposed terorting requirements would apply to the event mitigating systems and equipment which have or could have a significant effect on estimated core damage frequency or the probability of preserving containment integrity. Sumary infwnation reported to the NRC would be:
(a) The numb 3r of demands, the number of failures to start associe;ed with such demands, and the dates of any such failures, characterized according to the identification of the train affected, the type of demand (test, inadvertent / spurious, or actual need), and the plant mode at the time of the demand (operating or shutdown),
99
(b) The number of hours of operation followins each successful start, characterized-according to the ide'itification of the train affected and whether.or not the optration was terminated because of equipment failure, with the dates of any such failures,
! (c) The number of hours of unavailability, characterized i according to the identification of the train affected,
the plant mode at-the time of the unavailability (operating or shutdown), the type of unavailability (planned, unplanned, or support system unavailability), and, if due to
support system unavailability, identification of the support system, (d) For each unavailability due to component failure (s), a failure record identifying the component (s) and providing ,
the failure date, duration, mode, cause, and effect, and (e) The number of hours when two or more trains from the same or different. systems were concurrently unavailable, characterized according t.o the identification of the trains that were unavailable.
The proposed rule is intended to be a simple, performance-based rule supplemented with a detailed regulatory guide. The guide would previde methods for selecting systems and equipment subject to the rule. The guide would also provide methods to define demands, failure, unavailability, and train boundaries for each system consistent with PRA applications and suggest formats for reporting the data to NRC and maintaining the data on site. The NRC staff will work with public and industry representatives in developing the guide. A draft guide will be published for comment before it is finalized, and public workshops are planned before and after publication of the draft guide.
The proposed rule is necessary to improve the NRC's ability to make risk-effective regulatory decisions consistent with the proposed PRA policy statement. Implementation of the policy is expected to improve the regulatory process through (1) improved risk-effective safety decisionmaking, (2) more efficient use of agency resources, and (3) reduction in unnecessary burdens on licensees. Some examples of how reliability and availability information would be used to improve current NRC regulatory applications that consider risk in the decision process are generic issues resolution, indicators of plant performance, Accident Sequence Precursor models and events review, risk-based 100
inspections, maintenance monitoring, risk-based technical specification requirements, performance-based quality assurance
and cost-beneficial licensing actions.
Our schedule is to issue the final rule in the Federal Reaister by May 30, 1996, to become effective on July 1,1996, consistent with
, the Maintenance Rule. There would then be a six-month period for
implementation.
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PROPOSED RULE
{ e Rule is a simple, conceptual statement of the data to l be reported l -
Annual report of quarterly, train-level data for risk-l significant systems
[ -
Demands, failures, hours of operation, j unavailability, component failure information and i concurrent train outages Supporting documentation and records maintained
on-site e Regulatory guide will provide further detail Minimum set of basic systems for all plants Method for selecting additional systems based on plant-specific risk-significance Definitions of risk-significant safety functions, l
failures, train-level demands Guidance on defining system and train boundaries NRC APPLICATIONS e Generic issue Identification and Resolution e Risk-based Indicators of Plant Performance e Accident Sequence Precursor Program and Event Review e Risk-based inspections e Maintenance Monitoring e Risk-Based and Customized Technical Specification Requirements e Performance-based Quality Assurance e Cost-beneficial Licensing Actions 102
l a
l SCHEDULE l
e Commission approval of proposed rule -
l 5/15/95 i
j e Publish proposed rule in Federal Register -
i
! 5/30/95 i
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e Pilot applications - begin Spring 1995 '
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First public workshop - 8/95 ,
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o issue draft regulatory guide for comment -
11/1/95 l o Second public workshop - 2/96 i
t O Commission approval of final rule - 5/15/96
! o issue Federal Register Notice of final rule -
1 l 5/30/96 i
j O Licensees set up reporting programs, collect
} d'ata and provide first annual report 1/1/98 103 i . __
PRA Staff Training-Kenneth A. Raglin, Director Technical Training Division Office for Analysis and Evaluation of Operational Data e Concept of Three PRA KSA Levels Enhanced use of PRA in the agency requires the staff to develop new knowledge skills and abilities (KSAs) in PRA methods and statistics. These KSAs are considered to fall into three broad categories: basic level KSAs, advanced level KSAs, and expert practitioner KSAs. Basic level applications include the use of PRA results.- Advanced level applications include working with PRA niodels ::'ich as IPEs.
Expert practitioner level applications includa quality assurance and new methods development. Extensive training elements are necessary to improve staff capabilities for the lower two categories of KSAs, while the most sophisticated PRA users require KSAs that can cnly be obtained through education and exp3rience. The existing PRA training-curriculum will serve as-the basis on which to continue staff development in the training area. The staff plans to -
provide rotational assignments to the PRA branches and other Lctivities to provide necessary experience, e' Four New Courses-Based on JTAs Based on needs identified as a result of job and task ._
analysis activities, four new courses are being added to the PRA training curriculur.
- Systems Modeling Techniques -
The Systems Modeling Techniques course is designed to.
provide students with advanced skills in event / fault tree development and common mode failure miculations. This
. course is currently being developed, nd the first presentation is scheduled for May 16, 1995.
- Risk Assessment in Event Evaluation The Risk Assessment in Event Evaluation course is also in development and 's designed to provide students with the necessary skills for the calculation of plant conditional 104
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core damage. probability using the Accident Sequence Precursor databases and the graphic evaluation module of the SAPHIRE suite of PRA computer programs. The first
i. presentation of.this course._is scheduled for June 27, 1995.
j -
Accident Progression Accident Consequence Analysis
! Accident Progression and Accident Consequence Analysis i
courses are designed to provide students with advanced t skills in level two and level three PRA methods.
Development of these courses will begin in April 1995, and
course presentations are projected to begin July 18, 1995 and August 15, 1995, respectively.
~
It-is expected that additional courses will be developed
! after the completion of the Nuclear Materials Safety and--
s Safeguards JTA, e Two New Courses Based on Student and Management Feedback l Two courses were added to the PRA training program as a j_ result of student and management feedback.
PRA Insights Into an IPE-The PRA Insights Into An IPE course is designed to provice
students with a realistic, intensive opportunity to use-l actual PRA results and information.as a decision-making
?
tool. Since its creation in October 1994, this course has been presented in_each of-the four NRC regions and i headquarters to a total of 134 employees.
4 -
Advanced IRRAS t
The Advanced IRRAS course is designed to develop advanced j skillsLin the use of the Integrated Reliability and-Risk i Analysis System software. The first presentation of this ,
course was in December 1994; _ the second_ is scheduled for l April'1995..
- e- Data Analysis Seminar A Data Analysis. Seminar was developed to satisfy special i i needs of personnel within the Reliability and Risk p Assessment Branch of AE00. 'This-seminar course covered i
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Binomial and Poison Updating and was completed in December 1994 with twenty students participating. Material from this seminar will be added to other courses in the PRA training program.
Additional courses are under consideration for development, including a PRA Technical Managers course. PRA training in the first two quarters of FY 1995 has already equalled that done in all of FY 1994. Assuming the availability of sufficient budget resources, this pace of PRA training is expected to continue, e Interaction With ACRS on the PRA Training Program The staff has briefed the ACRS on the status of the PRA training program and is working to evaluate and incorporate ACRS recommendations into the staff training planning process. There will be an ongoing dialog with ACRS to seek
, advice on the direction and content of staff training.
2
PRA Training Focus Group (PTFG)
The staff has also established a PRA Training Focus Group (PTFG) which consists of senior agency personnel who represent the NRC offices (NRR, NMSS, RES, and AE00) with implementation responsibilities in the PRA Implementation Pl an. The PTFG will take advantage of work previously done and documented by the PRA Working Group and the PRA training
! curriculum that has already been provided to agency personnel-for several years. It will help shape the PRA training program to best meet the integrated needs of the NRC staff.
k V
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PRA STAFF TRAINING e Concept of Three PRA KSA Levels e Four New Courses Based on JTA.s Systems Modeling Techniques Risk Assessment in Event Evaluation Accident Progression Accident Consequence Analysis e Two New Courses Based on Student and Management Feedback PRA Insights into an IPE Advanced IRRAS PRA STAFF TRAINING (Continued) e Data Analysis Seminar e Interaction With ACRS on the PRA Training Program o PRA Training Focus Group (PTFG) 107 l -..- __ . .. -. . _ _ . -
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i ProbabiListic Risk Assessment Policy and Implementation Plan l
4 Ray Ng !
Nuclear Energy Institute May 9,1995 .
Background
4 Regulatory Threshold Working Group Industry comments on PRA Policy '
Statement and Implementation Plan Industry's PSA Applications Guide -
Future Activities NEl 109 l
Regulatory Threshold Working Group
{'
. Mission !
- promote the use of PSA and other new approaches to regulation as an aid to focus ,
attention and resources more effective 19 Goals
- PSA Applications Guide
- coordinate generic industry activities
- provide industry interface with NRC
. m Industy Comments on NRC PRA Policy Statement and Implementation Plan
NRC policy statement consistent with RTWG mission Appropriate for NRC to encourage use of PRA, but should not mandate Must overcome differences with deterministic methods in complementary manner
Plan should not slow current applications NEl 110
Industry's PSA Applications Guide Complementary to NRC PRA Plan Provides framework for use of PSA insights Addresses main issues including l - decision criteria

l - minimum specifications j -
Will be issued by NEI in May 1995 l
J j
Future Activities Applications 1
- ISI/IST
- Graded, performance-based quality assurance l - Day-to-day risk management Interaction with NRC on proposed ciata rule Risk-based and performance-based l regulation I 3
4 NEl l
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LICENSE RF3EWAL l
i 113
License Renewal Requires Two ;
Separate Reviews.
i Safety Review,10 CFR 54
- Environmental Review,10 CFR 51.
10 CFR Part 54: Safety Review.
- Part 54, the license renewal rule, establishes the technical requirements that an applicant must meet in order to be granted a renewed license.
Part 54 also contains the administrative and procedural requirements that need to be met in order for a renewed license to be granted.
The amendment to Part 54 willimprove and simplify the safety review.
114
\
Improvomonts to tho Liconso Renewal Rule.
Establish greater credit for existing programs, including the maintenance rule.
Eliminate tlie term Age Degradation Unique to License Renewal and focus the renewal review on long-lived, passive structures and components.
Focus the renewal review on detrimental effects of aging rather than the aging mechanisms.
Additional recordkeeping and FSAR updating requirements have been simplified and made less !
prescriptive. I l
l l
l Issues and Comments:
Current Licensing Basis - Compilation and l l
Interpretation Scope of Rule Resolution of Generic Safety issues or Unresolved Safety issues l
Role of Probabilistic Risk Assessment l Redundant structures and components Backfit protection Piece-part review 115
Tho Now Licenso Ronewal Rule is
! Based on Two Principles.
i
! First Principle - With the possible exception of the
detrimental effects of aging on the functionality of I certain plant systems, structures, and components in the period of extended operation and possibly a few other issues related to safety only during extended
[ operation, the regulatory process is adequate to ensure
! that the licensing bases provides and maintains an acceptable level of safety.
second Principle - The plant-specific licensing basis j must be maintained during the renewal term in the l same manner and to the same extent as during the i original licensing term.
i Scope of the Renewal Review.
Safety-related systems, structures, and j components.
l Nonsafety-related systems, structures, and j j components whose failure could prevent !
I satisfactory accomplishment of any safety-related l functions.
4
- Systems, structures, and components relied on to l comply with the regulations for fire protection, environmental qualification, pressurized thermal j shock, anticipated transients without scram, and
! station blackout.
I 116 l
! Intograted Plant Assossmont, j
- All systems, structures, and components within the l scope are assessed to determine if an aging l management review is required.
Aging Management Review.
All structures and components that are long-lived and perform a passive function require
an aging management review.
i
Time-limited Aging Analysis Evaluation.
l - All calculations and analysis within the scope that i are based on time-limited assumptions, defined by i the current operating term, must be evaluated for the period of extended operation. !
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l Standards for issuance of a renowed
! license. ;
i l Actions have been identified and have been or will be !
taken with respect to -- l
! l i (1) Managing the effects of aging during the period l of extended operation on the functionality of l structures and components that have been
! identified to require review, and i
! (2) Evaluating time-limited aging analyses that have j been identified to require review l such that there is reasonable assurance that the activities authorized by the renewed license wi!! continue to be
! conducted in accordance with the current licensing basis.
117 i
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i Future NRC Activities:
Complete Part 51 rule revision.
Develop Part 54 Regulatory Guidance.
Review Owners Groups and utility reports and l
applications.
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. - - - - - = _.. . .. . _ _ . - . - . _ _ , _ - . _ _ . -- - . . _ _ _ - -
LICENSE RENEWAL l
10 CFR PART 51 RULE AMENDMENT PRESENTATION BY j DONALD P. CLEARY !
0FFICE OF NUCLEARY REGULATORY RESEARCH !
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BACKGROUND e PURPOSE OF RULEMAKING:
i e IMPROVE REGULATORY EFFICIENCY AND STABILITY e APPR0ACH:
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USE EXPERIENCE FROM OPERATING REACTORS
SCENARIOS FOR REFURBISHMENT AND CONTINUED DPERATION e IDENTIFY P0TENTIAL IMPACTS TO THE ENVIR094ENT l
< e CONSERVATIVE BOUNDING ESTIMATES OF IMPACTS i e DOCUMENT ANALYSIS IN GENERIC ENVIR0W4 ENTAL IMPACT j STATEMENT (GEIS) e C0DIFY FINDINGS IN 10 CFR PART 51
)
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MM0R FEATURES OF THE PROPOSED RULE I
$ 56 FR 47016, SEPTEMBER 17, 1991
! e ISSUES ADDRESSED 104 TOTAL 80 ADEQUATELY ADDRESSED IN THE GEIS (CATEGORY 1) -
22 REVIEW REQUIRED FOR SOME PLANTS AT TIME OF APPLICATION (CATEGORY 2)
( 2 REVIEW REQUIRED FOR EVERY PLANT AT TIME Of APPLICATION (CATEGORY 3)
SIGNIFICANCE OF IMPACT: SMALL, MODERATE OR LARGE MM0R FEATURES OF THE PROPOSED RULE C0N'T e ECONOMIC TEST TRIGGERS PLANT-SPECIFIC REVIEW 0F .
ALTERNATIVE ENERGY SOURCES
CONDITIONAL COST-BENEFIT BALANCE e ENVIRONMENTAL ASSESSMENT (EA) PROVISION 120
PUBLIC COMENTS
!
ADEQUACY OF PROCEDURAL PROVISIONS FOR COMPLIANCE WITH NEPA
INTERFERENCE WITH STATE REGULATION 0F i e NEED FOR GENERATING CAPACITY e MIX OF ALTERNATIVE SOURCES OF ENERGY e UTILITY ECONOMICS
) e WASTE MANAGFMENT e OTHER I
COMENT RESOLUTION 4
i
, o PROCEDURAL: UNDERSTANDING WITH CEQ & EPA r
e NO CONDITIONAL COST-BENEFIT CONCLUSION
SUPPLEMENTAL EIS RATHER THAN EA e CONCLUSION ON THE ACCEPTABILITY OF IMPACTS AT THE TIME OF THE PLANT-SPECIFIC LR REVIEW e PUBLIC COMENTS EVALUATED REGARDLESS OF CATEGORY OF ISSUE 121
r ComENT RESOLUTION CON'T e INTERFERENCE E TH STATE REGULATION e RESOLUTION PROCESS e STAFF APPRGACH - SECY-95-029 e DEFINITION 0F " PURPOSE AND NEED"
N0 NEED FOR POWER ANALYSIS e TREATMENT 0F ALTERNATIVES e STRICT ENVIR0 MENTAL FOCUS e N0 UTILITY ECONOMICS e PLANT-SPECIFIC REVIEW e DECISION STANDARD DEFINITION OF " PURPOSE AND NEED" "THE PURPOSE AND NEED FOR THE PROPOSED ACTION (RENEWAL OF AN OPERATING LICENSE) IS TO PROVIDE AN OPTION THAT ALLOWS FOR POWER GENERATION CAPABILITY BEYOND THE TERM 0F A CURRENT NUCLEAR POWER PLANT OPERATING LICENSE TO MEET FUTURE SYSTEM GENERATING NEEDS AS SUCH NEEDS MAY BE DETERMINED BY STATE, UTILITY, AND, WERE AUTHORIZED, FEDERAL (OTHER THAN NRC) DECISION-MAKERS."
NOTE: THE COMISSION HAS INSTRUCTED THE STAFF TO CONSIDER WHETHER USE OF THE WORD " UTILITY" MAY BE T00 NARROW A TERM GIVEN TODAY'S ENVIRO M ENT OF DEREGULATION, 122
DECISION ST C ARD "NRC WOULD REJECT THE LICENSE RENEWAL APPLICATION IF THE ANALYSIS DEMONSTRATED THAT THE IMPACTS OF THE INDIVIDUAL LICENSE RENEWAL WERE SUFFICIENTLY IN EXCESS OF THE IMPACTS OF ALL OR ALMOST ALL 0F THE ALTERNATIVES SUCH THAT PRESERVING THE OPTION OF LICENSE RENEWAL FOR FUTURE DECISION-MAKERS WOULD BE UNREASONABLE."
l
i GENERAL FEATURES OF THE PROPOSED FINAL RULE e PROVISIONS REFLECT DEFINITION 0F " PURPOSE AND NEED"
. N0 NEED FOR POWER
! . ALTERNATIVE SOUR.CES OF ENERGY
. . ALTERNATIVES ANALYSIS FOCUSES ON ENVIRONMENTAL IMPACTS e NO ANALYSIS OF UTILITY / ENERGY ECONOMICS e NEW DECISION STANDARD e EIS REQUIRED 4
LR DECISION ONLY AFTER PLANT-SPECIFIC REVIEW e OTHER THAN NOTED AB0VE THE SCOPE OF ISSUES REMAINS THE SAME e SU M ARY TABLE IN THE RULE CONTINUES TO LIST ENVIRONMENTAL ISSUES
! AND IDENTIFY WHETHER PLANT-SPECIFIC REVIEW WILL BE REQUIRED SCHEDULE 3
e FINAL RULE PACKAGE ME TO THE COMISSION OK NAY 15, 1995 ;
e ANTICIPATE PUBLICATION OF THE FINAL RULE BY THE END i 0F JUNE 1995 l
123 4
- LICENSE RENEWAL INDUSTRY PERSPECTIVE AND STATUS OF ACTIVITIES DOUG WALTERS NUCLEAR ENERGY INSTITUTE
-ABSTRACT l
- As utilities consider choices for satisfying the anticipated electricity detaand of the next two decades and beyond, they will explore a range of options, In addition to renewing the operating licenses of nuclear power plants, other options include extendSg the lives -
of fossil fueled plants and installing new baseload capacity whether it be coal, gas, nuclear or renewable energy.
The determination of which option to pursue is a business decision that considers safety and environmental issues, ef"icient use of capital, and the associated operating and maintenance costs.
Focusing on the nuclear license renewal option, the promulgation of a stable and predictable license renewal regulation will result in an efficient process that is an essential element of the business decision facing utilities today.
'Ihe industry believes the proposed amendments to 10 CFR Part 54 are an improvement to the existing regulation and can result in a stable and predictable renewal process. The amendments move away from evaluating unique aging mechanisms and instead focus on evaluating the aging effects on a defined subset of components and structure; those that
- are long-lived and passive. Further, the amendment acknowledges the existence and 1 benefit of the maintenance rule and exiting plant programs; the latter principally as aging management programs.
Similarly, the amendments to 10 CFR Part 51 appear to be moving in a direction that will promote stability and predictability in the environmental requirements for license renewal. The industry continues to support the concept of a Generic Environmental Impact Statement (GEIS) and we are optimistic that the most recent SECY will further enhance the streamlining.
There are a number of ongoing industry programs: some utility specific, others under the purview of the NSSS Owners groups. NEI is focusing its efforts. on an industry implementation guideline that will be submitted to NRC for endorsement. This guideline'-
is under the oversight of the NEI License Renewal Working Group, chaired by Mr. Mike Tuckman of Duke Power. The guideline is expected to be completed within three months from the date the final rule is published.
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NUCLEAR POWER PLANT LICENSE RENEWAL
! INDUSTRY PERSPECTIVES AND ACTIVITIES I
DOUG WALTERS NUCLEAR ENERGYINSTITUTE
] U.S. NUCLEAR REGULATORY COMMISSION REGULATORY INFORMATION CONFERENCE MAY 9,1995 WASHINGTON, D.C.
LICENSE RENEWAL - BACKGROUND i l Options for satisfying future demand Nuclear power plants can operate safely beyond 40 years.
Continued plant operation is a business decision Renewal process an important prerequisite to the I business decision
- Stable and predictable renewal regulations: 10 CFR Part 54 and 10 CFR Part 51.
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LICENSE RENEWAL - FINAL AMENDMENT TO PART 54 a Focuses aging management reviews on " effects" rather than mechanisms Aging management reviews on smaller set of plant components and structures: long-lived and passive Recognizes maintenance rule and existing plant programs i
a LICENSE RENEWAL - FINAL AMENDMENT TO PART 51 Support concept of Generic Environmental Impact Statement Only incremental environmental impacts need to be reviewed
' I 126
LICENSE RENEWAL -INDUSTRY ACTIVITIES 4
Utility programs

NSSS Owners Group programs NEl Task Force Developing implementation Guideline for
Part 54 4
LICENSE RENEWAL -INDUSTRY IMPLEMENTATION GUIDELINE
- Kickoff meeting in September 1994 Develop a technical guideline
- Use technical guideline as input Submit to the NRC for endorsement
- Scheduled for completion within 3 months from publication of final rule 127
.-. }
LICENSE RENEWAL -INDUSTRY IMPLEMENTATION GUIDELINE o An approach for satisfying requirements of Part 54.
o Does not address Part 51 o Draws on experience and existing programs, including the maintenance rule
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i May 9,1995 Afternoon Plenary Session 1 1
2:00 p.m. - 3:30 p.m.
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/
INSPECTION PLANNING, OVERSIGHT, AND FOLLOWUP L. JOE CALLAN REGION IV 130 Y _-___ .
INSPECTION PLANNING PROCESS Available Inspection Resources
> SALP NRc
_ inspection
^ Program (MC 2515) v vv g Plant .
Reactive Completed Performance f > MIP* ->
Inspections inspections A
-> y
> PPR*
OMIP - Master Inspection P;on
& PPR - Pionned Performance Review
\ . . .
INSPECTION RESOURCES vs DEMAND FOR NRC REGION IV
. TOTAL AVAILABLE INSPECTION HOURS 48,000 hrs /yr
- 48 Region-based inspectors 23,200 its/yr
- 27 Site-based Inspectors 25,000 hrs /yr i
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. TOTAL EXPECTED INSPECTION HOURS 52,000 hrs /yr
- Planned inspection Hours 47,000 hrs /yr .
- Expected Reactive inspection Hours 3,600 hrs /yr i
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TYPICAL INSPECTION HOURS FOR A SINGLE UNIT SITE (ANNUALIZED) i l '.
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, TOTAL 2000 HRS /YR TOTAL 4000 HRS /YR i
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l REGULATORY IMPACT FORM DATE ORIGINATOR (NAME/0RG) 1 LICENSEE (NAME/ TITLE)
FAVORABLE FEEDBACK UNFAVORABLE FEEDBACK COMMENTS l
l RECOMMENDATIONS / RESOLUTION 4
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l May 9,1995 1
4 Afternoon Breakout Sessions l
l 3:45 p.m. - 5:15 p.m.
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i SHUTDOWN RISK PROGRAM Gary M. Holahan, Director Division of Systems Safety and Analysis Office of Nuclear Reacter Regulation U. S. Nuclear Regulatory Commission l
139
_--J
SHUTDOWN RISK PROGRAM l Proposed rule published in FR 52707 on 10/19/94 54 commenters provided > 1000 comments by 2/95 Staff met with commenters in public meeting 4/7/95:
Summarized comments
Provided initial staff response
Plans continuing dialogue with industry
Modifying rule, regulatory guide, & regulatory analysis
ACRS review planned 10/95
Issue rule, guide, & analysis for comment 12/95
Publish rule, guide, & analysis 8/96 OUTAGE PLANNING AND SHUTDOWN RISK Staff is modifying rule; writing new regulatory guide and new regulatory analysie. Rule will:
Provide minimum requirements for safety
Ree aire cont'1gency plan if minimums not met e Require controls to meet safety requirements
Allow practical and flexible operations
Be designed to minimize event occurrence
Be designed to assure mitigation of events
(
140
l OUTAGE PLANNING AND SHUTDOWN RISK - Centinu:d Rule will not encompass: l
Outage planning
Low power operation
Fire protection ;
Technical specifications
Fuel stora0e pool
Single failure criterion Rule will:
Allow open/ closed containment concept
Require redundancy where appropriate
Use concept of available rather than safety related
Not require specific instrumentation i
l 141
' OUTAGE PLANNING AND SHUTDOWN RISK Tony Pietrangelo Nuclear Energy Institute May 9,1995 i
142
g Backgrcund {
i
Industry initiated efforts in 1990 to address shutdown risk 4 in parallel with NRC activities NUMARC 91-06 focused on assessing and improving shutdown management; approved by NUMARC Board of Directors as a formal industry initiative INPO conducted workshops, outage review visits, and revised outage management guidelines EPRI developed tools for utility use through Outage Risk Assessment and Management program l
Background (continued)
Industry comments were submitted on draft NUREG-1449 in 19P2 l Promulgation of maintenance rule and regulatory guide endorsement of NUMARC 93-01 Severalletters in 1994 to the NRC staff and Commission communicating concerns with technical approach and regulatory analysis supporting proposed rule Industry comments on proposed rule submitted 2/95 NEl 143 l
Industry Porsp ctivo Substantialimprovements have been realized in shutdown safety over the last few years due to increased management attention Ancillary benefit has been more efficient outages
Self-interest will spur further improvements - shorter, safer outages benefit all parties Maintenance rule provides appropriate regulatory oversight and enforcement basis when needed Industry Actions
. Industry will continue efforts to improve outage practices NEl will continue to provide industry interface with NRC NEl Nuclear Strategic issues Advisory Committee will discuss future course of industry actions later this month NEl 144
10 CFR PART 52 ADVANCED REACTORS / DESIGN CERTIFICATION
+#yt.kn REoq%
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l DENNIS M. CRUTCHFIELD l ASSOCIATE DIRECTOR FOR ADVANCED REACTORS AND LICENSE RENEWAL OFFICE OF NUCLEAR REACTOR REGULATION MAY 9,1995 i
145
)
10 CFR Part 52 Advanced Reactors / Design Certification e Status of design reviews / COL implementation issues - D. Crutchfleid e Industry view of COL implementation issues - R. Simard e NRC Construction Inspection Program - R. Borchardt e Industry commitment to life cycle standardlwlon P. Mcdonald EVOLUTIONARY DESIGN REVIEWS ABWR e FDA issued July 13, 1994 e FSER published July 1994 (NUREG-1503) e DCD approved February 1995 System 80+
e FDA issued July 26,1994 e FSER published August 1994 (NUREG-1462) e DCD approved March 1995 Proposed Design Certification Rules issued for both designs Public Meeting on Proposed Rules at 9:00 a.m. on May 11, 1995 146
WESTINGHOUSE AP600 DESIGN REVIEW DSER Issued No- uber 1994 e > 1100 Open Items e Open item tracking system developed Selected Significant Issues e Testing and Code Verification and Validation e Regulatory Treatment of Non-safety Systems (RTNSS) Process e PRA/ Passive System Reliability e Source Term Expedited Schedule e DSER Supplement on Test Program October 1995 e Publish Final Safety Evaluation Report - August 1996 e Issue Final Design Approval (FDA) - September 1996 e Proposed Design Certification Rule - December 1996 l
ADDITIONAL DESIGN REVIEWS I SBWR o Design-related review activities suspended August 1994 e
NRC will revise design review schedule based on test program status and GE's decision to restart CANDU e AECLT submitted design certification application for CANDU 3U in September 1994 - acceptance review completed December 1994 e in March 1995 AECLT requested that review be discontinued MIITGR e Preapplication. safety evaluation report will be completed in 1995 EPRI PASSIVE URD e FSER published August 1994 (NUREG 1242, Vol. 3) 147
COMBINED LICENSE (COL) ISSUES Contents of Application l
l
Reference a cedified design 1
- Site-specific design Information
- Demonstrate compilance with interface requirements
- Document changes from standard design e Siting information (assuming no ESP) l
- Environmental report :
- Site redress plan
Construction Plan e Emergency planning information e Living PRA COMBINED LICENSE (COL) ISSUES Form and Content of License
l e Combination of CP & OL e Incorporate Design Certification Rule by reference
- Both Tier 1 and Tier 2 e License conditions fo c post fuel activities 148
COMBINED LICENSE (COL) ISSUES COL ITAAC e Design Certification ITAAC plus plant-specific ITAAC
Include site-specific design features
Include emergency planning ITAAC Must address all requirements for authorization to operate COMBINED LICENSE (COL) ISSUES ITAAC Verification Licensee must develop detailed construction drawings NRC developing new Construction Inspection Program Increased interaction between licensee and NRC Licensee determines. completion of ITAAC
)
NRC evaluates licensee's determination NRC publishes notices of successful completion of ITAAC 149
Construction Inspoction Program
CIP Purpose
CIP Objectives
Inspection Techniques
Inspection Scheduling
Inspection Staffing
Inspection Procedures
CIP Data Base Management System 4
Construction Inspection Program Purpose Provide requirements and policy for implementing the inspection program during power reactor construction l
l 150
i Construction Inspoction Program Objective Ensure public health & safety by evaluating licensee performance
Technical requirements
Quality requirements
Administrative requirements Construction Inspection Program Inspection Techniques -
provide QA insights and independent verification
Procedure review
Direct observation
Indeoendent measurement
Record review 52
Construction Inspoction Program .
Inspection Scheduling
Scope of program developed during application review- site specific inspection plan prepared
Long & short range schedules -
updated frequently to follow construction schedule
Onsite NRC scheduler interfaces with licensee
Controlled & implemented by resident staff Construction Inspection Program Site Specific Inspection Plan
Relate license conditions (including ITAAC) to IPs
Identifies SAYGO points (if used)
Identifies frequency of IP performance
Identifies period of IP performance l
Consistent with minimum CIP requirements
Basis for developing inspection schedules 152
Construction Inspoction Program ,
Resident inspection Staff Construction Site Manager Senior Construction Civil / Structural Inspector Senior Construction Mechanical Inspector
Senior Construction Electrical and l&C inspector Construction Site Scheduler Construction inspection Program Specialist inspectors das appropriate)
Geotechnical
Civil / Structural
Vendor
Welding /NDE
Mechanical
Electrical
I&C
Fire Protection
QA/QC
Testing & Preoperational
Security /HP/EP 8 to 12 inspectors routinely onsite 153
Construction Inspoction Program Inspection Procedures
New format for revised CIP
Critical Attributes for each IP must be inspected
Sampling criteria provided for each IP
New IPs will be required for inspecting the application of new technologies
For facilities constructed under Part 52, IPs will be linked to ITAAC Construction Inspection Program l CIP Data Base Management System
Microprocessor based system l
l
Used to record inspection generated data Provides for quick retrieval of inspection data
Will be used to create inspection documentation Will be used to create management reports 1RA
i l OOMMITMENT MANAGEMENT /CBLA l
l PROGRAM STATUS UPDATE GAR REG O 49 -
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l Gene Imbro U.S. Nuclear Regulatory Commission May 9,1995 i
l 155 l . -
CBLA PROGRAM PURPOSE
Purpose of the CBLA Program:
/ Enhance safety
/ Reduce unnecessary regulatory burden
/ Increase efficiency of licensee and regulatory staff CBLA DEFINITION
Identified By Licensee as CBLA
High Quality Submittal- Technically Complete
CBLAs are NOT Safety Significant issues -
Results in at least $100,000 Savings in O&M Costs or Capital Expenses Over Life of Plant
CBLAs Should be Plant-Specific.
Have Current Application (No Contingency issues) 1 156 l
CBLA GROUP FUNCTIONS l
i
Institutionalize the CBLA Program
/ Assure program implementation
Track CBLAs - Provide Reports to EDO/ Commission

Point of Contact for Licensees On CBLA issues l CBLA ADMINISTRATIVE LETTER l Administrative Letter 95-02 issued 2/23/95
Major Points:
/ Definition of CBLA Criteria
/ NRR Receptivity / Responsiveness
/ NRC Safety Focus is Unchanged
/ CBLA Program is Strictly Voluntary i
157
r LICENSEE ACTIONS TO FACILITATE REVIEW i
Indicate That CBLA Status is Requested i Prioritize CBLAs with Other Licensing Activities
~
l Consider: 1
/ Technical Complexity i
/ Change of Current Staff Practice l
/ Regulatory Vehicle Needed l (Amendment, Rulemaking) l
High Quality / Technically Complete Submittals :
/ High Cost / Low Safety Determination

Include Estimate of Lifetime Cost Savings 4
CBLA DATA 4
(From 1/1/94 Through 3/17/95)
ACTION 1993* 1994 1995 Total -
t Submitted 33 106 6 145 Approved 6 54 27 87 Denied 2 6 0 8 Withdrawn 3 0 0 3
Under Review 22 68 47 47 N
Estimated $ Savings $20 M $324 M $66 M $410 M of Approved CBLAs**
Data from 1993 CBLA pilots (Entergy, Vepco, NEU, FPC, Georgia Pwr).
Savings based on licensees' estimates.
158
CBLA Completion Rate
Does not include 1993 Pilot Program Data]
! # of Completed CBLAs l 20 uw
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i Months to Complete
! Average CBl.A completion age = 4.5 months
! Average Priority 3 completion age = 11 months 1
MANAGING REGULATORY COMMITMENTS I
NEl Effort Establishes a Uniform Process for Managing Commitments
Process Will Reduce Regulatory involvement j
Benefit for Regulator and Licensees

NRC Goal- Acknowledge the NEl Process as ;
One Acceptable Method to Manage Commitments i
I MANAGlNG REGULATORY COMMITMENTS NEl Evalution Process Contains Five Levels of Significance
/ FSAR and Plan Changes - 50.59 or 50.54
/ Determine Safety Significance
/ Necessary to Maintain Compliance
/ NRC Reliance on Commitment
/
Commitment Minimizes Recurrence of Adverse Condition 160
MANAGING REGULATORY ODMMITMENTS 3
NRC Pilot Program Completed Verifying j Implementation of NEl Guicance ;
j / Millstone, Browns Ferry l / Comanche Pea <, Fermi h Regional and Headcuarters Participation in Pi o:s lo Licensees Implementation Conservative lo NRC considering minor clanges
.to NEl process jo NRC Acceptance Le:ter Sclecu ec l for Aug 1995 161
. ._- . - - .. l
0 Commitment Management and the NEl Process by Tim Hoae Regulatory Com aliance Manager TU Electric-Comanche Peak 9 May 95 162
I 1
l i
j l Presentation Outline l
i l = Background l
History Commitment Management Burden Reduction Efforts
= NEl Guidance Implementation Definitions l
Procedure Revisions
! = Pilot Plant Review 1 i -
Scope l
Results l
Conclusions k
l l
l
[
j 163
Background
! = History 4 -Commitment Tracking Established to
support Unit 1 licensing and ongoing compliance
- Historical reviews completed for past 4 correspondence
- License Basis Documents reviewed,
includes FSAR, and all other LBDs
! - Commitments maintained in a site wide
computer data base called the i
Commitment Tracking System (CTS)
-Commitment and related source and i implementing information contained in CTS j as a Commitment Data Form (CDF)
= Commitment Management
- Commitments identified, and maintained by site wide procedures to assure ongoing l compliance
- Procedural controls rec uire CTS commitments to be rev ewed as part of a procedure revision
-10CRF50.59 safety screen procedure requires reviewing affected LBDs. LBDs at CPSES include CTS commitments
- Material changes to commitments not addressed by existing codified processes done by revising the source, or by 10CFR50.59 Safety Evaluation 164
i i
l i
I i
l Background l ,
t l
= Burden Reduction Efforts
- Commitment reduction effort started after Unit 2 license issued in 1993 j -Scope of review:
. review of construction phase CDFs to delete those not applicable to the operational phase i e consolidation of similar or redundant !
l CDFs while maintaining all source !
l information ,
i . Other CDFs reviewed as targeted by l l subject area, organization, or as part of l l ongoing procedure reviews.
l . Goal was to have all CDFs reviewed by i end of 1996 i
165 L . . _ _ _ ._. - . . . . _ . . - _ . -_ .- . _ --__ _ _ _ - - . . __
4 I
i i Comanche Peak Steam Electric Station (CPSES) l l
Commitment Reduction Values D === 5= 5- Ea sv ,
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" R seus AL N ccT H #Ud M AMt M Aue N NCN AMt 88 Date Open Incorporated Cinacd Deleted TOTALS Jul93 269 9693 4541 12114 26617 Oct 93 236 9591 4569 12256 26652 Jan 94 243 9418 4604 12434 26699 Apr 94 184 8744 4950 12867 26754 Aug 94 173 8276 5062 13270 26781 Dec 94 165 7931 5123 13614 26833 Apr 95 159 7688 5191 13886 26924 i
Changes -110 -2005 +650 +1772 +307 166
i l NEl Guidance implementation l = Definitions
! -CPSES Commitment definition j . "An actual or implied pledge by TU l
Electric, or an uncontested imposition by a regulatory agency, with regard to a parti ~cular course of action or j regulatory requirement which has j been submitted on the docket.
l Commitments identified in the cover
} letter of NRC Inspection Reports are j considered regulatory commitments."
i
- NEl Commitment definition
. Regulatorv Commitment means an i explicit statement to take a specific
action agreed to or volunteered by a licensee that has been submitted on the docket to the commission, by designated licensee management, in writing"
-CPSES retained it's existing definition of a commitment. CPSES definition encompasses NEl definition scope, but includes other NRC document sources.
- Added the NEl definition of an Obligation 167
NEl Guid~ance implementation
= Procedure Revisions
- Station procedure on commitment management revised to contain the new NEl change process.
. A new form called the Commitment Material Change Evaluation (CMCE) , and associated instructions were added.
. CMCE approval requires signatures from a preparer, management approval from the resposible organization, and final approval ~ by the Regulatory Compliance Manager
- Station procedure on 10CFR50.59 screens and evaluations was revised to endorse the CMCE process to evaluate changes to commitments.
. "10CFR50.59 Screen" form was changed to become an " Activity Screen" because the CMCE is now an option inaddition to the 10CFR50.59 Evaluation for certain changes 168
1 l
Pilot Plant Review l = SCOPE
- A subset of approximately 80 CDFs l
^
previously identified as part of an engineering consultant review as potential candidates for reduction selected to have "
! hypothetical" evaluations performed using j the CMCE guidance.
l Real" changes evaluated using the CMCE l as required by procedure would be added
! to the population when they became
! available i
l l 169
l L
l j
Pilot Plant Review I = Conclusions '
-The NEl commitment change guidance provides an effective method to evaluate and approve changes to commitments not already addressed by an existing codified process
-The level of review is sufficient to assure that the appropriate NRC notification, if required, is performed
-The NEl change process is less time consuming and less expensive than using a 10CFR50.59 Evaluation for changes to commitments outside of the "SAR"
. The required levels of review is less for the CMCE 10CFR50.59 evaluations require SORC (PORC) review and the CMCE does not
-The NEl guidance can be implemented now within the existing regulations 170 l
i i
i l Virainia Power's
~
l Cost Beneficial Licensina Proaram l
l
' Regulatory Information Conference l May 9-10,1995 l
l l
l l M. L. Bowling, Jr. - Manager Nuclear Licensing and Programs I
i i 171 l
Regulatorv Reduction Strategy
Rethink compliance philosophy
Identify regulatory requirements that are resource intensive but do not contribute to nuclear safety Put priority on eliminating commitments that do not require external review or approval
Keep issues that require NRC approval simple, straight-forward and non-controversial (i.e., low-hanging fruit)
Establish frequent communication and coordination with the NRC
Refer " generic" issues to NEl Rea_ulatory Reduction Implementation An. oroach i
Submit site specific changes to the NRC or other government agency l (e.g., FEMA, FERC, etc.) via TS changes, exemptions and code relief requests l
Set company and employee goals for regulatory reduction and establish
! Level 1 schedules to track implementation status Request reduced scope of NRC reviews or inspections
. Take advantage of generically approved Technical Specifications line item improvements Evaluate / revise / delete internal commitments Propose generic rulemaking 172 l
M i
identifying Regulatory Reduction items
Perform departmental functional reviews 1
Identify significant outage time requirements i
Review other utilities / industry groups efforts i l i
Influence proposed regulatory initiatives (Generic Letters, j rulemaking, etc.)
i )
i I
L i
1
! Selection Criteria
Safety impact
Cost benefit
!
Regulatory significance l
Plant specificity
Previously approved / recommended
- Other licensees submittals
! - Sanctioned by NRC (Generic Letter or other document) i e Generic application
Schedule l
l 173 i _
Examples of CBLAs Implemented By Virginia Power
Commitments Control Room Design Review $11,409,000 Reassessment AFW Pump Inspection Deletion $190,000/yr IRS Pump Inspection Deletion $104,000/yr P250 Computer Data isolation $2,000,000 Examples of CBLAs implemented By Virginia Power (Cont'd)
. Technical Specifications Chance Recuenta Performance vs. Prescriptive-Based $450,000/yr QA Audit Frequency Eliminate Sensitized Stainless Steel $129,000/yr Piping Inspections Type A Test Schedule Revision $750,000 Eliminate Loop Stop Valve Interlock $94,000/yr Change Semi-Annual Effluent $7000/yr Release Report to Annual 174
1 i
Examples of CBLAs implemented Bv Virginia Power (Cont'd)
Exemption Requests i
Biometric Personnel Entry System $155,000/yr l
i 10 CFR 50 Appdx J Type A $2,478,000
Exemptions i
! EP Annual Exercise Exemption $216,000 j (NAPS).
i 4
l 1
Regulatorv Reduction items Currently Working i
Turbine Valve Freedom Test Frequency Reduction
Extend EDG Allowed Outage Times 1

