ML20034F848
| ML20034F848 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 02/26/1993 |
| From: | Norrholm L Office of Nuclear Reactor Regulation |
| To: | Rossi C Office of Nuclear Reactor Regulation |
| References | |
| GL-91-05, GL-91-5, NUDOCS 9303050100 | |
| Download: ML20034F848 (26) | |
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j FEB 2 61993 Dociet No. 50-298 MEMORANDUM FOR:
Charles E. Rossi, Director Division of Reactor Inspection and Licensee Performance FROM:
Leif J. Norrholm, Chief Vendor Inspection Branch Division of Reactor Inspection and Licensee Performance
SUBJECT:
MINUTES OF PUBLIC MEETING WITH NEBRASKA PUBLIC POWER DISTRICT ON COMMERCIAL GRADE DEDICATION AT THE COOPER l
NUCLEAR STATION Backaround Between December 1991 and June 1992, the NRC completed five pilot inspections that were conducted to evaluate the implementation of licensee programs for the procurement and dedication of commercial grade items (CGis) and to finalize an inspection procedure for future inspections of this type.
These inspections identified weaknesses in licensee CGI dedication programs and their implementation. During this same period, the Nuclear Regulatory Commission (NRC) received significant feedback from several utilities and the Nuclear Management and Resources Council (NUMARC) questioning the regulatory basis for the CGI dedication guidance contained in NRC Generic Letter (GL) 91-05, as well as specific interpretations of that guidance by the NRC t
inspection teams.
Because of the need for additional discussion of the requirements and implementing guidance for dedication of CGis, no enforcement action was taken based on any of the five pilot inspections. Rather, it was decided that a series of meetings with licensees and industry representatives would be beneficial to identify, and attempt to resolve, specific areas of difference.
This meeting with Nebraska Public Power District (NPPD) representatives is the fourth of such meetings with licensees inspected during the pilot inspections.
Meetina Summary On February 3, 1992, the Director, Division of Reactor Inspection and Licensee Performance, and members of the Vendor Inspection Branch (VIB) met with Mr. D. A. Whitman, Division Manager of Nuclear Support, and other representatives of NPPD at the NRC's One White Flint North office building in Rockville, Maryland. The meeting provided an opportunity to discuss key procurement and commercial grade dedication issues for which the NRC and NPPD i
might have differing views.
These issues were identified during the five I
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Charles E. Rossi,
pilot inspections.
The meeting agenda is included as part of NPPD's handout entitled " Commercial Grade Dedication Issues Meeting' (Enclosure 1). The NRC i
stated that the objective of the meeting was to obtain input for the NRC to l
aid in its ef fort to identify the prcper level of dedication necessary to assure safety and compliance with 10 CFR 50, Appendix B (Appendix B).
In order to facilitate the discussion, the NRC provided NPPD a list of generic i
dedication issues (Enclosure 2) that was originally provided to NUMARC in a l
public meeting held with the NRC on November 13, 1992.
These dedication issues were also used as discussion points for the meetings with Florida Power Corporation on December 4, 1992, NUMARC on December 10, 1992, Southern California Edison on January 13, 1993, and with Iowa Electric Light and Power
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on January 26, 1993. The main dedication issues include the basis for the selection and verification of critical characteristics, sampling, traceability, commercial grade surveys, like-for-like replacements, and acceptance of vendor / supplier documentation and are tied either directly or indirectly to Appendix B requirements for safety-related applications.
These issues were derived from previous meetings with NUMARC and represent the major points of ongoing discussion.
i During their opening remarks, NPPD stated they had performed a detailed review of NRC Inspection Report No. 50-298/92-201 for the February 1992 procurement inspection at Cooper Nuclear Station (CNS), and that all inspection report concerns were addressed.
In response to the first deficiency identified in the report, NPPD stated that all inspection findings had been adequately resolved and all the CGIs were determincd to be suitable for their intended safety-related applications.
In response to the second deficiency, NPPD stated they had revised 15 procedures and also developed 11 new procedures to l
support the commercial grade dedication program at CNS. NPPD then described the remaining ongoing corrective actions in place that address the inspection report deficiencies.
NPPD stated they have made many improvements to the dedication program at CNS and also stated there is a significant difference between the dedication program inspected by the NRC in February 1992 and the program in-place today.
The other area discussed during the meeting was NPPD's position with regard to the generic commercial grade procurement and dedication issues as documented in Enclosure 1.
