ML19253C306
| ML19253C306 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 11/26/1979 |
| From: | Minnick L YANKEE ATOMIC ELECTRIC CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0585, RTR-NUREG-585 WYC-79-30, NUDOCS 7911300479 | |
| Download: ML19253C306 (7) | |
Text
7/ daib Telephone 617 366-90ll twx 780 + 3 90-073 9 YANKEE ATOMIC ELECTRIC COMPANY Mh'go 20 Turnpike Road Westborough, Massachusetts 01581 Y4mase
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November 26, 1979 Mr. Harold Senton, Director Nuclear Reactor Regulation United States' Nuclear Regulatorv Commission Washington, D.C. 20555
Subject:
Comments on the Final Report of the TMI-II Lessens Learned Task Force (NUREG 0585)
Dear Mr. Denton:
The purpose of this letter is to offer perspective on the philosophy and recommendations described by the Lessons Learned Task Force in their final report, NUREG 0585.
It is hoped that these suggestions will be considered before the specific recommendations in that report are finalized and forwarded to the Commissioners. There are many concepts in the final report which we endorse wholeheartedly. The concepts "... that the improvement and maintenaace of operational safety is a fundamental responsibility of licensees
..." and "... that the NRC role should be to provide minimum acceptable criteria which are fundamental..." are fundamental to our own philosophy. We at Yankee Atomic Electric Company have been dedicated to the maintenance of the highest level of operational safety throughout our 20 years of plant design and operation. We demand that "... designers, draftsmen, workmen,
[ engineers, operators], supervisors, and managers all be responsible for their work."
We require that they be responsible for recognition, acknowledgement, and correction of errors, should they occur. The report presents many specific ways in which the role of licensees and the staff might be enhanced.
These ele the subject of specific comments in the attachment, hereto.
In the discussion and the specific recemmendations, it is clear that the Task Force intends a role for the NRC which 9,es far beyond that of providing
... acceptable criteria...". The report suggests active NRC involvement in
.such matters as selection of supervisory personnel and review of detailed plant procedures. These suggestions extend the activities of the NRC into management and technical areas generally prescribed to the licensee.
- However,
)b.h t/ 77 7911300 ef
Mr. Harold Denton Page 2 November 26, 1979 they fail to recognize the attendant obligation which would be incurred by the NRC by venturing into ther ' areas.
If the NRC intends to influence and constrain licensee activities at the suggested level of detail, then, individual accountability must apply equally to the regulator and the licensee. Whenever the regulator undertakes to impose his interpretation of operational information or situations and dictate methods of operation, he must be fully prepared to bear the full responsibility for his action. This obligation should be weighed carefully before any recommendations which involve steps in this direction are endorsed for implementation.
Furthermete, increased volume of requirements spiraling ever more deeply into detail, can have the effect of detracting from performance and safety if attention to these fundamentals by licensees is impaired. This condition can be identi fied in the I&E inspection results at many facilities in recent years. To some degree the impression has been left to plant staffs that discrepant findings, regardless of their triviality, are the major objectives of an inspection. This impression is difficult for management to combat, and is in fact intensified by the complete lack of recognition of good performance in any of the reports. This "mindset" of inspection reports, is contrary to all principles of constructive management.
The fundamental goal of the report will never be realized by creating an endless stream of additional regulatory requirements. The goal, simply stated, is exemplary performance by all those individuals necessary to design, build, operate, and maintain a Nuclear power station. This goal lies largely in the realm of attitudes.
Its realization comes through the dedication by individuals to achieve their assigned task in the "best possible way."
It demands a managemt;nt group responsible for each facility which is sufficiently experienced to exercise judgment and technically knowledgeable enough to understand when judgment is necessary.
Realization of this goal should be achievable.
It will not, however, be achieved by stifling the sense of individual responsibility with yet another wave of requirements and restrictions.
Indeed, refocusing of many of the current staff programs may be necessary in order to restore the necessary oersonal participation.
The Task Force has suggested a need for a national nuclear safety policy in the form of a safety goal which would enable "... achieving a balanced regulatory perspective." We support that recommendation but view with concern, the specific means of implementation, which involves a qualitative goal consisting of a regime of requirements that are " required for safety."