Reduce Record Retention Requirements I
l
Decrease RPS/ESF Functional Test Frequency l
1 l
a Reduce Security Requirements
Reduce Surveillance of Sealed Sources 175
CBLA Summary
27 CBLAs submitted to the NRC for approval
Status # of items Savings Approved 17 $10.2 M - One-Time
$1.15 M - Annually
, Pending NRC Approval 8 $1.4 M - One-Time
$1.1 M - Annually hur nt y 6 $144 K- One-Time
$655 K - Annually Virginia Power Begulatory Reduction Summarv
48 Regulatory Reduction items -(includes CBLAs) 1) Submitted to the NRC or Other Regulator or 2) Internti Commitment Changes I
Status # of items Savings Implemented 31 $19.3 M - One Time
$1.6 M - Annually Pending NRC $1.7 M - One Time Approval 13
$1.4 M - Annually Currently 7 $144 K - One Time Working
$771 K- Annually 176
i 4
! Reaulatory Reduction Benefits I
i
o Reduces workload l
l
o Reduces outage time and complexity l
o Allows existing resources to be focused on higher priority items i
lo Reduces costs through the elimination of unnecessary design
! change work i
l
o Reduces NRC inspection fees l
177
g
____-. Whd
4 i
l-l l
l l
l l REGULATORY BURDEN REDUCTION t
! Stephen D. Floyd Director, Nuclear Economics Nuclear Energy Institute i
NRC Regulatory Information Conference
! May 9,1995 i
i I
j 179
DEFINITIONS REGULATORY BURDEN
- Obligations and regulatory commitments that provide
negligible safety benefit or prohibit more effective means of achieving the intended safety benefit i
OBLIGATION
- Any condition or action that is a legally binding
requirement imposed on licensees through applicable j rules, regulations, orders, and licenses (including j technical specifications and license conditions).
! - REGULATORY COMMITMENT
- An explicit statement to take a specific action agreed to i- or volunteered by a licensee that has been submitted on i
the docket to the Commission, by designated licensee l management, in writing.
]
i 1
i REGULATORY BURDEN REDUCTION 1
INITIATIVES i
4 l
OBLIGATIONS
- Changed through:
Technical Specification Changes n License Condition Changes a Code Relief Requests a Rulemakings a Exemptions to Rules a Revisions to Plans Covered by 10 CFR 50.54 (QA, Security, EP)
- NRC Cost Beneficial Licensing Action Program provides elevated priority to burden reductions related to Obligations (with the exception of rulemakings) -
180
REGULATORY BURDEN REDUCTION i INITIATIVES i a COMMITMENTS i
- Can be changed without staff approval l - Process for changing commitments varies widely I across industry i
- NEl Commitment Management Guideline
developed to:
! a Focus resources on high value commitments a Eliminate unnecessary commitments l w Streamline and/or eliminate reporting l
l
! NEl COMMITMENT CHANGE PROCESS
!
Approach balances need for NRC to be aware of
commitment status and need for industry flexibility

Process asks five questions to assess safety i significance and/or regulatory interest in
, commitment change i - is there a codified process for changing commitment?
- is the change significant to safety?
! - Was the original commitment necessary to achieve j compliance?
l - Did the NRC rely upon the original commitment?
- Was the original commitment made to minimize
recurrence of an adverse condition?
he l
l 181
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l NRC Regulatory information Conference l May 9 & 10,1995 I
l l
i 183 i
l
CBLA Items Completed
-Engineered Safety Features / Reactor Protection Surveillance Test Frequency Reduction Containment Integrated Leak Rate Tut Schedule Biometric Access Control Removal of Licensing Condition Requiring RCP-Vibration Monitoring Program Return of Unit i to 100% of Rated Thermal Power t
5
. CBLA11tems: Completed Schedular Exemption from 10 CFR 50, App. J for Unit ILRT Scheduled for Retueling 5 Alternatives to ASME Section XI Code Application of Fire Induced Vulnerability Evaluation (Five) Methodology Appendix R, Fire Protection Modifications Radioactive Effluent Release Report Frequency a, : , v:w . ~ .: v . .
,e ,
in ,g =s'$26.9 eE,Estinisted Sh.v.sg e, y, a u,,Million p g g ,,iy<
l 184
I CBLA Items with the NRC Generic Shape Annealing Matrix Elimination of Charging / Auxiliary Spray System Commitments Removal of Accelerated Testing and Special Reporting Requirements for Emergency Diesel Generators
EstimatA. d Savbgsk$13.3 Million
,,3 h
, ,; . +
4 l
CBLA Items In-House ~
Elimination of 2/3 Cycle Moderator Temperature Coefficient Test High Energy Line Break in Auxiliary Building:
Risk Based TS Graded QA
, _,7 q <, , ,. ,
,. c!Estiinate'd'Savingi
.- _ m < :-
=. $23.6 Millio,n> 1 r, . s 185
, ~ . _ _ _ _ _ _
CBLA Items Being Considered Reduced STA Requirements in TS Reduction of Reactor Trip Breaker Surveillance Testing Continue Review of Commitments Continue Reviewing Industry /NRC Actions
.Estimsted Savings = $5.0 Millionf [
Line item improvements Completed 11 In Process 2 l
Decision to not implement 2 186
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l k Program!Shoul(C6ntinuelfbt $sar Futbre[
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' % fong Term: Goal Sholid besto Achieve:a c'ulture li xWithinJNRCLStaff That Focuses?oriCBLKissuese '
I!i Without the;Needlfor an Official ProgrhO em
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e- , L }$ suki;a la%a.>uLa b a m L aw-w as.s+ L a M a s s a a u uzu a rtur d uk A ,11; w k ud&, M wx ;p aa m a waus w.uar m a ua.;a.auaaua u w saam aexax a.w w aGs M e fi )) o Northeast Utilities o, 1, Commitment Mana ement a o j j Program a a p g a j Richarc M. Kacich - Director, l} fj y ,A, .uclear Planning, Licensing anc.
'g !!
i;. Buc geting X! Oh c d a
; o yi i b gtheast 1 Jtilities Commitment Management Program J #
1 l 189 1 1
NEI Guic.eline is "Resaonsiie" * * ' * * ' *
- 'U"#'*M*'"**' ~ # "^ '#
en*
j%+ ps , ~1/_w A c A%v : ehe w .*

A ****a -
_ _ _ _ _ ._._'a*"e*iewm _ ... _ _ - - _ - . - - - i I j u Use of the Guideline ensures safety
) ; significant issues receive appropriate a
i. !, review and concurrence
! a Consistent with company Strategic j Business Plan, Operational Excellence Objectives, and culture l
a t 3
} . .
s . Commitment Rec uc': ion Mus: [] ALways be Suaorcina:e :o Safety
-. -.- .._.~.- - - . . . - _ _ . , ; s ! i a We had difficulty fully testing the NEI Guideline 4
i . - Few safety significant commitments considered for j change 4 i - Most commitments had little relationship to safety - merely programmatic enhancements l j u Experience demonstrated need for stronger
! commitment management program k , - improved clarity warranted j - commitments should be meaningful ] , - commitment control is superior to commitment j j reduction i b ortheast Jtihties Commitment Management Program {
s ' 190 I
Use of Guic eline Improves i j Overall Safey
._ m _ . . * --+1a1... 1 . x m n u 6 r,~.
1
, : a Commitments changed by the Guideline are j 3 of minimal safety significance ; a Guideline is consistent with NRC and NU i : burden reduction initiatives i
a a Allows process managers opportunities for l associated productivity and safety 4
; improvements 1
l 9 [] NU Position on NEI Guide _ine
..,,...~ _ .~ . _ _ _ _ , _ . . t_ _ _ __ _......~ . _ _ _ _ . . . _ _ . _ - m ..
1 i
! la NRC should endorse Guideline through l { issuance of an administrative letter i ; in NU is planning to institute a formal company
[ l procedure consistent with the Guideline ( !m Pilot program illustrates the need for regional workshops e
! In Improvement in safety is sufficient grounds j l to devote necessary resources ; 4 hN Ik)($ Ob $N NhkNS h l
191 l -]
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NTERGRANULAR STRESS CORROSION CRACKING lOF BOILINGWATER REACTORINTERNALS Robert A. Hermann, Chief Chemical Engineering and Metallurgy Section EMCB, DE, NRR i Regulatory information Conference Rockville, Maryland May 9,1995 193
STRESS CORROSION CRACKING OF BWR INTERNALS
1. Initial Observations of Shroud Cracking

2. Descriptions and Cracking Mechanisms

3. Safety Significance

4. Regulatory and Industry Actions

5. Current Status

6. Susceptibility Ranking of BWRs

7. Inspection Experience

8. Conclusions and Bases for Continued Operation

9. Core Shroud Repairs

10. Comprehensive Assessment of BWR Internals Cracking

11. Future Actions INITIAL OBSERVATIONS OF SHROUD z CRACKING IN U.S. PLANTS )
Initial Reports of Shroud Cracking Reported in Foreign Reactor- KKM

Significant Shroud Cracking First Observed at l Brunswick Unit 1

Discovered During GE-Recommended Visual Examination of internals

Cracking at Weld H3 on the Inside of the Top Guide Support Ring

Extent of Cracking was 360 , with a Maximum Depth of 1.7 Inches

Similar Cracking in the Core Plate Support Ring Subsequently Observed at Dresden Unit 3 and Quad Cities Unit 1, and in a Circumerential Weld in the Oyster Creek Mid Shroud Sholl 1"
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BACKGROUND - CORE SHROUD FABRICATION O Shroud Material- 304 or 304L Stainless Steel o Typical Dimensions - 14 to 17 Feet in Diameter, 1.5 to 2 Inches Thick o Construction - Welded Plates, Welded Plates + Ring Forgings o Fabrication involves Both Circumferential and Axial Welds o Residual Stresses are Present from Welding o Weld Heat Affected Zones Particularly Susceptible to IGSCC INTERGRANULAR STRESS CORROSION CRACKING (IGSCC) MECHANISM Material
Material
-Higher Carbon Content More Susceptible -Rolled More Susceptible than Forged
Environment
-Susceptibility increases with Greater Oxygen /
Contaminants in the Reactor Coolant
-irradiation increases Susceptibility
Stress
-Higher Stress Levels increase Susceptibility 198 \_
SAFETY SIGNIFICANCE
Potential for Shroud Separation if Cracking is 360 Through Wall

Normal Operating Conditions -Through-Wall Cracks at Upper Elevations Detectable By Core Flow / Power Mismatch; However Through Wall Cracks at Lower Elevations May Not be Detectable

Worst Case Accident Scenarios are Main Steam Line Break, Recirculation Line Break and Safe Shutdown Earthquake

Major Concerns are Uplift of Top Guide, Interference with Control Rod Insertion and Loss of Floodable Volume REGULATORY ACTIONS

Information Notice 93-79 issued September 30,1993

Information Notice 94-42 and Supplement 1 lssued on June 71994 and July 19,1994 {

Generic Letter 94-03 issued on July 25,1994
-Inspect / Repair Shroud at Next Refueling Outage -Provide Safety Assessment Justifying Operation Untilinspection/ Repair -Provide Inspection / Repair Plans 30 Days Prior to the Outage 199
INDUSTRY ACTIONS
GE Service Information Letters

Formation of BWR Vessel and internals Project (BWRVIP)

BWRVIP Subcommittees:
-integration -inspection - Topical Report (9/2/94) , - Assessment - Topical Report (9/?!94) -Repair- Topical Report (8/18/94) -Mitigation CURRENT STATUS
NRR Review of Generic Letter 94-03 Responses Completed

Analysis of Inspection Results Continuing

Staff Continues Plant-Specific Assessments for Repair Acceptability

Staff Action Plan forInternals Developed

BWRVIP to Provide Updates on inspection and l Evaluation, Re-Inspection, NDE, Repair and Mitigation i
Guidelines and Criteria l l 200 ,
l__ SUSCEPTIBILITY RANKINGS l l !
Category "A" BWRs - Less Than 8 On line Years of Operation; Good Initial Water Chemistry; Low Carbon Materials (304L) l

Category "B" BWRs - More Than 8 On-line Years of l Operation; Good to Moderate Initial Water Chemistry; Low j Carbon Materials (304L) l

Category "C" BWRs - More Than 6 On-line Years for BWRs l with Shrouds Fabricated from 304 SS; 8 Years for Those l Constructed using 304L; Moderate to Poor Water Chemistry I
i ! MOST SUSCEPTIBLE PLANTS l
The Staff Concluded that 11 of the 22 Category "C" BWRs l
i had the Potential for Containing Significant Cracking

Conditions at These Plants Bounded All Other BWRs l Plant inspection Repair i Pilgrim 4/95 Dresden 2 6/95 i Quad Cities 2 4/95 i NMP-1 2/95 Complete,3/95 l Dresden 3 Complete,4/94 3/96 i Quad Cities 1 Complete,4/94 9/95 FitzPatrick Complete,2/95 Complete,2/95
; Oyster Creek Complete,10/94 Complete,11/94 ; Brunswick 1 Complete,10/93 Complete,1/94 Brunswick 2 Complete,5/94 Complete,6/94 ]
Hatch 1 Complete,10/94 4 201
OVERALL INSPECTION RESULTS TO DATE
13 of 22 Category "C" Plants inspected

Part Through-Wall 360 Circumferential Cracking at Four Units
.
Three Category "A" and Two Category "B" Plants inspected - No Cracking Identified GL 94 CONCLUSIONS

No 360 Through-Wall Cracking to Date

ASME Code Structural Margins Satisfied for All Identif!ed Cracks

No Symptoms of Power to Flow Mismatch Have Been identified During Power Operation

25 of the 28 Category "B" and "C" Shrouds Will Have Been Inspected or Repaired by the End of Spring 1995

With the Exception of Browns Ferry Unit 1, All of the Category "B" and "C" Shrouds Will Have Been Inspected or Repaired by the End of Winter 1996 202
CORE SHROUD REPAIRS
If Cracking is identified Licensees May Demonstrate Structural Margin by Analytical Evaluation or Install Repair Option

Some Licensees Have Decided to implement Preemptive Repairs in lieu of Comprehensive Shroud Examinations

Repairs Designed to Functionally Ensure the Structural integrity of the Shroud in lieu of Circumferential Welds

Domestic Repairs Using Reinforcing Clamps: Brunswick Units 1 and 2

Domestic Shroud Repairs Using Tie Rod Designs: Hatch Unit 1, Oyster Creek, FitzPatrick, Nine Mlle Point Unit 1, Dresden Unit 2, Quad Cities Unit 2 and Pilgrim NUCLEAR POWER PLANT PROPOSED REPAIR TO REACTOR SHROUD
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COMPREHENSIVE ASSESSMENT OF CRACKING IN BWR INTERNALS o Other BWR Intemals Are Susceptible to IGSCC o inspections and Evaluations of These Components Have Been and Are Continuing to be Conducted o Staff has Requested the BWRVIP to Develop a ! Comprehensive Plan Addressing Potential Cracking in All l BWR Intemals o January 1995 Commitment Letter Received from BWRVIP, Detailed Plan to be Submitted in April 1995 o NRR User's Request issued to Office of Research in December 1994 - Studies to Address Crack initiation and Growth, Mitigation and Assessment of NDE Methods, and Analysis of the Effects of Cracking on Multiple Intemal Components FUTURE ACTIONS
Continue Review of Inspection Results

Review Licensee inspection Plans Before Plant Outages
-
lasue Summary NUREG Report

Comprehensive Assessment of all BWR Reactor Vesselintomals

Review Repairs 204
i l l BWRVIP REGULATORY INFORMATION CONFERENCE CORE S HROUD AND BWR lhTERNALS N AY 9,1995 ' Roain Dy e 205 _--- -- J
n BWRVIP Regulatory Information Conference Purpose
. History of inc ustry Activities BWROG BWRVIP . Description o" BWRVIP . Future Actions 206
BWRVIP Reputatory information Conference
1989 BWROG InternalInspection and Repair Comrnittee e 1990 KKM Crack VT e 1990 GE RICSIL 054
! e 1991 Domestic Utilities Implement RICSIL (High Carbon plants inspect) l
7/93 -RICSIL 054,r1 Reports results of KKM Boat Sample (IASCC)
- Initial Report on Brunswick 9/93 BWPOG asked to Consider Generic Action 10/93 GE lasues SIL 572,r1 - Update on Brunswick - New Inspection & Assessment Guldance l
BWRVIP Regulatory informatot Conference 11/93 BWROG issues H3 Safety Assessment 2/94 Hatch 2 1st Domestic 304L Indications e 4/94
- GE RICSIL 068 - 304L information - BWROG lasues Shrourt Evaluation Guide - BWR Executives Plan a New Internals initiative - Dresden and Quad Cities Exams - BWROG Assessing Generic Implications e 5/94 - GE RICSIL 068,r2 - 304L Boat Sample - NRC lasues *10 Generic Questions" to BWROG NRC/ Comed /BWROG Meeting 5/28 207
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- SWRVIP -
- - ilrWormehen Conference e 6/94
- 6/10 BWR Vessel & Internals Project (BWRVIP) Formed - 6/17 Inspection Lessons Leamed y - 6/28 initial NRC/BWRVIP Meeting ! . Initial Response to 10 Questions l . Discussed Safety implications of Shroud Cracking ) . Described BWRVIP and Fall 1994 Plans .
7/94- '
- - 7/6 NRC Requests Generic Safety input - 7/11 BWRVIP Initial Technical Committee Meetings - 7/13 BWROG Supplies Safety Assessment - 7/25 GL 94-03 Issued - 30 Day Response (Resource issue) e 8/94 ' - 8/5 BWROG lasues: . Final Response to 10 Questions .~ Revision 1 to Generic Safety Assessment - 8/18 BWRVIP Generic Repair Design Criteria ; - 8/31 NRC Letter Denying 50.59 Process for Repairs Requires Relief ' BWRVIP - i neguinary inkrmshon cordererm 9/94 - 9/2 BWRVIP Inspection and Evaluation Guidelines - 9/7 ' NRC lasues RAI on Repair Criteria - 9/8 Standards for Visual Examination of Core Shrouds 9/9 ACRS Presentations by NRR & BWRVIP - 9/13 Core Shroud Repair Design Criteria, rev.1 - 9/21 BWRVIP/NRC Meeting on Shroud Inspection Criteria - 9/29 NRC Safety Evaluation on Repair Design Criteria e 10/94 - 10/11 Response to RAI on Inspection & Evaluation Document - 10/27 Full Executive Meeting for Update and 1995 Program Approval e 11/94 ~ - 11/21 Core Shroud NDE Uncertainty and Procedure Standard - 11/29 BWRVIP EOC and NRC - 1994 Results & 1995 Plans . 12/94 - 12/8 x NRC/BWRVIP Meeting on Crack Growth Rates & Predictive Moilels - 12/28 Safety Evaluation of. Shroud insoection & Evaluation Document ros
BWRVIP Regulatory information Conferonce e 1/95
- 1/3 Information on Core Plate and Top Guide Ring Cracking - 1/13 Transmittal of BWRVIP Program Plan to NRC e 2/95 - 2/7 Kickorf Meeting for Beltline Team - 2/8 Kickoff Meeting for Strategic Planning Team e 4/95 - 4/4 NRC & Strategic Planning Team Meet - 4/11 BWRVIP 1995 and 1996 Milestone Transmittal BWRVIP Regulatory information Conference BWR Vessel and Internals Pro,iect Overview The BWR Vessel and Internals Project is an association of utilities which own and operate a bolling water reactor. The BWRVIP is focused exclusively on reactor vessel and vesselinternals issues on operating plants. Members of the BWRVIP are committed to sharing of resources and project information on an equitable basis to achieve the objectives of the project.
209
BWRVIP no ui. c o,m.non c - e,.nc. BWR Vessel and Internals Pro;ect Ob ectives
. To lead the BWR industry toward generic resolution of vessel and internals integrity and operability issues.
To identify or devel.op generic, cost effective strategies from which each operating plant will select the alternative most approprihte to their needs.

To ser/e as the focal point for the regulatory interface with the industry on BWR vessel and internals integrity and operability issues.

To share information among members, and to obtain useful data from many sources.
BWRVIP Regulatory inform.uon Conference BWR Vessel and Internals Project Oraanization BWRVIP Executive Oversight Committee 1 Integration Inspection Assessment Mitigation Repair 210
BWRVIP Regulatory information Conference BWRVIP Committee NRC Interfaces Committee Utility NRC EPRI Executive Chair Technical Chair EOC Chairman Beckham (GPC) Thadani EOC Vice-Chair LaBruna (PSE&G) Carpenter (PM) Integration Lyster(Comed) Virgilio Bilanin Wagoner (CP&L) Rubin inspection Keaton (GPUN) Sheron Lance Leonard (NMPC) Hermann Assessment Terry (NMPC) SheronNirgilio Carter Dyle (SNC) Hermann Mitigation Rothert (BECO) Sheron Gilman Wilson (PSE&G) Hermann Repair Campbell (CP&L) Sheron Thomas McLeod (GPC) Manoly BWRVIP e Raulatory information Conference Integration Committee
The goal is to enhance / assure coordination of all BWRVIP and related activities between the technical working groups, EOC, BWROG and Industry
. Measures of success include resolution of vessel and internals integrity issues within schedule and budget . Primary NRC Interface 211
r------ ---- - - - - - - - - - - - - - - - - - - - - - - - - - - - - BWRVIP Reguletory information Conference Inspection Committee e The goal is to determine the condition of vessel welds, attachments, internals and penetrations using effective, predictable techniques, e Measures of success are the availability, reliability and cost-effectiveness of methods for the required inspections.
NDE method qualification programs BWRVIP Regulatory information Conference Assessment Committee e The goal is the methodology for the evaluation of decisions for operation, inspection, mitigation or repair.

Success will lead to realistic and defensible assessments of serviceability and service life Avoiding premature repair / replace decisions and support prompt evaluation of findings Supporting timely implementation of countermeasures 212
BWRVIP Regulatory information Conference Mitigation Committee
. The goalis to develop and demonstrate countermeasures for service-related degradation. . Success means that significant reductions are achieved in the costs of repair and scope of inspections i
i BWRVIP Regulatory information Conference ! l I Repair Committee '
. The goal is to assure the availability of cost-effective repair alternatives for {
internals, vessel attachments, penetrations and other components damaged by service-related degradation. i 4
. Success means that applications have been anticipated, repair capability is available and repair design criteria have been defined so that service vendors can respond promptly to, plant-specific needs.
213
_ _. - ... - -- .- _ - _ . _~._ . . ,~ .._.-- _.-...-._ .,.-. - -.-__-~ --.a -_... _-.a-BWRVIP Regut%ory informatum Conference
- Assessment Milestones l
1. Revise Core Shroud Insoection & Evaluation Report - 4/95 l . 2. Core Shroud Reinspection Guidelines - Interim guidance 9/95; Final 6/96 l
3.Near-Plant Specific Core Shroud Evaluations - 8/95 ! 4. Crack Growth Evaluation - Stainless 8/95; low-alloy steel 3/96 j 5.Stratealc Plannina Team's Internals Evaluation - Interim 8/95; Final 12/96
6. SCC Assessment Database - 12/96
{ l i i 4 DWRVIP - Regulatory information Conference inspection Milestones
1. Quantify Shroud NDE Canebilities - Existing technology 9/95; New technology for H1-H6 by 12/95; New technology for H&-H-9 by 12/96.
. 2. Shroud NDE Development - Advanced Techniaues - - Procedure Development: H1-H6 by 9/95; H7-H9 by 12/96 - Scanner Evaluations by 9/95 - Scanner Development by 12/96
3. Shroud Mock-uns for H7-H9 - by 7/95 4.Trainina & Qualification of Internals Inspection Personnel - 9/95 -12/96

5. NDE Quantification for Other Intemals - All complete by 12/96 214
__ . _ _ ..__..._. ._ _ - - . m.._ - _...._ __ m. _ _ _ _ . . _ _ _ . . _ _ . _ . . - . . _ _ . . . _ . . _ . - _ l-BWRVIP : y Regulatory Informatm Conference j Inspection Milestones (cont.) ;
6. Advanced NDE for Other Internals - Visual Training and uncertainty measurements 9/95; Advanced procedures and scanners by 12/96
] 7.Other Internals Mock-uos - Complete by 12/96 . 8 Generic Activities- Ongoing
- Compile Raw Data
- Applications Assistance

- Post-Repair Assistance 4
1 i-i BWRVIP Regulatory Informaton Conference i i
- Repair Milestones
1. Develoo Repair Priority Rankina - 4/95
. 2.Comoonent Repair Evaluations - Draft 5/95 i j 3. Reoair Technoloav Development - Underwater welding 3/96
4. Reoair Criteria Develoomen_1 - Tube roll-expansion 7/95; others to follow 5.Reoair Acolication Develooment Complete qualification & criteria by 6/96 1
i i 215
BWRVIP Aegulatory information Conference f Mitigation Milestones
1. Revise BWR Water Chemistry Guidelines - Revise the 1993 guidelines to reflect the latest operating guidance and mitigation options by 6/96. 1 2.Toolcal Report on Reaulatory Credit for Mitiaation - 12/96 BWRVIP Regulatory information Conference Summary e SCC and Degradation of BWR Internals is a Significant issue for the future e The Industry through the BWROG and BWRVIP has Accomplished much over the Last Two Years e The BWRVIP is Committed to " Staying in Front" of This issue l
)
216
S 5 i 1 a 4 8 i ! May 10,1995 1
Morning Breakout Sessions

8:00 a.m. - 10:00 a.m.
i i p I ( ' l i 1 i l ! I i , I l l 1 4 i i i l 217 3 i
NRC / Licensee Interface and Communications 1 Breakout Sessions 4 Regions I, ll, Ill, IV) ! l l i
1. Communication and Interface e Regulatory impact e Feedback Report on Inspector Professionalism o Communication and Interface improvements

11. Safety issues
, o Cost Reduction and Safety 1 e On-Line Maintenance l l I i 218
1 ll1. Inspection and Assessment , e Systematic Assessment of Licensee Performance (SALP) Process and Superior Performer Program o Licensee Self Assessments e Inspection Planning, Oversight, and Followup i IV. Enforcement e Notice of Enforcement Discretion (NOED) o Enforcement Program Improvement Initiatives 219
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a i 4 i i i i h May 10,1995 Morning Breakout Sessions 10:15 a.m. - 12:00 p.m. 221
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Jack Strosnider Chief, Materials & Chemical Engineering Branch l Office of Nuclear Reactor Regulation 223
REACTOR PRESSURE VESSEL ISSUES
Generic Letter 92-01

Palisades PTS Evaluation

Proprietary Data Issues

Future Actions GENERIC LETTER 92-01

Review of Licensee Responses Completed

Results Documented in Letters to Licensees and NUREG 1511-
- Identified 2 plants (Palisades & Beaver Valley.1) potentially over screening criteria before end-of-license - Based on docketed information - Subject to change based on new information
Reactor Vessel Integrity Data Base (RVID) Created 224 i_______ _ _ .
PALISADES PTS EVALUATION

Demonstrated Sensitivity of PTS Analyses to chemistry
!
Variability in Chemistry Data Greater Than Expected PROPRIETARY DATA ISSUES

NRC Reviews Indicate That Data Exist That Were Not Considered in the 92-01 Evaiuations

No Single Organization Appears to Have All the Information . Applicable to a Particular Reactor Vessel

All Data Should be Considered in Reactor Pressure Vessel Evaluations 225
l FUTURE ACTIONS
Action is Necessary to Assure That Licensees Consider All Relevant Data in Evaluation of Their "
Reactor Pressure Vessels
Generic implications of Palisades Evaluation Need to be Assessed a GL 92-01 Evaluations May Need to be Revisited 226
THE NRC PRESSURE VESSEL SAFE"- RESEARCH PROGRAM David L. Morrison Director office of Nuclear Regulatory Research The office of Nuclear Regulatory Research is continuing to conduct an aggressive research program addressing the integrity of reactor pressure vessels. Assuring the integrity of the reactor pressure vessel is a key aspect of assuring overall plant safety since the pressure vessel is the only primary system component for which the 1 engineered safety features cannot assure core cooling in the event of its failure. The research program, initiated 28 years ago,-focusses on
. determining the material properties and fracture behavior of heavy section steels and welds. Within that focus, the research-fncludes analysis developments, metallurgical studies, and testing of standard as well as specially designed specimens to evaluate the effects of fracture in thick sections, including bi-axial
, loading effects. Evaluating the effects of neutron irradiation is another major aspect of the program. The pressure vessel safety research program has provided the analytical and experimental bases for virtually every technical and regulatory position pertaining to pressure vessel safety. However, experience has shown that those technical and regulatory positions warrant continuing evaluation. In October 1994, the staff published for comment several proposed amendmente. to the rules pertaining to pressure vessel safety. Additionally, a new rule on thermal annealing was proposed. Comments on these proposed amendments and new rule were received, and ve anticipate submitting the final proposed rule to the Commission in August of this year. As plants continue to operate, and as we learn more about pressure vessel integrity, new issues are emerging. Thus, a strong research program is essential to assuring pressure vessel safecy in the years to come, and may be particularly important in assessing issues associated with plant license-renewal. Additionally, in keeping with the initiatives to be more responsive to our customers. 3 anticipate continuing interactions with the public and the indusery through a series of workshops on specific topics. We firmly believe that close interaction with the national and international technical community, with the public, and with the regulated industry will assure a program that is well focussed, technically excellent, and timely. The pressure vessel safety program has and will continue to foster such interactions. I l l l l 227 s
i l
i l i l l l l THE NRC PRESSURE VESSEL SAFETY l i RESEARCH PROGRAM i I l NRC REGULATORY INFORMATION i i CONFERENCE l 1 l 4 MAY 10,1995 l - David L. Morrison l 1 Director i 4 Office of Nuclear Regulatory Research 1 l a i i 4 i 2 1 i 1 i 228
PRESSURE VESSEL SAFETY RESEARCH
- An Evolving Program
Program initiated in 1967 in response to ACRS

Focussed on material properties and fracture behavior

Additional topics includod over time Analysis methods Irradiation effects Environmentally assisted cracking PRESSURE VESSEL SAFETY RESEARCH
- An Evolving Program NRC-funded work and interaction with international community CSNI program on evaluating large-scale experiments International Group on Radiation Damage Mechanisms Evaluation of materials from Japan Power Demonstration Reactor European Community Network on Evaluation of Steel Components i
229
PRESSURE VESSEL SAFETY RESEARCH l
- Program Results l
Research results provide bases for regulatory positions Fracture analysis methods for P-T limits
- Identified significance of copper in irradiation damage - Developed embrittlement estimation methods 4 - Developed and validated PTS analysis methods - Developed and validated LUS vessel analysis methods - Demonstrated effectiveness of thermal annealing
Research results used in plant-specific evaluations
- Recent examples are Yankee Rowe and Palisades i
PRESSURE VESSEL SAFETY RESEARCH
- Program Results
On-going activity to amend rules 10 CFR 50.61 -- PTS rule 10 CFR 50, App. G -- Fracture Toughness Requirements 10 CFR 50, App. H -- Surveillance Requirements Additional activity to develop thermal annealing rule (10 CFR 50.66)
Proposed amendments and new rule to Commission by August 31,1995 I l 230
PRESSURE VESSEL SAFETY RESEARCH 4 - Program Results e DG-1023, "Ev-'uation of Reactor Pressure Vessels with Charpy Upper-Shelf Energy Less than 50 ft lb"-- June 1995 e DG 1025, " Calculational and Dosimetry Methods for Determining Pressure Vessel Fluence" -- Revised Draft Summer 1995 o DG-1027, " Format and Content of Plan for Thermal Annealing of Reactor Pressure Vessels" -- Published with 10 CFR 50.66
RG 1.154, " Format and Content of Plant Specific Pressurized Thermal Shock Safety Analysis Reports for Pressurized Water Reactors" -- Draft for Comment 1996 n RG 1.99, " Radiation Embrittlement of Reactor Vessel Materials"
-- under evaluation PRESSURE VESSEL SAFETY RESEARCH - Summary e Research has contributed to safe regulation of pressure vessels e Recent experiences highlighted areas for further work o On-going and planned research stresses problem resolution e Program designed to anticipate problems as plants age e Close interaction with public and industry is key to success 231
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l I SAFETY OF SPENT FUEL POOL STORAGE l l Martin J. Virgilio, Deputy Director Division of Systems Safety and Analysis Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Regulatory information Conference Breakout Session May 10,1995 233
I SAFETY OF SPENT FUEL POOL STORAGE r I l i
Significant issues Loss of Spent Fuel Pool Cooli7g
- Loss of Spent Fuel Coolant Im entory
NRC Actions and P!ans Generic Communications
- Technical Evaluations
Basis for Acceptance of Current Conditions

Features and Operating Practices Significant to Risk

Generic Spent Fuel Poci Action Plan Activities SIGNIFICANT ISSUES

Sustained Loss of Spent Fuel Pool Cooling l - Identified Through 10 CFR Part 21 Report by Prevatte & Lochbaum I
- Fuel Pool Cooling Sys' tem Design at Susquehanna Not Safety Grade - Sustained Loss of Srent Fuel Pool Cooling Leads to Fuel Pool Boiling, and Sustained Boiling May Degrade Safety Systems - Safety System Degradation May lead to Core Damage and Degraded Containment Performar:ce
Loss of Spent Fuel Coolant Inventory
- Identified through Dresden 1 Special Inspection - Potential for Rapid Spent Fuel Pool Coolant Inventory Loss and Associated Hig'n Local Radiation Dose Rates - Unmonitored Release of Contaminated Water 234
NRC ACTIONS AND PLANS e Generic Communications Issued Information Notices and Communicated with BWR Owners Group Regarding Loss of Spent Fuel Pool Cooling Concerns Issued Bulletir: and Information Notice Regarding Coolant inventory Loss and inspection Findings at Dresden 1, Respectively
Technical Evaluations Susquehanna Risk Assessment and Safety Evaluation for Pool Boiling
- Specialinspections of Fuel Storage Practices at Permanently Shutdown Reactors . Generic Action Plan for Evaluation of Spent Fuel Pool Storage Practices, including Above issues, Underway BASIS FOR ACCEPTANCE OF CURRENT CONDITIONS
Loss of Spent Fuel Pool Cooling Scenarios '
Probabilistic Safety Assessment Indicates Low Frequency of Spent l Fuel Pool Boiling
- Operating History is Consistent with Safety Assessment Conclusions Generic Action Plan includes This lesue for Resolution and Generic Communications Have Informed Industry of Concerns
Loss of Coolant inventory Scenarios
- Bulletin and inspections Address issue at Permanently Shut Down Facilities Generic Communications and Generic Action Plan Resolution Will Address issue at Other Facilities . Off-site Consequences Not Safety Significant 235
4 FEATURES AND PRACTICES SIGNIFICANT TO RISK 1 l e Loss of Spent Fuel Pool Cooling Scenarios
- Reliability of Spent Fuel Pool Cocling and Make-up Systems - Availability of Instrumentation to Monitor Fuel Pool Administrative Controls on Pool Temperature and Availability of ; Cooling and Make-up Systems during Periods of High Heat Loads (i.e., Refueling Outages) - Separation of Fuel Pool Atmosphere from Systems Necessary for Reactor Vessel Decay Heat Removal
Loss of Coolant Inventory Scenarios
- Design Features Preventing Drainage or Siphoning
- Level Indication and Leakage Detection Capability i
i GENERIC SPENT FUEL POOL ACTION PLAN
Includes Following Actions:
- Analysis of Information on Spent Fuel Pool issues - Focused On-Site Assessments to Gather AdditionalInformation Safety Assessment of Findings Determination and Execution of Appropriate Course of Action
Broad Scope Addresses:
Loss of Spent Fuel Pool Cooling / Boiling
- Loss of Spent Fuel Pool Coolant inventory - Radiation Protection - Reactivity Controls - Instrumentation
Status:
- Spent Fuel Pool issues identified for Assessments - On Site Assessments Completed at Brunswick and Monticello - Assessment Findings Do Not Alter Conclusions 236
Multi-Purpoco Canistor Dovolopmont
.i JeffWilliams
Director, Engineering Division j Office of Civilian Radioactive Waste Management U.S. Department of Energy l NRC l Seventh Annual :
i Regulatory Information Conference l Washington, DC l May 9-10,1995 i i f Office of Civilian Radioactive Waste Management f ! Multi-Purpose Canister L Development 4 i
Spent Fuel Storage in the U.S.
!
What is a Multi-Purpose Canister l

Why is an MPC System being Considered
) MPC Licensing Strategy

MPC Development Schedule 4
i i 237
!J Spent Fuel in At Reactor Dry Storage I. m la Ive, on a per state basis States Needi i le Dry Stora = I (No interim Storagi C I Spent Fuel in At Reactor Dry Storag !mI ive, on a per state basis . . . t- .n =
Spent Fuel in At. Reactor Dry Storage - ~~ um la Ive, on a per stato basis wo :euiw I'5 pent Fuelin At. React 9r Dry Stora m la Ive, on a per state basis
. i. \\ ~
Offl30 cf Civill n Rcdisectivo Wcsto Man:g m:nt : Technologies Used in U.S. ISFSis ; Location Vendor Model Calvert Cliffs VECTRA NUHOMS 24P Ft. St. Vrain Foster Wheeler MVDS ' HB Robinson VECTRA NUHOMS-7P Oconee VECTRA NUHOMS-24P Palisades Sierra Nuclear VSC-24 Prairie island Transnuclear TN 40* Surry General Nuclear Systems Castor X/33 Surry General Nuclear Systems Castor V/21 Surry Nuclear Assurance Corp. NAC-SIT-128 Surry Westinghouse MC-10
Loading scheduled for Spring 4ummer 1996 " "' "*' '
@ Office of Civilian Radioactive Waste Management
, COMPATIBILITY OF DRY STORAGE l SYSTEMS WITH WASTE ; MANAGEMENT SYSTEM l l l 4 NRC Endorsed as a Safe Supplement to Existing Wet , Pool Storage, and for Shut-Down Reactors
Individually Designed for Reactor-Specific Fuel )

No Consideration Given to Waste Management System

Site Storage Needs Driven by Economics

No Consideration Given to Disposal Requirements

Not Licensed for Transportation

Need to Return to Spent Fuel Pool for Reloading 240
Office of Civilian Radioactive Waste Management
Multi-Purpose Canister System

g Ca is or(M ) - Uni STORAGE ) ,fM ,
,_. A semblies -
Iter MPC , , ! TRANSPORTATION
'ransp allon N l
Other Possible Overpacks MPC + SN Waste Form ,p-N - - DISPOSAL p MPC wegg, nta n r P CD57M ome.of civiii n a.dio.ctiv.w. to man a.m.nt MPC Conceptual Design Requirements
Must meet the requirements of 10 CFR 71-Packaging and Transporting Radioactive Material

Must meet the requirements of 10 CFR 72-Licensing Requirements for independently Storing SNF and Higt-Level Radioactive Waste

Must be conipatible with the requirements of 10 CFR 60-Disposing of High-Level Radioactive Waste in Geologic Repositories

Must recognize utility interfaces 241 ,
1
office of Civilian Radioactive Waste Management Why is the MPC System Being Pursued?
No Availability of Federal Facility

Reactor Pools are Reaching Capacity

Utilities are adding Dry Storage
- Utilities will add Commercial Dry Storage According to
! Site Needs i
Single-Purpose Storage is not Compatible with Transportation l - Additional Handling ofIndividual Fuel Assemblies is Required Prior to Transport

To Standardize Design Office of Civilian Radioactive Waste Management Stakeholder input

Nuclear Regulatory Commission

Nuclear Waste Transportation Review Board

State of Nevada

State of Tennessee

eel /UWASTE

Western Interstate Energy Board

Southwest Research and information Center

Virginia Power !