NPPD presented their comments regarding each issue and indicated whether they agreed or disagreed with the staff position.
NPPD expressed qualified agreement with many areas of the staff position.
Several of the apparent disagreements resulted from misunderstanding or misinterpretation by NPPD of the actual staff position as documented. After the NRC clarified the issues in question, NPPD identified no significant disagreements between the NPPD and NRC positions regarding what is necessary to comply with the requirements of Appendix B for commercially dedicated items. However, NPPD did identify some areas, including sampling, traceability, commercial grade surveys, and like-for-like replacements, where they felt additional clarification would better define the staff's positions.
The exceptions or qualifications to the NRC positions by NPPD are clearly stated in Enclosure 1 under the section on procurement issues.
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i Charles E. Rossi '
Finally, it was stated that the NRC would be conducting a public workshop which will address issues concerning the existing dedication guidance and specific interpretations of that guidance.
Prior to the public workshop, the propused inspection procedure for future inspections will be issued for public comment and discussion at the workshop. A list of meeting attendees is included as Enclosure 3.
The VIB is considering all the comments provided by NPPD.
The meeting provided a useful exchange of information and accomplished the goal of aiding the NRC by gaining industry insight and feedback related to the consercial grade dedication process.
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- <' Leif dh $ rholm, Chief Vendor Inspection Branch 6
Division of Reactor Inspection and Licensee Performance Office of Nuclear Reactor Regulation Er. closures:
1.
Commercial Grade Dedication Issues Meeting 2.
Dedication Issues For Discussion 3.
Meeting Attendance List cc w/o enclosures:
W. Russell I
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Charles E. Rossi Finally, it was stated that the NRC would be conducting a public workshop which will address issues concerning the existing dedication guidance and specific interpretations of that guidance.
Prior to the public workshop, the l
proposed inspection procedure f or future inspections will be issued f or public comment and discussion at the workshop. A list of meeting attendees is included as Enclosure 3.
The VIB is considering all the comments provided by NPPO. The meeting provided a useful exchange of information and accomplished the goal of aiding the NRC by gaining industry insight and feedback related to the cormercial 1
grade dedication process.
Leif J. N rrholm, Chief.
I Vendor Inspection Branch Division of Reactor Inspection and Licensee Performance Office of Nuclear Reactor Regulation
Enclosures:
1.
Commercial Grade Dedication Issues Meeting 2.
Dedication Issues For Discussion 3.
Meeting Attendance List cc w/o enclosures:
W. Russell DDL g
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1 ENCLOSURE 1 l
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DEDICATION lSSUES MEETING February 3,1993
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NRC OFFICE OF NUCLEAR REACTOR REGULATIONS
NEBRASKA PUBLIC POWER DISTRICT REPRESENTATIVES D. A. WIIIThiAN DIVISION MANAGER OF NUCLEAR SUPPORT C. M. ESTES PROCUREMENT PROJECT TEAM LEADER D. R. ROBINSON QUALITY ASSURANCE MANAGER G. R. SMITII NUCLEAR LICENSING AND SAFETY MANAGER M.J. SPENCER ENGINEERING PROGRAMS SUPERVISOR 1
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MEETING AGENDA NRC/NPPD 3 FEBRUARY,1993 s
L THE DEGREE OF *PJiASONABLE ASSURANCE A.
Critical Characteristics B.
CMTRs/COCs C.
Traceability D.
Like-For-Like E.
Sampling I.ot/ Batch Control i
Heat Traceability Bulk Commodities F.
Engineering Judgement II.
THE ROLE OF DEDICATION IN PROCUREMENT A.
Dedication Process versus an Appendix B Purchase i
III.
FAILURE MODES AND EFFECTS ANALYSES A.
Application to the Design Phase versus Procurement Activities IV.