As explained in Section IV of NUREG 0585, decisions relative to safety would,
be "... anchored in the necessity to be consistent with and in furtherence of the regulations..." (which, in turn, constitute an aggregate of requirements which are required for safety). This type of qualitative goal appears to be so flexible as to be easily adaptable for any use deemed " appropriate" at the moment. Thus, any new regulatory " improvement" would obviously be " required" for safety; and given the need for consistency with a national goal, individual cases would not be relevent. The " improvement" would become a backfit, uniformally applied, for the sake of consistency rather than for the sake of safety.
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Mr. Harold Denton Page 3 November 26, 1979 The safety goal for nuclear power must be anchored in a realistic comparison of alternatives available today for supplying large quantities of energy to our nation. Nuclear, coal, hydro, gas,. oil, geothermal and other sources should be considered together in terms of public safety. The resulting safety goal must be based on a comparison of the hazard presented by each of the technologies involved, and to be r elevant, it must include a consideration of the public health and safsty impact of all wide-spread energy shortages. The degree to which an energy source is domestic, and the inherent national security that it implies must also be recognized and considered. A safety goal created for monitoring nuclear power in isolation and which ignores these factors will merely assure its continued decline.
The preceeding comments and the attached specific recommendations are not intended as an indictment of the NRC.
Their purpoce is to call your attention to matters that deserve consideration. Many times you have suggested that there is need for a "new way of doing business." That new way must be developed from the ground up.
The need is not for more and more regulation, but for better and better regulation. The NRC must be cognizant of the finite constraints that exist on industry resources. These resources can be devoted to intelligently analyzing problems that have been presented and developing innovative and worthwhile solutions. Conversely, they can be expended on long and unnecessary disputes over staff imposed political fixes and generically contrived conveniences which may or may not improve plant safety, but generally are at the expense of operational ease and flexibility. The degree to which the NRC may infringe upon the ability of licensees to dedicate resources towards improvements in performance and, hence, safety should be paramount to all NRC decisions.
We would be happy to discuss these comments at your convenience.
Very traly yours, h4tDK/y L. E. Minnick President jgh Attachment O
e
COMMENTS ON SELECTED FINAL RECOMMENDATIONS OF TMI-II LESSONS LEARNED TASK FORCE Recommendation 1 (1.1, 1.2, 1.3, 1.5, 1.7, 1.8) - Personnel Qualifications and Training We generally endorse these recommendations.
Recommendation 1.4.(2) - Operator Training - Identification of Individuals The report suggests that individuals committing errors be specifically identified in Licensee Event Reports. This suggestion presents many difficulties because of right to privacy laws both at the state and federal level. Regardless of this, the individual's name has no relevance to the circumstances (i.e. seriousness, etc. of the event).
Licensees certainly will monitor and reward or punish individual performance. This aspect of plant operation is entirely inappropriate to the plant docket.
Recommendation 1.4.(3) - Operator Training - NRR Trainino Program It would probably be beneficial to have operators participate in some training courses at NRR.
It would be even more productive to require that NRC per Tel who are reaching a similar level of supervisory responsibility partialpate in work efforts at nuclear steam supply vendors and architect engineering firms.
In addition, these personnel should be required to fulfill work assignments in operating plants. The resulting upgrading in practical understanding would be remarkable.
Recommendation 1.4.(4) - Operator Licensing - Interviews NRC examinations should be conducted at the simulator (for requalification) and at the site (for initial qualification). Examination or re-examination by the NRC in the agency headquarters would tend to focus primarily on interview skills instead of first hand knowledge and experience with the operating facility.
In addition, this recommendation appears to be contrary to the fundamental premise of the report, which suggests that the principal responsibility for safe operation lies with the organizational licensee.
Recommendation 1.4. (5) - Operator Licensing - Workshoos We would strongly support an NRC sponsored annual workshop. A candid exchange by NRC staff and utility operators could greatly enhance understanding of problem areas by both. This mechanism for exchange of information should be structured for maximum participation by utility attendees on such topics as'
"... impact of licensing [ requirements) on shift activities..." and should carry mandatory attendance requirements for NRC managers f rom the Chief Staff,
level upwards.
Alternatively, the NRC staff could emphasize participation in the regional workshops sponsored by the American Nucleae Soc ie ty.
In the past several years, the local chapters of the American Nuclear Society have provided regional, Operating Plant Experience Workshops. These workshops generally 1443 032
involve many of the licensed shift personnel from the operating plants in the region. Safety concerns, operating practices, and improvements in operations are the principal topics of discussion. The NRC staff could achieve a large measure of their intended purpose by active participation in these workshops.
Creation of an entirely new series of workshops would not, then, be necessary.