Environmental Action

Manufacturing industry 242
Omco of Civilian Radioactive Waste Management MPC System Benefits
Introduces Standardization & Compatibility

Contributes to Dry Storage Program at Shut-down and Operating Reactors and Federal Interim Central Storage or Repository Surface Facilities

Reduces Handling ofIndividual Spent-Fuel Assemblies

Reduces Costs, Case and Low-Level Radiological Waste Generation

Incorporates a Systems Approach omco of CMilan Radioactive Weste Management MPC Certification Meet the requirements of:
- 10 CFR 71 Packaging and Transport of Radioactive Material - 10 CFR 72 Licensing Requirements for the independent Storage of Spent Nuclear Fuel and High Level Radioactive Weste Be compatible with the requirements of: - 10 CFR 80 Disposal of High Level Radioactive Weste in Geologic Repositories Vendor Expertise in Parts 71 and 72 m " "' " '
ome.of civiii.n Radio.ctiv. waste unn aoment Major Criteria Factor Approach Thermal - Designed to meet cladding temperature limits for storage and disposal Containment - MPC provides containment during storage
- Overpacks provide containment for transportation and disposal Criticality - MPC provides criticality control for storage, transportation, and disposal Shieldir'g - MPC shield plug for handling - Overpacks for storage, transportation, and disposal Structural - Designed to meet transportation requirements eum m ,, @ Office of Civilian Radioactive Waste Management 10 CFR PART 60 COMPATIBILITY
Manage Risk of NRC Acceptance for Disposal
- Economic - Operational
Obtain " Letter of No Objection" from NRC Staff 244
Office of Civilian Radioactive Waste Management MPC Part 60 Design Considerations Report Scope and Content Guidance from NRC Pre-submittal Interactions with NRC Staff ! Schedule:
- Submit Technical Report to Obtain Letter of No Objection 4/96 - NRC lesues " Letter of No objection" 4/97 l
Office of Civilian Radioactive Waste Management Past Accomplishments Completed Feasibility Study - March 1993 Completed Conceptual Design - September 1993 Developed MPC Specification - April 1994 lasued Request for Proposals - June 1994 Initiated Review of Proposals - November 1994 Completed MPC EIS Scoping - January 1995 245 ' mm -
(h Future Accomplishments omce of civiiian Radioactive waste Management
Award Design Contract - Spring 1995 3

Complete Environmental Impact Statement -
Fall 1995
Complete Transportation and Storage Safety Analysis Report - 1996 ,

Submit 10 CFR Part 60 Design Considerations Report to NRC - Spring 1996

Complete Certification Activities and Construct Prototypes a Revise Standard Contract (10 CFR Part 961)

Receive NRC Approval office of Civilian Radioactive Waste Management MPC System Acquisition
- Large (125-ton) and small (75-ton) rail systems - Canisters - Prototype transportation casks - On-site transfer units - On-site storage modules - Welding equipment Three-phase procurement l - Phase I-Design and SAR preparation - Phase Il-NRC certification - Phase lil-MPC fabrication and deployment 246 E----------._________-----.
)
Office of Civilian Radioactive Waste Management NRC-DOE MPC Certification
)
Schedule B TAsENAuf Jirlui A!uld J Ale!cle!D J! flu Alu 4 J Altiplelp JIfle!aleJJAl g i h- : house 146 @
! heimw Cysene htMF r 7 8 letc hsisd t heitsu M 4 Dos Anspones k R1 osassums M
4 tesc husd a mesess m nosns.,s mn o.es s e au r me rvid a e amm i mcm ren. nase. som o reaum a n==nemaeras,. = c as a me % wf.wte r j m .s l l
@ Office of Civilian Radioactive Waste Management Conclusions a
Development of Commercial at-reactor Dry Storage will Continue Commercial Dry Storage Systems are Safe, but not Compatible with the Federal Waste Management System MPCs are Compatible with Fsderal Waste Management System and will Provide Benefits:
- Reduced Dose - Reduced Total System Cost - Reduced Handling of Spent Nuclear Fuel Assemblies - Reduced Low Level Waste Generation MPC Procurement is Proceeding 247
y I 4
-. ..a
i UTILITY AT REACTOR SPENT FUEL STORAGE REQUIREMENTS Eileen M. Supko Energy Resources International, Inc. . l l
1. BACKGROUND :
The Nuclear Waste Policy Act of 1982 and its 1987 amendments (NWPA) along with the Standard Contract for Disposal of Spent Nuclear Fuel and/or High Level Radioactive Waste, require that the U.S. Department of Energy (DOE) Office of Civilian Radioactive Waste Management (OCRWM) begin i to accept spent fuel from Contract Holders' in 1998. Recent DOE announcements have suggested that it is highly unlikely that it will be able to begin accepting spent fuel into an operating system by 1998. 12gislative proposals have been introduced with the goal of reaffirming the government's obligation to accept spent fuel from utilities beginning in 1998 and establishing an integrated spent fuel management system that includes centralized interim spent fuel storage. According to the NWPA, utilities are responsible for at reactor spent fuel storage until DOE accepts spent fuel from their sites. The uncertainties associated with the DOE program punctuate the fact that most utilities will have to implement some form of additional at reactor spent fuel storage at both operating teactors and reactors shutdown for decommissioning. The majority of U.S. utilities have already reracked their spent fuel pools one or more times and most have reached the limit of increasing spent fuel storage pool capacity by this means. Rod consolidation is another method available for further increasing in pool spent fuel storage capacity, although this technology has not been utilized other than in demonstrations. The remaining avenue for utilities to increase at reactor spent fuel storage capacity is through dry storage of spent fuel in metal or concrete casks or concrete modules or vaults. Energy Resources International. Inc. 4 249
i I
2. SPENT FUEL STORAGE REQUIREMENTS l 2.1 Stornse Requirements at Operstlag Reactors ;
The first step in determining the level of additional at reactor storage that will be required by utilities is the projection of commercial spent nuclear fuel ; arisings, as provided in Exhibit 1. This projection assumes that no new reactor orders are placed in the U.S., existing plants operate for 40 years, lifetime ; capacity factors average 70%, and average discharge fuel burnups gradually 4 i increase to 50,000 MWD /MTU for pressurized water reactors (PWR) and , 40,000 MWD /MTU for boiling water reactors (BWR). These assumptions ; result in a total of 86,000 MTU of commercial spent nuclear fuel arisings for all U.S. reactors through the year 2040. Permanently discharged spent fuel in. ! storage at the end of 1994 amounts to approximately 30,000 MTU. . Maximum spent fuel pool capacities, as reported by utilities in DOE Form RW 859, have been utilized in the following projections to determine additional spent fuel storage requirements. In addition, reracked capacities > for spent fuel storage pools have also been included for those utilities that have announced plans to rerack, but have not yet indicated these plans via , DOE Form RW-859. Utilities that have spent fuel pools that are shared by more than one reactor are assumed to reserve space for full core discharge , capability for each reactor. Historical spent fuel discharge data are consistent with data reported by utilities via DOE Form RW-859. For prudent planning, most utilities assume that they will have to provide life. of plant spent fuci rtorage capacity. A projection of the number of reactors reaching the limit of their in pool storage capacity as a function of time,if it were assumed that there was no spent fuel acceptance by DOE prior to reactors reaching the end of their operating licenses, is provided in Exhibit 2. Under these assumptions, approximately 26 reactors would require additional spent fuel storage capacity by 1998 and 80 reactors are projected to require additional capacity by 2010. As shown in Exhibit 2, a significant need for additional at reactor storage capacity will exist at operating reactors by 1998, the starting point for waste acceptance by DOE as specified in the NWPA. Energy Resources International, Inc. (ERI) projects that 26 reactors will require additional storage capacity by 1998i Further, ERI projects that even if DOE begins Energy Resources International, Inc. 250
4 i 1 accepting spent fuel by 1998, between 39 and 63 operating reactors will have l to take action at some point in time to expand onsite storage capacity, ' depending upon DOE's spent fuel acceptance rate. These operating reactor ' are projected to add between 2,800 MTU and 8,100 MTU of additional 4 storage capacity, depending upon DOE's spent fuel acceptance rate. The majority of these reactors have already made spent fuel storage decisions or are expected to make decisions in the near future. i The need for additional at reactor storage capacity will further increase if spent fuel acceptance is delayed until operation of a permanent geologie
repository, which is currently projected by DOE to begin operation by 2010

at the earliest. If DOE does not begin spent fuel acc:ptance until 2010, ERI projects that approximately 89 operating reactors, will have to take action to
. increase at reactor storage capacity, adding an estimated 15,800 MTU of storage capacity. While some of these reactors may have the capability to
increase in pool storage capacity through reracking, installation of storage racks in areas of the pool that are currently unracked, consolidating spent fuel, or transshipping spent fuel between reactors, the majority of these reactors are expected to rely on dry spent fuel sto

age technologies.

Utilities with requirements for additional at. reactor storage between 1998 and 2005 are now beginning to assess their options and make decisions for increasing spent fuel storage capacity. Progress in the design and licensing of i
DOE's multi purpose canister (MPC) system and centralized interim storage facility willinfluence the spent fuel storage decisions of utilities with spent fuel
storage requirements that begin after the year 1998.
2.2 Storage Requirements at Reactors Shutdown for Decommissioning Some utilities are currently considering the cost effectiveness of unloading spent fuel from spent fuel pools to dry storage following reactor shutdown for decommissioning. Decommissioning of spent fuel pools prior to removal of fuel from the site, by moving the fuel to dry storage, may help to reduce the cost of spent fuel storage after shutdown. Cost savings associated with decommissioning the spent fuel storage pool may be feasible in the future if . the NRC allows storage in transportable or dual purpose" storage systems or MPC systems without requiring that spent fuel pools remain operable to off-load dry spent fuel storage systems if the need arises, in order for storage
pools to be decommissioned prior to all spent fuel leaving reactor sites, it is Energy Resources International, Inc.
251
1 likely that an alternate system may be required as a backup for unloading storage canisters if necessary, such as a dry transfer system. The estimates of operating reactors requiring additional spent fuel storage capacity, provided in Section 2.1, do not consider those reactors that might choose to offload the spent fuel from the spent fuel storage pool to dry storage following reactor shutdown for decornmissioning. If DOE begins spent fuel acceptance in 1998, spent fuel would, on average, still be stored at reactor sites following reactor shutdown for decommissioning for 8 to 15 years after shutdown, depending upon the rate at which DOE accepts spent fuel. If all spent fuel remaining in spent fuel pools at each reactor five years after reactor shutdown were placed in dry storage, then, depending on the rate at which DOE accepts spent fuel, between 61 and 110 reactors (including those currently shutdown) would require additional dry storage capacity to accommodate the 7,300 to 26,700 MTU of spent fuel unloaded from the spent fuel storage pools. Higher DOE spent fuel acceptance rates will result in lower utility spent fuel storage requirements. If spent fuel acceptance does not begin until 2010,117 reactors (including those currently shutdown) would require additional dry storage capacity to accomraodate the 29,000 MTU of spent fuel unloaded from the spent fuel storage pools. ERI projects that under this scenario spent fuel would remain at reactor sites for an average of 18 years after shutdown. A comparison of total spent fuel storage requirements at operating and shutdown reactors is presented in Exhibit 3 for several scenarios for spent fuel acceptance by DOE discussed in Sections 2.1 and 2.2. Two scenarios assume that DOE begins accepting spent fuel in 1998. Approximately 34,800 MTU of additional spent fuel storage capacity will be needed at operating and shutdown reactors if spent fuel acceptance begins in 1998 at the low acceptance rates that are currently assumed by DOE. If spent fuel acceptance takes place at the higher acceptance rates endorsed by the utility industry, a total of 10,100 MTU of additional storage capacity will be needed at operating and shutdown reactors. The third scenario assumes that DOE begins spent fuel acceptance in 2010 at the higher acceptance rates. Under this scenario, a total of 45,000 MTU of additional spent fuel storage capacity will be required at operating and shutdown reactors. Energy Resources International, Inc. 252
3. CONCLUSIONS Even if DOE can begin spent fuel acceptance at a centralized interim storage facility by 1998, the majority of utilities will be required to take some action to increase current spent fuel storage capacities either while operating or following shutdown for decommissioning. At reactor alternatives for spent fuel storage expansion include reracking of the spent fuel storage pool, transshipment to another reactor, spent fuel consolidation, or dry storage of spent fuelin an ISFSt. Utilities are also considering the availability of private .
spent fuel storage facilities. The majority of utilities requiring further I expansion of at reactor spent fuel storage capacity are expected to utilize' dry storage technologies, i
,Since 1986, the U.S. has gained extensive experience in at reactor dry storage 1 of spent fuel. At the present time there are six reactor sites (10 reactors) with ,
spent fuel in dry storage facilities. By the year 1998, at least 26 operating j l reactors are expected to require additional storage capacity. By the year 2010, approximately 80 operating reactors will require additional storage l capacity if spent fuel acceptance has not started by that time. Additional reactors are expected to use dry spent fuel storage following reactor shutdown for decommissioning to allow decommissioning of the spent fuel storage pools. Many of the uncertainties associated with utility spent fuel storage decision making are related to uncertainties in the schedule for DOE's civilian waste management program. The schedules associated with design and licensing of - I a MPC system and a centralizcd interim spent fuel storage facility affect utility I at reactor storage planning and can have significant impacts on utility storage requirements and the cost of at reactor spent fuel storage. Most utilities now assume that they will be required to store spent fuel for the life of the facility and for many years following plant ' shutdown for decommissioning. Development and implementation of firm schedules that ensure design, licensing, and deployment of MPCs by 1998 and design, licensing, and operation of a centralized interim storage facility by 1998 will minimize at. reactor storage requirements at both operating and shutdown reactors as well as minimize system costs. Energy Resources International, Inc. 253
Cumulative U.S. Spent Nuclear Fuel Generation ProLection x n h
N n .
3 ' C . C . : . 4 . . . o . '., m n . c) u . N , . .c . o .9 , , O l' '. . } p n . iiigiiii c ,iiiii .iiigiiiiiiiiiggiii . igiiiii 2000 3010 3020 acno M YEAR Exhibit 1 Energy Resources International, Inc, 254
Reactors Reaching Storage Capacity Assuming No DOE Spent Fuel Acceptance tio -- 100- ' fm.. . U)
~ ' '
g. a- . O 1 s *- ' O
<. 70- ,
i [ g. . 11]
> r.o- .
i::g .- [p 40- . D . y w- . a *** O .. 10-o iiiiiiigiiigiiigiiigiiiiiii i i YEAR Exhibit 2 Energy Resource
International, Inc.
255
Spent Fuel Storage Requirements At Operating and Shutdown Reactors
.c I- '
i ll- . V / e 20-
*6 -
d E 10-U) A 1998 Acceptance 1996 Acceptance 2010 Acceptance Low Acceptance Rate High Acceptance Rate High Acceptance Rate
@ Operating 8 Shutdown Exhibit 3 Energy Resources International, Inc.
256
MPC System Status and Regulatory Challenges Bob Rasmussen Duke Power Company i fenC R404& tone pepo 4matices CogPghthCt i tief flot MPC System Background
Utility Storage Expansion inevitable e interim Storage is Uncertain

Interim Storage Capacity is Uncertain

Utilities May Be " Paying Twice" After 1998

Compatibility Within Waste System Makes Sense I
hmC A80AATOAY pePomesaisDesCONP8malect # hat 16te l I 257
MPC System Logistics
Dellver to Utilltles on Alocation Basis to be Determined

Utility Loads Fuelin MPC

Utility Provides Storage Overpack for On Site Storage (if needed)

DOE Provides Transportation Overpack

DOE Provides Interim Storage and Repository Disposal Overpacks S
hRC AIOVlatDRV WeFORMATON CONF (R$NC8 i haf 1999 MPC System Benefits
Cleaner Operations at DOE Facilities

System Wide Cost Savings Potential

Minimizes Diversity Among Dry Storage Systems

Simplifies Transportation Process

Reduced Spent Fuel Handling All Facilities

Post Shutdown Savings at Heactor Sites

Represents Hear Term Progress

Addresses " Pay Twice" Concern

E1 courages Repository Decisions / Progress 4
hRC R10VLATORY 4NFORMATCN CONFERENCE # hAV 1999 258
MPC System Status C cview
Fully Endorsed By Utility indus /

Actively Under Development by DOE

EIS Process Underway

Dee'an Procurement Awards This Month

Included in House and Senate Waste Reform Legislation

Initial Deployment Scheduled for 1998 1 ,
anc asonatone wonmAtos cowinsuct uAv s ees Regulatory Issues - Storage Certification
Public Scrutiny of General License Provision

Number of Certified Systems?

Flexibility of Certifications

Added Industry Certifications

Compatibility with Current Systems

NRC vs. lAEA Requirements

Interim Storage Licensing hele A40AATOAV WORWATION COW 8 AENCE i MAT 16et l
l 259
-' I
Regulatory Issues Transportation
Transfer Cask Fleet Certification

Burnup Credit Allowance

Moderator Exclusion Allowance

Drop Testing Requirements

Number of Cask Designs Needed

Shipment Date vs. NRC Review Schedule I
Nat 480VLATORY #WONMATON CONFER $NC$ f M&T 1998 Regulatory issues - Deployment Schedule e initial Use for on Site Storage e Demonstration Role
Utility Site Specifc Reviews Needed

Timely NRC Review of Systems e Availability of NRC Resources

Prior 6ty Mandated for MPC Review

Availability of Interim Storage

Deployment Ramp Up Schedule e increased Diversity of Non MPC Systems NRC htGWdTORV INf 0Ruaf Ch CONFlR4NC8 i NAT 1994 260
Regulatoryissues Repository Uncertainty
Cold vs. Hot Repository Strategy

Fate of Disposal Standards and Regulations

Allowable Fuel Clad Temperatures

Need for Burnup Credit

Cavity Backfill Requirements

Lag Storage Capability i
NGC 480WL&t041 NF04uAt:0N COW 448NCt i WAV l$$$ Conclusions
MPC Concept Makes Sense for HLW Program

Utility Endorsament is in Place

Regulatory Review will be Major Activity

NRC Cooperation is Essential

NRC Resources Will be c'iallenged

Current DOE Deployment Schedule Ensures Effectiveness and Benefits of System i.
NRC 450VLA?04VINF0nuaf DN CONFI4ENCE # ha? 1996 261
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Pall 5ADES NUCLEARPLANT DRY FUEL STORAGE (DFS) IMPLEMENTATION i AT CPCo PALISADES NUCLEAR PLANT PRESENTATION
SUMMARY
The discussion will summarize the spent fuel { storage issue at Palisades Plant including problem ) identification, option selected to address problem, l project implementation history and future opportunities. The Licensing approach, hardware fabrication problems, cask loading history and general performance summary will be discussed. 1 263
-. j
l 1 1 1 DRY FUEL STORAGE l l IMPLEMENTATION AT CPCo PALISADES NUCLEAR PLANT Pall 5ADES
.p'@.
AUCLDAPLANT Kurt hi. Haas Palisades Plant Safety and licensing Director May 10,1995 i i i J NRC Regulatory Information Conference 1995
. 264 x .
l i DFS IMPLEMENTATION AT PALISADES AGENDA ! Problem Identification ! l l Option Selected - SNC VSC - 24 i l Implementation History l Licensing Issues ! QA Problems j Loading History & Performance i Future Opportunities i ) I l ! l l i NRC Regulatory htformation Conference 1995 l 265
DFS IMPLEMENTATION AT PALISADES Problem Identification - 01/1988 e Palisades would loose full core offload capability in 1992 despite two rerackings of the spent fuel pool, o DOE schedules to implement MRS/ Repository continued to slip. e Fuel consolidation trials were not successful, e State of Michigan law limited storage to above ground pools. NRC Regulatory Information Conference 1995 266
i 4 j
DJS IMPLEMENTATION AT PALISADES Option Selected - SNC VSC - 24 l 3/01/89 i
Advantages-

Least impact on existing plant design.

Minimized storage area size.

Local fabrication.

Low cost option.
Disadvantages
Not licensed, constructed or in use.

Small support organization.
l l 1 NRC Regulatory Information Conference 1995 267
i DFS IMPLEMENTATION AT PALISADES 1
vsc - 24 l
Sectional View of a l Dry Fuel Storage Container 1 Air Flow Vent / - Cask Lid Air inlet A l. 29' Thick 1' Concrete Cask j 4 ,, NInner Cask
\ Liner Covering . y Sealed Basket ig., ; /<
Air Flow M .
. i NRC Regulatory Information Conference 1995 268
1 I DFS IMPLEMENTATION AT PALISADES IMPLEMENTATION HISTORY - LICENSING 1989 State of Michigan Public Act 113 Revised. 3/12/90 CPCo Applies for Specific License. 8/06/90 10 CFR 72, Subpart K (General License) issue. 8/21/90 CPCo withdraws site specific license application. l l 4/04/91 PSN (SNC) Applies for VSC-24 C of C. i 6/26/92 NRC Notices proposed " Rule Change." 1/21/93 NRC Reopens comment period for 30 days. 2/23/93 NRC Extends comment period for 5 days. l 4/07/93 FR Notice adding VSC-24 to 10 CFR 72 effective I 5/07/93. 5/03/93 NRC issues VSC-24 C of C. 5/07/93 Load out of first cask begins. 5/94 Special assessment of pad by NRC. NRC Regulatory Information Conference 1995 269 J
i l DFS IMPLEMENTATION AT PALISADES OA PROGRAM IMPLEMENTATION PROBLEMS i j e Early 1994 CPCo, NRC and other utility audits
revealed vendor quality program implementation j problems.

e Late July CPCo surveillance as part of increased j audit / surveillance programs revealed unacceptable
! flaws in welds of MSB 4. i i e July 28,1994 CPCo issued a stop work order on all fabrication activities and halted all loading operations. MSB 4 to be unloaded. e Independent assessment of vendor quality problems directed by CPCo VP-NOD. e August 23,1994 notice of violation directed to vendor. NRC Regulatory Information Conference 1995 270 u__ ---
)
I i i i DES IMPLEMENTATION AT PALISADES i ,
CPCo ASSESSMENT ISSUES !
l
1. QA program implementation was not adequately 1
l j verified early in the fabrication ,yrocess. l
2. A more rigid source verification plan should have been !
l invoked during fabrication. I l 3. Poor oversight plan defm" ition and execution. s
4. Our early actions emphasized production and sent the wrong message to the new QA organization of the vendor.

5. Root causes of audit findings were not identified.

6. CPCo project organization lacked integration and focus.

7. Large workload and competing work priorities of the project team.
NRC Regulatory Information Conference 1995 271
- - . - _ - . --~. - -. - . _ _ _ . . . - _ - _ - - . - - DFS IMPLEMENTATION AT PALISADES LESSONS LEARNED ACTIONS TAKEN 2 e Palisades Performance Enhancement Plan - (P EP).
New project team and separation of QA/ Production roles, e Increased oversight and inspection presence.

Common cause evaluation of vendor.
e Detailed deficiency resolution process for all completed components.
Additional vendor corrective action.
NRC Regulatory Information Conference 1995 272
DFS IMPLEMENTATION AT PALISADES LOADING HISTORY / PERFORMANCE
13 VSC's loaded to date.

Typical dose to load < 200 mrem.
Operational dose rates less than design.
Thermal performance as designed.
Load out schedule shorter than anticipated.
Field loading performances has been excellent.
NRC Regulatory Information Conference 1995 273
DFS IMPLEMENTATION AT PALISADES o FUTURE OPPORTUNITIES e Offloading MSB 4 - Fall 1995, o Fuel design change support. e Reconfiguration design / plan for final shipment. e Support legislative initiatives to set / achieve ( MRS/ repository schedule. l l l NRC Regulatory Information Conference 1995 274
BREAKOUT SESSION 1 l NEW SOURCE TERM ISSUES OPENING REMARKS I . May 10,1995 I ! ASHOK C. THADANI i i ASSOCIATE DIRECTOR I FOR ! INSPECTION AND TECHNICAL ASSESSMENT OFFICE OF NUCLEAR REACTOR REGULATION d I
BREAKOUT SESSION - NEW SOURCE TERM AGENDA:
Opening rernarks Ashok Thadani, NRC i
t
NRC presentation Charles Miller, NRC Use of new source term for ALWR design certification
- Status of application to operating reactors
ALWR presentation Stanley Ritterbush, ABB-CE 4
i 4-
NEl presentation Alex Marion, NEl s
)
Pilot utility presentation Ray Crandall, NEU 275 L__
NEW SOURCE TERM e RES developed substantial information on the release of fission products based on recent severe accident research e RES published NUREG-1465, " Accident Source Terms for Light Water Nuclear Power Plants," and is developing companion regulatory guidance for its implementation e SECY 94-302 (Drcember 1994) addressed ALWR Licensing and Technical lasues for Design Basis and Severe Accident Source Term Assessments e NRR and NEl engaged in discussions regarding potential implementation of NUREG-1465 at operating reactors CURRENT STATUS e AP600 includes safety enhancements for short term severe accident mitigation e Current operating reactors have features for long term severe accident management e NRC concerns about AP600 long term accident management e Containment pressure elevated for icng time e Uncertainties in aerosol removal analysis model e Capability to maintain pH control of water in containment e Westinghouse considering these issues 276
l System 80 + I l
Used Draft NUREG-1465 release fractions and timing i
! e Coolant, Gap & Early in-Vessel' releases used for DBA . assessment and equipment qualification = l
e Ex-Vessel & Late In-Vessel releases added for severe
, accident asssessments & post accident sampling i e 0.25 percent of lodine in organic chemical form i j e Containment sprays dominated fission product removal e Safety-related HEPA and non-safety charcoal adsorbers provided with no credit for iodine removal by charcoal
e FDA issued in July 1994 & proposed design certification i rule published 4/7/95 1
! AP600 e Final NUREG-1465 release fractions & iodine chemical forms j e Coolant, Gap & Early in-Vessel releases used for DBA i- assessment and equipment qualification e Ex-Vessel & Late in-Vessel releases added for severe , accident asssessments & post accident sampling j e Proposed Part 100 criteria - 25 Rem TEDE in worst two i hours at EAB e Westinghouse timing - Gap release begins at about one hour 0 No containment spray or safety grade filtration system i' e Only passive aerosol removal mechanisms in containment 4 l- 277
1 SBWR e Proposed EPRI passive reactor design source term o Staff r,lans to use NUREG-1465 source term o Review on hold at GE's request PLANS FOR OPERATING REACTORS l l e SECY 94-302 issued December 19,1994 addressed ALWRs i e NUREG-1465 based on LWR research & experience < i e No basis for mandatory backfit to operating plants e Interest expressed by several utilities (Northeast Utilities & Entergy) e NRC resources could not handle large number of plant specific requests; strategic generic approach needed ' i e NRC 7/27/94 letter to NEl "what do you want to do with , the new cource term" l l 278
i j BREAKOUT SESSION 1
NEW SOURCE TERM ISSUES i
l. ) CHARLES L. MILLER i CHIEF ! EMERGENCY PREPAREDNESS i AND RADIATION PROTECTION BRANCH ! OFFICE OF NUCLEAR REACTOR REGULATION i i A3WB 4 j e Used TID-14844 source term i
e Allowed an appropriate credit fcr lodine removal in j main steamlines and condenser following a DBA j e FDA issued 8., July 1994 i e Proposed design certification rule published 4/7/95
) i i k l I i ) l 279 a
.-n,, .. - -... - ., , .
System 80 + j e Used Draft NUREG-1465 release fractions and timing i i e Coolant, Gap & Early In Vessel releases used for DBA
assessment and equipment qualification i
i e Ex-Vessel & Late In-Vessel releases added for severe-l accident assessments & post accident sampling l e 0.25 percent of lodine in organic chemical form i l e Containment sprays dominated fission product removal i j e Safety-related HEPA and non-safety charcoal adsorbers l provided with no credit for ledine removal by charcoal e FDA issued in July 1994 & proposed design certification l rule published 4/7/95 l l i
AP600 l
l e Final NUREG-1465 release fractions & iodine chemical forms e Coolant, Gap & Early in-Vessel releases used for DBA assessments and equipment qualification e Ex-Vessel & Late in-Vessel releases added for severe accident assessments and post accident sampling e Proposed Part 100 criteria - 25 Rem TEDEin worst two hou s at EAB e Westinghouse timing - Gap re; ease begins at about one hour e AP600 source term issues under review by the staff 280
l SBWR J e Proposed EPRI passive reactor design source term o Staff plans to use NUREG-1465 source term o Review on hold at GE's request 1 PLANS FOR OPERATING REACTORS e SECY 94-302 issued December 19,1994 addressed ALWRs e NUREG-1465 based on LWR research & experience e No basis for mandatory backfit to operating plants
- e interest expressed by several utilities (Northeast Utilities &
Entergy) i e NRC resources could not handle large number of plant l specific requests; strategic generic approech needed i e NRC 7/27/94 letter to NEl "what do you want to do with i the new source term" 4 l 281
PLANS FOR._ OPERATING REACTORS Cont. i !
NEl 9/24/94 letter proposed agenda for meeting with NRC i
j e NEl & NRC met on 10/6/94
- NEl established task force to identify industry interest 1
- NEl to develop generic guidance document e NUREG-1465 published finalin February 1995 e NEl plan to be discussed later in this breakout session i
i l
PLANS FOR OPERATING REACTORS Cont.
KEY SOURCE TERM ISSUES e Fission Product Release Timing
/ Containment isolation / Secondary Containment Pressure Drawdown / Control Room Habitability / Loading of Diesel Generator e Equipment Qualification e Fission Product Chemical Forms / Requirement and Testing of Charcoal Adsorbers e Proposed 25 rem TEDE dose Criterion 282
BREAKOUT SESSION - SECURITY ISSUES OBJECTIVES:
Discuss regulatory initiatives in the area of security and provide the status of progress in these areas.

