ML19221A732

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Seeks Approval of Plan to Formalize Interim Organizational Structure to Deal W/Impacts of TMI Incident,Using Resources & Priorities within Office.Forwards Task Description,& Chart of Organization Structure
ML19221A732
Person / Time
Site: Bailly
Issue date: 05/19/1979
From: Harold Denton
Office of Nuclear Reactor Regulation
To:
Shared Package
ML19221A733 List:
References
SECY-79-344, NUDOCS 7907030173
Download: ML19221A732 (33)


Text

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"av 19,1979

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SEGY-79-344 COMMISSIONER ACTION

_To:

The Ccamissioners Thru:

Lee V. Gossick Executive Director for Operations From:

Harold R. Denton, Director Office of Nuclear Reactor Legulatio

Subject:

INTERIM NRR ORGANIZATION TO DEAL WITH IMPACTS OF TMI-2 AND OTHER NRR PRIORITY TASKS

Purpose:

To obtain Commission approval of NRR plan to formalize an interim organizational structure to deal with the impacts of TMI-2 on resources and priorities within that office.

Category:

This paper contains a major policy question.

Discussion:

The accident at TMI-2 which occurred on Marct 1979 has and is continuing to divert significent managec and technical resourcPJ of NRR from its principal FY 79 work priorities (Operating Reactors including SEP and Safeguards, Unresolved Safety Issues and Caseweork).

It is clear that certain TMI-related activities (TMI Direct Support, Bulletins / Orders and " Lessons Learned") which have evolved since the accident require such priority attention.

As a result, we have exanined our pre-and post-TMI activities and have determined that our current and near-term (six to eight months) priority tasks should be as follows:

1.

TMI Direct Support 2.

Bulletins / Orders 3.

Lessons Learned 4.

Operating Reactors. including the five shutdown facilities 2 [ j_,

)9j, 5.

Unresolved Safety Issues (USI's) h 6.

Casework (as resources permit)

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The Commissioners A short description of each of the above ta!,ks is contained in.

Examination of the tasks in Enclosure 1 sugi;ested the interim organizational structure to best accomplish these tasks.

The first three priority tasks (TMI Support, Bulletins and Lessons Learned) are three efforts requiring immediate attention and an initiation of immediate task force efforts for these tasks appears to be in order.

The last three priorit.y tasks (0perating Reactors, Unresolved Safety Issces and Casework) are now being worked within the current NRR organizational structure and should remain there.

Since the first three priority tasks will require substantive resources (approximately 70 professionals from the NRR staff),

reassignment of NRR personnel to these tasks will require a realignment of managerial and some technical personnel.

In addition, nne NRR Division Director has been assigned to the Commission Investigation and we anticipate the loss of an addi-tional 6-8 senior staff to that effort. contains the interim NRR organizational and managerial structure and essential-ly formfiizes the ad hoc efforts which are now ongoing.

The efforts of the interim Divisional structure (DOR, DPM, DSE and 055) will be directed toward maintaining the FY 79 and FY 80 goals in the Operating Reactors and Unresolved Safety Issues Decision Units.

As a result of the realignment of resources and pr w rities, the expected accomplishments in the Casework task will be severely limited.

The priority of casework revies will be:

e Near Term OLs Completion of cps in hearing e

Other OLs where completion of construction is anticipated e

by January 1981 cps and OLs having special review considerations (i.e.,

e Bailly, Midland)

A preliminary and optim% tic identi#ication of specific reviews that will be continued is contained in Enclosure 3.

A final and more realistic assessment of the expected casework accomplit nents can only be made after retnurce allocations to other higher

-i -

ority tasks and assignments to the Commission investigation

. ave been made.

At this point in time the available resources can be matched against the resources required to continue the reviews identified in Enclosure 3 on a "best-effort basis."

It is our expectation that the casework accomplishments in Enclosure 3 are the most we can expect to accomplish and that it i i hl i ely

The Commissioners that our accomplishments in this area would be less than that identified.

In addition to the identified impacts on Casework, the following FY 79 and FY 80 efforts will be severely re-stricted in that these efforts will continue only as available resources permit:

Generic Issues (other than USI's) e e Licensing Improvements e Topical Reports e Contract Management s Research Coordination e Non-NRR Support e SRP Revisions e Audit Calculations e Advanced Reactors

  • e Standards Assistance e Training Several alternative approaches to address the post-TMI efforts were considered.

A potential alternative is to utilize the technical staff in other NRC program offices to supplement NRR resources.