ITEMS PROCURED FROM OTHER UTILITIES i
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INSPECTION REPORT 92-201 RECEIPT e PERFORMED DETAILED REVIEW e TWO CATEGORIES OF DEFICIENCIES WERE IDENTIFIED:
GENERIC WEAKNESS IN PROCUREMENT PROGRAM FAILURE TO ADEQUATELY DETERMINE SUITABILITY OF APPLICATION OF CGIs
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GENERIC WEAKNESS IN PROCUREMENT PROGRAM
- REVISED 15 PROCEDURES e DEVELOPED 11 NEW PROCEDURES l
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SUITABILITY OF APPLICA TION OF CGis ALL INSPECTION FINDINGS ADEQUA TEL Y RESOL VED ALL DEDICATION PACKAGES REVIEWED AND ALL COMMERCIAL SUPPLIERS RE-EVALUATED WITH NO QUALITY CONCERNS PLANT OPERATING HISTORY VERY GOOD PROGRAMMATIC SYSTEMS ARE IN PLACE TO IDENTIFY AND/OR PRECLUDE FAILURES e
PAST ENGINEERING INVOL VEMENT IN PROCUREMENT HIGH DEGREE OF AWARENESS OF CRAFTIN UTILIZING CORRECT PARTS STRONG WAREHOUSE CONTROLS OF TAGGING AND TRACEABILITY H
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CURRENT STA TUS OF PROCUREMENT PROJECT PLAN ON GOING ACTIVITIES PART CLASSIFICATION DEDICATIONS (CGis & Quality Commercial Grade items)
LUBRICATION (Dedication Method 1 & 4)
TESTING TRENDING TRAINING SUPPLIER AUDITS H
SUMMARY
e SIGNIFICANT PROGRESS SINCE JANUARY 1,1992 e
IDENTIFIED NO CONCERNS WITH MATERIALS / COMPONENTS INSTALLED IN PLANT MET THEJUL Y 1,1992 NUMARC COMPREHENSIVE PROCUREMENT INITIATIVE COMMITMENT e
ALL INSPECTION REPORT CONCERNS WERE ADDRESSED e
HOWEVER, THEREREMAINS SOMESPECIFICPROCUREMENTISSUES H
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PROCUREMENT ISSUES DISTRICT POSITION This paper provides the District's position with regard to the remaining comIercial grade procurement and dedication issues as defined by the Nuclear Regulatory Commission, as identified in their December 1992 meetings with Florida Power Corporation and NUMARC.
For the purpose of discussion, these items have been grouped into three general categories and placed in a prioritized order.
I.
REASONABLE ASSURANCE A.
Basis for the selection and verification of critical characteristics.
1.
" Critical characteristics should be based on the item's safety function."
The District concurs with this position.
2.
"The licensee is responsible for identifying the important design, material, and performance characteristics for each item, establishing acceptance criteria for these characteristics, and providing reasonable assurance of conformance to these criteria."
The District agrees with this position, provided that 'imponant characteristics ~ described herein are limited to those which would be considered to be ' critical characteristics. " It is the District's belief that
' critical characteristics" are a small subset of design, material, and perfonnance characteristics, which have been shown by evaluation to have direct impact on the ability of the item to accomplish its intended safety function. Once identiped, all critical characteristics need to be venfed cr addressed.
An approach which provides flexibility based on l
engineering judgement and item complexity may utilize any 2a l
combination of thefour acceptance methods, including demonstr.s. ion of
- i acceptable supplierperformance in some cases, to proside 're'.sonable l
assurance' that the item willperfonn its intendedfunction.
3.
"Upon the completion of the dedication process, the quality assurance or compensatory measures applied to those aspects of the item which directly i
affect its safety function should result in the same level performance reliability as for a like item manufactured under an Appendix B program."
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The District agrees with this position, prorided the process used is as described above.
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B.
Acceptance of Certified Material Test Reports (CMTRs) and Certificates of Compliance (COCs) 1.
"The validity of vendor CMTRs and COCs should be verified. 'nis can be accomplished through a commercial grade survey or, for simple items, periodic testing of the product upon receipt." ~
ne District does not totally agree with this position. The validity of CMTRs and COCs should also he able to be venfed using vendor historicalperformance. De extent to which the COC or CMTR requires venpcation should be dictated by the safety sigmpcance of the item.
2.
"Such verification should be conducted at intervals commensurate with the vendor's past performance."
he District agrees with this position.
3.
"If the item's supply chain includes a distributor, the verification survey should include warehousing and/or traceability controls at the distributor's facility."
ne District agrees with this position if the distributor has had physical control of the item. (See also item C.4 below)
C.
Traceability 1.
" Traceability can be defined as the ability to verify the history, location, or application of an item by means of recorded identification (NQA-1)"
The District agrees with this defnition.
2.
" Traceability is necessary to prevent the use of incorrect or defective material and should be maintained throughout the dedication process."
The District does not totally agree with this position. Assuming the purchaser is performing the venfcation of all critical characteristics and not relying on the manufacturer to control or venfy them, then traceability to the OEM is moot. Traceability to the OEM is only necessary if the purchaser is depending on the manufacturer to control or venfy one or more of the idennped critical characteristics.