Identify security issues that will be addressed by the agency in the future.
Obtain feedback from industry regarding agency activities. I 1 l 283
NRC STAFF PRIORITY SAFEGUARDS ACTIONS
Reduction of Reporting Requirements
- Effective Rule 3/14/95 Deleting Submittal of Logs - Future efforts
Rulemaking on Containment Access Control

Generic Letter on 50.54(p) Changes

Other insider issues
- Generic Letter - Rulemaking
Fitness-For-Duty Rulemaking

Rulemaking on Safeguards Audit Frequency Information Notice on Access Authorization Lessons Learned FUTURE NRC SAFEGUARDS ACTIONS Review One-Hour Reporting Review identification of Safeguards Information Review Retention of Quarterly Logs l
284
INDUSTRY PERSPECTIVE ON SECURITY ISSUES REGULATORYINFORMATION CONFERENCE May 1995 N.S. " Buzz" Carns Chairrnan, President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation and Chairman of the Nuclear Energy Institute Security Working Group
Background
NRC security regulations are prescriptive and detailed. Under 10 CFR Part 73, the commission specifies physical measures utilities must take to protect their nuclear power plants against security threats. Interpretations over the years have driven us toward protecting against some quite improbable threats for particular plants. Most of these requirements predate the separate requirements for fitness for-duty and access authorization programs, which help ensure that only trustworthy, reliable individuals are permitted to enter the protected area of a nuclear power plant. Thus, many existing requirements that pertain to the " insider threat" are no longer needed. Additionally, the industry believes current requirements for physical security measures . at nuclear power plants go far beyond what is needed to protect public ! health and safety. All of us want enough security, where we may differ is in the definition of"enough." ' The NRC has targeted its security regulations for c_anges under the commission's regulatory improvement program. Through this program, the NRC identifies requirements that add little if anything to plant safety, yet impose an administrative burden on both the NRC and utilities. This effort has been underway for some years, but the burden reduction philosophy has not permeated security regulation to , the extent desired by the industry and perhaps the NRC. l l 285
d 1 i At the March 28,1995, Commission briefing by NRR, Chairman Selin encapsulated the problem and solution as noted in his statement: I really hope that security is not like some other things where more is necessarily better. There is no reason to have any more security than you need. So I would hope i that we would go not only to steps that don't reduce effectiveness, but if somebody has more security than is ' necessary, they should be able to get down to some standard without having to apologize for having over performed in thepast. l- Now we need to get on with making it happen - we need to overcome the resistance to change. If we overshoot in some area, let's not be afraid to admit it and make the necessary course correction. There are many excessive requirements in Part 75 Security Regulation and in licensee Physical Security Plan commitments. Security issues must be brought to closure in order to minimize the continuing unnecessary expenditure of resources. The numerous specific recommendations made by the industry through NEI/NUMARC to the NRC concerning security regulations and associated guidance are therefore reiterated herein. The major generic security issues confronting us include: Issue 1: To modify security requirements for an internal threat. Make specific revisions to vital area access control measures, allowable outage times before needing compensatory measures, access lists, alarm response, door locks, etc. To eliminate the security post for containment access control. To eliminate the escort requirement for all searched vehicles with cleared drivers entering the protected area. The NRC positions on these and other security issues were expressed in SECY-92 272 & SECY-93-326 including a position on the industry's
" Alternative Protection Strategy" of June 1992. Industry concerns were further addressed by NUMARC letter to Chairman Selin on December 21,1992. Subsequently, on December 19,1994, NEI 286
commented on behalf of the industry on the proposed Generic Letter (59 f.ed. Egg. 54923 dated November 2,1994) concerned with insider threat issues. We understand that rulemaking has been initiated on some aspects of security regulation (e.g., eliminating the containment guard i requirement), but NRC regulatory activities concerning these issues ' remain unclear. For instance, the vehicle escort issue needs a
regulatory suitable" substitute to replace the narrow prescriptive definition in the rule ($ 73.55(d)(4)). This vehicle escort requirements are " resource intensive" with insignificant value added to safety or security. If we spend less time checking up on the people we trust and rely upon, our security resources will be better focused where they should be.
,- Issue 2: To provide flexibility in allowing Physical becurity 1-Plan (PSP) changes under i 50.54(p). Based on the NRC Regulatory Review Group's 1993 report, NRR suggested that the industry develop criteria s'ad/or examples that could be used to define the $ 50.54(p) phrae. . "...make no change which would decrease the effectiveness of a security plan ...." The " catch 22" problem remains because any lessening of commitments automatically conjures up the image of a decrease in effectiveness resulting in consideration of only $ 50.90 license modifications. In support of the NRR invitation, NEI provided " Industry Guidelines J for Making Security Plan Commitment Changes under 10 CFR 50.54(p)" to the NRC by letter dated June 9,1994. To establish a process to overcome the " catch 22," NEI proposed 22 examples of changes that can be made to security plans without NRC approval per i 50.54(p). Three questions, analogous in philosophy to the $ 50.59 process, must be answered for each example. If the answers provide a high level of assurance that protection against radiological sabotage from the design basis threat (i.e., comply with 10 CFR S 73.55) would continue to be maintained, the change could be made without prior NRC approval. 287
There is a backlog of modifications (including the twenty two proposed in the noted NEl letter) that would save significant resources as soon as this process is established. We understand that a process to address these issues is included in a proposed Generic Letter, " Standardization of Security Program Reviews," due out for public comment. Issue 3: To modify safeguards events reporting and logging requirements of 10 CFR i 78.71. The NRC published a final rule (60 End. Be_g.13615 dated March 14, 1995) eliminating the requirement for the quarterly submittal of safeguards event logs. This change had been recommended in Enclosure 6 of NUMARC letter of September 30,1992, and having it come to fruition is meaningful. However, there were several other recommendations in that enclosure that would have made the safeguards event logging and reporting processes more flexible and efficient for licensees. Included therein were recommendations associated with raising reporting criteria thresholds for " Safeguards Incidents to be Reported Within One Hour" as well as a document,
" Guidelines for Recording Safeguards Events" which had been developed by an industry task force to replace the burdensome process that resulted from Regulatory Guide 5.62 (November,1987); NUREG-1304 (February,1988); and Generic Letter 9103 (March 6,1991); all entitled, " Reporting of Safeguards Events."
In NEI an letter to the NRC dated December 19,1994, we reiterated the concerns expressed in 1992 and espoused the conclusions of the NRC's Regulatory Review Group (SECY 94-003) that this issue is a manifestation ... of treating security in a philosophically different manner than other regulated activities. The industry recommendations need further consideration in the burden reduction environment. Acceptance of the industry products would not adversely affect public health and safety but would unburden the process of maintaining and reporting safeguards information with associated resource savings. 1 288
v Issue 4: To establish more meaningful categorization of
safeguards information (SI).
By NUMARC letter to the NRC dated October 2,1992, we transmitted
a paper, " Guidelines for Categorizing Safeguards Information." The 4
paper had been developed by an industry task force to simplify and streamline the safeguards information categorization process that is
unnecessarily burdensome and results in the special handling of an excessive amount of material. The document redefines the i
categorization criteria and provides a logic flow chart to help reduce
- the number of documents currently over-classified and to help
, minimize similar excesses in the future. . Issue 5: To complete the action on fitness-for-duty (FFD) rule (10 CFR Part 26) change recommendations, NRC FFD program improvements and lacorporate the approved Department of Health and Human Services (DHHS-SAMHSA) changes to the
" Mandatory Guidelines for Federal Workplace Drug Testing

Programs."
Since the FFD rule was implemented by alllicensees on or before i January 3,1990, several industry inputs to the NRC based on the induatry e.xperience have not been ected upon. I In a letter tc the NRC dated April 17,1991, NUMARC detailed fifty-one specific change recommendations -- for example: more efficient suitable inquiry requirements, allowing entry for access j reinstatements after sample collection without awaiting test results i (as is done in the random program), deletion of triennial update
requirements for collection site persons maintained under a Continual j Behavioral Observation Program, provide for an " alcohol only" test,

shift FFD program audit frequency to biennial (or triennial if performance based per the Regulatory Revieri Group), etc.
i i 4 4 4 289 W-
. - _ _ - - . . _ - - - - . - - - - - - . - . . - - - - . - ~ - . =
In response to information in SECY 91293, dated September 17,1991, _, NUMARC letter to the NRC dated July 24,1992, provided further recommendations in " Industry Comments to Improve Programs Under the [FFD) Rule." NUMARC letter to Chairman Selin dated December 21,1992, reiterated several of the previously submitted FFD recommendations with further rationale for rule modification to reduce unnecessary costs to licensees.
- As of April 17,1995, except for a few issues ((clarifying the requirements for taking action against an individual (56 Ensl. Egg.
41922 -- August 26,1991) and reducing the random testing rate to 50% (58 Egd. Egg.15810 March 24,1993)), no other industry FFD recommendations have been provided for public comment through the rulemaking process, NUMARC letter dated June 22,1993 and NEI letter dated April 3, 1995, recommended the NRC consider a scheme analogous to that being used by the U. S. Department of Transportation for the performance based random testing rate of the railroad industry. In that federally regulated program of a safety-sensitive industry the testing rate has been 25% based on the low positive testing results for the previous two years. Additionally, it was reiterated that there are- ' significant FFD program differences for a subset of nuclear _ utility = workers (those with commercial drivers licenses) that are subject to both the NRC regulations and the DOT regulations. This creates-confusion and requires double effort relative to those people because the two federal agencies have not resolved the program differences. We suggested that the NRC take the opportunity to standardize all safety-sensitive federal FFD/ drug and alcohol testing program regulations through the National Performance Review Phase 2 - process currently under review. Additionally, we have requested that the NRC rulemaking incorporate the 1994 changes made by the U.S. Department of Health and Human Services in the document, " Mandatory Guidelines for Federal
- Workplace Drug Testing Programs," to make the NRC FFD program more efficient. These modifications included: specimen volume -
l L i 290 l' . . .. , -- _ .- . -
P f reduced from 60 ml to 30 ml, marijuana screen test positive level
reduced from 100 ng/ml to 50 ng/ml, blind sample submission requirements reduced from 10% to 3%, deleted batch sample reporting, and many more.
We strongly urge prompt action on all outstanding FFD program recommendations. Several millions of dollars of savings per year can result from these changes without any reduction in the safety benefit provided by the current industry FFD programs. Summary Although the NRC has targeted its security requirements for some changes under the agency's regulatory improvement program, little tangible relief has been forthcoming from industry attempts to 65tain generic or specific relief. There are still many security requirements that add little if anything to plant safety, yet impose a compliance burden on utilities. The industry proposed commitment reduction process and regulation modifications would enable greater flexibility in resource allocations with resultant reduction in the current economic ! outlay for security by utilities and therefore ratepayers, We all want a safe, secure environment for the nuclear generation portion of the electricalindustry. Ifit makes sense, we need to do it. It is in having people in security organizations that are alert, forward thinking, and focused that will provide the necessary and proper amount of protection for our power plants. Prescriptive past practices haven't and won't. Thank You. 1 4 I i i 291
g 1 1 1 l l l
._.J
I May 10,1995 Afternoon Breakout Sessions 2:00 p.m. - 3:30 p.m. 1 293
l lNTEGRATION OF PERFORMANCE INSIGHTS i.
PERFORMANCE INFORMATION l e PLANT PERFORMANCE REVIEW PROCESS ,
e INTEGRATED PERFORMANCE ASSESSMENT j PROCESS
SYSTEMATIC ASSESSMENT OF LICENSEE
! PERFORMANCE l
SENIOR MANAGEMENT MEETING i
INTEGRATION
+
IPAP
/ PPR in omce l Onsite PERFORMANCE PPR *o INFORMATION / PERFORMANCE \ / INFORMATION \
294
1
/\
WHO WHAT Longiorm Management Ordegrotion Panel SALP Report (24 months) p l A) Results of in Omco Review s- senior sten s) renei Report at conciusions of Tam IPAP '" 0*** """ *"d 0"*"' 1 Validation and inspection l
'""'"""" Recommendations '
7 7,, PPR
\ in PectionPlan gm rirst L6vei 3 PERFORMANCE inspection Reports lateoretion Alidation $ INFORMATION (6 months) i l
OBJECTIVE PERFORMANCE INFORMATION e I inspection reports and enforcement l e l Event assessmunt and risk insights ' e Performance indicators e Management meetings and direct site observation e Routine evaluations - PPRs, SALP, SMM i I e Special evaluations - AITs, llTs, DETs 295 N _ ____j
PLANT PERFORMANCE REVIEWS (PPRs) 1

Process i l l e Semiannual performance review by regions l I
j e Assess performance in SALP functional areas , i e Compare inspection plan with performance e Outputs e Inspection plan modifications SALP e Process e Periodic review by regional administrator
Integrate assessments over 12 to 24 months

Identify overall changes in performance e Outputs e SALP report and ratings

Increase / reduce SALP period

Inspection plan and SMM recommendations 296
SENIOR MANAEEMENT MEETING (SMM)
Process

Semiannual agency performance review

Screening meetings

SMM decisions / regulatory safety approaches

Outputs

Superior performer recognition

Problem plant list / trending letter l

Management meetings /special assessments INTEGRATED PERFORMANCE ASSESSMENT PROCESS l
. ASSESSMENT TEAM .
PERFORMANCE ASSESSMENT / INSPECTION PLANNING TREE 18 l REVIEW OF FINAL ANALYSIS /
= k. . IICENSEE --
SITE VISIT - DEV.OFINSR -- SALP/PPR i 7.,,*. l PERFORMANCE RECOMMEND. --
% Pr,timinary F6ndings Briefed to SALP Board (if aselsned) and Sits Visit Guidance Provided by SALP Board 4 Preilminary Findingo Provided To Uconoce v
1. FINAL INSPECTION INSPECTION PLAN - WP N CEN E PLAN ADJUSTMENTS DEVELOPMENT IMPLEMENTATION (PPRs) 2. FEEDBACK ON PROGRAM EFFECTIVENESS 9P Assessment Findings Presented to SALP Soard (if assigned) 291
INTEGRATED PERFORMANCE ASSESSMENT PROCESS: METHODOLOGY REVIEW PHASE
Purpose:
Integrate performance information and arrive at an ind<apendent view of strengths and weaknesses, e Review of Prior Inspection Results and Licensee Performance o inspection Reports, Enforcement Actions, Systematic Assessment of Licensee Performance, Senior Management Meetings, Plant Performance Reviews o Licensee Event Reports, Performance Indicators, Licensee Self-assessments o insights from IPE e Develop a preliminary Performance Assessment Tree o Brief management
Provide preliminary resuits to the licensee 298
SITE VISIT PHASE
Purpose:
Validate the results of the review phase e Multi-Disciplined, Performance-Based, , Assessment Team Site Visit i l e Approximately 2 week visit (may vary) e Preliminary exit meeting { EINAL ANALYSIS AND INSPECTION RECOMMENDATIONS PHASE
Purpose:
Develop the final licensee evaluation and inspection recommendations e Develop final conclusions and complete assessment tree e Develop inspection recommendations e Briof management e if necessary, conduct a final exit 299
ASSESSMENT OF REGULATORY PROCESS
Purpose:
Provide feedback regarding the effectiveness and implementation of regulatory programs
Analyze the results of the IPAP effort to identify regulatory program or implementation weaknesses o Were new issues identified?
o Was the inspection record complete and accurate? o Were inspection reports of good quality? o Were enforcement actions appropriate?
Document the results in a report from the team

Forward the report to NRR/IPB 300
gRREGuy I D O e r e 2 E k/ i \ Self-Assessments (Inspection Procedures and Lessons Learned) 301
Self_Assassments_Ilnspection Procedures _and Lassons_Leamadl e Review NRC IP 40501 guidance on evaluation of licenses self-assessments Bruce Boger, NRC e Provide utility perspective on service water self assessments - David Powell, AEP; Marty Bowling, VA Power e Provide NRC experience with Cooper SET Ed Jordan, NRC Inspection Procedure 40501 9 Recognizes good performance and quality self assessments e Permits reduced scope of effort on team inspections e Provides guidance on evaluating a licensee's effort e Establishes goal of 25% of the normal preparation and inspection effort 392
.Guldance on Evaluating a Licensee's Effort t Organization Capability 9 Assessment Team Experience 9 Scope of Effort Equivalence e Timing - NRC Planning and Review i
l l MILC Reduced Scope _jnspe.ntion e in Process inspection Smaller Team for up to 5 days Self assessment about 50% complete
- Evaluate scope / depth w well as objectivity and independence 9 Finalinspection - Self assessment final summary report issued - Evaluate completeness with multidiscipline team - On sampling basis cover items reviewed and not reviewed in self-assessment - Evaluate corrective actions 303
Baduced Scopa_lnsoection_Exnadenca e Applicd on Service Water System Operational Performance Inspections (SWSOPI) and Electrical Distribution System Functional inspections (EDSFI) e Performed by highly quallfled teams in an effective manner e Beneficial because of licensee ownership of findings and corrective actions e NRC spent about 45% of the normalinspection effort Status of Licensee Self-Assessmerits NRC Ucensee Self Assessments Tl inspections Performed Full Scope Reduced Requested Denied Performed Scope SWSOPl 18 9 25 0 17 2515/118 EDSFI 65 4 4 0 4 2515/107 304
Future Use hed scope of IP 40501 to include team inspections S Inspection Procedures (lP)
# Temporary instructions (TI) l t
l l l l l 305
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REGULATORY INFORMATION CONFERENCE MAY 10,1995 l UTILITY DIAGNOSTIC SELF ASSESSMENT l
+
NRC SPECIAL EVALUATION E. L. JORDAN AEOD l 307
PRESENTATION OBJECTIVES o Describe the diagnostic level assessment process used for Cooper Nuclear Station which relied, in part, on a licensee Diagnostic Self Assessment effort, o Discuss the lessons learned from the Cooper Sp.ecial Evaluation and future plans for the Diagnostic Evaluation Program. DIAGNOSTIC vs SPECIAL EVALUATION o Diagnostic level evaluation needed 0 Opportunity for innovative approach o Conditions for Special vs Diagnostic Evaluation The Diagnostic Self Assessment must have: Scrutability Independence Public exit meeting Publicly available report 38
PREPARATIONS FOR DET
Planned Full Scope, independent Self Assessment to Prepara for DET Diagnostic Self Assessment Team (DSAT)
Review Extensive Effort involved in DSAT 15 Team Members with Approximately 265 Years of Nuclear Experience Team Was On-Site for 4 Weeks from 7/25-8/19 About 4,000 Man-hours Were Expended in Direct Assessment and Evaluation Activities
NRC Recognized Our Effort - Special Evaluation in Lieu of NRC DET Preliminary Results Presented on August 19,1994 COOPER DIAGNOSTIC SELF ASSESSMENT TEAM Team Manager - Consultant Asst - Consultant Operations Maintenance Engineering Management and and and and Training Testing Technical Support Organization Farley Pilgrim INPO Phl:adelpia Electric Co Clinton Fort Calhoun Waterford Virginia Power Fitzpatrick Fort Calhoun Consultant '
Catawba INPO INPO log _ _ _ _ - - - - -
COOPER SPECIAL EVALUATION
Small experienced team o Diagnostic level evaluation l
e Evaluate / build on results of Diagnostic Self l Assessment i e Produce an NRC evaluation of Cooper COOPER STATION SPECIAL EVALUATION TEAM Ellis W. Marschoff
1. ,m
,, uger oi. e. wesi Mm n Assi tant l l l l PeterW tselgroth Peter J. Prescott Ronald L Lloyd Alan Madison
Mai tegne Enggeg Managemeg&gganizauon Ogs John W. Thompson Rudolph H. Bernhard Anthony J. D'Angleo Russell Brown Team M ber leam Member Yea meer le Me r 310
RESULTS OF NRC EVALUATION OF DIAGNOSTIC SELF ASSESSMENT o Overall assessment was effective o Minor process weaknesses were noted o Results Insightful assessment Identified significant weaknesses Effectively conveyed l l l COOPER SPECIAL EVALUATION PUBLIC EXIT MEETING o Diagnostic Self Assessment Team leader presented resUlts o NRC Special Evaluation Team leader presented results o Licensee senior management committed to addressing weaknesses 311
LESSONS LEARNED FROM COOPER SPECIAL EVALUATION (CONTINUED) Limitations of combined Diagnostic Self Assessment /Special Evaluation process: e importance of Diagnostic Self Assessment team qualifications and leadership
Potential Diagnostic Self Assessment /Special Evaluation conflict could delay corrective actions i
e Public perception of NRC's partial reliance on licensee's Diagnostic Self Assessment LESSONS LEARNED FROM COOPER SPECIAL EVALUATION ADVANTAGES
Special Evaluation process is an efficient use of recources

Results conducive to rapid " buy in" by licensee e Results available to licensee earlier

Reduced regulatory impact on licensee e Reduced NRC resources 312
SUMMARY
e Programmatically established the Special Evaluation approach as an alternative to an NRC Diagnostic Evaluation.
A Special Evaluation may be conducted in conjunction with a licensee Diagnostic Self Assessment.
I e Communicate NRC willingness to accept Diagnostic Self Assessment /Special Evaluation approach. 313
6
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1995 Regulatory Information Conference Standard Technical Specifications Technical Specification Improvement Program i
)
315 _. J ~' _ __ _ A
Commission Policy e ProvHe criteria for technical specification contents e Encourage complete conversions to improved STS e Use improved STS for line item improvements e Achieve greater standardization and consistency e Pursue risk based TS improvements l 10 CFR 50.36 Final Rule e Commission directed rulemaking May 1993
Codify four criteria from Flnal Policy Statement

Preserve voluntary program o Final Policy Statement published July 22,1993 e Proposed rule change published September 20,1994 e Comments on use of Criterion 4 316
Technical Specification Criteria
#1 Instalhd instrumentation that is used to detect and indicate, in the control room, a significant abnormal degradation of the reactor coolant pressure boundary. #2 A process variable that is an initial condition of a design basis accident of transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. #3 A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient analysis that olther assumes the f ailure of or presents a challenga to the integrity of a fission product barrier. #4 A structure, system, or component whicn operating experience or probabilistic safety assessment has shown to be significant to public health and safety.
Reactor Core isolation Cooling or Isalat6cn Condenser

Residual Heat Removal

standby Ucuid Control e Rec 6rculation Pumr; Trip Improved Standard Technical Specifications (STS)
Simpilfles technical specifications (reduces LCOs = 40%) Achieves substantial consistency in requirements Presents requirements in operator friendly format Enhancas bases: links requirements to safety analyses Clarifies long standing technical specification issues
Operability

Surveillance practices Allowed outage times (completion times) 317
i STS Implomontation e STS Conversions
5 units completed

8 units under review

19 units scheduled

11 units planned e Maintain improved STS as living document e incorporate enhancements when consensus achieved with Owners Groups

Incorporate new generic requirements which meet criteria e License amendment screening
* ~ 50% amendments have generic implications
Ensure consistent review of generic items

Avold duplication of review effort

Line item improvements License . Amendment Process improvements

Objectives

Maintain technical quality of amendments

Encourage consistency of amendments

Minimize effort and processing time e Process issues

Limited planning for amendment processing

Identification, access, and use of precedents

Variable quality of licensee applications

Consistency of guidance across NRR divisions 318
NRC Potential Improvements
Project Manager work planning

Precedent search Technical branch coordination

Work priority, schedule, and level of effort

Precedent database development

Cross Index amendments, SEs, and STS and SRP sections

Certify quality of precedent SEs

Establish database maintenance procedures

User friendly -- 95% + use in NRR i
l NRC Potential Improvements (continued)
NRR-wide license amendment processing guidance Role of technical staff and legalinformation needs Role of generic letters and amendment precedents Periodic communication describing line item precedents 319
Licensee Potential Improvements
Licensee guidance and communication

Voluntary use of standard amendment cover sheet
- Identify precedents - Index to STS and SRP - Provide relative priority of submittalc
Develop protocols for exchanging documents with licensees (Electronic Information Exchange effort) 320
. Improved Tech Specs n .e.
at c "- Grand Gulf I f., NRC RegulatoryInformation Conference l
;i May 10,1995 i, s Mike Meisner. Director, Nuclear Safety & Regulatory Affairs Entergy Operations Grand Gulf Nuclear Station 321 ' ~
d --
Improved Tech Specs Grand Gulf
. Level of effort . Benefits ,$t'T .
b -; . What would we do differently?
?
I r. Level of Effort
. Submittal development . Implementation 5 'N,.4, - Procedure changes - Training - Transition period ;L .' + important elements - Buy-in - Team members 3y - NRC Interface $k 322 ~-
l Benefits
s. -,
,, . Initialjustification . Real benefits , .- jy1 >p . E Relocated specifications - Changes in retained specifications . - Enhanced bases t
co l Fl} [
c Hindsight Observations
+ Submittal developmeist + Procedure changes gas ~~t . Training . Transition k = Ins (E
Wih b 323
, 1 _ -
l D j TS Conversion at R.E. Ginna l Nuclear Power Plant l George Wrobel 1 l Manager, Nuclear Safety & Licensing Rochester Gas & Electric Corp. l i I i 4 f i 324 i
i Background - R.E. Ginna :
y. - -

li" Obtained Provisional Operating License on i September 19,1969

" Custom" Technical Specifications (TS)
^
1 m Replacing SGs and converting to 18 month cycles in 1996
n Design Basis Documentation / Current Licensing Basis Programs 4
Qonversion Decision Pfaking 15 Licensing and Management Assumed: Present " custom" TS are flexible Operations comfort with existing TS after 24 years ofoperation a Fact Conservative operability and LCO decisions TS interpretations thicker than TS Difficultyin obtaining TS changes 325 1
Conversion Decision Making v..; nii Initiate discussions within RG&E Meet with implementing utilities Meet with the NRC a Perforrn a cost benefit analysis n Obtain management consensus and direction s w Cost Benefit Analysis
" Costs of Remaining with " Custom" TS Duration and cost ofindividual TS changes -Minimum TS change cost - $30k to $45k - Avg LAR duration from submittal- 18 months - Expected TS changes before 12/96 - $380k - TS interpdation cost - $2500 each Human factor concerns -Several NOVs and audit findings Unnecessary testing / safety focus 326
______________ a
Qost Benefit Analysis n Cost of Converting to Improved TS Preparation costs and staffing Training Procedure changes NRC reviewer fees Estimated Cost = $800k l Cost Benefit Analysis
\
Benefits "Hard"
- Surveillance test reductions - $75k/yr -Eliminate near-term TS changes - $380k " Soft" -Human factors improvements -Support 50.59 evaluations -Relocate several current TS requirements to more efficientprograms -Support DBJ/CLB efforts 327
ManagementDecision Criteria Obtain a return within 3-4 years Must be able to keep Ginna unique flexibility Could not adversely impact SG replacement
or conversion to 18 mor*h cycles c a Must resultin the mit talimpact to operations and plant staff as possible l n Maintain conversion effort within RG&E l
Staffing l' Staffing 1 licensing engineer full-time 1 shift supervisor full-time 1 licensed training instructor half-time Several members of PORC part-time Severalmembers of NSARB part-time Other Westinghouse 2-Ioop facilities Outside consultants 328 j
l Status l' l Final PORC approval schedule for May 12th l NSARB approva!next week j Submittal by the end of May l n NRC SER expectedin Nov 95 l n Implementin Feb 96 i 1 1 l l 4 l l ;Stimmary i Better design basis knowledge ! More plant control l TS focus on safety concerns l n Reasonable cost l l I i i i 329
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REVIEW OF THE NRC ENFORCEMENT POLICY AND PROGRAM : 1 l l l 331
REVIEW TEAM CHARTER FOR ASSESSMENT OF TIIE NRC ENFORCEMENT PROCESS
The balance between providing deterrence and incentivas (both positive and negative) for the identification and correction of violations.

The appropriateness oi Ni1C sanctions.

Whether the Commission should seek statutory authe-ity to increase the amount of civil penalties.

Whether there should be different enforcement policies and practices for material licensees in contrast to power reactors or large fuel facilities.

Whether the Commission should e..tablish open enforcement conferences as the normal practice.
EXISTING ENFORCEMENT SYSTEM 5 Severity levels and 8 activity areas Notices of Violations (NOV's) for all severity levels Can use Non-Cited Violations (NCV's) for: licensee Identified and corrected Severity Level (SL) IV licensee corrected SL V Enforcement Conferences SL 1,11, and til Repetitive SL IV Closed except for trial program
Civil Penalties SL I,11.111, and occasional repetitive SL IV Amounts are percentage of base penalty SL I - 100%, SL II - 80%, SL lli - 50%. SL IV - 15%
332
EXISTING ENFORCEMENT SYSTEM (CON'T) e Civil Penalties (Con't) Factors adjusting base for SL I,11. or til identification: ( 50%) -(+50%) I Corrective Action: (50%) -(+50%) Licensee Performance: ( 100%! - ( + 100%) Prior Opportunity: 0 - ( + 100%) i Multiple Occurrences: 0 - ( + 100%) Duration: l 0 - ( + 100%) j e biscretion ( to increase or decrease sanctions)
- Daily civil penalties Old design problems Willfulness Significant breakdown on management controls Performer.ce shutdowns Repeated poor performance Similar violations identified by corrective action - Special circumstances \
OBSERVATIONS l l
\
e Focus is on safety e Current enforcement system basically sound Severity levels Enforcement conferences Graduated sanctions Appropriate regulatory messages Utilization of discretion e implementatica is not always easy Multitude of adjustment factors Percentages allow for numerous results Current decisional process can be inefficient l l Civil penalty assessment process sometimes produces mixed messages 333
N -
HIGHLIGHTS OF THE ENFORCEMENT REVIEW e CLARIFY FOCUS Emphasize licensee Identification and corrective action Direct attention at licensees with multiple escalated actions Focus more on current performance o SIMPUFY PRCCESS Predictability is important Ucensees see the benefit of identifying and correcting violations Maintain basic elements of existing system (SL's, Enf Conf, base penalty amounts) Esse implementation i CLARIFY PURPOSE OF THE NRC ENFORCEMENT PROGRAM r To support the NRC's overall safety mission in protecting the public and the environment. o Emphasizing the importance of compliance with NRC requirements, and
Encouraging prompt identification and comprehensive correction of violations 1 335
- - - . -- . - - . - . - . - . . . - . - . . - - - . - . . . ~ - . - . _ . SEVERITY LEVELS e Retain four levels; drop Severity Level V e Citations not made for minor violations (formerly Severity Level V) e Utilize NCV'S (Non-Cited Violations) e Reevaluate severity level examples to determine if they reflect appropriate wvel of safety and regulatory significance ENFORCEMENT CONFERENCES e issue inspection report at least two weeks before conference e Enforcement conferences are pre-decisional to possible significant agency action e Enforcement conferences held for potential escalated actions if needed
1) For common understanding of facts, root causes and missed opportunities

2) For common understanding of corrective action

3) For common understanding of significance of issues and need for lasting corrective action,

4) To obtain other information that will assist NRC in determining the appropriate enforcement action, or if

5) Requested by licensee e if a conference is not held obtain a written response to inspection report, including description of corrective action
Enforcement conferences should be normally open subject to privacy, etc e Utilize standard agency method to announce conference 336
l PROPOSED ESCALATED ENFORCEMENT PROCESS 1 I e Consistency and predictability important e Umit the number of assessment factors
, Consider relevant circumstances for each factor e Use lunited outcomes Exercise discretion to escalate or mitigate sanctions where outcome does not convey appropriate regulatory message CIVIL PENALTY FACTORS e
CORRECTIVE ACTION Was the licensee's corrective action reasonably prompt and comprehensive? Action taken upon dis::overy to correct violation Action taken to prevent recurrence of violation at issue Action taken to be appropriately concrehensive, given the significance and complexity of the violation, to prevent occurrence of similar vloietions e IDENTIFICATION Should the licensee get credit for identification? Ucensee identification: Normally missed opportunities or repetition not considered. Self disclosing event: Normally conalder missed opportunities and repetition,
- i NRC Identification:
Was it reasonable for the licensee not to have identified it earlier? Mixed situations: Who should get credit for identification? l 3 :,'
. ws . _ _ _ _ _ _ _ _ .
ESCALATED ACTION PROCESS vas I vas 4 ' 9 vas e "S"
~
v' ,.. 9
- e.,
T
=-
g- y .a O . 7m1tMO?l".*7 ~.c CANDIDATES FOR DISCRETION e Severity LevelI and 11 e Overexposures, releases, and lost control nf material e Particularly poor performance or willfulness e Particularly poor enforcement history or directly repetitive violations e Duration with substantially increased risk e Sustained trend of good performance o Conscious decision to be in noncompliance to obtain economic benefit e Violations during extended shutdowns for poor performance (Vil.B.3) e Violations involving old design issues (Vil.B.4)
- e Violations identified due to previous escalated enforcement actinns (Vll.B.5) i e General discretion to increase or decrease a sanction (Vil.A.1 and B.8) e 338
. .- .- . .- . . ~ . . - ._ . . , _ . - . - _ . --. .. - . - . . .
CIVIL PENALTY AMOUNTS 1 e e Statutory locrease in civM penalty amount not needed (Current program has not maximized use of current authority) e Existing authority provides substantial flexibility for most cases e Use civH penalties only for Severity Levels I, it, and IH Keep exist'ng percentages of Severity LevelI base penalties (SL I - 100%, SL N - 80%, SL lil 50%) I
Keep existing base penalty for reactors delete "Other " category l -
combine medical categories e Delete special amounts for transportation violations I i i 1 i IC i BASE CIVIL P.ENALTY FOR SEVERITY LEVEL I a. Power Reactors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $ 1 00. 000
b. Fuel fabricators, industrial processors',
and independent spent fuel and monitored j retrievable storage installations . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 25,000 l
c. Test reactors, mills and uranium conversion
- facAlties, contractors, vendors, weste disposal licensees, and industrial radiographer . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $ 10,000
d. Research reactors, academic, medical, or other material hcensee . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 5,000 s
D rge tiras engaged in manufacturing or distribution of byproduct, source, or special nuclear material. safeguard violations for this category base penalty $100,000. 339
IMPACT OF RECOMMENDATIONS e Clearer regulatory focus e Better emphasis on safety e More predictability in decision making e Easier to implement e Preserve discretion e Est! mated reactor results 340
N0ED IMPROVEMENT INITIATIVES BACKGR002 j
IN MAY 1994 IN RESPONSE TO CONGRESSIONAL AW EDIA' QUESTIONS, AN NRC REVIEW TEAM, INITIATED REVIEW 0F THE N0ED POLICY Am ITS IWLEMENTATION '
PRACTICES REVIEW TEAM REC 0 WENDED CHANGES TO POLICY AND PROCEDURES SEPTEMBER 1994 OIG AUDITED NON. TECHNICAL ASPECTS OF THE N0ED POLICY IMPLEMENTATION - 0!G REPORT ISSUED 10/17/94 NRC SOLICITED AM RECEIVED PUBLIC COMENTS ON ITS ENFORCEMENT POLICY (INCLUDING N0EDs) OIG FINDINGS AW PUBLIC COMENTS %RE B0UWED BY THE REVIEW TEAM REPORT STAFF ADDRESSED THE REVIEW TEAM RECOMDIDATI0lls - SECY-95-078 AW NRC INSPECTION MANAL PART 9900 )
)
i REVIEW TEAM FI NI WS l MAJORITY (63%) 0F REQUESTS INVOLVED TEMPORARY C0 5 ITIONS. 37% INVOLVED- ' FOLLOW-UP TS AMEWMENTS. SMALL PERCENTAGE (11%) INVOLVED PLANT STARTUP SITUATIONS MOST N0EDS WERE PROCESSED IN ACCORDANCE WITH THE POLICY A M PROCEDURES. SOME INCONSISTENCIES odSERVED: N0EDS WERE ISSUED FOR TS REQUIREMENTS WICH WERE ALSO SPECIFIED IN REGULATI0llS OR CODES WITHOUT PROCESSING EXEN TIONS/ RELIEFS l N0EDS ERE ISSUED FOR WEATHER.RELATED EVENTS IN THE OVERALL PUBLIC INTEREST WHICH IS BEYOW THE RADIOLOGICAL SAFETY CONSIDERATIONS OF THE POLICY SOE N0EDS ISSUED FOR STARTUP SITUATIONS DID NOT MEET ALL 0F THE CRITERIA IN SOME CASES, WEN THE N0ED REQUEST WAS IN REVIEW PROCESS Am THE ALLOWABLE OUTAGE TIME HAD EXPIRED, THE STAFF DID NOT ENFORCE TS COW LIANCE 341
STAFF ACTIONS
STAFF FINDS N0ED POLICY TECHNICALLY SOUND. NO CHANGES NEEDED A ONS SU N C ,
(SECY-95-078)
PART 9900 GUIDANCE REVISED AND ISSUED JANUARY 5, 1995.
N RELA D N ON OM L E I E AND RE LAT NS
INISTRATIVE LETTER TO INFORM LICENSEES OF THE STAFF ACTIONS WILL BE

D N0EDS WILL BE POSTED ON THE ELECTRONIC BULLETIN BOARD ON A NOTICES OF ENFORCEMENT DISCRETION 24 -
22 - 20 - 18 - 16 - g 14 g 12 - 10 o ., .s . . M 20 30 4Q 10 2Q 30 4Q 1Q l 1993 l 1994 l 1995 l EISSUED 8STARTUP 342
l Printed on recycled paper Federal Recycling Program
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4. .
4 i i i i l l i ! IMPLEMENTATION OF REVISED [ SOURCE TERM AT OPERATING POWER PLANTS l l l l Regulatory Information i Conference i t } May 10,1995 i l l i : 1 1 I i
OVERVIEW OF PRESENTATION
Background
Implementation
- NEl Source Term Task Force - Process - Pilot plant applications Schedule Summary 2 .g.
i i l BACKGROUND l l NRC requeste NEl to coordinate industry's generic efforts (July 1994) NEl Source Term Task Force j i establishec (September 1994) ! NRC/NEl meeting to discuss concept of l generic framework document
~~

(October 1994)
NUREG-1465 published (February 1995) [ Action plan and schedule under { development l
- EPRI to develop generic framework document - Potential pilot plants and applications identified
i ! NEl SOURCE TERM TASK FORCE ! 1 j
i l Membership l
- Utilities (11) - EPRI - NSSS vendors (3) - Owners Groups (4) l 4 g l
i I
4 .
I PROCESS NEl Source Term Ta* sac NEl p9,
Accept generic
. Interface with NRC framew rk document + Review & comment on generic framework . Submit genen. . Issue SERs on pilot 4 y < >
document framework document iis (as appropriate)
+ Comment on pilot plant programs .
JL JL II V U EERI I " " " Develop genen,c Obtain technical framework document . Work m, parallel with ' - support , as required development of by utilities framework document Develop pilot plant specific analyses & applications 6,
APPLibATIONS UNDER CONSIDERATION BY PILOT . PLANTS Timing - Selective
- Containment isolation - Diesel generator sequencing l
L
- Spray initiation - Control room habitability Chemical form - Selective - Charcoal filter modification or ell'mination l - Spray additives l Chemical / Timing Combination - Dose analysis revisions c - Modify containment from sub-atmospheric to atmospheric i .
6,
( it .. l i l SCHEDULE 1 l Seek NRC staff comments on j implementation plan (early-June 1995) Finalize identification of pilot plants j . (early-June 1995) ! Submit generic framework document to [ NRC staff (August 1995) l Seek NRC staff acceptance of generic ! framework document (mid-October ] 1995) j Pilot plants actions in carallel with l framework-document development and acceptance (first pilot plant submittal L Fall 1995) j Seek NRC acceptance of framework l document (late-October 1995) ! - Pilot plants will directly seek NRC staff approval of ! submittals j. l 7 M'
_ _.y i l l i i
SUMMARY
e , i i: l l l l A generic approach for implementation l l of the revised source term is being : l developed i - NEl to coordinate industry generic activities i j Pilot plants will apply revised source i term i' - Pilot plant efforts will be in parallel with generic framework document developme'nt l NEl efforts to be completed by end of 1995
! - Seek NRC staff acceptance of framework document - Pilot plants will directly seek NRC staff approval of submit +als 6,
i. E Ei !
i ! PROPOSED T : l APPLICATION l
l. OFTHE l NUREG-1465 <
! SOURCE TERM AT : i NORTHEAST UTILITIES i ' l l l l l l i RAY CRANDALL l SUPV.- RAD ENG l MAY 10,1995 i
b. N SN:'M $2d I -- . - - _ _ _
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- u NEW SOURCE TERM NEW SOURCE TERM APPROVED FEB 1995 FOR ALWR'S NEl SOURCE TERM TASK FORCE WORK WITH NRC ON NUREG 1465 IMPLEMENTATION AT EXISTING LWR'S f
1 Nm s s <w is w
e em m j ~,
l i l e. 1995 NEl EFFORT l l i $ GENERIC FRAMEWORK l DOCUMENT l METHOD AND TECHNICAL l JUSTIFICATION l :) - TIMING ONLY - l - CHEMICAL FORM ONLY l - FULL IMPLEMENTATION i l PILOT PLANT i APPLICATIONS I \ ll l _t i t s- e
y m___ 1 SOURCETERMTIMING ! CURRENT T=0 RELEASE OF 100% NOBLE GAS 50% IODINES 4 1% SOLID FISSION PRODUCTS NUREG-1465 l l T=30 SEC RELEASE OF l 1 5% NOBLE GAS l j q 5% IODINE 5% CESIUM i T-30 MIN l l 95% NOBLE GAS l 22-35% IODINE l ; 15-25% CESIUM + OTHERS l [> L :- - - w w - - ' r
E . U i
. TIMING ONLY OPTION .l.
l SIMPLE TO IMPLEMENT
-USES CURRENT l
CODES l
-TECHNICALLY i
JUSTIFIED "
-FEW RELATED l lSSUES e
1
TIM.ING ONLY OPTION s WIN-WIN APPLICATION
1. IMPROVES SAFETY
-OPERATION OF SAFETY SYSTEMS ARE MECHANISTICALLY TIED TO TIME WHEN NEEDED
e