These offices are already providing assistance to NRR in the Unresolved Safety Issues program and SRP revisions.

They are also involved in post-TMI 2 analyses and investigations.

To further divert substantive resources for six to eight months may have serious adverse impact on their programs.

However, assistance, from these Offices, in several severly impacted disciplines could mitigate the impact on some of the diverted efforts identified above.**

It is our view that a realignment of NRR resources and priorities is required to effectively and expeditiously perform the post-TMI activities and continue efforts in our major programs.

The proposed alignment (shown in Enclosure 2) conbines the best of the advantages of several alternatives to this interim organization.

The range of alternatives available included maintaining the existing organization intact and accomplishing these tasks withir. the existing structure, or establishing task forces for all these efforts (which would result in essentially a complete abandonment of the current organization).

The advantages of the former include (1) maintenance of the existing managerial and organizational structure; (2) assurance of quality control of review product; Support efforts for Ft. St. Vrain and FFTF will be maintained.

273 195 IE is end will continue to provide assistance to NRR in reviewing responses to Bulletins.

RES is and will continue to provide assistance to NRR in the seismic design review area.

The Commissioners and (3) minimum disruption of the staff.

The disadvantages of the former include (1) no clear responsibility for task assigned, and (2) progress of tasks on expedited bases may be impeded because of conflicting priorities.

The advantages of the latter include (1) clear responsibility for each task, and (2) clear assignment of priority and resources to assure expedited effort.

The disadvantages are (1) a complete disruption of the current organization; (2) limited assurance of quality control of the review product; and (3) competing priorities for limited resources could restrict progress on other important NRR efforts.

It is our view that the proposed organizational structure shown in Enclosure 2 provides the best basis for performing the identified tasks within the next six to eight months The interim organization retains the integrity of the current Divisional structure.

Thus, an orderly transition to normal operations following completion of the TMI-2 tasks can be effectively accomplished.

Coordination Since this matter affects NRR solely, there was no coordination with the other program offices.

A Harold R. Denton, Director Office of Nuclear Reactor Regulation

Enclosures:

DISTRIBUTION 1.

Post-TMI Task Descriptions Commi s si oners 2.

Interin NRR Organizational Structure Commission Staff Offices 3.

Identification and Summary and Casework Exec Dir for Operations Impacts ACRS Secretariat Commissioners' comments shuld be provided directly to the Office of the Secretary by c.o.b. Friday, June 1, 1979.

Commission Staff Office comments, if any, shoula be submitted to the Commissioners NLT May 25, 1979, with an infor.m tion copy to the Office of the Secretary.

If the paper is of such a nature that it requires additional time for analytical renew and comment, the Commissioners and the Secretariat should be apprised of when comments may be expected.

273 196

POST-TMI TASK DESCRIPTI0f45 273 197

TMI-2 DIRECT SUPPORT This TMI-2 Support Task includes core cooling, cleanup and recovery operations.

The support effort will include:

o Analysis, as appropriate, of plant conditions and proposed changes in system design or operating mode.

o Performance of independent analysis of dose to public via all pathways for proposed releases of gaseous or liquid activity and evaluation of solid stcrage, o Analysis of plant activities in conformance with ALARA objectives, to include evaluation of plant organization, personnel training and procedures.

e Review and a alysis of proposed operating plans and procedures to accomplish major operations such as long term cooling, containment cleanup and entry, and core removal.

273 198

_2-o Preparation of Technical Specifications appropriate to the plant conditions and activities.

Interfacing with the licensee, IE, end all govern-o ment agencies involved in reactor safety and environmental issues.

o Preparation of presentations and correspondence appro-priate to the TMI accident such as green tickets, briefings of Stu., local and Federal agencies and the Commission as well as international officials.

The scope of this task will include all TMI-2 site activities.

Approvals and SERs for various stages and modes of core cooling, cleanup and recovery operations will be the principal end-products of this task.

273 199

Bulletin / Orders This Task includes review responses to orders and ISE Bulletins.

The support effort will include:

O'rders - Perform the necessary reviews cf licensee e

and vendor supplied infomation to support a decision regarding plant operations, e I&E Bulletins - Assure that (a) licensees are infomed of accident sequence and contributors, (b) minimum procedural and administrative actions are taken for continued safe operation, (c) plant designs are examined, (d) results are pronptly reported to NRC, and (e) necessary short-tem 273 200 measures are implemented.

The scope nf review for the order will be as defined for each facility.