The District does agree that traceability is requiredfrom receipt through installation.
3.
"Where the item's acceptance is based entirely or partially on a certification by the manufacturer, the traceability must extend to the manufacturer."
The District agrees with this position.
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4.
"If intermediaries (distributors) are included in the supply chain, their capability of maintaining traceability should be assured by audit."
The District generally agices with this position, with she following
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clanpcations. The purchaser mustfrst establish the distributors role in l
the supply chain to detennine the needfor an' audit or suncillance. In l
order for an audit /suncillance to be necessary the distributor must l
perfonn somefunction which has the capability of directly afecting the l
critical characteristics ofthe procured item. Distributors who merely act as sales ofices which never hase physicalpossession of the items may not '
I require an audit /suntillance.
D.
Like for Like Replacements 1.
"If it can be demonstrated that the replacement item is identical to the i
item that it replaces, review of the replacement item's safety functions and I
identification of the critical characteristics are not necessary."
i The District agrees with this position.
i 2.
"An example of such replacement would be the replacement of an installed I
commercial grade item with an item from warehouse which has the same model/part number and which was purchased from the same vendor at the-same time."
i The District agrees with the example. However, ne maintain that if,for J
a given item, it can be demonstrated that design and manufacturing processes have not been changed, whether through testing, commercial suney, or other method, neither idennpcation nor venfcation ofcritical characteristics is required.
i 3.
"If it can not be demonstrated that the replacement item is identical or if
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differences between the items are identified, an evaluation is necessary to determine if any changes in design, material, or manufacturing process -
l could impact the item's critical characteristics and its ability to perform the intended safety function."
The District agrees that diferences between the original and replacement items require documented evaluation and resolution.
Houever, ue maintain that the ability to perform the intended safetyfunction is inherent i
within the original design and need not be resenfed.
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E.
Sampling 1.
"When heat traceability of material is established through a commercial grade survey, the party performing dedication of this material may accept the certified material test report (CMTR) that certifies activities which must be performed during (1) the melting, and (2) the heat analysis; provided that the party dedicating the material performs or subcontracts the performance of all other requirements of the. material specification and/or those requirements identified as critical characteristics, on a representative sampic of that material."
ne District does not agree with this position. It is the District's belief that the same commercial survey which establishes heat traceability can be used to venfy the supplier's controlsfor some or all of the remaining material specyications and/or critical characteristics and to detennine which will be the responsibility of the supplier and which will be the resporuibility of the purchaser.
2.
"When Lot / Batch (defined as units of product of a single type, grade, class, size and composition, manufactured under essentially the same conditions, and at essentially the same time) control is established through a commercial grade survey, the party performing dedication can develop sampling plans based on standard statistical methods."
ne District does notfully agree with this position. Lot / Batch control does not necessarily need to be established through commercial suney.
Sampling should be considered appropriate absent assurance oflot/ batch controls. EPRI has reviewed this issue through NP-7218, which provides a method for using sampling plans in the CGI dedication acceptance process. Bis is a probabilistic process based on los size, sample size, accept / reject numbers, andpercent deficiencies allowable in the received lot. Lot homogeneity is not afactor. Derefore, sampling plans are valid in the absence oflot/ batch control. Homogeneity is a factor only in determining the degree of sampling necessary to achiese a gisen confidence level.
i 3.
"Such sample plans should be documented and provide for the verification of the critical characteristics with confidence level consistent with the item's importance to safety."
he District agrees with thisposition.
4.
"When Lot / Batch traceability can not be established, each item may need to be tested."
The District does not agree with this position. Bulk commodity items should not be treated diferently in that statistically valid sampling is still considered appropriate. See the previous item.
5.
"Any sampling plans for such items would need to be considered on individual, item-specific basis and assure that they are capable of providing I aigh level of assurance of the item's suitability for service."
The District does not agree with this positionfor the reasons presiously stated.
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Engineering Judgement 1.
"The use of engineering judgement in the dedication process is acceptable providing that the basis for such judgements are documented."
The District agrees with this position.
II.
THE ROLE OF DEDICATION IN PROCUREMFNT A.
"The dedication process is not a substitute for Appendix B. Rather, it represents a method of achieving compliance with Appendix B, with the purchaser assuming many of the responsibilities for assuring quality and functionality of an item which had previously been the responsibility of the vendor."