2. SAVES $$$
-OPTIMlZES DESIGN AND ,
SURVEILLANCE REQUIREMENTS
-ENHANCES CAPACITY FACTOR BY OPTIMlZING OPERABILITY REQUIREMENTS Ew s-g
9 l', E- d e= -_ E i TIMING ONLY OPTION i c s %; l PILOT PLANT DEMO 1995 q i i ! MILLSTONE 3 LOCA REANALYSIS t .
-CREDIT FOR SECONDARY l CONTAINMENT NOT NEEDED UNTIL 30 MINUTES l
i
- ELIMINATE COMPLICATED AUTO-INITIATION LOGIC OF SECONDARY CONTAINMENT HVAC -ELIMINATE DIFFICULT TO MEET SURVEILLANCES THAT PROVIDE NO SAFETY BENEFIT 1[mmner' N r s W E
n t _m TIMING ONLY OPTION 25g, ADDITIONAL NU APPLICATIONS SEYOND 1995
-DIESEL LOADING -CONTROL ROOM HABITABILITY -EEQ COMPONENT SELECTION -MOV CLOSURE TIME IMPROVES SAFETY IMPROVES ECONOMICS t A 4-4-4m e
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ONE HOUR SUPPLY OF AIR BOTTLES TO MAINTAIN POSITIVE PRESSURE IN CONTROL ROOM AUTO INITIATION FOLLOWING ONE MIN TIME DELAY UPON SAFETY : INJECTION SIGNAL- REQUIRED TO MEET GDC19 LIMITS BECAUSE
, OF INSTANTANEOUS PLUME
, UNLESS OPERATOR TAKES MANUAL f ACTION TO TERM!NATE, AIR SUPPLY EXHAUSTED IN ONE HOUR NO LONGER AVAIL.ABLE FOR MOST
, LiKELY TIME OF MAJOR CORE DAMAGE AND RELEASE ~
II mununchm<> F;Q
3_ y E EEQCOMPONEN"SEl.E0 TION v.c MANY COMPONENTS COMPLETE THEIR SAFETY FUNCTION WITHIN , FIRST 30 MINUTES 1 MANY OF THESE ARE IN A RADIATION-ONLY HARSH f ENVIRONMENT BECAUSE WITH INSTANTANEOUS SOURCE TERM, 30 MIN DOSE IS GREATER THAN 1000 RADS LIMITS COMPONENT SELECTION TO THOSE VENDORS WITH AN EQ QUALIFICATION PROGRAM. MAY PRECLUDE COMPONENT OF Bt.i i ER QUALITY OR MORE y IDEALLY SUITED FOR FUNCTION II sw<?mmmmm IB
#-y i
MOVCl.0SURETIME 4 SRP 6.2.4 - ISOLATION VALVES COMMUNICATING WITH CONTAINMENT ATMOSPHERE MUST CLOSE WITHIN 5 -
SECONDS OTHERS HAVE VARIOUS TIME REQUIREMENTS UP TO 1 MINUTE EXTENDED TIME COULD RESULT IN MORE RELIABLE VALVE AND ACTUATOR DESIGN 9
,y ,, -
Presentation to USNRC Regulatory Information Conference implementation of the Part 52 Licensing Process
- A Critical Year Ahead -
Ron Simard Director, Advanced Reactors Programs Nuclear Energy Institute May 9,1995 fi
The Strategic Plan for Building New Nuclear Power Plants , - Five Years Later - The goals of t7e alan are uncianged T1e sense of urgency remains T1e inc ustry commitment is as strong as ever Demoristration of a stable, predictable icensing 3rocess is a key arerecuisite 2 f,
The Requisite Regulatory Environment z A "precictaa e" icensing process for "
- design certification - early site approval - issuance of the combined license - construction and startup An o aerational rec ulatory framewor< that - protects public health and safety - provides NRC with adequate regulatory tools - gives licensees the flexibility needed to maintain economic competitiveness - meshes with the industry's approach to standardizing processes throughout a family of standardized plants
Pad 52
- The Foundation -
Early resolution of safety issues and certification of cesign features ITAAC to verify tlat the certified cesign gets built A discip ined hearing 3rocess
- Prima facie evidence an ITAAC was not met - resolution of any issues by fuelload ! - startup and interim operation if issues not resolved by fuel load 4
. Building on the Foundation

- The Near Term Challenges -
t l l T7e cesign certification ru es now out for pu alic comment - impacts on licensees i
- concerns with " applicable regulations"
- questions about " issue finality" The NRC construction inspection 3rogram and sign-off on ITAAC com aletion i

- the need for crisp definition of ITAAC completion
- the potential for hearings, possible startup delays COL conditions - the potential for hearings, possible startup delays i
t
Building on the Foundation
- More Near Term Challenges -
T1e interface between Part 52 licensing and "traditiona " Part 50 activities
- distinction between ITAAC and QA activities - verification of COL conditions, adequacy of licensee programs - role of the operational readiness review Bui ding on current uncerstancing o"t1e process and ceveloaing c ear documentation of im alementation c etails for the ultimate " customer" - future licensees and NRC staff
l. The Longer Term Opportunities to Create a New Operational Regulatory Framework A COL aaalication aac< age for eac1 .
alant in a family, with stanc ardized
- construction plans - operational functions and processes . - plans for maintaining the PRA - emergency response plans, ISI/IST plans, etc. - @50.59 process for evaluating / controlling changes in design and procedures across the plant family A 3erformance-basec framewor< that - reflects ALWR design features and safety margins - makes use of risk insights - meshes with the evolving regulatory framework 7 g
h ( b u i Benefit. s of MatrixTo. ol m
+L .Easyttoluse' / interpretL .
@n - l
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t
.: Improved awareness of relative risk - . . . _ .... __. .-.7 w
e e implementationLat PVNGS
+ LMatrixtintegratedhinto PRA strategy l
1
+ : Forma ntraining + Proceduralized + Configurationibeyond scope of matrix referred back-to: PRAi- to assess total / increased riskian'd appropriate uncertainty y
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c :. . N A OnlineiMaintenance: Scheduling
+ Em e rgent Iss.uesRWorkL . Eevelopf Maintenance Maitrix:: . LMatrix is based:oniCDFlandLpublici consequences .. . Us;e matrix to:assesstimpactioff Lemergent issues:/ work ,--mw,,,wy_,,,-, . - - - . - - - , . . _ _ _ _ _ . . . _ . . _ _ . . , - - - - - -_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ --
J
+
e Online Maintenance: Scheduling
+ : Planned .. Long; Range Maintenance? Plan . LOptimized basedLontriskL . Integrated resource: planning 1for!three units.
PVNGS Online Maintenance" Methods and Guidelines
+ Operation's responsibility to manage risk + Schedulers assess maintenance.
options
+ Management sets priorities and establisbes resource allocation
Palo Verde Nuclear Generating Station i On-Line Maintenance l z.
.c.:.. ~ ~
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[l -. , Bert Simpson
PV Maintenance Rule Status
+ Initial implementation on 4 MRule procedures + 32 of 34 Systems have data collected for the 1994 Monitoring Report + 5 of 34 Systems have been placed in (a)(1) poor performance category . Goals have been established for 3 of the 5 systems to improve performance + Respond to Nuclear Assurance Audit issues + 1995 priorities for development: . Computer Enhancements for Monitoring Performance . MRule Training
e April 1995 Program Audit Weaknesses:
+ Better documentation of decisions /
justifications
+ Integration of trending linked with System Engineering + OE consideration + Goal-setting process procedurally defined + Training and familiarization of site = . .
v April 1995 Program Audit Strengths:
+ PRA integration + Expert panel oversight + Performance Monitoring Program + Plant Condition Risk Indicator Matrix + 12-week schedule risk assessment + Early implementation for DGs
on-MR SSC's 53 Total # SSC's 124 Resource Non-Standby SSC's Allocation l
% of SSC's 40 10 %
4% Standby SSC's ~ _ 32% -12 20 % PV
~ Root q
10% ,-"~ g; . 30 % cause Mb N*'M Analysis l
<1 .m '40%_ '
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Work Mgmt System Equip Outage Eng. P ~aenance Sched. Mgmt ( ,n,- A N.# tA el
Palo Verde Nuclear Generating Station Maintenance Rule Project Status D
'T 4 _J_L - - j n . . E Bert Simpson
e v ie. ,,s :i cc c,. . , c,
. ,l " .:
Risk Management at PECO Energy M v PECO ENERGY . D. R. Helwig May 9,1995 i
Risk Management
. Is not risk minimization . Uses probabilistic and detenninistic insights . Can be accomplished today . Makes excellent business sense /
Specific Applications
. Outage risk management (ORAM) . On-line maintenance (Sentinel) . Reliability Centered Maintenance . Mod Design Evaluations . QA Program Application
The Future of PSA
, Regulatory threshold concept . More efricient regulation - . Effective resource utilization
_ _ _ _ _ - _ - _ _ _ _ _ - - a
1 P-d . NRC Regulatory Information Conference
! May 9,1995 a
Cm Life-cycle Standardization of Advanced Light Water Reactor Plants Pat Mcdonald - Executive Director Advanced Reactor Corporation i
,,, ,... N, ,,,, ,,,,,, ,,,,,,,,.,
4 Strategic Plan forBuilding NewNucler Powerplants F O U RT H A N NU A, U P D AT E 0 l e NOVEMBER 19 9 4 l l
Standardization Policy Statement
" Nuclear power plant standardization is a life-cycle commitment to the uniformity in the design, construction and operation of a family of nuclear power plants. Rigorous implementation of standardization is expected to achieve the efficiency and economy typically associated with '
increases in scale or breakthroughs in technology."
4
- i l !
l Benefits of Standardization ; ! i t i i 1. Early definition of requirements to ensure ! l regulatory stability and eliminate unnecessary ! changes.
2. Timely, systematic and thorough resolution of design, construction, operation and related problems.
l 3. Optimization of design to improve ! constructibility, reliability, operability and maintainability. l; : i 1 I. - -
l Benefits (continued)
4. More simple and uniform designs that are easier to construct and operate leading to more efficient and effective regulatory oversight and enhanced public confidence.

5. Focused and efficient application of technical and financial resources.

6. An expanded resource base that enhances support capabilities for design, manufacturing, construction, installation, inspection, testing, operation, maintenance and replacement of parts.

7. Maximized learning from past experience and accelerated experience feedback.
l _, Benefitsummary l All of the above benefits should make new nuclear plants viable, cost-competitive sources of electricity as well as contribute to safety.
EXAMPLE STANDARD FAMILY ORGANIZATIONAL RELATIONSHIPS l Licensees ! l l .
+ CNO__.
Chief Nuclear Officer Each i CNO w Family Support Bo ard Family Support <
] Operations Organization & > Maintenance y Facility s_
Engineering Q ] Admin Licensing Procurement NSSS* A/E* Functional Review / Approval
*As appropriate to support licensing, construction, and critical Committees (plant reps) plant startup needs. Additional involvement would be at the discretion of the !!censees and family support board
~ . i i
Conceptual Features of a Standardized Plant within a Family ' of Standardized Plants l i
a. is a member of a family of plants of the same 4
NSS model conforming to the " Utility Requirements Document" for Advanced Light Water Reactor Plants l b. has been licensed under the same Design l Certification. i
c. has been licensed under the same, standardized
< Combined Operating License (COL) requirements except those that are site-specific.
~
q t _ _ _ _ _ _ _ _ ____________._o
Features (continued)
d. has been built in accordance'with the same First-of-a-Kind Engineering except for site-specific requirements.

e. has been built with identical or near-identical products obtained with the same standardized procurement plan and its detailed processes (as updated / refined by conditions and experience).

f. has been built with the same standardized construction plan and its detailed processes (as updated / refined by conditions and experience).

g. has been started up with the same standardized' start-up plan and its detailed processes ( as updated / refined by conditions and experience).
Conceptual Features (continued)
h. is licensed and operated such that plant management is totally responsible and accountable to its licensed owner and/or operator for plant performance, including the accepted quality of services provided by the family support facility.

i. has the same organizational structure, with the same staffing and job descriptions and/or .
classifications. J. uses the same plans, procedures, work processes, plant and family configuration controls, training courses and etc. Eor administration, accounting, operations, design changes and etc. .
l Conceptual Featuret (continued)
k. utilizes a common procurernent systern and inventory of parts and snaterial for those goods and services determined by the family to be cost effective, as part of the services provided by the Family Support Facility.

1. utilizes a Family Support Facility which is assigned work functions for each plant that do not have to be done on site.

m. utilizes the Family Support Facility for services and information relative to any and all plants in the family for optiinizing operational, financial and other aspects of plant performance.
j .. . . l i r l Features (continued) 1 i ) i i j n. cooperatively participates in the steering and 4 oversight of certain specific activities of the Family Support Facility such as development and maintenance of plans, procedures, work processes and etc. r i i ! t i i i i i i I i I
i l
Conclusion Costs, Economics, and Investor Protection are the driving forces toward this conceptual model of life-cycle standardization G
i nimum i
U.S. NUCLEAR REGU 1995 REGULATORY INFORMA1 MAY 9-COMMISSIONER COMMISSIONER
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q* Ival Shirley A. Jackson
Kenneth C. R0gers DEPUTY EXECUTIVE DIRECTOR FOR NUCLEAR MATERIALS EXECUTl SAFETY, SAFEGUARDS, ANDOPERAll0NS SUPPORT FOR0 Hugh L. Thompson, Jr

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STORY COMMISSION bN CONFERENCE SPEAKERS ,1995 MAN COMMISSIONER COMMISSIONER
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in E. Gail de Planque Vacant 1ECTOR DEPUTY EXECUTIVE DIRECf0R FOR NUCLEAR REACTOR N8TbO 10NS REGULATION, REGIONAL OPERAIl0NS, AND RESEARCH A bb7(j[qg g so CARD w.4, g lylor James L. Milhoan* .-- .I R TOR R U 180N OF E C ENT 0 RA AL DA A F VESTIGATION ES RC
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.....# f i "' / ' M $0h l Office of Pubile Affairs Washingion, D.C. 20555 Remarks by Ivan Selin, Chairman United States Nuclear Regulatory Commission before the Regulatory Information Conference The Holiday Inn Crowne Plaza Hotel Rockville, Maryland May 9, 1995 The Future of Reactor Regulation Good morning. I am pleased to be here today to take part in the seventh Regulatory Information Conference. This conference continues to provide a unique forum for the NRC and all its reactor licensees to exchange views on regulatory issues. We value this opportunity for open communication as a key to our common successes. At the end of my presentation I would be happy to address any questions you may have.
I would like to share with you my view of the future of nuclear reactor regulation and the industry's key role in shaping this future, in light of four factors which shape it: first, a shift in the NRC's regulatory activities; second, government-wide initiatives toward agency efficiency and streamlining regulations; third, the shift from prescriptive regulations to performance-based regulations; and, fourth, the industry's role in this changing environment. CHANGES IN LICENSING ACTIVITIES Let me start by discussing the +.iture of NRC licensing activities. When I appeared before tnis audience two years ago, I said we could see the light at the end of the tunnel for advanced reactor design certification. Now I believe we are about to exit that tunnel. Years of NRC effort are coming to an end with the final design approval and initiation of the design t certification rulemaking process for the CE System 80+ and GE Advanced BWR evolutionary reactor designs. Design certification efforts for more revolutionary reactors have experienced delays, and exotic reactor designs are no longer being considered. At the same time, Watts Bar 1 is likely to be the last reactor to commence operation in this decade. This fact reflects today's economic reality of competition in electricity generation, which
discourages all long-range capital projects, such as completion ' of deferred reactors or new reactor construction. As a result of these factors the NRC will soon find itself without significant resources committed to reactor design review, construction inspection, or initial plant licensing. Instead, licensing activities will be driven oy issues of aging of operating reactors, licensing basis improvements, license renewal, and decommissioning. I anticipate that both old and new aging issues will continue to require significant regulatory attention. Recent experiences at Maine Yankee have taught us that even a well understood aging issue such as steam generator tube cracking can continue to require significant NRC and industry attention. At the same time, new aging issues, such as BWR internals cracking, will surface and require evaluation and corrective actions to support continued operation. It is clear to me that the we and the industry must improve our cooperation in order to anticipate and resolve such emerging aging issues. We also will continue to respond to licensing issues arising in operating reactors. T believe our Cost-Beneficial Licensing Action program is a magar success, and one which industry should continue to support and utilize. Additionally, we continue to work with industry to provide generic guidance for licenseo commitment management and to provide specific relief from commitments which have no safety benefit. A top priority in licensing will continue to be Standard Technical Specifications. We encourage licensees to take advantage of this program which offers enormous cost savings and other standardization benefits. I believe licensees frequently underestimate the benefits of this option because their analysis is too narrowly focused on implementation costs. Adopting Standard Technical S'acifications is not only a question of direct financial benefits to on-site organizations -- they also allow NRC project management resources to be reduced, resulting in savings that are passed on to licensees in the form of reduced license fees. Additionally, Standard Technical Specifications will permit many facility changes to be accomplished under 10 CFR 50.59 without prior NRC approval and without the need for license amendments. Finally, Standard Technical Specifications offer the NRC the possibility of a more consistent approach to inspection and compliance. When all these factors are considered, I believe adopting Standard Technical Specifications becomes en excellent licensing decision, and I urge more licensees to take advantage of this opportunity. One of our most significant accomplishments in the last two years has been the license renewal rule. I believe that the NRC has succeeded in clarifying the rule and making license renewal a workable alternative for the industry. We now stand ready to work with interested licensees toward implementation. The devil 2 I
is in the details, but I believe that we have managed to' define
the scope of the details clearly enough to make license renewal a viable option. I hope that those who have been discussing renewal efforts with us will now come forward and seriously consider filing an application for license renewal. The revised rule allows the nation to reap the full benefit of existing nuclear power plants uhere the economics are favorable, with due regard to public health and safety.
GOVERNMENT-WIDE INITIATIVES Certainly, the last two years have brought major changes in the federal government, and along with them, a drive for regulatory efficiency. The NRC was working with industry to streamline regulations before streamlining became fashionable, and the staff has done an excellent job in identifying and implementing improvements. However, though our progress on site-specific measures has been significant, many opportunities remain available to make generic improvements in the way we regulate reactors. Today, we find ourselves being encouraged by our country's leadership to cvercome past obstacles and move rapidly forward. Congressional initiatives to change the legislative basis for regulatory actions havc been numerous and potentially far-reaching. If these legislative proposals are enacted, the NRC may have to change significantly the way we conduct business. Meanwhile, the Clinton Administration has continued its own reform initiatives in the form of the National Performance Review, Phase 2. The focus of this review is twofold: first to reduce unnecessary regulations, and second, to improve relationships between the regulators and regulated entities. The NRC, committed to full participation in these initiatives, has established a steering committee to guide the < staff in implementing the President's directives. The first part of this effort, a review of existing regulations, is nearly complete; the results will be presented shortly to the Commission. Other parts to follow include functional and efficiency studies. In connection with NPR Phase 2, the President has specifically asked Federal regulators to meet with those affected by their regulations. We hope that this conference will be one of many sources of ideas on how the NRC can be a more efficient regulator. The NRC is serious about embracing these efforts and moving to make substantial progress in streamlining regulations and improving our relationship with industry. We need to deliver on promises already made, as well as looking for new ways to reduce the cost and burden of unnecessary regulations, t But moves to reform regulations are driven by efficiency efforts, not by safety concerns. Our current regulations, prescriptive though they may be, have proved effective in protecting public health and safety, and would continue to do so 3 l _____--__- )
without reform. Therefore, although there is a benefit in these reforms, it is not a health and safety imperative, and the NRC does not have the authority to impose them on its own. Furthermore, as we pursue regulatory reform, we will insist that it be accomplished without compromising our past successes in operating reactor safety. PERFORMANCE-BASED REGULATION Today, NRC has two types of regulatory initiatives: new issues originating from operating experience or aging, and the rewriting of existing regulations for improved industry or NRC efficiency. In both cases I see the thrust of reform initiatives as focusing regulations on issues important to safety. The whole range of programs such as PRAs, IPEs, and performance-based regulations have that same core goal. Our future direction and challenge lie in ensuring that both new and old regulations have this safety focus. In revising existing regulations, the industry must keep in mind that these changes are not a backfit of regulations to meet safety needs. Rather, they are an effort to improve efficiency and economy, and, more broadly, to simplify the licensees' job -- therefore they rely on industry leadership and cooperation for c success. When we discuss performance-based regulations in this context, we admit that we have learned that it is inefficient to define safety standards via detailed, prescriptive rules, because that approach often leads to plant-specific requirements that are not important to safety. To be efficient the industry and the NRC must instead use our knowledge of what is important to safety in order to develop rules which set the desired safety goals. Then we can work together to define acceptable ways to meet these goals while allowing licensees the freedom to define specific methods for-achieving them. The maintenance rule is an excellent example of new rulemaking using this performance-based regulatory approach. Recognizing that our regulation of plant maintenance was deficient, we developed a simple rule requiring licensees to set goals and to establish programs for maintaining safety system reliability. Then we proceeded to work with industry to define acceptable ways to meet these goals published in the form of a Regulatory Guide. We are now seeing that licensees with good maintenance programs can satisfy the new requirements with only minor changes. I believe the rule will achieve its goal to ensure that effective maintenance programs are in place to protect public health and safety without being overly prescriptive as to the nature of those programs. A more recent example is our performance-based containment leak rate testing rule, which has been published for public comment. In drafting this rule the NRC sought to avoid being overly prescriptive by allowing licensees relief from specific testing requirements which did not add to plant safety. 4 D _ _ _ _ _ - _ _ _ _ - _ _ - _ _ _ . _
9 Many of you, I am sure, would like to jump in to sta'te that the proposed shutdown rule was inconsistent with this philosophy. I would agree that the originally proposed rule was too prescriptive and not properly focused. But the weaknesses in the original proposal do not mean that no rule is needed. Repeated industry operational events demonstrate clearly that this is an important safety issue warranting regulatory attention. In sum, the need for a rule is clear; its form will ba appropriately addressed. I assure you that we will work w! industry to revise the previously proposed rule to ensure . hat any new requirements emphasize safety and are not inappropriacely burdensome. I expect that we will continue to pursue performance-based approaches to regulations. We are in the early stages of revising our fire protection requirements to make them performance-based. The industry has initiated action in this area through a Nuclear Energy Institute petition for a new performance-based fire protection rule. Although we have some concerns about the NEI proposal, we welcome the initiative and encourage communication on this issue from industry. In response to the petition thc staff has shown a willingness to broaden their activity to include the possibility of placing both the current Appendix R and new performance-based guidelines into Regulatory Guides. This would leave in the regulations only the original fire protection rule with its high-level programmatic requirements. Along with these individual regulatory initiatives, we have addressed the regulatory process. We have moved to improve the way new regulations are generated internally, to ensure that rulemaking proposals and their expected safety benefit and costs are identified early to senior managers and to the Commission. This will help ensure that the NRC's limited resources are expended on rules that have the most safety benefit, and that staff resources are not wasted developing rules that the Commission will not approve. These are the areas that represent the future of reactor regulation in an efficiency-oriented environment. But they do not represent the limit of what we can do in reforming regulations. I urge you to work with us to implement these existing initiatives and to identify additional areas for regulatory reform. At the same time our inspection activities also have to evolve to ensure that we are focused on issues important to reactor safety. We now have several new initiatives underway to improve the focus of inspection activities on items important to reactor safety. First, we are completing a broad review of our enforcement policy and are taking into account comments from the public in general, including many from industry. This review has identified some areas where our attention has not been sufficiently focused on safety. I anticipate that we will be 5 _ _ _ _ _ _ . 1
f changing and clarifying how we handle compliance issues w'hich are of low safety significance. Additionally, we are looking to simplify the use of escalation and mitigation factors in enforcement to ensure that appropriate credit is given for licensee identification and correction. I anticipate Commission approval for a trial implementation beginning this summer of a revised enforcement policy. Performance at operating reactors is, lar and large, excellent; we wish to keep it that way. To this end the NRC is working in parallel to sharpen its tools for early warning of declining performance at individual plants. We have identified a need for better integration of our separate inspection findings, for early identification of safety concerns. We can help licensees to correct them before seriouc performance problems develop. In support of this objective, senior managers are working to strengthen the process by which we review plant performance periodically and plan future inspections. Additionally, the agency has initiated a new inspection activity: the Integrated Performance Assessment Process. This process is planned to provide an infrequent but detailed review of all aspects of a licensee's performance. Facility operational reporto and data, inspection results, and self-assessments will all be used to formulate an accurate picture of performance. Then, the results of the IPAP will be used to revise long-range inspection plans. This process should help ensure that inspections are focused on safety-significant activities and on areas where attention may be required to avoid future programmatic problems. These new initiatives for early identification of declining performance are also important in light of the changing economic environment. We have a legitimate concern that competitive economic pressures may drive utility management -- individually, not across the board -- to cut corners or not make financial investments necessary to maintain equipment and organizations in top shape. These new assessment tools will allow us to spot incipient problems and will give us more lead time to focus on troubled plants before performance deterioration threatens public safety. THE INDUSTRY'S ROLE Now I want to turn to the industry's important role in the future of reactor regulation. I am confident that everyone here recognizes that industry has been an essential partner with the NRC in protecting public health and safety. The industry has done many things extremely well, and this performance record should be continued. For example, looking at performance indicators, I cannot help but be impressed with all that industry has accomplished, such as reducing plant scrams and transients, man-rem reduction, and radioactive effluents and waste. 6 l
i In the future, the success of a performance based ap'proach to regulation will depend a great deal on active industry participation. Unfortunately, I have recently become concerned about what I perceive to be a lack of industry leadership or coherent response to some of our regulatory initiatives. Recently, on several issues where the NRC had a legitimate safety concern, industry's reflexive reaction appeared to be an attempt to stop or delay any NRC action without seriously examining the validity of the concerns. Although I earlier alluded to the NRC's false start in developing the shutdown rule, industry's role in this area was also deficient. Industry leadership has insisted that new requirements were unnecessary and that voluntary industry initiatives were adequate, in the face of continually occurring shutdown events that have provided stark evidence to the contrary. Had industry accepted the existence of r problem and worked with the NRC to develop a performance-based .egulatory approach, successful resolution of this issue would have been much easier to achieve and would likely now be behind us. Severe accident management provides another example of an area where a lack of strong industry leadership has contributed to unnecessary delay. Since the late 1980s, the NRC has attempted to work with industry to ensure that severe accident guidelines are developed and exercised at plants. Industry representatives have consistently argued that this should be an industry-initiated effort, and we have accepted such an approach. However, nearly a decade later, we still do not have definitive severe accident guidelines in place, due in part to industry's reluctance to acknowledge the legitimate need for the NRC's involvement with regards to inspections. By contrast, the maintenance rule again is an example of what can be accomplished if industry works with the NRC to develop a performance-based approach to implementing a new rule. One key to success was early acknowledgement from industry that they benefited from cooperating in defining how the role could be implemented. The license renewal rule is another example of a significant improvement in the regulations that was accomplished when both the industry and the NRC recognized the need and worked together to accomplish changes. As I suggested earlier, a related area in which the industry must do better,is in anticipating generic problems and in solving thc= cnrly ' This need will become more acute as the universe of regulated reactors gets older and new generic aging issues emerge. Motor-operated valve issues were initially poorly handled by the industry and stand as an example of how we should not deal with emerging issues. When confronted with the problem, the industry's response was to deny its existence without investigation, forcing the NRC to spend much time and resources to prove the problem's existence. We were often limited in our ability to scope the problem accurately without industry 7
cooperation. Later, when the NRC was able to prove that its concern was valid, both of us found ourselves in a position where a safety issue had been known for several years, but corrective action had not yet been taken. A similar pattern has sometimes been seen in the way the industry has handled steam generator tube issues and BWR level instrument problems. When generic problems such as these are not promptly and fully addressed, both the NRC and the industry find themselves under justifiable criticism. Additionally, unnecessary financial and organizational resources are often required to deal effectively with such long-festering problems. On the other hand, the problem of cracking of BWR internals stands as a positive example of industry and NRC cooperation in a generic problem. I believe the BWR Owners' Group was appropriately aggressive in reviewing the issue, defining the problem, planning corrective actions, and implementing repairs. As a result, this safety issue is being addressed effectively by licensees working together through owner's groups and with us as regulators. Both the NRC and the industry must continue this approach on future generic issues: anticipate the problem, determine its scope without delay, and provide quick and effective solutions. In closing, I want to emphasize that since I last spoke with you two years ago, the NRC and the industry have both accomplished a great deal in focusing the reactor regulatory environment on issues that are truly important to safety. I believe the NRC staff deserves credit for its hard work and substantial progress in improving the way the agency does business. Also, I would like to commend you, the reactor industry, for your efforts to assist us in identifying certain problems and proposing solutions. But, as I have said here today, the changing licensing environment and the external political environment are both impelling us toward further regulatory reforms. Most of these reforms will take the form of performance-based regulations which are needed, not for safety but for efficiency. The success of these initiatives in establishing a clear, safety-oriented regulatory environment will depend in a large part upon industry support. Industry leaders must work more closely with us to reform existing regulations and must improve in early recognition of emerging generic problems and in prompt generation of solutions to those problems. Conferences such as this one can contribute much to further progress in these areas. I would like to encourage industry representatives here to be candid in your discussions and innovative in your suggestions, and I would like te 5911enge the NRC staff here to listen carefully and be receptive .hange. I wish you all a productive and effective next two days, i 8 l
o . .. O I would now like to use the remainder of my time to' answer any questions you may have. 9
o. 4 GETTING OUT IN FRONT PRESENTED DY COMMISSIONER KENNETH C. ROGERS U.S. NUCLEAR REGULATORY COMMISSION AT THE NRC REGULATORY INFORMATION CONFERENCE HOLIDAY INN CROWNE PLAZA ROCKVILLE, MD MAY 9, 1995 1Diroduction Good afternoon, ladies and gentlemen. I am pleased to be here with you on the opening day of the 1995 NRC Regulatory Information Conference. This is not the first time that I have had the pleasure to speak to you after you have had a satisfying lunch. I hope that the remarke I make will not be too hard to swallow and not cause you any more indigestion than they have in the past. I am pleased to see that this series of regulatory information conferences continues to engender so much serious interest. I believe that the NRC, industry and the public can, and indeed do, interact in a mutually beneficial and respectful manner. This is evidenced by the success of meetings such as these, the various public workshops that have been held, the cooperation on new regulatory initiatives such as cost Beneficial Licensing Actions and the Maintenance Rule, and the implementation of improved electronic communication, among others. One of the primary means for fostering improved cooperation is for the NRC to be totally open in our regulatory actions and to obtain early input, from both industry and the public, before getting locked into a hard and fast position. This is what I call "Getting Out in Front." We are, and have been, following this philosophy for quite some time; both in the regulatory decision making process as well as in the actual regulatory positions that are being developed and promulgated. Furthermore, this approach is consistent with the directives recently announced by President Clinton and Vice President Gore on February 22 of this year; in particular, the two directives to "Get out of Washington - create grass roots partnerships," and
" Negotiate, don't dictate."
With regard to openness, it is an essential element in ensuring our independence from external pressures by special interests and in maintaining the confidence of the public. There must be a high degree of openness in our regulatory processes and i
. o i
2 . the means we use to come to definitive conclusions. NRC is a very open agency and the nuclear power industry is one of the most open of all U.S. industries, but there is room for improvement. There are some on the NRC staff who resist being as open as possible and there are some industry leaders who find it difficult to expose themselves and their organizations to attacks from partisan groups which they fear will be the consequence of an open policy. I continue to hold the opinion that paradoxically, openness is a much more protective shield than concealment. The public needs to be constantly reassured that we and the industry we regulate are acting straightforwardly. Openness from the very beginning is the best way to earn and maintain necessary credibility. I would like to describe some of the instances where we have attempted to "get out in front." Where we have tried to either:
1. Gather input from the various interested parties prior to establishment of an NRC position; or

2. Develop requirements that would ensure that the public is provided both early information and the opportunity for substantial input and comment prior to NRC or licensee actions taking place.
LICENSE RENEWAL RULE A prime example of the NRC getting out in front is how it approached the license renewal rule. The impetus for the rule was not because there were a large number of license renewal applications in hand, but, to provide a viable option for both industry decision-makers and public utility commissions. The concept was to allow them to be able to decide whether or not it would be economically and technically justified to renew plant operating licenses, it was necessary to establish clear and unequivocal technical requirements for license renewal. We thought we did this when we issued a final rule that went into effect ir January, 1992. But it scon became apparent we did not. In developing a regulatory guide and standard review plan; in interacting with lead plant licensees and the Nuclear Energy Institute (NEI); in convening a public workshop with industry and government representatives; and in holding numerous internal NRC management reviews, it became evident there was room to make the renewal process clearer and easier to implement. Furthermore, it was concluded that greater advantage should be taken of existing licensee activities and programs and that we should rely more on the benefits derived from implementation of the Maintenance Rule. I assure you we listen carefully, and when we see how we can improve, we do so. We have just approved a revision to the license renewal rule that we expect will resolve ambiguities in interpretation of the existing rule and establish a more efficient, stable, and predictable license renewal process. If l
,. 3 you attended the breakout session this morning you know all about it. If not, you can read the full text-on the NRC's bulletin i board system on Fedworld which can be accessed either over the Internet or directly with a modem. Talking about getting out in front, I understand the rule appeared on Fedworld almost simultaneously with the Commission's final review of the notice of rulemaking. Possibly even before, but don't ask me how. I don't want to know. I should add, as an aside, that the rule was published in the Federal Reaister yesterday in all its glory. The basic principles and philosophy of license renewal, as espoused in the original rule, continue to be retained in the revised rule. There will be absolutely no relaxation of safety standards during the license extension period. The license renewal requirements are intended to supplement the existing regulatory oversight processes to provide sufficient assurance that adequate safety will be maintained during any period of extended operation. The rule establishes the safety criteria on which a determination can be made that if the plant continues to operate after the initial licensing period of 40 years, that it will continue to operate safely, The focus of license renewal is on mitigation of the detrimental effects of aging on the ability of systems, structures, and components to perform important safety functions during any period of extended life. The decision on whether or not a plant should attempt to obtain a license extension will be based on a number of factors including the physical condition of the plant, the ability to ' operate safely, and the economics of power production. The economics issue is not something the NRC considers in the context of license renewal. Decisions about the appropriate energy mix and costs of electrical generation are weighed by state regulatory agencies, not the NRC. DECOMMISSIONING OF NUCLEAR POWER REACTORS Another example of where we are trying to get out in front involves the requirements for decommissioning nuclear power reactors. A proposed rule is intended to clarify the applicability of certain regulations to permanently shutdown nuclear power reactors and provide for public participation in the process. The new rule would codify practi es that the Commission has approved for use by licensees in ongoing decommissionings. There appear to be three distinct phases of decommissioning that must be addressed. The first phase covers permanent cessation of power production operations, public notification, early plant modifications, and on-site rearrangement, packaging and removal of components and waste prior to entering SAFSTOR < status. This phase includes the licensee's early component removal program, if any, during which plant structures, systems,
4 . and components may be removed and shipped off site, as allowed by S50.59 and other regulations. The duration of this phase is probably measured in months or, in some cases, a few years. The second phase would be when the facility is in the SAFSTOR mode with little on-site or off-site activity other than monitoring of systems required to maintain SAFSTOR, e.g., Spent Fuel Pool cooling systems. This phase will probably last for years or even decades and its duration will depend upon the availability of low level waste sites to accept waste materials from plant dismantlement at a feasible price. If the licensee chooses to proceed to final decontamination and license termination shortly after completion of the first phase, the second phase could be compressed, but would probably still be dependent on the availability of suitable radioactive waste sites. The third and last phase would cover the period after the licensee commences the final steps to complete decommissioning and would involve complete dismantlement of the plant, and termination of the license. This would include cleanup of the site or permanent entombment of the plant and reassignment of the remainder of the site for other purposes. This phase is probably measured in months or years. This final phase will require a license termination plan somewhat similar to that currently envisioned and described in 10 CFR 550.82. However, during this phase, we plar to include a provision for the opportunity for a public hearing on the termination plan. This hearing would be held under 10 CFR Part 2, Subpart L, a so-called Subpart L hearing. These additional requirements appear justified in view of the significant time delay that may conceivably occur between the time that the licensee completes major component removal activities and enters 4 SAFSTOR phase and the time when final decommissioning activities resume. In addition, there is the likelihood, because of this time delay, that the licensee's staff will consist of many new operating and engineering individuals, if not an entirely new organization, and new engineering and decommissioning techniques may have become available. As you may recali, I indicated that there would be public notification and participation during the first phase. This is another example of "getting out in front." During the first phase, we're proposing that the licensee would be required to submit a preliminary report, called a post-shutdown decommissioning activities report, or PSDAR, that would describe the planned decommissioning activities, a schedule, estimated costs, and a discussion of the envirtamental impacts. We propose to make the PSDAR available for public comment and will hold a public meeting in the vicinity of the reactor facility site to discuss the licensee's plans. Major decommissioning activities
5 would not commence until about 30 days after the public meeting.
By this technique, we hope to ensure that the public will be fully informed and will be able to make its concerns known before rather than after decommissioning starts. We also propose to provide the opportunity for an informal Subpart L hearing on the termination plan during the final phase. This is appropriate for a permanently shutdown facility where the fuel has been removed from the site, since the facility would be similar to a nuclear materials site that typically uses subpart L hearings for license amendments. We are also considering requiring a full public meeting to be held when the license termination plan is received. I expect that this proposed rule will be issued for public comment within the next few weeks and we will be looking forward to your comments. Radiolocical Criteria for Decommissionino Probably the foremost example of "getting out in front" is the enhanced participatory process the Commission has followed in developing a proposed rule on radiological criteria for decommissioning. Rather than proceeding as we have in the past, the Commission decided to obtain early public input well before a formal position is established and " locked in". The staff conducted a series of seven workshops throughout the country to obtain comments on scope, issues, and approaches that must be addressed in establishing radiological criteria for decommissioning. A dcdicated electronic bulletin board system was also created to disseminate information and obtain comments on the rulemaking. Finally, a series of eight public meetings were held in four cities during which comments were obtained on the proposed scope of the generic environmental impact statement supporting the rulemaking. An additional period of public ' participation was provided during an early stage of rule development when copies of a draft rule and summaries of comments were sent to the NRC agreement states, workshop participants, and - other interested parties. The workshops and meetings proved _to ! be of great value, to both the NRC, industry, and the public, f Without going into the details of the proposed rule, which would apply to most of the NRC licensed facilities, let me say I that the requirements will be significantly affected by the lessons we learned during the public meetings. Many of the n participants, including the NRC staff, altered their views [ through the-course of the meetings. The enhanced participatory : process pointed out the real value that can be gained by "getting l out in front" and addressing concerns before being locked into ' what might prove to be an untenable position. . 5
6 . Thermal Annealino of Reactor Pressure Vessels Last October the NRC issued for comment a proposed rule on fracture toughness requirements for light water reactor pressure vessels. Part of the proposed rule provided requirements for the thermal annealing of a reactor pressure vessel to restore the reactor vessel which had been degraded by neutron irradiation. Without delving into the details of the thermal annealing rule, one of the major issues the Commission has considered with respect to the rule is the nature and timing of public participation related to the NRC's review and approval of the licensee's thermal annealing plan. This significant new activity has caused the Commission to spend a great deal of time trying to decide the best way to inform the public about a new issue. This can be done with either informal hearings or public meetings or by formal hearings under the Atomic Energy Act. There are several circumstances where there could be the opportunity for a formal hearing under the Atomic Energy Act during the NRC review and approval process. This could occur when NRC approval is needed either: e For the thermal annealing plan prior to implementation;
If the annealing necessitates a license amendment or there is a violation of a technical specification; or e If the licensee cannot meet the new reactor vessel performance criteria.
The Commission has some question regarding whether the Atomic Energy Act requires a hearing. Therefore, the Commission is considering four different alternatives and has requested public comment. The alternatives are:
1. No opportunity for hearing is required under the Act since a determination of approval will be given by the Director NRR, and hearings are not routinely offered in this type of situation.