With respect to the I&E Bulletins, the scope will limited to short-tem measures to assure safe operation of restarced B&W plants and continued safe operation of operating Westinghouse, Coebustion Engineering and General Electric designed plants.

The end-prooucts for this task will include: (1) Safety evaluations and authorizations to resume or continue operations; (2) Licensing :ositions regarding the implenentation of short-tem measures on operating BaW, W, CE and GE designed plants, and (3) Recommendations for further inprovements in the areas of:

design and operation /and administrative procedures.

Lesson Learned This Task for the TMI-2 accident includes the review ar.d evaluation of. investigative information, staff evaluations of responses to I&E Bulletins and orders, staff recommendations and recommended actions from outside of the flRC; to identify, analyze and recommend changes to licensing requirements and the licensing process for nuclear power plants based on the lessons learned and provide recommendations for interim requirequirements for new operating licenses prior to completion of long-term activities.

There is a range of area of imaediate interest to fiRR in which possible regulatory improvements are suggested by the TMI accident.

These include:

(1)

Reactor operator training ar.d licensing.

(2)

Reactor trar.sient and accident analysis.

(3)

Licensing requirements for safet; and process er.pment, instrumentation, and controls.

(4)

Offsite and onsite emergency preparations and procedures.

(5)

Reactor siting.

(6)

Licensee technical qualification.

. (7)

NRR accident response role, capability and management.

(8)

Reactor operating experience (9)

Environmental Effects (10)

Licensing requirements for post-accident monitoring and controls.

(11)

Post-Accident Cleanup and Recovery.

(12)

NRR engineering evaluation of the TMI-2 event sequence.

End-products may take the form of proposals for changes in legislation, policy, regulations, staff technical positions, review procedures, or NRR organizational structure and responsibilities.

All information developed by the Task Force will be made public and submitted to others investigating the TMI-2 accident.

The Task Force will serve as the focal point for NRR interaction with these groups.

273 202

Operating Reactors The Task for Operating Reactors is to assure the continued safe operation of operating plants.

All routine DOR activities with the exception of those specifically included in other tasks, are included in the scope of this task.

Review and authorization of restart of thc five plants shutdown for seismic design reanalysis, continued support of Unresolved Safety Issues, the Systematic Evaluation Program and Safeguards are also included.

Routine licensing approvals, orders, etc., and authorizations for restart of Maine Yankee, Beaver Valley 1, FitzPatrick, Surry 1 and 2 are the end products for this task.

273 203

Unresolved Safety Issues This Task is to continue tu,erform those reviews and analyses necessary to complete generic tasks that address " Unresolved Safety Issues" with minimum impact on current schedules.

Initially this Task will include the 19 generic tasks identifad in NUREG-0510 that address " Unresolved Safety Issues."

Several of these 19 generic tasks will likely be expanded to address issues identified as e result of the Tril-2 acciden+.

In addition, new " Unresolved Safety Issues" will likely be identified as a result of the TMI-2 accident.

This " Unresolved Safety Issues" Task will be expanded to include generic tasks to address these new issues as they are identified.

The end products will be NUREG reports describing the staff's evaluation of and conclusions for each issue.

More specific end products are described in the Tash Action Plan for

~each generic task.

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273 204

Casework This Task includes; e Completion of review of near term 0L's and coordinate "TMI Lessons Learned" for these pl a nt s.

Plants in this group include Salem 2, North Anna 2, Sequoyah i and 2, Diablo Canyon 1 and 2, McGuire 1 and 2, Zimmer, and LaSalle 1 and 2.

e The continuing of ongoing OL reviews with priority based on NRC estimates of construction completion dates up to January 1981.

Plants in this group include Watts Bar 1 and 2, Fermi 2, Sumer, Shoreham, San Onofre 2 and 3, Susquehanna 1 and 2, and WPPS 2.

e Completion of CP's now active in hearing process.

Plants in this group include Perkins, Pebble Springs

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l and 2, Skagit 1 and 2, Pilgrim 2, Allens Creek, New England 1 and 2 and Black Fox 1 and 2.

o Completion of environnental reviews for the identified projects to proceed with corresponding priorities.

The end products for this task includes the issuance of 273 205 SER's and EIS for the projects identified.