The District does not totally agree with this position. We do not believe that DEDICATION is an inferior process to an Appendix B, Pan 21 purchase. Even though responsibilities shiftfrom a legalistic view point, the final responsibilityfor assuring quality andfunctionality has always been with the Licensee. Thisposition is compatible with the previous NRC position: 'Upon completion of the dedication process, the quality assurance or compensatory measures applied to those aspects of the item which directly afect its safetyfunction should result in the same level performance reliability asfor a like item manufactured under an Appendix l
B program. "
As increasing numbers of suppliers drop their Appendix B programs, either due to a lack of business with the nuclear industry and/or to adopt i
ISO 9000 programs, dedication sill become a larger pan of all utilities procurement process. It is imponant to acknowledge that there are a number ofsuppliers who haw historically provided high qualitypans and materials which ha e not been processed under an Appendix B program.
The ability ofutili ses to continue to do business with all ofthese suppliers is vital.
B.
"In this context, reasonable assurance consists of the purchaser providing control over the activities affecting the item's quality to an extent consistent with the items's importance to safety."
The District does not agree with this as stated.
Rather than the purchaser "providing control over" those actisities, the District believes that it is the purchasers responsibility to provide reasonable assurance that those activities are controlled, either by the supplier or by the purchaser.
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III.
FAILURE MODES AND EFFECTS ANALYSIS l
i A.
" Failure modes and effects analysis can be a valuable tool which can be used for both, classification of an item as safety-related or non-safety-related and for identifying the critical characteristics of an item."
The District agrees that such an analysis can be a useful toolfor such detenninations. The District does not, howewr, beliew that such an analysis is mandatory in all instances nor does it belien that such an h
analysis should result in a design basis change ofan item. In addition, the depth of this analysis should not be the same as in a Design Basis l
Reconstitution.
B.
"An evaluation of credible failure modes of an item in its operating environment and the effect of these failure modes on the item's safety function should be used as the basis for selection of critical attributes to be verified during the dedication process."
With the exceptions previously idenn)ed, the District generally agrees with
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this position.
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ADDITIONAL ITEMS OF INTEREST TO THE DISTRICT
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A.
The Commission's documented position concerning procurement of items from another licensee.
The District bellens that the licensing and inspection process inherently provides reasonable assurance that items procuredfrom other utilities are acceptablefor use.
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i DEDICATION ISSUES
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1.
BASIS FOR THE SELECTION AND VERIFICATION OF CRITICAL CHARACTERISTICS a.
Consideration of Item's Safety Function Critical characteristics should be based on the item's safety function. The licensee is responsible for identifying the important design, material, and performance characteristics for each item, establishing acceptance criteria for these characteristics, and providing reasonable assurance of conformance to these criteria.
Upon the completion of the dedication process, the quality assurance or compensatory measures applied to those aspects of the item which directly affect its safety function should result in the same level performance reliability as for a like item manufactured under an Appendix B program.
b.
Failure Modes and Effects Analysis Failure modes and effects analysis can be a valuable tool which can be used for both, classification of an item as safety-related or nonsafety-related and for identifying the critical characteristics of an item. An evaluation of credible failure modes of an item in its operating environment and the effect of these failure modes on the item's safety function should be used as the basis for selection i
of critical attributes to be verified during the dedication process.
c.
Reasonable Assurance The dedication process is not substitute for Appendix B.
Rather, it represents a method of achieving compliance with Appendix B, with the purchaser assuming many of the responsibilities for assuring quality and functionality of an item which had previously been the responsibility of the vendor.
In this context, reasonable assurance consists of the purchaser providing control over the activities affecting the item's quality to an extent consistent with the item's importance to safety.
For more complex items, dialogue with the original equipment manufacturer may be necessary to identify the design and functional parameters of specific piece parts.
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Engineering Judgement The use of engineering judgement in the dedication process is acceptable providing that the bases for such judgements are documented.
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2.
SAMPLING a.
Established Heat Traceability (materials)
When heat traceability of material is established through a comrcial grade survey, the party parforming dedication of this material may accept the certified material test report (CMTR) that certifies activities which must be performed during (1) the melting, and (2) the heat analysis; provided that the party dedicating the material performs or subcontracts the performance of all other requirements of the material specification and/or those requirements identified as critical characteristics, on a representative sample of that material.
b.