2. Discretionary opportunity for hearing since the Act does not require a hearing, but there would be a case-by-case determination by the Commission of whether or not there would be a hearing.
Under these first two alternatives, neither implementation of the annealing plan nor resumption of operation, once approved by the NRC, would be contingent upon cumpletion of any hearing.
3. A hearing is required under the Act for NRC approval of both the thermal annealing plan and the resumption of operation.
l
. 7 The annealing plan could not commence until the hearing is concluded unless the NRC makes "a no significant hazards determination."
4. Modify the proposed rule to require the suspension of a license prior to thermal annealing. Since the license was suspended, the licensee would anneal its reactor vessel without prior NRC approval. After the annealing is completed, the licensee would have to demonstrate that the annealing addressed the reactor vessel embrittlement such that it was acceptable to operate the plant. There would be no opportunity for a hearing under this alternative.
We are now in the process of reviewing and evaluating the comments on the thermal annealing rule. But whether or not there is a requirement for a formal hearing, we anticipate there will be informal hearings or public meetings to permit discussions of both the thermal annealing plan and the technical issues involved. These meetings will be announced in the Federal Reaister and held near the reactor site, as is expected to be done under the nuclear power reactor decommissioning rule. Conclusion I have mentioned only a few of the more significant issues where the NRC has tried to get out in front. We are actually taking this approach in many activities and find that it serves to defuse problems before they mature. By being totally open with industry and the public and by ensuring that everyone is informed we hope to achieve quicker resolution of significant issues. I am very pleased to have had this opportunity to be with you this afternoon and to discuss with you an aspect of regulation that I think is extremely important. As I said before, I believe thht this series of conferences provides a very worthwhile and necessary function and I know that they will be continued in the future. Not only do these meetings bring you up to date on the current nuclear regulatory issues but they also provide a valuable forum for the exchange of ideas and the opportunity for each of you to get to know us better. Thank you for your attention. Now I would be happy to respond to any comments or questions you may have.
, . 6
,o RISK ANALYSIS AND THE RETURN TO COMMON SENSE Dr. E. Gail de Planque, Commissioner U.S. Nuclear Regulatory Commission presented at the USNRC Regulatory Information Conference Rockville, Maryland i May 9,1995 I. Introduction l Today, I would like to speak to you about a subject which has in recent years assumed center stage in the debate over how government regulators ought to regulate; namely, the extent to which regulatory decisions should be based on a particular mode of regulatory decision-making called risk analysis. My talk is intended to respond to the complaint, voiced by many, that too often regulations make rio sense and actually inhibit the goals they are designed to achieve. For reasons which I hope will become clear, I view risk analysis as an extremely valuable tool which, used appropriately, can restore common sense to regulation and thereby hopefully re-engender the confidence of the American public in their government. II. The Death of Common Sense First, though, we need to understand the problem. It is clear that a broad segment of the public believes that we are over-regulated, a sentiment most often expressed in the phrase "get-the-Government-off-our-backs," and that the way to cure this is through extemivo de-regulation. It also seems clear that many believe that even where regulation may be warranted such as in the fields of health and safety and environmental regulation, our priorities are skewed. Resources are misdirected to minor problems in such a way that the costs of regulation do not justify the benefits to be derived. At the moment, this anti-r.gulatory movement may be focused on Federal Government bureaucracies in Washington, but in actuality it extends to State and local regulators as well. Two authors have recently provided excellent capsule summaries of the regulatory climate which has ushered in the present anti-regulatory mood. Philip Howard in his 1994 book entitled The Death of Commo1 Sense: How Law is Suffocatinn America,8 gives a variety of examples of how red tape at all levels of government puts a stranglehold on the actions of individuals and companies, including no less a personage than Mother Theresa herself. It seems, according to Mr. Howard, that her order of sisters wanted to convert two fire-gutted buildings in the South Bronx into a homelesi selter. Although the sisters spent more than a year navigating the New York City bureaucracy and eventually obtained the necessary permissions, their plans were ultimately sunk by a requirement that a renovated four-story building have an elevator even though the sisters, for religious reasons, would never have used it and did not think it an appropriate expense. The bottom line-the homeless were deprived of a shelter altogether. Mr. Howard's general thesis is that regulatory requirements have become so detailed and inflexible
' Philip K. Howard, The Death of Common Sense. New York: Random House,1994.
Risk Aclysis aid the Return ts Commes Sense Dr. E. Gall de Pinque, NRC Cem:21ssio::r that regulators cannot make use of common sense to devise regulatory solutions to real life needs and problems. He second author, Stephen Breyer, no e Justice Breyer on the Supreme Court, focuses particularly on the problem of skewed priorities. His 1993 book Breakinn the Vicious Circle: Toward Effective Risk Regulation: asks whether it makes sense to spend enormous sums of money to reduce environmental dangers which pose minimal risk. This problem arises when regulations that are originally sought to reduce risks that most people would consider unacceptable are ultimately made so unnecessarily stringent that large amounts of time and money must be expended to remedy the last little bit of environmental harm even though no significant safety benefit will result. He refers to this as the problem of the last 10%" and gives, as an example, a lawsuit involving hypothetical dirt-eating children in New Hampshire. The case involved a private party trying to avoid the expenditure of $9.3 million dollars to clean up the last remnants of a toxic waste dump. The property had already been cleaned up to the point that the waste dump was clean enough for children playing on the site to eat small amounts of dirt daily for 70 days each year without sigidficant harm. The additional cleanup which was being required would enable the children to get their daily dose of dirt for 245 days. Ironically, the actual site was a swamp so there were no dirt-eating children around in any event. His example illustrates a common regulatory problem: at what point does it make sense to say that a given level of risk is acceptable because it does not make sense to expend further resources on the problem. Judge Breyer's broad concern is that there is a " vicious circle" of "public perceptions, Congressional actions and reactions and technical regulatory methods [which] reinforce each other ... diminishing public trust in regulatory institutions and thereby inhibiting more rational regulation."2 In sum, these two books bespeak a public plea to all regulators to return to common sense as a basis for regulation. While one can argue about what the anecdotal evidence employed by these authors proves, I think it is fair to say that much of the public shares their perception that greater common sense in government regulation is needed. 2 Stephen Breyer, Breaking the Vicious Circle, Cambridge: Harvard University Press,1993. 81d at 33. Regulatory Information Conference 2 May 9,1995
Risk A= lysis cod the Rettre 13 Ccam:c Sense Dr. E. Gail de Pla q!e, NRC Cc:2=lssioner III. What is Risk Analysis, or Risk Based Decision-Making? As I have indicated, I view risk analysis, or risk based decision-making, as a way to reincorporate common sense into the regulatory process. This mode of decision making can be divided into at least three distinct components: risk assessment, selection of an acceptable risk level, and risk management. Each of these is important and I want to briefly describe each step. It is also important to note at the outset one other aspect of risk analysis: each of these steps involves an intermix of science and value judgments. It is in the value judgments part of the mix that the " reality check" of common sense ought to be given considerable weight. Risk Assessment. The first component of risk analysis, risk assessment, attempts to measu:t and describe the risk or hazard associated with the use of a substance or technology, itis basically a scientific endeavor which becomes more accurate as scientific knowledge grows, as methodologies are perfected and as measuring instruments become more refined. It must be acknowledged, however, that there are considerable gaps and uncertainties in the sckntific knowledge which underlies most risk assessments. One must make certain assumptions to bridge these gaps and overcome these uncertainties which, in scientific parlance, are referred to as
" default assumptions." These assumptions are essentially policy decisions which rest on value judgments, especially and usually tne value judgment that when it comes to unknown hazards "it is better to be safe than sorry."
Selection of an Accmtable Rla 12 vel. The second component of risk-based decision-making is the selection of an acceptable risk level. This stage, while based on the first step, is not
. strictly a scientific endeavor. Rather, the benefits to society in using the substance or technology, and the cocts to society of reducing the risks must be considered. In the process, the risk at issue may be compared with other similar risks confronting society.
This step may be the most contentious because selecting an acceptable risk level clearly calls for value judgments and, therefore, for input from society as a whole. Getting this input represents a real challenge and also involves the important element of risk communication. This is why regulatory agencies should be "up-front" about whatever default assumptions may have been used in a given risk assessment. To make intelligent judgments about what level of risk is acceptable, one needs to have a sense of what certainty there is that there h a risk and what the real nature of this risk may be. Risk Management. The third component of risk analysis is risk management. This consists of devising a regulatory process designed to keep the risk below the level determined to be acceptable. This has traditionally been the primary task assigned to regulatory agencies by the President and the Congress. The political bodies have sometimes given agencies broad mandates that leave the agency with a good deal of discretion and sometimes have given very detailed instructions as to how risk management is to be accomplished. Regulatory leformation Conference 3 May 9,1995
Risk Aulysis and the Ret:ra 13 Ccmm 2 Se:se Dr. E. G:ll de PI:nque, NRC Cammissloser IV. The Role of Risk Analysis in the Regulatory Proces.: Now that we are familiar with the main ingredients of risk analysis, or risk-based decision-making--risk assessment, selection of an acceptable risk level and risk management-we come to the hard question: What role abould risk analysis play in the regulatory process? The Administration, the Congress and probably most of the public familiar with this issue appear to want an increased role for risk analysis in regulatory decision-making. In 1993, President Clinton ismed E::ecutive Order 12866 calling for increased use of risk analysis by Federal agencies. He also established in the White House Office of Science and Technology Policy a Regulatory Working Group that includes a Subgroup on Risk Analysis. I am pleased to have served on the Subgroup which has produced risk assessment principles and is currently assessing various Congressional proposals regarding use of risk analysis. The House of Representatives has passed H.R. 9 which includes risk analysis provisions and a number of bills on this subject are pending in the Senate, la short, there seems to be agreement across the political spectrum that Government decision-inakers should make increased use of risk analysis. That having been said, however, it is also true that being in favor of an increased role for risk analysis in the regulatory process is somewhat akin to being in favor of a balanced budget. Just as many agree that having a balanced budget would be desirable so long as my favorite programs are untouched, many agree that risk analysis should be part of the regulatory process but only so long as my favorite regulations are unaffected. There are some who see risk analysis as a poison pill which, once it is dicyyed into the regulatory process, will destroy the very goals the process is designed to achieve. However, I would like to suggest that risk analysis can be seen as an underused and much needed tool for decision-maing, a tool that can restore common sense to the decision-making process. Risk analysis can fill this function if it incorporates common sense at those points of the process where value judgments rather than strict scientific conclusions are needed. To illustrate my point, I would like to look a little more closely at a few of the places in the risk analysis process where value judgments must play a role. A. The Problem of Cumulative Default Assumptions The first place to look is at that part of the process where default assumptions are made. You will recall that default assumptions must be employed at the risk nase << ment stage to bridge the gaps created by scientific uncertainty, Often, the default assumption chosen is the most conservative option based on the judgment that "it is better to be safe than sorry" when it comes to unknown risirs.' At first sight, that value judgment may seem to be just common sense. However, there is a problem which may not be readily apparent: a single risk assessment will most likely need to incorporate many such assumptions, thereby building conservatism upon conservatism and producing an ultimate picture of the risk which may well be extremely disproportionate to its true nature. Indeed, the National Research Council, in its 1983 report Regulatory Information Conference 4 May 9,1995
Risk A clysis c:d the Ret:rn ta C mmm Sense Dr. E. Gall de Pixqre, NRC Ccamissioner on risk assessment, the Red Book,' identified more than 50 such assumptions that arise in the course of a risk assessment. Unless one takes the position that escry conceivable risk must be avoided-a position which I think would make it difficult to get out of bed in the morning--some common-sense approach to bridging scientific gaps and uncertainties needs to be considered. In 1994, the Department of Energy published an interesting study of the interplay between science and policy judgments with respect to default assumptions titled Choices in Risk Assessment: The Role of Science Policy in the Environmental Rink Manaoement Process.8 This book cites an example of two risk assessments done for exposure to tetrachloroethylene or "PCE." The risk assessments were done in the same manner except for the default assumptions used to bridge uncertainties in the scientific evidence with respect to three questions: (1) whether the dose-response relationship is linear at low doses where no scientific data exists when data indicate a dose response relationship at high doses; (2) whether the scaling factor applied in extrapolation from animals to huma's should be based upon surface area or body weight equivalence; and (3) whether experiuats involving mice or rats ought to be used for the extrapolation. The assessment which used conservative default assumptions to answer each question produced a risk estimate for exposure to PCE that was 35,000 times greater than the : estimate reached when alternative default assumptions were used. This example suggests that it may be more reasonable to produce risk assessments that will result in a range of risk estimates rather than in a single number or perhaps that the wisest course would be, in appropriate cases, to forego quantitative risk assessments altogether and instead provide a qualitative description of the risk. DOE's study on Choices in Risk Assessment describes a variety of alternatives to conservative default assumptions which are scientifically respectable and reasonable in given circumstances. My point here is not that conservative default assumptions must be abandoned altogether in favor of more realistic alternatives. Rather, my point is that the goal of the risk assessment stage of the risk analysis process should be to produce a credible picture of the nature of the risk. To the extent that , multiple conservative default assumptions render a given ri.k assessment incredible, surely it is reasonable to search for and mtke use of alternatives. Doing so is simply common sense. There are, I know, contrary views. Some contend that conservative default assumptions should be used wherever there are scientific uncertainties that must be overcome because this assures the greatest conceivable amount of public protecticn. In this view, the inherent biases of conservative assumptiore are best dealt with by rendering them explicit; i.e., as long as the public is aware of where " guesstimates" have been made, they will know how to regard the risk estimate. However, I happen to think this is unsatisfactory, especially when the risk is
National Research Council, Committee on the Institutional Means for Assessment of Risks to Public Health, Risk A= =: in the Federal Gc,w =- : Man ==ine the Praca*=. Washington, D.C.: National Academy Press, 1983.
8 Regulatory Impact Analysis Project, Inc., f% ices in Rizh A*aa===an'. U.S. Depi iu-ut of Energy: Washington, D.C.,1994. Regulatory Information Conference 5 May 9,1995
Risk A alysis cod the Ret:ra is Cam:::cc Sense Dr. E. G:S de Ptrq:e, NRC O>mmimbeer ult' unately expressed as a number, because it is too easy to lose sight of the gaps in 11 e evidence on which that raunber rests.- Moreover, simply recognizing that there is a built in bias doesn't reveal the extent of the bias anri leaves both decision-makers and the public uncertam as to how the risk assessment should be used. It is the function of risk managers, based on input from both the scientific community and the general public, to determine the desired degree of public protection; risk assessment, on the other hand, should be oricated toward giving the decision-maker the most credible picture of the problem possible. , B. The Problem of DetermLling an Acceptable level of Risk This brings me to a second area in the risk analysis process where value judgments are particularly important. Once the nature of the risk is characterized, an acceptable level of risk must be determined. This is, perhaps, the most d!Mcult value judgment to be made in the course of doing a risk analysis. It is difficult because the answer cannot be reached on the basis of scientific data alone but must take into account both expert and popular views on what type of risks are socially acceptable and the views of these two groups can be quite divergent. The matter becomes even more complex when the risk in question stems from exposure to a non-threshold substance; that is, a substance which is known to cause harm when humans are exposed to it at high dose levels but where the risk froni exposure at low dose levels is unknown and nossibly non-existent but is assumed to exist down to zero. I would like to focus on a particular case where a regulatory atency struggled to determine an acceptable level of risk so that we can see the interplay of science and value judgments and also so that we can ask what role common sense might play in this determination. The regulatory agency is the Environmental Protection Agency and the particular case was EPA's effort to establish an air emission standard for vinyl chloride, a non-threshold carcinogen. This is one of the emission standards, called a NESHAP or National Emiazion Stmiard for Hazardous Air Pollutant, mandated by the Clean Air Act. Under the regulatory scheme set up - by the Clean Air Act, EPA must first identify suspect " hazardous air pollutants"-meaning pollutants which might cause or contribute to death or serious illness-and then promulgate emission standards for such pollutants unles: the Adminierator of the EPA finns that the suspect air pollutant is not in fat.: hazardous. Congress also provided EPA with the standard it nr.ust use in promulgating a NESHAP: any standard must be at a level which will provide an ample margin of safety to protect the public health from the hazardous air pollutant. In assessing De risk posed by human exposure to vinyl chloride, EPA had little difficulty in concluding that a NESHAP was needed. The problem came in determining what level of risk was acceptable, given the impossibility of establishing any definite threshold level below which no adverse health effects would occur. As EPA saw the matter, it had two alternatives. First, it could determine that the statutory mandate to establish a standard that would provide an ample margin of safety meant that a complete prehibition was a~~=ary because only a zero emission limitation would assure complete safety. Or, as a second alternative, it could set the limitation at the lowest level achievable by use of the best available control technology if it fo*:nd that the cost of achieving a zero emission standard would be grossly disproportionate to the benefits of Regulatory Information Conference 6 May 9,1995
- Risk A -lysh and the Retira 43 Crmm:n Sense Dr. E. Gail de Pla:qYe, NRC Cc=missio2ir removing the risk. EPA selected the latter course upon finding that a zero emission standard could require closure of an entire industry, a cost it found extremely high for elimination of a risk to health that is of unknown dimensions.
EPA's choice did not prove satisfactory to all segments of society and the struggle to determine an acceptable level of risk moved to the judicial branch of the Government. The lawyers among you will likely be familiar with the case that decided this controversy: National Reenurces Defense Council v. Environmental Protection Anency, a 1987 ga bara decision of the United States Court of Appeals for the District of Columbia Circuit which is usually referred to as the " Vinyl Chloride decision."' The court was willing to give EPA broad discretion in determining the meaning of the term " ample margin of safety" but concluded that the agency had ducked the issue. EPA was not faulted for rejecting a "zero release" standard. As the court put it, " safe" does not mean " risk-free" or that the matter is free from nacertainty. But the court did insist that EPA decide, as a predicate to formulating an " ample margin of safety" standard, what was "an acceptable level of risk" and not avoid the issue by simply basing the standard on whatever the best available technology could produce. The court even suggested a method for accomplishing this task. This method is a two-step process. The first step focuses solely on the risk to health. The agency would consider not only scientific information but also "what risks are acceptable in the world in which we live." And the court gave as examples of such socially acceptable risks daily activities like driving a ca- or breathing city air. Only after completion of the first step would the agency, in a second step, 6 consider other factors like cost and technological feasibility to come to a conclusion as to what standard represented "an ample margin of safety." At the risk of some oversimplification, what it seems to me the court was saying here was: Use your common sense! Being safe from possible harms does not mean living in suspended animation; it means accepting reasonable risks. As the court put it, " safety" does not mean
" risk-free." When you must answer a difficult question like "what level of risk is acceptable" from the possible harms of a carcinogen, take a look at other risks people accept in daily life, risks like driving a car or breathing city air. Both of those activities entail risk but millions of people every day decide to " chance it," to take the risk. Of course, carried too far this mode of thinking could freeze the status quo and defeat the goal of producing a healthier and safer environment. But I don't think the court was suggesting a trap; I think the court was suggesting that some common-sense judgment needed to be made as to what risks are acceptable and then attention can be focused on what costs society might be willing to pay to further reduce the risks.
i There is one further point I would like to make before leaving the Vinyl Chloride decision. The court provided EPA with considerable flexibility in devising its NESHAPS. Recall that EPA had originally seen only two options for its standard-setting: "zero release" and "best Hational Resources Defense Council v. EPA. 824 F.2d t146 (gn hang) (D.C. Cir.1987). Regulatory Information Conference 7 May 9,1995
I 1 . Risk Analysis cad the Ret:rn 13 Csamon Sense Dr. E. Gill de Plangre, NRC Cammissioner available technology." But the court said: find out what is an acceptable risk, not what is the minimal risk technology might achieve. Of course, after determining the acceptable risk, EPA was free to decide that an ample margin of safety would only exist if the standard was based on the best available technology. But EPA was equally free, at this second step, to consider the full range of the costs of further reducing the risk from what was found to be acceptable. The effect of the court's decision, oddly enough, was to permit EPA to take a good deal more stock of the costs and benefits of a proposed standard once it had made its " acceptable level of risk" decision. C. The Problem of Comparing Risks I do not mean to downplay the difficulties involved in actually determining an acceptable. level of risk, whether for vinyl chloride or for any other hazardous substance or technology. In fact, a third area of the risk analysis process in which value judgments play an important role , is in the comparison of risks. A number of studies have shown that many factors influence a person's willingness to accept a given risk, factors such as the certainty and severity of the risk, the reversibility of the health effect, the knowledge or familiarity of the risk, whether the risk is voluntarily accepted or involuntarily imposed, the ber.: fit to be derived from accepting the risk and who the responsible party may be. There are also difficulties in comparit g actuarial risks where available statistics give a very acc trate picture of the risk, such as the risk of death in an auto accident, with risks that are substantally hypothetical. Finally, one of the most vexatious problems in comparing risks is the problert of how to reconciie the views of the " experts" and the -iews of the lay public which are often qaite disparate. Since we are dealing primarily with value judgments, the scientists cannot assume that science alone must dictate the solution. D. The Problem of Prioritizing Risks Finally, I want to mention a probiert that transcends the issues involved in doing any particular risk analysis and that is the overarching problem of how society can assure that attention and resources are devoted to the regulation of risks that are truly significant and not have them diverted to further reductions of triinimal risks. This is the problem that attracted the auention of Judge Breyer in his book Br**ine the Vicious Crcle. As he s::es it, the results of America's investment in risk reduction have been very uneven but this " hodgepodge of results does not reflect a public that really wants dirty Boston harbors and superclean swamps; rather, such policy priorities more likely reflect the psychological and practical dimculties of maine risk decisions one = ham at a time."7 His solution - creation of an elite corps of civil servants with interagency jurisdiction and authority whose mission would be to build an improved, coherent risk-regulating system with established priorities within and among programs
- has proved controversial but he has undeniably raised an issue that needs to be addressed. % eyer. nn siL. p. 55.
Regulatory Information Conference g May 9,1995
Risk Analysis cad the Retira 13 Cemmts Sense Dr. E. Gall de Pleare, NRC CemElssioIer There are other ideas out there. For example, tl:e Harvard Group on Risk Management Reform, in its report, Reform of Ri* Renulationr Achievine More Protection at Irss Cost, makes a number of recommendations including this c.ne: " Congress should authorize the President's science advisor to lead, integrate, and oversee the assessment and ranking of health, safety, and environmental risks in collaboration with federal agencies responsible for risk regulation."' This group urges that a new organization be created within the Office of Scienw and Technology at the White House to be administered by a Director of Risk Analysis and whose duties would include preparation of risk assessment guidelines and creation of methods for citizen participation in risk-ranking exercises. Finally, I might mention the Committee for the National Institute for the Environment which advocates legislation to create a new Government agency whose mission would be to improve the scientific basis for environmental decision-making policy. Whether any of these ideas will get off the ground remains to be seen but the ongoing ferment on this issue seems likely to produce some results. IV. The Need To Establish a Uniform Methodology for Standard-setting: Federal Radiation Protection Standards as a Case Example I have suggested that increased use of risk-based decision-rnaking by federal agencies can serve as a vehicle for putting more common sense into federal regulations and thereby enhance the credibility of those regulations with the public. This gorf will not be achieved, however, if each federal agency does risk analysis differently. We need to forge agreement among the federal agencies with respect to how risk analysis is properly done and particularly with respect to how common sense needs to be inserted into the process. An example of this need and of how it is currently being met is provided by federal radiation protection standards. In September 1994, the General Accounting Office issued a report entitled Nuclear Hemith and Safety: Consem= on Accantable Radiation Bl* to the Public is iM-ine.' As the title of the repon indicates, the GAO found inconsistencies, gaps and overlaps in the radiation protection standards issued by different federal agencies. The GAO Report prompted
- Senator Glenn to request the EPA and the NRC to develop a plan for addressing these problems and for achieving greater consistency in these standards. The two agencies are currently developing ajoint " White Paper on Risk Harmonization" which is intended to provide a common understanding of the statutory and logical rationale underlying the agencies' risk assessment and management decisions. EPA and NRC are also members of an interagency steering committee which is reviewing the current radiation regulatory framework.
Given that the agencies do risk analysis differently, it really should come as no surprise that they wind up with different standards. However, this is exactly the situation that puzzles and
' Harvard Group on Risk Management Reform, Reform of Risk Renulation: Achievinn More Protactian at Imss f0at, Boston: Center for Risk Analysis, Harvard School of Public Health, March 1995, p. 3. %,i==e Hamith and hf ev: Caa====== on Ace-nemht. Radiatlan Risk to the Public is i metrina (GAO/RCED 190. Sept.19,1994).
Regulatory inferination Conference 9 May 9,1995
Risk Analysis and the Ret:ra is Cammu Sense Dr. E. G:ll de Planque, NRC Cem::lesioner I I fmstrates the public. -The current effort to reemime methodologies and achieve greater consistency in standards is certainly worthwhile. The potential harm to the public from exposure to radiation is, after all,- the same whether the harm is regulated by EPA, NRC or any other agency, My hope is that this review will provide an opportunity to assure that all federal radiation protection standards will be grounded both in good science and in good common sense. V. Conclusion I have attempted today to describe a particular method of regu! story decision-making, risk analysis, and to show you some of the points in the process where it may be possible to return to common sense in the course of making nara===ry value judgments. Risk analysis is neither an insidious device for destroying the environmental gains of the las.t 25 years nor a rcientific
" deus ex machina" which will precisely calibrate the right degree of risk with the right degree of benefit without the need for making any " judgment calls." Rather, judgment calls need to be made but they can be made in a common sense and democratic fashion which will result in the right degree of regulation to resolve agreed-upon health and safety ud environmental needs.
The issue of the near future will be to figure out how to best use toe tool of risk analysis to achieve this end-both the environmental and the economic well-being of our society are in peril if we don't. s Regulatory Information Conference 10 May 9,1995
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Gianni Petrangeli j ATOMIC ENERGY CONTROL BOARD 1 ' Director, New Technologies Via V. Brancati 48 G.J.K. Asmis Roma, Italy 00144 Director, Safety Evaluation Division (Engineering) (39) 6-5007-2819 280 Slater Ottawa, Canada KlP 122 (613) 238-0000 7 . -. - ARIZONA ~ P_UBLIC SERVICE. COMPANY ~ Nicky M. Ballingall 280 Slater Street Kenneth C. Manne Ottawa, Ontario KIP SS9 Attorney (613) 943-0130 400 N. 5th Street MS 9820 Bernard Gerestein Phonenix, AZ 85004 Regulatory Affairs Coordinator (602) 250-3513 280 Slater Street Ottawa, Ontario KIP SS9 E.C. "Bert" Simpson (613) 995-6618 Vice President Palo Verde Nuclear Generating Station
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P.O. Box 52034 ' " ' ' MS-7616 JBALTIMORE GAS & ELECTRIC COMP. DYE Phonenix, AZ 85072-2034 (602) 393-5148 James P. Bennett Counsel Lexington & Cathedral g r ,- :,,ww.~ . - m, Baltimore, MD 21203 g / ATLAS, CONSULTING GROUPL: (410) 234-5607 Edward D. Fuller Gary 1 Detter President & COO Director-Nuclear Regulatory Matters 2533 South Highway 101 #240 1650 Calvert Cliffs Parkway Cardiff, CA 92007 Lusby, MD 20657 (619) 632-9206 (410) 260-3872 segulatoggggogerene >2<
Patricia S. Furio _ Getochew Tesfaye Senior Engineer Senior Engineer o 1650 Clavert Cliffs Parkway 1650 Calvert Cliffs Parkway Lusby, MD 20657 Lusby, MD 20657 (410) 260 4374 (410) 260-4455 Peter E. Katz Manager Nuclear Engineering Department < IBATTELLE 1650 Calvert Cliffs Parkway Lusby, MD 20657 Nancy E. Durbin (410) 260-4455 Research Scientist 4000 NE 41st Street Gerald Knull Seattle, WA 98105 5428 On-Line Mainterance Project Administrator (206) 528-3248 10054 Herring Place durbin@battelle.org St. Leonard, MD 2%85 (410) 260-4863 Brian D. Mann T' - BECHTEL' POWER-CORPORATION c Senior Engineer 1650 Clavert Cliffs Parkway Alice Carson Lusby, MD 20657 SERCH Supervisor (410) 260-6517 9801 Washingtonian Blvd. Gaithersburg, MD 20878 Michael D. Milbradt (301) 417-4458 Nuclear Regulatory Analyst 1650 Calvert Cliffs Parkway Nancy G. Chapman Lusby, MD 20657 SERCH Manager (410) 260-4352 9801 Washingtonian Blvd. Gaithersburg, MD 20878 John M. Osborne (301) 417 3771 Nuclear Regulatory Analyst 1650 Calvert Cliffs Parkway Edward M. Hughes Lusby, MD 20657 Manager of Quality Services (410) 260-2252 9801 Washingtonian Bivd. Gaithersburg, MD 20878-5356 Timothy E. Roxey (301) 471-3777 Senior Engineer 1650 Calvert Cliffs Parkway Carl F. Sundstrom Lusby, MD 2%57 Manager (410) 260-2065 9801 Washingtonian Blvd. Gaithersburg, MD 20878 Craig Sly (301) 417-8557 Senior Engineer 1650 Calvert Cliffs Parkway Theresa Sutter Lusby, MD 20657 SERCH Licensing Engineer (410) 260-4858 9801 Washingtonian Blvd. Gaithersburg, MD 20878 (301) 417-4244 tasutter@bechtel.com Regulato inf onference > .5 4
Romney B. Duffey ( Chairman, Department of Advanced Technology BOSTON EDISON COMPANY - Building 197C Upton, NY 11973 John F Alexander (516) 282 2454 Department Manager duffey@bal. gov 46 Sandwich Road Plymouth, MA 02360 See Meng Wong (508) 830 7673 Nuclear Engineer Bldg.130 E. Thomas Boulette Upton, NY 11973 Senior Vice President Nuclear (516) 282 2111 Pilgrim Nuclear Power Station wong2@bnl. gov 600 Rocky 11111 Road Plymouth, MA 02360 ="- ~ (508) 830 8814 CAROLINA POWER & LIGitT e Robert V. Fairbank Roy A. Anderson Regulatory Affairs & Emergency Preparedness Vice President Department Manager Burnswick Nuclear Plant 600 Rocky 11111 Road P.O.- Box 10429 Plymouth, MA 02360 Sotdhport, NC 28461 (508) 830 8189 (910) 457 2496 Jack M. Fulton Jci.n P. Cowan Sr. Counsel Director Site Operations 800 Boylston Street P-360 P.O. Boy 10429 Boston, MA 02109 Southport, NC 284'il (617) 424 2553 (910) 457 2869 John _fulton@bedison.com Michael D.11111 Alan R. Shiever Manager Nuclear Assessment Licensing / Compliance Division Manager P.O. Box 165 600 Rocky 11111 Road New 11111 NC 27562 Plymouth, MA 02360 (919) 362 2188 (508) 830-7948 Scotty C. Illnnant Vice President Robinson Nuclear Plant [i.'"'~kOOKHAVEN B '~ NATIONAL LABORATORY. 3581 West Entrance Road ilartsville, SC 29550 Michael F. Bonner (803) 857 1499 NRC Coordinator Box 5000 Rod M, Krich Upton NY 11973 Manager Regulatory Affairs ' (516) 2d2 3340 3581 West Entrance Road llartsville, SC 29550 (803) 857 1802 Retutatogigtygogerence >4<
Richard P.1.oPriore ; Manager, Regulatory Affairs CENTRAL NUCLEAR VANDELLOS 11 P.O. Ilox IN19 Southport, NC 28461 Conrad Dube (910) 457 2212 Licensing Manager Trv. Les Carte 55 Edward D. Schrull Barcelona, Spain 08014 Director. Operating Experience Programs (34 3) 334 7000, Ext. 248 6N Trappers Run Cary NC 27513 ; (919) 546-4055 ' ClllNESE EMBASSY t'ynthia L. Tully lluaLiu Director Commitment Management Second Secretary P.O. Box 1551 (011S-9) 2300 Connecticut Avenue, NW Raleigh, NC 27602 Washington, DC 20008 (919) 362-7924 (202) 328 2531 Thomas D. Walt ' Managet Regulatory Affairs ; CITY OF AUSTIN ELECTRIC UTILITY P.O. Ilox 165 New 11111 NC 27562 Peter W. Goloe (919) 362 2100 Manager Joint Projects 721 Barton Sprinks Road Clay C. Warren Austin, TX 78704 Plant Manager Unit 2 (512) 322-6233 P.O. Box IN21 Southport, NC 28461 (910) 457-2864
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CLEVELAND ELECTRIC ILLUMINATING 7 . COMPANY . CATARACT, INCORPORATED; Richard D. Brandt O. Leonard Johnson General Manager Regional Manager 10 Center Road 750 Old Main Street Perry, Oli 44081 Rocky 11111, CT 06067 (216) 280-5440 (203) 563 3925 llenry L. Ilegrat
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Supervisor Licensing 10 Center Road u - CENTERIOR ENERGY Perry, Oli 44081 (216) 280-5606 John P. Stetz Vice President - Nuclear (Davis Besse) Keith R. Jury 5501 N. State Route 2 Supervisor-Compliance Oak liarbor, Oil 43449 10 Center Road (419) 249 2300 Perry, Oli 44081 (216) 280-5310 Regulato I onferenet >$4 ~
James D. Kloosterman _ Dona!d R. Brindle Manager, Regulatory Affairs Regulatory Assurance Supervisor 10 Center Road 4450 N. German Church Road Perry, Oli 44081 Byron, IL 61010 (216) 280-5833 (815) 234 5441 Ext. 2280 Dennis L. Farrar
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n
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Nuclear Regulatory Services Manager
= COMMITTEE FOR A SAFE 1400 Opus Place, Suite 500 , ;ENGERY FUTURE , ,
Dowr.ers Grove, IL 60515 (708) 663 2094 William S. Linnell Spokesman 1 arry, P. Gerner P.O. Box 4034 Regulatory Assurance Supervisor Portland, ME 04101 2601 N. 21st Road (207) 772 2958 Marseilles, IL 613419757 + (815) 357-6761
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Peter G. llolland t l COMMONWEALTH EDISON : Regulatory Assurance Supervisor I 6500 N. Dresden Road Charles M. Allen Morris,IL 60450 Dresden Unit 1 Licensing Director (815) 942 2920. Ext. 2714 6500 North Dresden Road Morris, IL 60450 John B. Ilosmer (815) 942 2920. Ext. 2857 Engineering Vice President 1400 Opus Place Kevin G. Bartes Downers Grove, IL 60515 Regulatory Assurance Supervisor (708) 663-7344 RR #1, Box 84 Braceville,IL 60407 Irene M. Johnson (815) 458-2801, Ext. 2980 Licensing Operations Director 1400 Opus Place, Suite 500 Joseph A. Bauer Downers Grove, IL 60515 Executive Assistant (708) 663 2096 4450 N. German Church Road Byron, IL 61010 Karl L. Kaup (815) 234 5441, E.st. 3602 Site Vice-President Commonwealth Edison-Braidwood Station Ron N. Baumer Rt. Box 84 Quad Cities Nuclear Power Station Braceville,IL 60407 Nuclear Regulatory Commission Coordinator (815) 458 2801
- 22710 206th Avenue Cordova, IL 61242-9740 Jim Madden (309) 654 2241 Regulatory Assurance Supervisor 101 Shiloh Blvd.
Gary G. Benes Zion IL 60099 Nuclear Licensing Adminstrator (708) 746 2084, Ext. 2244 1400 Opus Place Downers Grove, IL 60513 (708) 663 7282 Betulato ig_ygcogerence >64
.,. _- . - - -_- ~__ -_.- - - .- - . - . _ - . . - - _ - - . - . - .
Victor Mullin i Manag:r ;
CONSFJO DE SEQURIDAD NUCLEAR 3 Laura Lane ilopewell Jct., NY 12533 Alfonso Arias (914) 734 5106 General Secretary Justo Dorado, !!
J. Stephen Perry Madrid, Spain 28040 Vlec President Boling Water Reactors (34 1) 346-0327 1400 Opus Place Downers Grove, IL 60515 Anibal Martin , (708) 663-6160 Justo Dorado,11 Madrid, Spain 28040
Donald Ray (34 1) 346-0377 Station Manager - LaSalle Company Station 2601 N. 21st Road Jose 1. Villadoniga Marseilles, IL 613419757 Division of Operational Analysis (815) 357-6761 Ext. 2212 Justo Dorado,11 Madrid, Spain 28040 Denise M. Saccomando (34 1) 346-0146 Nuclear Licensing Administrator 1400 Opus Place i Downers Grove, IL 60515 8 .
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(708) 663-6484 CONSOLIDATED EDISON COMPANY _ Martin J. Vonk Joseph M. Bahr Licensing Administrator Principal Engineer 1400 Opus Place, Suite 500 Broadway & Bleakley Avenue Downers Grove, IL 60515 Buchanan NY 10511 (708) 663 7292 (914) 734 5602 Michael J. Wallace . Brent L. Brandenburg Senior Vice President / Chief Nuclear Officer Assistant General Counsel 1400 Opus Place 4 Irving Place Suite 900 New York, NY 10003 i Downers Grove, IL 60515 (212) 460 4 33 (708) 663-7558 Thomas L. Talbot (, ~ gn ,,,, -e y ,g,, [E,# iCQ Q gCUT K N 4 Irving Place Room 1325 John D. Ilaseltine New York, NY 10003 Engineering Director (212) 460-6632 362 Inlun llollow Road East Hampton, CT 06424 Stephen E. Quinn (203) 267-3601 Vice President - Nuclear Power Broadway & Bleakley Buchanan, NY 10511 (914) 734 5340 Regulato fr n onference >l4
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, CONSUMERS POWER COMPANY