ENCLOSURE 2 INTERIM NRR ORGAtlIZATIONAL STRUCTURE 273 206

TMI-2 SUPPORT NRR IE OPERATIONS TMI-2 R. VOLLMER OPERATIONS J. COLLINE TECHNICAL ACTING SUP ORT ASB (l)

TA (1)

RSB (l)

ASB (1)

ETSB (1)

RSB (1)

RAB (1)

_ ICSB(l)

STS (1)

ETSBfl)

OLB (1)

PSS (1) no

[j TOTAL STAFFING:

14 PROFESSIONALS AND MANAGERS N

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LESS0flS LEARNED MATTSONf TEDESCO '

STAFF RSB

( 3)

ASB (1)

CSB (l)

ICSE (2)

PM (1)

OLB (1)

N AB (1)

N L-1 CPB (I)

RAB (1)

Nca co TOTAL STAFFING:

14 PROFESSIONALS r.ND MANAGERS

BULLETINS /0RDERS D. ROSS BRW ORLtiR1 B&W ORDER 5 B&W OTi(ER

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BULLETINS AND RESTAR

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GENERIC GENERIC A.TliADANI S* VARGA S.

ISRAEL lJ, MAZETIE

' ROSZTOCZ"

- PM (2)

- ICSB (1)

- PSB (1)

AB (5)

_ RSB (3)

- RSB (1)

- IE (1)

- IE (1)

RSB (2)

_ AB (2)

IE (1)

- ASB (1)

- ASB (I)

MTEB (I)

- ICSB(I)

- RSB (1)

- OLB (1)

ICSB(l)

- ASB (2)

~ O LB (I)

PM (3)

- OLB (1)

" PM (1)

Total Staffing:

39 Professionals and Managers UNTIL JUNE 1 D. ROSS DEPUTY-(TO BE NAMED)

N N

U1 PROJECTS SYSTEMS ANALYSIS y

_IIELTEMES NOVAK ROSZTOCZY LPM (4)

- RSB (8)

AB (6)

- ORPM (1)

- ASB (4)

OLB (2)

- PSB (1)

AFTER JUNE 1 Total Staffing:

33 Professionals and Managers

UNRESOLVED SAFETY ISSUES S.

HANAUER M. AYC0CK

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Staff: 17 Prof.

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TECHNICAL SUPERVI SI ON Staff: 18 Prof.

DIVISIO.*! 0F OPF_ RATING REACTORS V.

STELLO D. EISErlHUT l

AD:S&P AD:ERP AD:SG J. til LLER BE MED RSLB (CLARK) (9)

- SEPB (DAVIS) (11)

ORB #3 (IPPOLITO) (8)

RSDB (PAGANO) (s)

ORB #1 (SCHWENCea)(8)

ORB #4 (REID) (9)

ORB #2 (ZIEMANN) (8)

EB (NOONAN) (19)

PSB (LAINAS) (27)

EEB (KNIGHTON) (14)

RSB (CHECK) (18)

STS (BRINKriAti) (3)

N N

L-1 TOTAL STAFFING: 143 PROFESS 10tlALS NID MANAGERS

DIVISION OF PROJECT MANAGEMENT R.

BOYD AD: LWR AD:0ARO TO BE D.

SKOVHOLT NAMED.

LWR //l (STOLZ)( 7)

OAB (HAASS) (10)

LWR //2 (BAER) (5)

OLB (P. COLLINS) (5 )

LWR //3 (PARR) (6)

FINAtl. (PETERSON)(3)

LWR //Il (VARGA) (6)

STDZN. FUNCTION (2)

ADV. REACTOR FUNCTION (FT. ST. VRAIN) (2) g (FFTF) (2) y vs

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N TOTAL STAFFlf!G: 51 PROFESSIONALS AND tWlAGERS

DIVISION OF SITE SAFETY AND ENVIRONMENTAL ANALYSIS D. MULLER, ACTING AD:EP&T AD:SA M. ERNST W.

KREGER

- ETSB (BANGART. ACTING) (7)

EP-1 (BALLARD) (8)

RAB (CONGEL, ACTING) (8)

- EP-2 (REGAt0(10)

CBAB (YOUt1GBLOOD) (10)

- AAB (HOUSTON) (16)

- HMB (HULMAN) (16)

- ESB (LEAR) (14) i Nw us TOTAL STAFFING: 92 PROFESSIGIALS AND lWT.3ERS U

DIVISION OF SYSTEliS SAFETY F.

SCHROEDER, ACTING AD:E AD:RS AD:PS V. MOORE,

3. DENISE,

.l.