Established Lot / Batch Control When Lot / Batch (defined as units of product of a single type, grade, class, size and composition, manufactured under essentially the same conditions, and at essentially the same time) control is established through a commercial grade survey, the party performing dedication can develop sampling plans based on standard statistical methods.
Such sample plans should be documented and provide for the verification of the critical characteristics with confidence level consistent with the item's importance to safety.
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c.
Bulk Commodity Items When Lot / Batch traceability can not be established, each item may need to be tested. Any sampling plans for such items would need to be considered on individual, item-specific basis and assure that they are capable of providing a high level of assurance of the item's suitability for service.
3.
TRACEABILITY a.
Material / Items Purchased from Distributors Traceability can be defined as the ability to verify the history, location, or application of an item by means of recorded identification (NQA-1). Traceability is necessary to prevent the use of incorrect or defective material and should be maintained 1
throughout the dedication process. Where the item's acceptance is based entirely or partially on a certification by the manufacturer, the traceability must extend to the manufacturer.
If intermediaries (distributors) are included in the supply chain, their capability of maintaining traceability should be assured by audit.
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4.
COMMERCIAL GRADE SURVEYS a.
Verification of Vendor's Control of Specific Characteristics A commercial grade survey should be specific to the scope of the commercial grade item or items being purchased. The vendor's controls of specific critical characteristics to be verified during the survey should be identified in the survey plan. The verification should be accomplished by reviewing the vendor's program / procedures controlling these characteristics and observing the actual implementation of these controls in the manufacture of items identical or similar to the items being purchased.
b.
Identification of Applicable Program / Procedures The vendor must have documented program and/or procedures to control the critical characteristics of the item or items being procured which are to be verified during the survey. When many items are being purchased, a survey of a representative group of similar items may be sufficient to demonstrate that adequate controls exists. If the vendor's controls are determined to be satisfactory, purchase orders for these items should invoke these controls as contract requirements by referencing the applicable program / procedure and revision. Upon completion of the work, the vendor should certify
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compliance with the purchase requirements.
c.
Documentation of Survey results Commercial grade survey documentation should include the identification of item or items for which the vendor is being surveyed, identification of the critical characteristics of these items which the vendor is expected to control, identification of the controls to be applied (program / procedure and revision) and a description of the verification activities performed and results obtained. Deficiencies identified during the survey which may affect control of the identified critical characteristics should be addressed by requiring the vendor to institute additional controls or by utilizing other verification and acceptance methods.
5.
LIKE FOR LIKE REPLACEMENTS a.
Replacement with Identical Item If it can be demonstrated that the replacement item is identical to the item that it replaces, review of the replacement item's safety functions and identification of the critical characteristics are not necessary. An example of such replacement would be the replacement of an installed commercial grade item with an item -from warehouse which has the same model/part number and which was purchased from the same vendor at the same time.
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Like-for-Like Verification l
If it can not be demonstrated that the replacement item is identical or if differences between the items are identified, an evaluation is i
necessary to determine if any changes in design, material, or manufacturing process could irnpact the item's critical characteristics and its ability to perform the intended safety function.
6.
ACCEPTANCE OF CERTIFIED MATERIAL TEST REPORTS (CMTRs) AND CERTIFICATES OF COMPLIANCE (C0Cs)
Validity Verified Through Vendor / Supplier Audit or Testing a.
The validity of vendor CMTRs and C0Cs should be verified. This can be accomplished through a commercial grade survey or, for simple items, periodic testing of the product upon receipt. Such verifications should be conducted at intervals commensurate with the vendor's past performance.
If the item's supply chain includes a distributor, the verification survey should include warehousing and/or traceability controls at the distributor's facility.
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ENCLOSURE 3 i
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I FEBRUARY 3, 1993 i
MEETING WITH NPPD
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ATTENDANCE LIST i
NAME ORGANIZATION
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Richard McIntyre NRC/NRR/VIB Robert Pettis NRC/NRR/VIB Michael Spencer NPPD i
David R. Robinson NPPD David A. Whitman NPPD Mike Estes NPPD Gregory R. Smith NPPD Charles E. Rossi NRC/NRR/DRIL Uldis Potapovs NRC/VIB Harry Rood NRC/PD4-I Larry Campbell NRC/VIB Charles Petrone NRC/NRR/DRIL Coretta Yates NRC/PD4-1 Leif J. Norrholm NRC/NRR/VIB Bob Gramm NRC/NRR/DRIL Biff Bradley NUMARC Roy Zimmerman NRC/NRR/DRIL l
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