1 1 COOPER NUCLEAR STATION Elizabeth A. Bogue Raymond G. Jones Chemistry llealth Physics Manager Senior Manager, Safety Assessment 10269 US 31 North Box 98 Charlevoix, MI 49720 Brownsville, NE 38605 (616) 547 8134 (402) 825 5775 Patrick M. Donnelly ?
Plant Manager i~ . COUNCIL;FOR NUCLEAR SAFETY
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10269 US 31 North Charlevoix, MI 49720 Ross L. Garcin (616) 547 8132 Nuclear Quality Assurance inspector P.O. Box 7106 Robert A. Fenech llennopsmeer 0086 Vice President, Nuclear Operations Republic of South Africa 320246 27780 Blue Star Memorial (012) 663 5500 Covert, MI 49043 (616) 764-8913
. DAVID'ANDF.ESN AND ASSOCIATES ~
Kurt M.1laas Plant Sm.:ty & Licensing Director David Andress 27780 Blue Star Memorial liighway President Covert, MI 49043 11008 liarriet Lane (616) 764 8913 Kensington, MD 20895 (30l) 933 7179 David W. Joos Executive Vice President / COO - Electric 212 W. Michigan Avenue f; . . Jackson, MI 49201 D.C. COOK PLANT (517) 788 1352 Michael E. Barfelz Michael G. Morris Superintendent-Nuclear Safety . President & CEO & Analysis Departna.at 1 212 W. Mich4an 1 Cook Place 1 Jackson, MI 49201 Bridgman, MI 49106 (517) 788 1111 (616) 465 5901, Ext.1484 Robert A. Vincent John R. Sampson Licensing Administrator Assistant Plant Manager 27780 Blue Star Memorial Highway 1 Cook Place Covert, MI 49043 Bridgman, MI 49106 (616) 764-8s13 (616) 466-2409 Gregory C. Withrow Joel S. Wiebe Plant Safety and Licensing Director Superintendent-Quality Assurance & Control 10269 US 31 North ! Cook Place Charlevoix, MI 49720 Bridgman, MI 49106 (616) 547-8176 (616) 465-5901. Ext. 2510 Regulato fgytyonference >84
t [ DEPARTMENT OF ENERGY.!!JJNOIS DUKE POWER COMPANY John S. Loomis J. Ed Burchfield Argonne National Lab Regulatory Compliance Manager Argonne, IL l Oconee Nuclear Station j (708) 252 1562 P.O. Box 1439
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Senera, SC 29679
" (803) 685 3292 DETROIT EDISON Skip Copp Lynne S. Goodman Manager, Nuclear Regulatory Affairs Director Nuclear Licensing P.O. Box 1006 6400 N. Dixie liighway Charlotte, NC 28201 1006 Newpon, MI 48166 (704) 382 5826 4
(313) 586-4097 Bryan J. Dolan George Smith Safety Assurance Manager Fenni-2 McGuire Nuclear 6400 North Dixie liighway 12700 llagers Ferry Road , Newport, MI 48166 Iluntersville, NC 28078 (313) 586 1696 (704) 875-4225 '
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Mary 11. Ilazeltine p . Engineer DUKE ENGINEERING & SERVICES. 422 South Church Street Charlotte, NC 28201 Stephen G. Benesole (7N) 382-6111 Licensing Consultant l 2650 Park Tower Drive Daniel P. Kimball Vienna, VA 22180 Catawba Nuclear Station . (703) 204-8598 Safety Review Manager 4800 Concord Road Robert G. Morgan York, SC 29745 Regulatory Manager (803) 831-3743 13936 Stonefield Drive Clifton, VA 22024 T. C. McMeekin (7N) 204-8863 Vice President gac7323@dukepower.com McGuire Nuclear Site 12700 llagers Ferry Road John 11. Reeves liuntersville, NC 28078-8985 Licensing Engineer (704) 875-4800 2650 Park Tower Drive Suite 800 Robert O. Sharpe Vienna, VA 22180 Senior Engineer (703) 204 8885 422 South Church Street Charlotte, NC 28201 (7N) 382-0956 ros7392@dukepower.com RetuMoQ13t$ogonference >9A
James E. Snyder Regulatory Cornplicnce Manager 12700 llagers Ferry Road ELECTRIC POWER RESEARCil INSTITUTE lluntersville, NC 28078 (704) 875-4 47 John M. Gisclom Manager, Maintenance Technology 3412 Ilillview Avenue
, DUQUESNE LIGifT COMPANY Palo Alto, CA 94304 (415) 855-2571 Roy K. Brosi Manager, EP Gary L. Vine P.O. Box 4, BV-T Senior Washington Representative Shippingport, PA 15077 2000 L Street, NW (412) 393 5767 Suite 805 Washington, DC James E. Cross (202) 293-6347 Vice President gvine@mstn.epri.com Rt.168 Shippingport, PA 15077 (412) 393-5255 ELECTRICITY DE FRANCE (EDF)
George J. Thomas Division Vice President Nuclear Services Charles Benedetti Rte.168 Project Manager, Engineering & Construction Shippingport PA 15077 Division, Marseille (412) 393 5206 1730 Rhode Island Avenue, NW Suite 509 Nelson R. Tonet Washington, DC 20036 Manager, Nuclear (202) 429 2527 P.O. Box 4 Shippingport, PA 15077 Michael Debes (412) 393-5210 Charge de Mission 32 Rue de Monceau Paris Cedex, France 75384 (33 1)40-12 38-36 EARTl! SERVICES CONSULTANTS Bernard Fourest Michael J. Manski Deputy Manager Nuclear Safety Department Radiological Services Manager 17 Avenue Clodoald One Trianpk Drive Saint Cloud, France 92210 Export, PA 15632 (33 1) 49020453 (412) 733 3000 Ext. 271 Bernard P. Roche
ECKERT, SEAMANS, CllERIN & MELLOTT General Manager 1214 Avenue Dutrievoz Barton Z. Cowan Villeurbanne, France 69628 Partner (33) 72-82 75-10 600 Grant Street,42nd Floor Pittsburgh, PA 15112 (412) 566-6029 Regulatoggmg%n anference g > 10 <
Carter 11. Nolond ji , . EMBAS8Y OF AUSTRALIA Vice President, Atlanta Ope ations 1600 Parkwood Circle Suite 600 Allan Murray Atlanta, GA 30339 Counsellor (Nuclear) (404) 980-2360, Ext 380 1601 Massachusetts Avenue, NW Washington, DC 20036 John D. Richardson (302) 797 3042 Senior Vice President amurray@capcon. net 1600 Parkwood Circle, Suite 600 Atlanta, GA 30339 (4N) 980-2360 Ext. 372 ENERCON SERVICES INCORPORATED ~ Thomas D. San'er Client Services Manager Benjamin D. Acojido 2$05 S.17th Street Client Services Manager Wilmington, NC 28401 595 Market Street, Suite 2500 (910) 791-0169, Ext. 375 San Francisco, CA 94105 (415) 969 1097 Alcuin J. Schneider Project Manager MichaelI. Aneshansley 1600 Parkwood Circle, Suite 600 President Atlanta, GA 30339 10820 E. 45th Street, Suite 100 (404) 980-2360, Ext. 375 Tulsa, OK 74146 (918) 665-7693. Ext. 334 Douglas R. Whitson Client Services Manager Gary L. Augustine 10820 E. 45tn Street, Suite 100 Vice President, Pittsburgh Operations Tulsa, OK 74146 4115 William Penn liighway (918) 665 7693 Ext. 343 One Franklin Centre Murrysville, PA 15668 Arthur R. Woods (412) 733 8711 Manager, Design 1600 Parkwood Circle, Suite 600 William M. Davis Atlanta, OA 30339 Client Services Manager (4N) 980-2360 10820 E. 45th Street, Suite 100 Tulsa, OK 74146 (918) 665-7693, Ext. 327 Michael S. Grim Director, Tulsa Division 10820 E. 45th Street, Suite 100 Tulst, OK 74146
. (918) 665-7693, Ext. 342 >
ENERGY RESOURCES INTERNATIONAL INC.-
Dennis B. Ilacking ' ' Client Services Manager 10820 E. 45th Street, Suite 100 Eileen Supko Tulsa, OK 74146 Senior Consultant (918) 665-7693, Ext. 330 Regulatoy fgrgat onference > )) <
a i 14sley A. England ENGINEERING APPLIED SCIENCE Coordinator Nuclear Safety & Licensing
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INCORPORATED 1340 Echelon Parkway Jackson, hiS 39213 Robert A. Wiesemann (601) 368-5766 Executive Vice President 505 Pleasant Valley Road Jamec J. Fisicato Trafford, PA 15085-9765 Director Nuclear Safety (412) 744-7793 P.O. Box 220 St. Francisville, LA 70775 (504) 336 6225 iENGINEERING PLANNING & MANAGEMENT' C. Randy liutchinson INCORPORATED Vice President. Operations GGNS P.O. Box 756 W. Wade Larson Port Gibson, hts 39150 President (601) 437 2146 959 Concord Street Framingham, hiA 01701 Dan R. Keuter (508) 875 2121, Ext. 206 General hianager Plant Operations P.O. Box B Killona LA 70066 (SN) 464 3120 FNTERGY OPERATIONS, INC, GGNS John R. hicGaha Robert G. Azzarello Vice President Operations Director Design Engineering River Bend Station P.O. Box B P.O. Box 220 Killona LA 70066 St Francisville, LA 70775 (504) 739-6680 (504) 381-4388 Ross P. Barkhurst Dwight C. hiims Vice President, Operations, Waterford 3 Licensing Director P.O. Box B S.R. 333 Killona, LA 70066 Russellville, AK 72801 (SN) 739-6661 (501) 558-4601 Raymond F. Burski hiichael J, hicisner Director Nuclear Safety Director of Nuclear Safety & Regulatory Affairs P.O. Box B P.O. Box 756 Killona, LA 70031 Port Gibson, hiS 39150 (504) 739-6774 (60l) 437-6470 Lormie F. Daughtery Jerry C. Roberts Technical Coordinator to Director of NS&RA Director, Nuclear Safety & Licensing P.0, Box 756 1340 Echelon Parkway, h1U660 Port Gibson, hts 39150 Jackson, hts 39213 (601) 437 2334 (601) 368-5758 y ... ,,a-i.- .n-
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Mike B. Sellman Manag:r Plant Operations River Bend Stations FEDERAL MINISTRY OF P.O. Box 220 ENVIRONMENTAL NUCLEAR St. Francisville, LA 70775 REACTOR SAFETY (504) 381-4200 Wolfgang Blau Fred W. Titus Dip Ing. Vice President. Engineering Federal Ministry of Environment, Nature Conservation P.O. Box 31995 & Nuclear Safety Jackson, MS 39286 1995 Ilusarenstrabe 30 (601) 368 5390 Bonn, Germany D53048 (49) 228 305 2298 Donald W. Vinct Licensing Manager P.O. Box B Killona, LA 70066
FLORIDA POWER CORPORATION (504) 739-6370 Larry C. Kelley Jerry W. Yelverton 15760 W. Power 1.ine Street Vice President Operations Crystal River, FL 34428 6708 3211 Oak 11111 Court (904) 563-4529 Russellville, AR 72801 (501) 858-4888 Ken Wilson
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15760 W. Power Line Street Crystal River, FL 34428-6708 ENY1RONCARE OF UTAH ' (9N) 563-4529 Eugene J. Gleason <
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Senior Manager i FLORIDA POWER & LIGIIT COMPANY -
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46 West Broadway Salt Lake City, UT 84101 Robert E. Dawson (801) f321330 Licensing Manager P.O. Box 128 EQE, INTERNATIONAL (407) 468 4 07 Bruce Norton Jerome 11. Goldt erg Senior Consultant President Nuclear Division 44 Montgomery Street P.O. Box 14000 San Francisco, CA 941N Juno Beach, FL 33408 (415) 989-2000, Ext 3047 (407) 694-4222
- EXCEL SERVICES CORPORATION Donald E. Jernigan Donald R. Iloffman Plant General Manager Pr:sident P.O. Box 4332 11921 Rockville Pike, Suite 100 Princeton, FL 33032 Rockville, MD 20852 (305) 246-6180 (30l) 984-4400 Regulatogiggg'onfereur > 13 <
Larry C. Kelley Director, Nuclear Site Support GE NUCLEAR ENERGY 15760 W. Power Line Street (SA2A) Crystal River, FL 34428 George B. Stramback (904) 795 1994 Licensing Services Project Manager 175 Curtner Avenue, M/C747 liarry N. Paduano San Jose, CA 95125 Manager Nuclear Licensing & Special Programs (408) 925 1913 700 Universe Blvd. Juno Beach, FL 33408 (407) 694 4190
GENERAL PUBLIC UTILITIES (GPU)'
Edward J. Weinkam 111 : NUCLEAR CORPORATION Licensing Manager ' Turkey Point George W. Busel P.O. Box 029100 Manager, Regulatory Affairs Miami, FL 33102 9100 752 Brim Raod (305) 246 7383 Landin liarbor, NJ 08724 ed_weinkam_at_us fpl 102 @email . cpl .com (609) 97l 4643 Kenneth Wilson George W. Busch Manager, Nuclear Licensing Manager, Oyster Creek LI ensing 15760 W. Power Line Street (SA2A) P.O. Box 388 Crystal River, FL 34428 Forked River, NJ 08731 (904) 563 4549 (609) 971 4643 Don K. Croneberger Director Special Projects [ _ .
. One Upper Pond Road
[, GENERAL E1ECTRIC COMPANY Parsippany, NJ 07054 (201) 316 7031 Kenneth W. Brayman Systems Manager, Nuclear Quality Assurance Dennis P. Kelly 175 Curtner Avenue Technical Analyst San Jose, CA 95125 1 Upper Pond Road (408) 925-6587 Parsippany, NJ 07054 (20l) 316-7885 Major R. Knight Licensing Engineer P.O. Box 480 [ ._ Middletown, PA 17057 L jGENERAL; PHYSICS COMPANY (717) 948 9554 Don R. Duquette Rober: L. Long Vice President Nuclear Services Vice President & Director Nuclear Services 6700 Alexander Bell Drive One Upper Pond Road Columbia, MD 21046 Parsippany, NJ 07054 (410) 290-2489 (201) 316-7484 Regulaso yy}'onference > 14 4
Max A. Nelson E
Manager Nuclect Safety, 4 GOLDER FEDERAL SERVICES Three Mile Island P.O. Box 480 Diana N. Ilirrlinger Middletown, PA 17057 Senior Project Manager (717) 948 8639 4 Research Place mnelson@gpu.com Suite 140 Rockville, MD 20850 Robert A. Pinelli (301) 417 6705 4
Chairman-BWROO OneUpper Pond Road Parsippany, NJ 07054 (201) 216 7155 ' DRS Edmund Roessler Edmund T. Kersting Manager Nuclear Safety Assessment Schwertnergassel . P.O. Box 388 Koln, Germany 50667 Forked River, NJ 08731 (49) 221 2068 316 (609) 971 4212 kee@'mhsyw.grsce Philip F. Scallon Safety Review Manager F P.O. Box 388, RT. 9 So. i HAZARD TECHNOLOGY NEWSPAPER Forked River, NJ 08731 (609) 971-4625 Bill Boyle Contributing Editor -
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1401 Rockwille Pike l Suite 500 GILBERT /COMMONWEALTif, INC. Rockville, MD 20852 (301) 738-6900 Daniel L. Curry Director Nuclear Projects P.O. Box 1498 Reading, PA 19603 1498 (610) 855 2366 gc!ghmallollal223@gilcom.attmail.com [ HOUSTON LIGHTING & POWER COMPANY John F. Ililbish Ted 11, Cloninger Senior Licensing Engineer Vice President Nuclear Engineering 34 Cross Key Road South Texas Project Bernville, PA 19506 P,0. Box 289 (610) 855 2547 Wadsworth, TX 77483 (512) 972 8787 Jim Warren Project Manager William T. Cottle 1055 Commerce Park, Suite 200 Group Vice President, Nuclear Oak Ridge, TN 37830 P.O. Box 289 (615) 220-4507 Wadsworth, TX 77483 i (512) 972-8434 l Regulato hf m tygonference > 55 4
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Mark A. Mc Burnett '- - ' South Texas Project Electric Generating Station *
. ILLINOIS DEPARTMENT OF NUCLEAR Manager Nuclea Licensing SAFETY 7'
Box 289 Wadsworth, TX 77483 Lyle J. Black (512) 972-7206 Senior Steff Attorney 1035 Outer Park Drive Springfield, IL 62704 (217) 524-0770
.. ._.. - IBEX _GR. -, INCORPORATED _ -
Michael C. Parker Robert E. Sweeney 1035 Outer Park Drive Chief Operation Officer Springfield, IL 62704 7315 Wisconsin Avenue, #515 East (217) 785-9854 Bethesda, MD 20814 (301) 951 1191 Roy R. Wight Manager, Office of Nuclear Facility Safety 1035 Outer Park Drive if" D ~'
~ , Springfield, IL 62704 - IES UTILITIES INC./DAEC ,
(217) 785-9851 Lisa llenderson Gary N. Wright Emergency Planning Senior Nuclear Engineer 3277 DAEC Road 1035 Outer Park Drive Palo, IA 52324 Springfield,IL 627N (319) 398-8117 (217) 785 9867 Jim Kinsey Licensing Supervisor ^ '" 3277 DAEC Road t - ILLINOIS POWER
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Palo, IA 52324 ' ' (319) 851 7177 Joe A. Miller Manager - Nuclear Station Engineering 3201 Monticello Road Keith D. Young Bloomington,IL 61704 Manager, Licensing (217) 935-8881 3277 DAEC Road Palo, IA 52324 Roger W. Morgenstern (319) 851 7229 Plant Manager P.O. Box 678 Ken Peveler Clinton,IL 62535 Manager Quality Assurance (217) 935 8881 3277 DAEC Road Palo, IA 52324 Richard F. Phares-. (319) 851-7801 Director - Licensing P. O. Box 67 Clinton, IL 61737 (217) 935 8881. Ext. 3405 Regulatogyanogonferener > 16 A
Michael D. Stickney Supervisor Licensing Clinton Power Station INTERNATIONAL ENERGY SERVICES Clinton, IL 61727 (217) 935 8881, Ext. 3421 David G. Powell President Patrick D. Yocum 1307 Dolley Madison Blvd. Director Nuc! var Assessment Suite 4C P. O. Box 678 McLean, VA 22101 Clinton,IL 61727 (703) 761 1194 (217) 935 888I Ext. 3195 g J.M. LEIVO ASSOCIATES -
;.; INPO James M. Leivo Consulting Engineer Richard P. LaRhette P.O. Box 556 Government ReMons Mount Airy, MD 21771 700 Galleria Parkway (301) 831 3003 Marietta, GA l (404) 644 8217 JUPITER CORPORATION?
U ' Marty Martinez
INSIDE N.R.CJ* Senior Engineer
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2730 University Blvd., West Kathleen llart Suite 900 Reporter Wheaton Plaza North 1200 0 Street, NW Wheaton, MD 20902 Suite 1100 (301) 946-8088 Washington, DC 20005 (302) 383 2161 khart@mhr.com
'x KANSAI ELECTRIC POWER ~ COMPANY ^
Kensuke Yos'dnara I ' ' ' Researcher g INSTITUTE OF NUCLEAR SAFETY SYSTEM - 2001 L Street NW, Suite 801 Washington, DC 20036 Yukimitsu Okano (202) 659 1138 Deputy General Manager 1-7, liikaridal, Seika-CllO Kyoto, Japan 619-U2 Taechul Park (0774) 95 5093 Senior Researcher 1000 Prospect 11111 Road Windsor, CT 06095 (203) 285 8925 Regulato inf m onference > ll 4
!^ Yong 11o Ilyu c : KHAN CONSULTING SERVICES llead, Performance Evaluation Safety P.O. Box 114 Yusung Masurer A. Khan Taejeon, Korea 305 600 President (82) 42-868-2621 217 Brendan Choice Cary, NC 27511 (919) 481 2229 :
bdmt04a@ prodigy.com ' KOREA POWER ENGINEERING COMPANY
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Kwang 11 Lim
, KOREA ELECTRIC POWER CORPORATION ; Senior Engineer p 87 Samsung Dong. Kangnam Ku, Seoul Dae Yul Chung Seoul, Korea 135-090 Assistant Manager (02) 510-5148 Seoul Korea Kang Namgu Samsung Dong (02) 550-5744 Myung Youl. Yoon Project Manager Kisang Song 87 Samsung Dong, Kangnam Ku, Seoul Senior Engineer, Manager Seoul, Korea 135-090 270 Sylvan Avenue (02) 510-5168 Englewood Cliffs, NJ 07632 (201) 894 8855 ~ ' ' ~ "
1 KYUSHU ELECTRIC POWER COMPANY
, ' KOREA INSTITUTE OF NUCLEAR SAFETY _ " INCORPORATED-Dae Wook Chung Akira Murayama Senior Researcher Engineer P.O. Box 114 Yusung 3301 Stonecliff Drive Taejeon, Korea 305-600 Monroeville, PA 15146 (82) 42 868-8237 (412) 374 3276 Young S. Eun Director ;<
P. O, Box 114 Yousung " MAINE STATE PLANNING OFFICE Taejeon, Korea 305-600 (82) 42 868 8237 Uldis Vanags State Nuclear Safety Advisor Sung Kyu Lee 184 State Street, Station #38 Manager, inspection Planning Augusta, ME (M3?3 P.O. Box 114 Yusung (207) 624-6039 Taejeon, Korea 305-600 (82) 42 868-2641 Chang flyun Lim Senior Researcher P.O. Box 114 Yusung Taejeon, Korea 305 600 (82) 42-868-2624 t Regulato nf m onference > ]8 4
! MAINE YANKEE ATOMIC POWER ~ MIDWEST POWER SYSTEMS James R. lierbert Manager Licensing & Engineering Support Jim C. Parker 329 Dath Road Senior Engineer Brunswick, ME 04011 P.O. Box 657 (307) 298 4285 Des Moines, IA 50303 (515) 281 2967 Graham M. Leitch Vice President, Operations P.O. Box 408 MINISTRY OF SOCIAL AFFAIRS NL Wiscasset, ME N578 (207) 882 5800 . Peter DeMunk Anna Van liannover Street 4 ; Denilag, NL 250GLV
: MARYLAND DEPARTMENT OF - (31) 70-333 5539 '
NATURAL RESOURCES Richard McLean Manager, Nuclear Programs PPER Tawes Hldg., B 3 580 Taylor Avenu ' M& O/ WOODWARD CLYDE' Annapolis, MD 21401 : FEDERAL SERVICES - (410) 974-2261 David F. Fenster Manager, Requirements & Licensing [ - MARTIN MARIE 1TA ENERGY SYSTEMS c/o TRW
! , j lNCORPORATED 2650 Park Tower Drive, Suite 800 V!enna, VA 22180 Julie J, Robinson (703) 204-8866 Program Manager ORNL, P.O. Box 2009 Oak Ridge, TN 37831 ' ' '
(615) 576-4130 MORGAN, LEWIS & BOCKIUS' William E. Sykes George L. Edgar Nuclear Regtilatory Affairs Manager Partner P.O. Box 1410 1800 M Street, NW Paducah, KY 42001 Suite 500 South (502) 441 6796 Washington, DC 20036-5869 (202) 467 7459 3 MATERIALS & ENERGY ' Tim Matthews Attorney L. Erik Titland 1800 M Street, NW President Washington, DC 20036 512 1Jlewild Road (202) 467 7527 Bel Alt, MD 21014 matt 7527@mlb.com (410) 879-0718 RegulangfniqygonfeAt > 19 4
_7_____ a Jack R. Newman > Partner , HEW YORK POWER AUTHORITY 1800 M Street, NW ' t Suite 500 South William Cahill, Jr. i Washington, DC 20036 5869 Chief Nuclear Officer ! (202) 467 7115 123 Main Street White Plains, NY 10601 (914) 681 6840 i ( James Comiotes [1- , , MPR , General Manager Support Services . Indian Point 3 Nuclear Power Plant Jack Stone Bleakley Avenue 320 King Street Buchanan, NY 10511 Alexandria, VA 22314 (914) '136-800! (703) 519-0200 4 Robert Deas, Alex Zarechnak Vice Prnident Appraisal & Compliance Services Engineer 123 Main Street 312 King Street White Plains, NY 10601 Oakton, VA 22314 (914) 681 6488 (703) 519-0200 Thomas Dougherty T 9 ?
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Vice President Engineering b m.; MROCEKA ASSOCIgIES , 123 Main Street White Plains, NY 10601 Edward J. Mroczka (914) 681 6800 Performance improvement Specialist 11 Wildwood Road Charles Falson Portland, CT 06480 Director Nuclear Licensing (203) 342 3488 123 Main Street White Plains, NY 10601
* ^^ ' * ' ' ~ "* ' ' . 4 (914) 681 6306
[ NE8RASKA PUEtJC FOWER DISTRICTj , Peter Kokolakis , Robert C. Godley Manager Generic Licensing Nuclear Licensing and Safety Department Manager 123 Main Street Cooper Nuclear Statior. White Plains, NY 10601 P.O. Box 98 (914) 631 6254 j Brownville, NE 68321 , (402) 825 5819 John 11. Maurer Director of Nuclear Program Assessments Guy R. llora 123 Main Street Vice President, Nuclear ~ White Plaim, NY 10601 141415th Street (914) 736-8380 Columbus, NE 68601 (402) 564 8561, Ext. 5518 1 Regulatoyinfysiggn,fogerence > 20 <
Kenneth Peters Manag:r IP 3 Licensing , Indian Point 3 Nuclear Power Plan' (NORTtIEAST UTILITIES SERVICE COMPANY Bleakley Avenue Buchanan, NY 10511 Ray Crandall (914) 736 8029 Supenisor Radiological Engineering Rope Ferry Road liarry Salmon P.O. Box 128 Resident Manager JAP Waterford, CT 06385 James A. Pitzpatrick Nuclear Power Plant (203) 447 1791 P.O. Box 41 Lycoming, NY 13093 Eric A. DeBarba (315) 349-6001 Vice President Nuclear Enginee:Ing Senices Arthur Zaremba Rope Perry Road Manager JAP Licensing P.O. Box 128 James A. Pitzpatrick Nuclear Power Plant Waterford, CT 00385 P.O. Box 41 (203) 440-2089 Lycoming, NY 13093 (315) 349-6365 Ted C. Peipnbaum Senior Vice President & Chief Nuclear Officer - NAESCO, P.o. Box 300 p ~ Seabrook, Nil 03874
. NIAGARA MOHAWK POWER (603) 474 9521, Ext. 4400 .' CORPORATION:
lloills P. Risley W. David Baker Director Engiacering
- NRC Program Director P.O. Box 128 P.O. Box 63, Lake Road Waterford, CT 06385 Lycoming, NY 13093 (203) 437-5918. Ext. 5918 (315) 3494 245 Richard M. Kacich Martin J. McConnick, Jr. Director Nuclear Planning, Vice President, Nuclear Safety Licensing & Budgeting Assessment & Support P.O. Box 128 Nine Mile Point Waterford, CT 06385 0128 P.O. Box 63 (203) 440-2076 Lycoming, NY 13093 (315) 349-2660 James M. Peschel Regulatory Compliance Manager Mike O. Mosier NAESCO, P.O. Box 300 Licensing Engineer Seabrook, Nil 03874 P.O. Box 63, Lake Road (603) 474 9521. Ext 3772 Lycoming, NY 13093 peschjm@naesco.com (315) 349-7577 Denise J. Wolnlak Manager Licensing P.O. Box 63, Lake Road Lycoming, NY 13093 (315) 349-4246 Retshga/;ggWerrace > 21 4
William J. Qu!nl:.n Att:rnef !. ,
, NPP KRSKO P.O. Box 270 Jose Spile. r 11artford, CT 061410270 Licensing Superintendent (203) 665 3761 Vibina 92 Krsko, Slovenia 68270 Stephen E. Scace (386) 6082 % 29 Vice President . Nuclear Operations Services P.O. Box 128 Waterford, CT 06385 .(203) 437 2600 Mike J. Wilson b ' . NUCLEAR ENERGY INSTITUTE (NEI) '
Manager Nuclear Licensing P.O. Box 128 Ralph L. Andersen Waterford, CT 06385-0128 Project Manager (203) 440-2081 17761 Street, NW Suite 400 Washington, DC 20006 j_ . (202) 739-8111 NORTHERN STATES POWER COMPANY : Roger O. Anderson Project Manager Director, Licensing & Management issues 1776 I Street, NW 414 Nicollet Mall Suite 400 Minneapolis, MN 55401 Washington, DC 20006 (612) 337 2051 (202) 739-8144 Theodore (Ted) E. Amundson Russell J. Bell Director, Generation Quality Service Project Manager Advanced Reactors 414 Nicollet Mall (RS8) 1776 i Street, NW Minneapolis, MN 55401 Suite 400 (612) 337 2200 Washington, DC 20006 (202) 739 8087 David M. Musolf Consulting Production Engineer Robert W. Bishop Monticello Nuclear Plant Vice President & General Counsel Monticello, MN 55362 17761 Street, NW (612) 295 1201 Suite 400 Washington, DC 20006 3708 Michael D. Wauley (202) 739-8139 Plant Manager 1717 Wakonade Drive East Biff Bradley Welch, MN 55089 Project Manager (612) 3881121. Ext. 4564 1776 i Street, NW Suite 300
. Edward L. Watzl Washington, DC 20006 Vice President Nuclear Generation .(202) 739-8083 ,
414 Nicollet Mall, (RSQ 8) Red Wing, MN 55401 (612) 330-7719 Resulmogntyggonierence > 22 < l
__-_._.r _.._ .._ _ _ _ _ _ _ . _ __ _ _ _ _ _ _ . _ _ __ _ .. __._ _ _ _ _ '. l
R. Clive Callaway Alexander Marlon 1
Project Manager Manager 17761 Street, NW 17761 Street, NW ? Suite 300 Suite 400 Washington, DC 20006 Washington, DC 20006
= (202) 739,8114 ;
(202) 739-8080 t Kurt O. Cozens David J. Modeen i Project Manager Manager. Operatiom and Management l 1776 i Street, NW 1776 i Street, NW Suite 400 Suite 300 Washington, DC 20006 Washington, DC 20006
(202) 739-8085 (202) 739 8084 I James H. Eaton Warren P. Murphy l Project Manager Executive Assistant to the Vice President 17761 Street, NW 1776 i Street, NW l Suite 300 '
Washington, DC 20006 Washington, DC 20006 (202) 739 8099 ,
(202) 739 8115 caton02@ ibm. net Lynne Neal Senior Writer

Stephen D, Floyd 17761 Street, NW Director - Nuclear Economics Suite 400 1776 i Street, NW Washington, DC 20006 Washington, DC 200006 (202) 739-8037 l (202) 739-8078 Ray N. Ng Ellen C. Ginsberg Manager, Licensing & Performance Regulation Assistant General Counsel 1776 i Street, NW 1776 i Street NW. Suite 400 Washington, DC 20006 Washington, DC 20006 3708 (202) 739 8095 (202) 739-8140