KNIGHT ACTING

_ & IDLG

-ASB (BENAROYA) (4)

- MEB (B0SNAK)(7)

_ AB (PHILLIPS, ACTI NG) (5)

-ICSB (SATTERFIELD) (5)

- MTEB (PAWLICKI) (5)

_., RSB (SPEls. ACTING) (5)

-PSB (ROSA) (5)

SEB (SCHAUER) (9)

CSB (BUTLER)' (12) g GSB (JACKSON) (12 )

- CPB (KNIEL) (ll)

N L4 N

4 TOTAL STAFFING: 84 PROFESSIONAL AfD fWMGERS

IDENTIFICATION AND

SUMMARY

AND CASEWORK IMPACTS 273 215

Identification of Continued and Suspended Casework Reviews The completion of reviews of near term OLs including the coordination and implementation of input from Lessons Learned and Bulletins groups for these plants:

Salen 2 (May 1979)*

North Anna 2 (June 1979)

Diablo Canyon 1 (June 1979)

Sequoyah 1 (July 1979)

McGuire 1 (October 1979)

Zimmer (December 1979)

LaSalle 1 (December 1979) m

  • Construction conpletion dates are shown in ().

The completion of CP's for which the reviews are essentially complete and are already active in the hearing process:

Perkins Pebble Springs 1 and 2 Skagit I and 2 Pilgrim 2 Allens Creek New England 1 and 2 Black Fox 1 and 2 273 216

. The resulting Board actions could adversely impact staff efforts to complete these reviews in a timely manner.

The review of OL's for which construction is expected to be completed prior to January 1981 include will continue.

These reviews include:

Watts Bar 1 (June 1980)

Fermi 2 (June 1980)

Sumner (October 1980)

Shoreham (October 1980)

San Onofre 2 (November 1980)

Susquehanna 1 (December 1980)

WPPSS 2 (December 1980)

In spite of recently announced delays in Fermi 2 (now June 1981) and WPPSS 2 (now March 1981) these reviews will continue due to the considerable amount of effort already expended.

273 217 Sespended Activities As a result of realignment resources and new priorities the following in the Casework Decision Unit will be susperded:

1.

Suspend OL reviews until January 1980:

Grand Gulf I and 2 (March 1981)

'Farley 2 (June 1981)

Waterford 3 (September 1981)

Byron /Braidwood (September 1981)

Midland 1 and 2 (November 1981)*

Comanche Peak 1 and 2 (Novembeer 1981)

Bellefonte 1 and 2 (March 1982)

Catawba 1 and 2 (September 1982)

South Texas 1 and 2 (October 1982)

  • Except for work on structural / foundation problems t

273 218

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2.

CP reviews to be suspended until January 1980:

Erie 1 and 2 Davis-Besse 2 and 3 Haven 1 New Haven 1 and 2 Greenwood 2 and 3 (Preapplication Review for Carroll County will be postponed; however, Early Site Review efforts will continue.)

3.

Other activities:

a.

Standardization Reviews (1)

All seven B0P reviews (2)

FDA review of CESSAR-80 (3)

RESAR-412 PDA (for Carroll County) will be delayed well into 1980 (FNP, if possible, will be continued but with no essential priority).

b.

NASAP and INFCE activities 273 219

. Summary of Casework Imcacts The following summarizes the Casework Impacts resulting from the realignment of resources and priorities:

o Near term OL applications delays:

Salem 3 months North Anna 2 2 months Diablo Canyon 1 2 months Sequoyah 1

.1 month Reopened hearing for Three Mile Island 2 issues could cause further delays o Suspended OL review delays:

Grand Gulf 12 months Waterford 3 6 months Byron /Braidwood 6 months Comanche Peak 4 months Other ninor delays may occur in Bellefonte, Catawba and Comanche Peak reviews 273 220

, o CP Delays Carroll County 12 months Haven 1 Central Virginia 12 months Erie

  • Davis Besse*
  • If applicant proceeds on schedule - 12 months delay o Suspend Standardization Reviews 273 221

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0 tiler CP APPLICATIONS ERIE 182 NEw IIAVEN 182 DAVIS BESSE 283 GREENWOOD 283 IIAVEN 1 OTHER OL APPLICATIONS GRAND GULF 182 (3/81)

FARLEY 2 (6/81)

WATERFORD 3 (9/81)

BYRON /BRAIDWOOD (9/81)

MIDLAND 281 (11/81)

COMMANCnE PEAK 182 (11/81)

BELLEFONTE 182 (3/82)

CATAWBA 182 (9/82)

S0uTu TEXAS 182 (10/82) va u,