James A. Perry .
t Melvin W. Gmyrek . Project Manager, Engineering Project Manager . Advanced Reactors 17761 Street, NW i 1776 i Street, NW Suite 400
Suite 400 Washington, DC 20006 1
Washington, DC 20006 (202) 739-8138 (202) 739 8096 - _ Anthony R. Pietrangelo
. Arland L MacKinney Project Manager Project Manager 17761 Street, NW
] 1776 i Street, NW Suite 400-
Suite 400 - Washington, DC 20006 Washington, DC 20006 (202) 739-8081 j (202) 739 8137 i
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_ _ - - . . _. _ _ _ _ _ .~ . _ _ _ _ _ _ . . . _ _ _ _ _ William II. Rasin George C. Wu Vice President Technical / Regulatory Division Project Manager 1776 l Street, NW 17761 Street, NW - Suite 300 Washington, DC 20006 Washington, DC 20006 (202) 739 8086 (202) 739-8088 r Phyllis M. Rich ' " Technicri Assistant [ NUCLEAR INFORMATION & RESOURCE 1776 i Street, NW c SERVICE ' Suite 30n Washington, DC 20006 Paul V. Gunter ' (202) 739-8079 Reactor Watchdog Project, Director 142416th Street, NW, Suite 601 Mehdi Sarram Washington, DC 20036 Project Manager (202) 328-0032 1776 i Street, NW nirsnet@aol.com Washington, DC 20006 (202) 739-8181 Mary Olson Reactor Watchdog Project. Dhector John F. Schmitt 142416th NW, Suite 601 Directo.- Washington, DC 20036 1776 i Street, NW (202) 328-0002 Washington, DC 20006 nirsnet@aol.com (202) 739 8108 Ronald L. Simard
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T Director l, : NUCLEAR MUTUAL LIMITED 1776 i Street, NW Suite 400 Gregory G. Wilks Washington, DC 20006 Vice President lfss Control (202) 739 81?.8 1201 Market Street, Suite 1200 Wilmington, DE 19801 Tom Tipton (302) 573 2273 Vice Presikr.t 1776 i Street, NW " ' Suhe 400 : ' NUCLEAR POWER ENGINEERING -: Washington, DC 20006 ' e, >
~ CORPORATION 1 ^ ^ '
(302) 739 8107 Akimoto Seiichi Douglas J. Walters Manager, Office of Nuclear Safety Planning Project Manager 4F, Fujita Kanko Toranomon Bldg. 17761 Strut, NW 171,3-Chohme, Toranomon, Minato-ku, Tokyo,105 Suite 400 (3) 5470-54S6 Washington, DC 20006 l (302) 739 8093 I l l Regauoq, fgrygonference > 24 4
p Kurt M. Taylor
= NUS CORPORATION ,
General Manager 180 Sycamore Bend Rod K. Buckles Fayetteville, GA 30214 Manager, Licensing Information Service (404) 460-8904 2650 McCormick Drive
! Cleawater, Fl. 34619 Jon G. White (813) 796 2264 Senior Executive Consultant i
tbuckles@nus.com 2650 McCormick Drive Suite 300 Clearwater, FL 34619 Darrell G. Eisenhut (813) 796 2264 President ' 910 Clopper Road F Gaithersburg, MD 20878 ! OMAHA PUBLIC POWER DISTRICT' (301) 258-2524
, Terry L. Patterson Stephen V. Guarcello Division Manager Nuclear Operations Program Manager P.O. Box 399 2650 McCormick Drive, Suite 300 liighway 75 North of Fort Calhoun Clearwater, FL 34619 Fort Calhoun, NE 68023 (813) 796-2264 (402) 636-6669 j
Paul W. liarar Delvin R. Trausch Director, Business Development P.O. Box 399 . 910 Clopper Road liighway 75 North of Fort Calhoun Gaithersburg, MD 20878 Fort Calhoun, NE 68023 (30l) 258 2439 (402) 636-6609 Edward D. Ilollis - Director, Business Development '
; ON MARC CONSULTING :
910 Clopper Road Gaithersburg, MD 20878 Todd P. Malts (301) 258-1863 5204 Clinton Avenue, S. Minneapolis, MN 55419 David N. Perkey (612) 823-0703 Manager, TRENDS 2650 McComilck Drive, Sulic 300 n
Clearwater FL 34619 ~ OTHER PRIVATE COMPANIES & -
(813) 7%-2264 Ext. 4441 , 3 CONSULTANTS perkeycix,netcom.com Paul W. Eshleman
;rrdan S. Peter Consultant Program Manager 17415 Applewood Lane 2650 McCormick Drive, Suite 300 Derwood, MD 20855 Clearwater, FL 34619 (301) 548-0399 (813) 796-2264 Ext. 4441 William S. Farmer Consultant , 10115 Green Forest Drive Silver Spring, MD 20903 (301) 434 8263 suptasogigtgontenace > 25 <
Lcurence S. Gifford Consultant 5914 Benfield Drive PECO ENERGY Alexandria, VA 22310 (703) 960-2151/ 0032 Garrett D. Edwards Plant Manager RD 1 Box 208 p Delta PA 17314 [- PACIFIC GAS AND ELECTRIC COMPANY (717) 456-4244 James E. Tomkins David P. IIelwig Director Vice President P.O. Box 770000, MCA10A (610) 327 1200 San Francisco, CA 94177 (415) 973-2466 Marilyn C. Kray Manager, Peach Bottom Licensing Lawrence P. Womack 965 Chesterbrook Blvd. Vice President Wayne, PA 19087 333 Market Street 8024 (610) 640-6789 San Francisco, CA 94105 (415) 973-0601 Glenn 11, Stewart Ifwl@pge.com Enginect-Experience Assessment Limerick General Sistion [- P.O. Box 2300 PACIFIC NORTHWEST LABORATORY Sanatoga, PA 19464 2300 (610) 718-3411 Alvin R. Ankrum 2320 Q. Avenue, K8 31 Anthony J. Wasong Richland, WA 99352 Manager, Experience Assessment (509) 372-4095 Road #1, Box 208 Delta, PA 17314 Eugene (Joe) Cleary (717) 456-4744 Project Manager Battelle Boulevard Richland, WA 99352 ~ ' (509) 372-4094 PENNSYLVANIA DEFI'. OF ENVIRONMENTAL' RESOURCES / BUREAU OF RADIATION Mitchel E. Cunningham g, ; PROTECTION' NRC Program Of0cc Manager P.O. Box 999 Rich Janati Richland, WA 99352 Nuclear Safety Division Chief (509) 372-4987 P.O. Box 8469 liarrisburg, PA 17105 g - ~- -~
.7 (717) 787 2163
[iu.a PARADIGM CONSULTING. Jeffrey D.E. Jeffries President 104 Torrey Pines Drive Cary, NC 27513 (919) 481-4578 Regulato n.fg,r,on goQrence > 26 <
[ PENNSYLVANIA POWER O LIGHT : , POLESTAR APPLIED TECHNOLOGY Edgar W. Figard John D. Trotter hianager Nucl:ar Infonnation Services 4 Main Street P.O. Box 467 Los Altos, CA 94022 Berwick, PA 18603 (415) 948 8242 (717) 759 4994 johnt@ polestar.com Raymond ht. Ilarris Senior Project Specialist
! PORTLAND GENERAL ELECTRIC COMPANY) 2 N 9th Street Allentown, PA 18101 hiark hiullen (610) 774 7307 71760 Columbia River liighway Rainier, OR 97048 George T. Jones (503) 556 7480 Vice President Nuclear Engineering 2 N. Ninth Street, A61 '
Allentown, PA 18101 PROGRAMMATIC SOLUTIONS, (610) 774 7602 INCORPORATED James hl. Kenny liarry W. Johnson Supervisor Nuclear Licensing Senior Consultant 2 N. Ninth Street, A6-1 24 Woodbine Avenue, Suite 12 Allentown, PA 18101 Northport, NY 11768 (610) 774 7535 (516) 261 5536 Patricia L. hilkus Donald 11. Rutherford Senior Project Engineer Senior Consultant 2 N. Ninth Str;tt, A6-1 24 Woodbine Avenue, Suite 12 Allentown, PA 18101 Northport, NY 11768 (610) 774 7815 (516) 261-5536 Rocco R. Sgarro 1
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Senior Project Engineer >' PROTO-POWER CORPORATION 2 N. Ninth Street, A6-1 ' Allentown, PA 18101 Kenneth A. Ewell (610) 774 7552 1 resident 591 Poquonnock Road Richard R. Wehry Groton, CT 06340 Power Production Engineer (203) 446-9725 P.O. Box 467, S&A4 Berwie'. , PA 18603 (717) 542 3664 r PUBLIC CITIZEN James P. Riccio Staff Attorney 215 Pennsylvania Avenue, SE Washington. DC 20003 (202) 546-4996
Frank X, Thomson F~< Manager iPG8LIC SERVICE COMPANY OF COLORADO" P.O. Box 236 * [- llancocks Bridge, NJ 08038 (609) 339 1286 Michael 11. Ilolmes Project Assurance Manager 16805 WCR 191/2 Platteville, CO 80651 PUBLIC UTILITIES COMMISSION-(303) 620 1701 John N. Vitellas F Energy Specialist
, PUBLIC SERVICE ELECTRIC AND GAS - 180 East Broad Street
[ COMPANY,(PSEAG) Columbus, 01143226-0573 (614) 644 5480 Jeffrey A. Benjamin Director-QA/NSR P.O. Box 236 RAYTHEON NUCLEAR llancocks, Bridge, NJ 08038 (609) 339 1400 Edward J. Borella Chief Engineer Robert J Dolan 2 World Trade Center Principal Engineer - Chemistry New York, NY P. O. Box 236, MC N51 (212) 837 3245 llancocks Bridge, NJ 08038 (609) 339-2471
' ROCHESTER' GAS & ELECTRIC (RG&E)
Leon Eliason CNO & President Nuclear Business Unit Glenn A. llennes PSE&G NDAB N09 Senior Engineer P.O. Box 236 89 East Avenue llancocks Bridge, NJ 08038 Rocherster, NY 14649 (609) 339.I101 (716) 124-8013 Dave Dodson George J. Wrobel Principal Engineer Licensing & Regulations Manager Nuclear Safety & Licensing PSE&G NDB-N21 89 East Avenue llancocks Bridge, NJ 08038 Rochester, NY I4649 (609) 339 1282 (716) 724-8070 Christopher Pupek Senior Staff Engineer-PRA MC N20 P.O. Box 236 'S, LEVY INCORPORATED : llancocks Bridge, NJ 08038 (609) 339-5336 Joseph A. Famiglietti President /CEO Dave Smith 3425 S. Bascom Avenue Prinicpal Engineer Licensing & Regulations Campbell, CA 95008 PSE&G NDAB-N21 (408) 377-4870 llancocks Bridge, NJ 08038 (609) 339--1282 Regulatoqfgegoderence > 28 <
Don K. Schapfer { j,;, ,SARGENT & LUNDY. Vice President 55 E. Monroe Stteet Bernard Andrews Chicago, IL 6%03 Principal Engineer (312) 269-6078 55 E. Monroe Street,24th Floor Chicago, IL 60603 s (312) 269 3804 l SCIENCE & ENGINEERING ASSOCIATES, INCORPORATED Dennis Demoss ^ ~' Associate & Project Manager Frank W. Sciacca
$5 E. Monroe Program Manager Chicago,IL 60603 6100 Uptown Blvd.
(312) 269 3737 Suite 700 Albuquerque, NM 87110 Dennis P. Galle (505) 880-9858 Executive Consultant 55 E. Monroe Street Gilbert L. Zigler Chicago,IL 60603 Senior Engineer (312) 269-6443 6100 Louisiana Blvd.. NE Albuquerque, NM 87190 Roger C. Ileider (505) 884 2300 Senior Vice President 55 E. Monroe Street L .
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Suite 23 ;' SHAW, PITTMAN, POTTS & TROWBRIDGE Chicago, IL 60603 (312) 269 7046 David R. Lewis Partner Dwight J. Johnson 2300 N Street NW Project Engineer Washington, DC 20037 18893 N, St. liighway 106 (202) 663 8474 Scranton, AR 72863 (501) 938 7016 John 11. O'Neill, Jr. Partner Kenneth T. Kostal 2300 N Street, NW Executive Vice President Washington, DC 20037 55 E, Monroe Sneet (202) 663 8148 Suite 23 Chicago, IL 60603 Mitchell S. Ross (312) 269 7713 Associate 2300 N Street, NW Brian L. Renwick Washington, DC 20037 Vice President (202) 663-9351 55 E. Monroe Street Chicago,IL 60603 (312) 269-2498 ResulmypyggjWerm > 29 <
a l Frank M. Quinn (. SEQUOIA CONSULTING GROUP Senior Principal Engineer 11140 Rockville Pike Daniel L. Maret Rockville, MD 20852 Program Manager (301) 468-6426 Ext. SN 247 N. Main Street Randolph, MA 02368 F (617) 961 9556 i SOUTH CAROLINA DEPARTMENT-HEALTH & ENVIRONMENTAL CONTROLE if . _ W Roruld W. Kinney [ SIEMENS POWER CORPORATION Director Division of Waste Assessment & Emergency Response Robert Copeland 2600 Bull Street Manager, Product Licensing Columbia, SC 29201 3101 llorn Rapids Road (803) 896-4092 Richland, WA 99352 (509) 375-8290
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1 l SOUTH CAROLINA ELECTRIC & GAS SCIENTECH, INC. , j COMPANY Charles A. Gepford Robert M. Fowlkes 11140 Rockville Pike Manager, Nuclear Licensing & Rockville, MD 20S52 Operating Experience (301) 468-6425 P.O. Box 88 Jenkinsville, SC 29065 Steven M. Pope (803) 345-4210 Senior Engineer 11140 Rockville Pike Gary J. Taylor Suite 500 Vice President, Nuclear Operations Rockville, MD 20852 P.O. Box 88 (301) 468-6426 Ext. 503 Jenkinsville, SC 29%5 spope@scientech.com (803) 345-4344 Marlin Strand 11;40 Rockville Pike r~ ~ ^ ' Rockville, MD 20852 ISOUTHERN CALIFORNIA EDISON COMPANY:
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(301) 468-6425 shrrbait@ scientific com Walter C. Marsh Robert L, Tedesco Manager of Nuclear Regulatory Affairs Sr. Technical Advisor 23 Parker Street 600 Maryland Avenue, SW Irvine, CA 92718 Washingten, DC 20024 (714) 454-4403 (202) 488-1464 liarold B. Ray Senior Vice President 2244 Walnut Grove Avenue Rosemead, CA 91770 (818) 302-1695 Regulatoy nigr,m,argonference > 30 <
Richard M. Rosenblum Brad Moore Vice President Manager, Licensing 23 Parker Street P.O. Box 1295 Irvine. CA 92718 Birmingham, AL 35201 4 (710 458-4550 (205) 868
3 3 v . .
g SOUTHERN COMPANY SERVICES
- SOUI1 TERN TECHNICAL SERVICES, INC. -
Charles B. lleard Senior Engineer Lynn Connor P.O. Box 2625 3 Metro Center Birmingham, AL 35202 Bethesda, MD 20814 (205) 870-6878 (20l) 652 2500 William C. Ramsey Ted L. Heatherly Manager, Nuclear Technical Services Director of Operations P.O. Box 2625 3 Bethesda Metro Center. #610 Birmingham, AL 35202 Bethesda, MD 20814 (205) 877 7936 (30l) 652 2500 wramsey@sesnet.com R. Paul Rec, Jr.
~t Regulatory Compliance Engineer 3 Bethesda Metro Center #610 SOUTHERN ~
NUCLEAR OPERATING COMPANY ' Bethesda, MD 20814 (301) 652 2500 James A. Bailey Manager, Licensing Michael A. Schoppman 40 invernes Center Parkway Manager Bethesda Office Birmingham, AL 30521 3 Metro Center, #610 (205) 877-7097 Bethesda, MD 20814 (30l) 652 2500 Don M. Crowe Licensing Services Manager Lloyd P. Zerr P.O. Box 1295 Licensing Specialist Birmingham, AL 35216 3 Bethesda Metro Center, #610 (305) 877 7248 Bethesda, MD 20814 (30is 652 2500 Robin L. Dyle Project Engineer P.O. Box 1295 - *
Birmingham, AL 35201 SRI -
(205) 877 7121 Thomas E. Ilicks Ben J. George Senior Consultant Manager Licensing Services 5603 Madison Street P.O. Box 1295 Bethesda, MD 20817 Birmingham, AL 35201 (301) 530 2653 (205) 877 7870 Regulato fg,rganogj'enference > 31 4
g 1 . b . ri Omar S. Mazzon! '
,1 President .SMM" 'l NUCLEAR POWER k, 120 E. Baltimore Street ' - NSPECTORATE '
7 Suite 1910 Baltimore, MD 21202 trene Blom (410) 685-3833 S 10658 Stockholm, Sweden S-10658 (+468) 698-8400, Ext. 8471 y . nm . . STATE GOVERNMENT NEW JERSEY
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L 3 TAIWAN POWER COMPANY:~ L Richard H. Pinney
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Nuclear Engineer Wen-Shir Chih CN 415 Supervisor, BWR Licenshg, NSD Trenton, NJ 08625 242 Roosevelt Road, Section 3 (609) 987 2086 Taipei,10763, Taiwan, R.O.C. Taipei, Taiwan 10763 Dennis J. Zannoni (02) 366-7618 Supervisor-Nuclear Engineer CN 415 Trenton, NJ 08625 (609) 987 2037 TECHNICAL' MANAGEMENT CONSULTING! Lee A. Oxsen ) - I'~ a_ ( . '. ...f
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f STETLER- AND t.S,3OCIATES( Consultant Rte.1, Box 5469 Richland, WA 99352 Claudia G. Stetler (509) 967 3139 Management Consul 0 P.O. Box 331 ' ~ Beaver, PA 15009 STECHNOGRAM - _ (dOO) 284-1051 Michel Rozenhole r President P"" " " "
?Y 267 Lecourbe SSTONE &LWERSTER ENGINEERING .
Paris, France 75015 {, JCORPORATION: , . , (331) 45573024 Ajoy K. Banerjee Manager of Projects ' ' 245 Sununer Street iTECRO: Boston, MA 02210 (617) 589-1298 Frank Y.K. Fu Deputy Director Steven L. Stamm 4201 Wisconsin Avenue, NW Nucleu Business Manager Washington, DC 20016 245 Summer Street (202) 895-1932 Boston, MA 02210 (617) 589-7499 l Retuutogiqujogonference > 32 A
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,g 1ENNESSEE VALLEY AUTHORlTYi .
917 TNT
$ TEXAS UTILITIES ELECTRIC James E. Blackburn '
Nuclear Assurance & Licensing Manager Tim Hope P.O. Box 2000 - Regula:ory Compliance Manager Hollywood, AL 35752 P.O. Box 1002 Mail Stop A08 (205) 574-8070 Glen Rose, TX 76643 (817) 897-6370 Donald P. Ferraro Nuclear Licensing Attorney James J. Kelley, Jr. 400 W. Summit Hill Drive /ET10204A-K Vice President, Nuclear Engineering & Support Knoxville, TN 37902 1601 Bryan Street (615)632-7317 Dallas, TX 75201 (214) 812 8688 Roger W. Huston Manager, Rockville Licensing Office Wes M. Taylor 11921 Rockville Pike, Suite 402 Executive Vice President Production Rockville, MD 20852 1601 Bryan Street (301) 770-6790 Dallas, TX 75201 (214) 812-4699 John P. Maciejewski
. wing General Manager Lance C. Terry Wlear Assurance and Licensing Group Vice President, Nuclear 1 rJ1 Market Street, LP 3B 1601 Bryan Street .hattanooga, TN 37402 Dallas TX,75201 (615) 751-4929 (8174) 897-8920 Pedro Salas Roger D. Walker Manager, Licensing Regulatory Affairs Manager P.O. Box 2000 1601 Bryan Street Decatur, AL 35609 Dallas, TX 75201 (205) 729-7556 (214) 812-6866 Matk O. Sanford E*"" " ' ' ' "
Manager, Corporate Licensing /New General Planning b
~ TENERA, " " ~ ~
LIMITED PARTNERSHIP; ,3 1101 Market Street, BR-4G
' Chattanooga, TN 37402-2801 Jude G. Del Percio (615) 751-4747 Senior Consultant mosanford. office @mhs-tva.attmail.com 4250 Veterans Memorial Highway Holbrook, NY 11741 Ralph H. Shell (516) 737-5075 Licensing Manager P.O. Box 2000 Rick B. Ennis Soddy-Daisy, TN 37379 Project Manager (615) 843-7170 1901 Research Blvd.
Rockville, MD 20850 (301) 294-3740 Regulato inf onference > 33 <
Michael E. Schefers Princip:1 Consultant UNITED KINGDOM HEALTH & SAFETY 1901 Research Blvd. EXEC. (Nil) Rockville, MD 20850 (301) 294 3740 Alan C. Rae Principal Inspector
St Peters llouse LTRW ENVIRONMENTAL SAFETY SYSTEMS' Ballioc Road

1NCORPORATED; Bootle, Liverpool L616XG (151) 951-3706 Ext. 3706 Ramon L. Ashley Consultant William M. Ross 101 Convention Center Drive Deputy Chief Inspector Las Vegas, NV 89109 St Peters llouse (702) 794-1848 Ballioc Road Bootle, Liverpool L616XG Homi Miawalle (151) 951-4169 Ext. 4169 Management & Operating Senior Staff Engineer 600 Maryland Avenue SW, Suite 695 .
Washington, DC 20024 U.S. DEPARTMENT OF ENERGY (202) 488-2306 Samuel F. Armour x Department of Energy Project Manager
, TOKYO ELECTRIC POWER COMPANY - 850 Energy Drive (MS1219)
Idaho Falls, ID 83401 Hiroaki Yasui (208) 526-1951 Manager inelarmoursf 1901 L Street, NW Suite 720 Washington, DC 20036 4 (202) 457-0790 U.S.' GENERAL ACCOUNTING OFFICE toS79748@pmail.tepc.co.jp
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Odell W. Bailey sjTOLEDO EDISON; COMPANY t Senior Evaluator Patrick V, McNamara Federal Building Ted J, Myers 477 Michigan Avenue Director-Nuclear Assurance Suite 865 300 Madison Avenue Detroit. MI 48226 Toledo, OH 43652 (313) 256-8091 (419) 249-2306 Javier J. Garza William T. O'Connor Senior Evaluator Manager Regulatory Affairs Patrick V. McNamara Federal Building 300 Madison Avenue 477 Michigan Avenue Suite 3065 - Suite 865 Toledo, OH 43652 Detroit, MI 48226 (419) 249-2366 (313) 256-8N5 Regulato f onference > 34 < _ _ - - - --- J
Tony A. Krukowski Manager Bob E. Sojka Patrick V. McNamara Federal Building Operations Support Manager 477 Michigan Avenue Old Ferry Road Suite 865 Brattleboro, VT 05301 Detroit, MI 48226 (802) 258-4111 (313) 256-8026 James O. Weigand George W. Moore, Jr. President /CEO Evaluator Ferry Road Patrick V. McNamara Federal Building Brattleboro, VT 05301 Suite 865 (802) 257-5271 Ext. 200 Detroit, MI 48226 (313) 256-8145
- , .-" ^ 'I IA' DEPARTMENT.OF.'EMERGENCYL ' . . U.TILITIES INTERNATIONAL 1 > SERVICES -
Fred E. Jennings George O'N. Urquhart Vice President Deputy Director, Plans Division 2860 River Road 310 Turner Road Suite 375 Richmond, VA 23225 Des Plaines,IL 60018 (804) 674-2438 (708) 390-6060 t m,n ,. , c ~ n
;"'VIRGIN 11 ELECTRIC & POpT.RyOMPANYf ~20 ;jVECTRA TECHNOLOGIES) ,
William R. Benthall James H. Riley Supervisor - Licensing Project Manager 5570 Hog Island Road Ship Point Research Park, Bldg. F Surry, VA 23883 13325 Rousby Hall Road (804) 365-2074 Lusby, MD 20657 (410) 326-7102 Marty L. Bowling Manager-Nuclear Licensing and Programs x 5000 Dominion Blvd j , , _ . . " r *' ' ' ' Glen Allen, VA 23060 s VERMONT YANKEE NUCLEAR POWERi _ (804) 273-2699 [ba- naa _ [CORPORNIJONc , . g Herbert M. Fontecilla Donald A. Reid P.O. Box 7470 Vice President Operations Arlington, VA 22207 Ferry Road (703) 527-2217 Brattleboro, VT 05301 (802) 258-4102 David A. Heacock Assistant Station Manager Nuclear Safety & Licensing P.O. Box 700 Mineral, VA 23117 (703) 894-2108 Regulato inf m onference > 35 4
l Joseph D. liegner Don L. Cecch.tt Supervisor Licensing Senior Engineer 5000 Dominion Blvd. Northern Pike
Glen Allen, VA 23060 Monroeville, PA 15146 (804) 273 2770 (412) 374-4999 joch@aol.com Sharon L. Ellenberger Michael R. Kansler Senior Engineer, Integrated Programs Vice President Nuclear Services P.O. Box 355 5000 Dominion Boulevard Pittsburgh, PA 15230 Glen Allen, VA 23060 (412) 374-4794 (804) 273-3586 L. Ike Ezekoye John A. Stall Engineer Station Manager-North Anna Power Station P.O. Box 355 P.O. Box 402 Pittsburgh, PA 15230 Mineral, VA 23117 (412) 374-6643 (703) 894-2101 John S. Galembush Senior Engineer
""' " " " 'C " " "
P.O. Box 355 h iWASHINGTON PUBLIC POWER SUPPLY: Pittsburgh, PA 15230 km au 2$I @ . . (412) 374-5036 galembush .J .s . % wec@chalcom.tymnet .com Paul R. Bemis Director Regulatory & Industry Affairs Nayeem M. Farukhi P.O. Box 968 Program Manager Riclunond, WA 99352 P.O. Box 355 (509) 377-4027 Pittsburgh, PA 15230 (412) 374-4557 William G. Counsil Managing Director Tony Granada P.O. Box M8 Director Nuclear Technology Marketing Richland, WA 99352 P.O. Box 355 (509) 372-5504 Pittsburgh, PA 15090 (412) 374-6770 J. Vic Parrish Vice President Nuclear Operations Robert R. Laubham P.O. Box %8 Senior Engineer Richmond, WA 99352 4334 Raynard Drive (509) 377-8222 Murrysville, PA 15668
.m.mm, (412) 374-4707 - .- e g[ WESTINGHOUSE ELECTRIC CORPORATION Nick Liparuto$
Marc Beaumont (412) 374-5169 Manager, Rockville Licensing 11921 Rockville Pike
#450 Rockville, MD 20852 (301) 770-1M8 Regulato inf m nference > 36 <
_ _ _ - - _ _ - _ _ _ _ _ _ - - - . - -__-_-_- _--______--__-_-__ _ __n
Daniel S. Lipman llank Sepp Project Manager Manager, Regulatory Infonnation Sycs. P.O. Box 355 413 Franklin lielghts Drive Pittsburgh, PA 15230 Monroer^dle, PA 15146 (412) 374-6920 Steven Tritch Brian A. McIntyre General Manager Manager, Advanced Plant Safety & Licensing P.O. Box 355 Box 355 Pittsburgh, PA 15230 Pittsburgh, PA 15230 (412) 244-2000 (412) 374-4324 Maureen Zawalick Thomas D. Moser P.O. Box 355 Manager, RCS Engineering & Field Service Pittsburgh, PA 15235 P.O. Box 855 (412) 374-4826 Pittsburgh, PA 15230 (412) 829-3980 moser.t%wec@dialcom.tymnet.com
. UNION ELECTRIC -
A. Joseph Nardi Supervisory Engineer Dave E. Shafer P.O. Box 355 Supv. Engr. - Licensing Pittsburgh, PA 15230 P.O. Box 149 (412) 374-4652 St. Louis, MO 63166 (314) 554-3104 Edward M. Petrosky Senior Engineer P.O. Box 355 ' Pittsburgh, PA 15230 WINSTON & STRAWN (412) 374-6384 James R. Curtiss Carl W. Pro Partner Principal Engineer 1400 L Street, N.W. P.O. Box 355 Washington, DC 20005 Pittsburgh, PA 15230 (202) 371-5751 (412) 374-4820
. vhael McGarry Dale E. Rugg Partner Manager, Strategic Operations 1400 L Street, N.W.
P.O. Box 355 Washington, PC 20005 Pittsburgh, PA 15230 (202) 371-5733 (412) 829-3920 rugg.d.e % wec@tyrrnet.dialcom.com Nicholas S. Reynolds Partner Roger M. Schene 1400 L Street, N.W. Manager Washington, DC 20005 P.O. Box 355 (202) 371-5717 Pittsburgh, PA 15230 (412) 374-3852 Regulato inf onference > 37 <
l Daniel P. Stenger Thomas G. Mulanowski ltrtner Project Engineer Licensing 1400 L Street, N.W. 231 W. Michigan Street P377 '
- Washington, DC 20005 Milwaukee, WI 53201 (202) 371 5742 (414) 221 3950 Duane D. Schoon ^ r' '
Manager Regulatory Services A WISC,4ONSIN ELECTRIC- POWER w- _ . - m COMPANY 6610 Nuclear Road Jeff E. Anthony (414) 755-6680 Manager Quality Assurance 231 W. Michigan Street - P377 ^
""~ " '" ^ "'
Milwaukee, WI 53201 yISCONSIN;PU'BLIC SERVICE CORPORATIONj (414) 221-2481 Kenneth H. Evers Gary M. Krieser Manager Nuclear Plant Support Services Manager-Industry & Regulatory Services N490, Highway 42 231 W. Michigan Street - P377 Kewaunee, WI 54216-9510 Milwaukee, WI 53201 (414) 388-2560, Ext. 2009 (414) 221 2810 Thomas R. Grow Bob Link Control Room Supervisor Vice President Nuclear Power Kewaunee Nuclear Plant 231 W. Michigan Street - P377 N 490, Highway 42 Milwaukee, WI 53201 Kewaunee, WI 54216-9510 (414) 221 2811 (414) 382-2560, Ext. 2202 Thomas G. Malanowski Gary 1. Harrington Senior Project Engineer Engineering & Technical Support Analyst 231 W. Michigan Street Kewaunee Nuclear Plant Milwaukee, WI 53201 N 490 Highway 42 (414) 221-3950- Kewaunee, WI 54216-9510 (414) 388-2560, Ext. 2559 Mark Marchi Manager Kevin C. McCann 231 W. Michigan Street - P377 Engineering Systems Group Leader Milwaukee, WI 53201 N 490 Highway 42 (414) 221-2811 Kewaunce, WI 54216 (414) 388-2560, Ext. 2410 ' Greg J. Maxfield Nuclear Operations Manager
, Point Beach 6610 Nuclear Road Two Creeks, WI 54241 (414) 755-6212 Michael G. Millen Senior Nuclear Engineer 231 W. Michigan Street Milwaukee, WI 53201 (414) 221-3372 Regulato inf Conference > 38 <
-- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - = - - -
3 n:,v-,. w m:+, ,- an + :w , m k ' iWOLF . CREEK NLACLEAR; b ~.m, _! O_P_ ERAT _ING CORPO. RATION _. . s Neil S. Carns Chairman, President & CEO P.O. Box 411 Burlington, KS 66839 (316) 364-4100 Richard D. Flanningan Manager Regulatory Services P.O. Box 411 Burlington, KS 66839 (316) 364-8831, Ext. 4500 Michael Lindsay Manager Performance Assessment P.O. Box 411 Burlington, KS 66839 (316) 364-8831. Ext. 8760 Lori A. Sutton Engineering Group Leader Kewaunee Nuclear Plant N490 Hwy. 42 Kewaunee, WI 54216
- (414) 388-2560, Ext. 2278 ~-
g-, wr wyp mm , ep mmq (($ YANKEE ATOlyC ELECTRIC 50MPANR , 3 Jane M. Grant Manager 580 Main Street Bolton, MA 01740 (508) 779-6711, Ext. 2112 grant @ yankee.com John D. Sutton Principal Engineer 580 Main Street Bolton, MA 01740 (508) 779-6711, Ext. 215I sutton@ yankee.com Regulato nf nn gonference > 39 < 1
4 y a ery* v A t DNRC AND OTHER LOCAL , h jGOVERNMENT ATTENDEESJ Soma A, Bainette Carol F. Abbott NRR/NRC/DOPS NRC/Of0cc of the Controller (301) 415-6034 Singh Bajwa NRR/NRC/DOPS Elinor G. Adensam (301) 415 1013 NRR/NRC (301) 415-1353 Robert C. Barr Region IV/NRC Bamidele Akins (509) 377-2627 Nrr/DE (301) 439-3855 William H. Bateman NRR/NRC (301) 415 1372 Francis M. Akstulewicz NRR/NRC William M. Beecher (401) 415-1136 OPA (301) 415-8200 Ronald J. Albert Region 1 James L. Belanger (610) 337-5268 Region Ill/NRC (708) 829-9858 Pat Alexander U.S. Department of Engery Eric J. Benner (208) 526-1951 NRR/NRC/DOPS (301) 415-1171 RAJ Anand NRR/PDLR Thomas A. Bergman (310) 415-1146 NRR/ DOTS /TQMB (301) 415-1021 Ralph Architzel NRC/NRR Herbert N. Berkow NRR/DRPE/PDil-3 Samuel F. Armour (301) 415-1485 DOE-ID Mary Ann Biamonte
- Frank S. Ashe NRR/DRPE/PHDil 3 NRR/NRC (30l) 415-1073 (301) 415-2785 Suzanne C. Black - Ramin Asia NRR/ DOTS /TQMB NRR/NRC (301) 415-1017 (301) 415-1391 Odell W. Bailey USGAO tp R0 M OnfUtNCC > kh A i
p. Bruce A. Boger . Patrick 1. Castirman NRR/NRC NRR/ DISP ,:* (301) 415-1004 (301) 415-3747 James Bongarra Pel Ying Chen NRR/DRCH/HHFB NRR/NRC (30l) 415-1046 (30!) 415-2789 Bill Borchardt Angela T. Chu NRR/ADAR/PDST NRR/DOPS (301) 415 1118 John M. Clauss Thomas H. Boyce Sandia National Labhoratories NRR/ADAR/PDST (505) 844 5449 (301) 415-1130 thb@nrc. gov Timothy O. Colburn NRR/PD-31 William F. Burton (301) 415-1341 NRR/NRC/DSSA (301) 415-2853 Laban L. Coblentz NRR/PIPB L.J. Callan (301) 415 2619 Region IV 4 (817) 860-8225 Joseph Colaccino NRR/DE Jose A. Calvo (301) 415 2753 NRR/NRC (301) 415-1243 John W. Craig NRR/NRC Larry L. Campbell (301) 415-6982 NRR/NRC (301) 415-2976 Michael C. Cullinfford DONRR/NRC Robert A Capra ..(301) 415-1276 NRR/DRPW (301) 415-1995 LeMoine J. Cunningham NRR/ Safeguards Branch Cynthia A. Carpenter (301) 415 2933 NRR/DRPW Albert W. DeAgazio Michael J. Case NRR/NRR NRR/NRC (301) 415-1443 (301) 415-1134 Kulin D. Desai Alford E. Cha&c NRR/NRC NRR/NRC (301) 415-2835 (301) 415-1168 David Desaulniers NRR/DRCH/HHFB (301) 415-1043 arguta ogtyggonterence > 41 <
\.
4 Joseph E. Donoghue Bill Gleaves NRR/DSSA/SRXB NRR/NRC (301) 415-1131 (301) 415-6788 Robert J. Dube Clare Goodman NRR/ Safeguards Branch NRR/DRCH/IlliFB (301) 415-2912 (301) 415-1447 Thomas R. Farnholtz Edward F Goodwin Region ll/DRP/V.C. Summer Station NRR/OECB (803) 345-5683 (301) 415-1154 , Howard J. Faulkner Robert A. Gramm OlG DOTS /NRR/NRC (30l) 415-2762 (301) 415-1010 Norman Fletcher Brian K. Grimes USGAO DOPS/NRR/NRC (301) 903-3275 (301) 415-1163 Thomas Foley Christopher Grimes TQMBINRR/NRC NRR/NRC (301) 415 1036 (301) 415-1161 , Ronald K. Frahn Jr. Jin Sien Guo NRR/ DOTS SPLB/DSSA/NRR (301) 415 2985 (301) 415-1816 Michael X. Franovich Walter P. Haass NRR/NRC NRR/ DOTS /QMB (301) 415-8465 (301) 415-3219 Robert M. Gallo Peter J. Habighorst NRR/ DOTS /TSIB Region I/NRC (301) 415-2967 (203; 267-2571 David L. Gamberoni Ed Hackett NRPJNRC NRR/DE (301) 415-1144 John N. Hannon John K. Ganiere NRR/DRPW NRR/DRCH/HICB (301) 415-1340 Javier J. Garza Allen Haen USGAO NRR/NRC (30l) 415-1390 James Gavula Region III/NRC Paul W. Harris (708) 829-9755 Region 1/NRC (802)257-4319
"Mb?U$Y0$"I'"""
J
Teresa A. Hayes Prr. sad Kadambi NRC/OlG NRR/NRC
-(310) 415 5914. (301) 415 58 %
Ronald W. Hernan Timothy Kobetz NRR/NRC Region lil'NRC (301) 415 2010 (414) 755-2309 Stephen 1. Hoffman Donald C. Kosloff NRR/ADAR/PDLR Region Ill/NRC (301) 415 3245 (216) 259-3610 Gary M. Holahan Tony A. Krukowki NRR/DSSA USGAO (30l) 415-2884 Pao-Tsin Kuo Darl S. Hood NRR/ADAR/PDLR PD2 3/NRR (301) 415-3147 4 (30!) 415-3049 Michael Labatut George T. Hubbard NRR/ OSSA NRR/NRC/DSSA/SPLB (301) 415-2870 Robert M. Latta NRR/NRC William C. Huffman, Jr. (301) 415 1023 NRR/DE/EMEB (301) 415-2766 James J. Lazevnick NRR/PELB Anthony H. Hsia (301) 415 2782 NRR/NRC (301) 415-1075 Jag Y. Lee TERB/ DOTS /NRR Kahtan N. Jabbour (301) 415-1080 NRR/NRC (310) 415-14 % Sam Lee __ Neil Jensec Office of the Commissioner Eric J. Leeds (301) 415-1800 MRR (301) 415-1133 Steve R. Jones
' NRR/NRC/DSSA/SPLB Robert Lerch (301) 415-2833 Region Ill/NRC (708) 829-9759 ,
Jong Chull Jo NRR/NRC/PDST/ADAR Alan Levin (310) 415-1022 NRR/NRC/DSSA Joseph P. Joyce NRR/NRC (301) 415-2842 Retulaglygonierence > 43 <
Chang Yar.g Li Bill McDowell NRR/SPLB NRR/NRCIG (301) 415-2830 (30l) 415-5974 Yueh-Li C. Li - Richard P. McIntyre NRR/DE/EMEB NRR/ DOTS (301) 415 2772 (301) 415-3215 William D. Liggett Richard D. McWhorter DOE Office of the Chairman (202) 254-5508 (301) 415-1768 wliggett@ela. doc. gov. t James Medoff Maria E. Lopez Otin' NRR/NRC Federal Liason (301) 415-2715 (301) 415-2598 George J. Mencinsky Joel Lubenau RES/DRA Office of the Commissioner (301) 415-6206 (301) 415-1800 Anthony J. Mendiola Stewart L. Magruder NRR/NRC NRR/NRC/ADAR/PSDT (301) 415 1054 (301) 415-3139 Melanie A. Miller Melinda Malloy NRR/NRC NRR/NRC/ADPR (301) 415-7323 (301) 415-1178 mxm@nrc. gov Frank J. Miraglia NRR/NRR Gail H. Marcus (301) 415-1272 NRR/NRC (301) 415-1111 Jocclyn A. Mithcell DEDO Josehp J. Mate (310) 415-1727 NRR/NRC (301) 415-1109 Michael C. Modes Region 1/NRC Jerry L. Mauch (610) 337-5198 NRR/NRC mem@nrc.60v --
.(30l) 415-3248 Aby Mohseni John B. Martin AEOD/NRC Region III/NRC (708) 829- % 57 George W. Moore, Jr.
USGAO David B. Matthews NRR/NRC David L. Morrison
-(301) 415-1490 NRR/NRC/RES (301) 415-6641 arguimogfnfyggonferenea > 44 < - ---- -_ a
Mark Mullen USNRC William D. Reckley 1 Thomas E. Murley DRPW/NRR/NRC Consultant (301) 415-1314 (30l) 469-7513 Stuart A. Richards Emmitt Murphy HOLB/DRCH/NRR NRR/NRC (301) 415-1031 (301) 415-2710 Chris Rourk Randall A. Musser NRR/NRC Region II/NRC (301) 415-5865 (205) 729-61 % Mark P. Rubin - Victor Nerses NRR/NRC/DSSA/SPSB NRR/NRC (301) 415-3234 (301) 415-1484 William T. Russell Paul W. O'Connor Director NRR/NRC NRR/NRC (301) 415 1270 (301) 415-1307 pwo@nrc. gov' Lawrence C. Ruth NRR/NRC Philip A. Olson USGAO Steven P. Sanchez (30l) 903-4085 NRC/NRPJDISP/PIPB (30l) 415-1287 Juaa D. Peralta NRR/NRC Cayetano G. Santos (301) 415-1052 NRR/RES (310) 415-5888 Sheri R. Peterson NRR/NRC/DE Dino C. Scaletti (301) 415-2752 NRR/NRC (301) 415-1104 Charles D. Petrone NRR/NRC/ DOTS Larry L. Scholl (301) 415-1027 NRR/NRC Region I (610) 337-5144
. Joe Petrosino l NRR/NRC/TSIB R. Michelle Schroll (301) 415-2979 NRC Public Document Room ;
(202) 634-3273 George T. Pourchot
-.OlG/NRC Dennis J. Scott ;
(301) 415-5973 USEC Dale A'. Powers Wayne E. Scott Region IV/DRS NRR/NRC (817) 860-8195 (301) 415-1020 Regulato inf onference > $5 4
As sok C. Thadani Charles Serpan NRR/NRC NRR/NRC (301) 415 1274 (301) 415-5658 Dole F. Thatcher Krist'.ne M. S%mbarger NRR/NRC NRRINRCADAR/PDST_ (301) 415 3260 (301) 415-1114 George Thomas , Brian W. Sheron NRR/NRC - NRR/NRC/DE (301) 415 1814 (301) 415 2722 Charles A. Thompson Richard R. Sherry USDOE ACRS (301) 903-5501 (301)415-6891 Kathleen J. Turner Larry L. School GAO Region 1/NRC (202) 512-6899 (610) 337-5144 turnrrk.rced@gao. gov Mohammed A. Shuaibi Martin J. Virgilio NRC/NRR DSSA (301) 415-1812 (301) 415-3226 Byron L. Sieger Kenneth C. Wade NRR/NRC USDOE (202) 254-5514 R. Lee Spessard kenneth.wede@hq. doe. gov DOTS /NRR (301) 415-2903 Marsha L. Ward Ofdce of the Secretary /PDR John F. Stole (202) 634-3361 NRR/NRC -(301) 415-1435 Jchn W. Warren USDOE Dennis J. Sullivan (301) 903 6491 NRR/ DISP (301) 415-1295 Gerald H. Weidienhamer Office of Research Francis X. Talbot (301) 415-6015 NRR/ DOTS!QMB (301) 415-3146 Jared S. Wermiel NRR/NRC David T. Tang (301) 415-7821 NRR/NRC
-(301) 415-1147 Richard H. Wessman i NRR/DE/EMEB John R. Tappert (301) 415-3288 USNRC/NRR (301) 415-1167 argutvogigarygonference > 46 <
_ _ - - _ - - - - - - - - -- - ~
U
~ K. Steven West o Plant Systems Branch' (301) 415 1220--
Duke Wheeler
- NRR/ Division of DRPE (301) 415-1444; Keith Wichman NRR/NRC (30l) 415-2757 J. D. Wilsox, Jr. - NRR/ DOTS (30l) 415-1262 David C. Williams OlG (30l) 415-5930 Jerry N. Wilson NRR/NRC (301) 415-3145 jnw@nrc. gov - Cheng-lh Wu NRR/NRC s (301) 415 2764 Ronald M. Young NRR/NRC .(301) 415-2852 B .rry Zaleman - NRR/NRC - ' .(301) 415-3467 Mario Zavala USGAO (202) 5 D-6949 Jaceb 1. rmmerman NRR/hRC (301)-415-2426 Roy P. Zimmerman NRR/NRC (301) 415-1284 aasutasogygga.aturance > 47 <
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