Recommendation 1.6. (1) - Licensed Operator Qualifications The Task Force recommended increased formal education requirements for shif t supervisors and :enior reactor operators. The need for additional training for' these personnel has been recognized by the industry. Efforts are underway to enhance training. Practical fundamentals of thermal hydraulics and other physical phenomenon is important to the well rounded understanding of the supervisory personnel. However, the suggestion that shift supervisors hold a 4-year college degree is at best inappropriate. The President's own commission findings in this area called for not a degree, but rather accreditation of training through an organization such as INPO.
Requirement of a college degree for shift supervisors is inappropriate for the following reasons:
A shift supervisor and/or senior control room operator develops a
" feel" for plant operation by operating the equipment as they progress through the plant operator stations subordinate to the senior watch stations.
It would be very difficult to make college graduates patiently work through several levels of plant operation responsibility before achieving senior operator status.
An operator a function is primarily reactive rather than analytical.
In a control room environment, a theoretical approach to problem solving is very much less effective than an operational hands on approach.
The degree requirement on the senior watch stations creates a " dead end" career path for equipment operators and licensed control operators. Presently, these ind;.cluals, with more experience _ and training, can progress significaritly in terms of responsibility and economic reward.
The recommendation is inconsistent with our long term experience.
A major motivation for degreed personnel seems to involve getting off shift.
The best all-around performance has been consistently turned in by practical steam engineer type of personnel.
Recent testing performed by a well qualified independent consultant at one of our facilities has indicated a possibility of an inverse relationship between level of formalized education and operator recognition and response to unusual plant circumstances.
- 4k) l There are practical constraints presented by labor union contract conditions.
Recommendation 2 - Staffing of Control Room We generally endorse this reccamendation.
Recommendation 4 - Emergency Procedures Detailed review and comment on emergency operating procedures for nuclear power plants by the NRC is counterproductive. Past history suggests that such a review process would lead in a relatively short time to generic procedures which would emphasize ease of review by the so called " interdisciplinary review groups" instead of ease of performance.
Plant emergency procedures must be plant specific and thej must be developed by the most knowledgeable operating experts available to the facility. Emergency procedures naed to be clear, concise, technically correct, and urederstandable to the operator. The NRC has repeatedly demonstrated itself to be uniquely unable to produce such documentations involvement of the NRC in the procedure review process would make it unnecessarily more complicated and most probably introduce extraneous information which would on balance, detract from the procedures.
Recommendation 5 - Verification of Correct Performance of Operatino Activities We generally endorse this recommendation however, backfitting of Regulatory Guide 1.47 to all plants is unwarranted and unreasonable. Findings from TMI do not provide solid justification for this requirement.
Recommendation 6 - Evaluation of Operatino Experience Part of the program for disseminating information to operating plants should include a mechanism for separating the significant from the insignificant information. To process and submit information, regardless of its significance to operating plants, will simply add to the paper burden. Unless the additional information can be culled, with only significant information extracted for dissemination, people will react with much less enthusiasm to it.
It could also lead to a greater amount of time being spent by operations personnel in dealing with paper and less time spent in control of the plant.
Evidence of dilution of relevent information can be seen by a historical review of plant operating experience reports. Originally, significant operational incidences were reported throughout the industry via NRC Operating Experience Bulletins. Though distribution of these bulletins was slow, they generally were descriptions of significant malfunctions or maloperations.
Careful review and discussion by all plant operators was a certainty. With the onset of the Licensee Event Reporting System, and subsequent refinements, each instance of set point drift, meter miscalibration, and other relatively,
minor incidents were given the same level of importance as the significant events reported previously. The result has been lost interest on the part of operating personnel when faced with literally hundreds of reports which must be " waded-through" for a few significant pieces of information.
1443 034 Recommendation 7 - Verification of Correct Performance of Operating Activities We generally endorse this rec 3mendation. Current work at EPRI is bting watched carefully for results chat can be implemented at our facilities. Much can be done in terms of clarification of display by panel segregation and improved labeling.
In addition, composite status light groupings which indicate a summary of system status offer potential improvements thLt can practicably be retro-fitted.
Extensive redesign and exotic integrated digitalized display have not been evaluated.
The' impact of major modifications to plant control rooms, including extraction of key indications, has not been evaluated fully. We feel there may be significant negative influence on plant operation by modifications such as these. The benefits of these types of modifications should be clearly establ!.shed before such activities are undertaken.
He have had several discussions with potential design teata members on a Disturbance Analysis System design study for EPRI; we hope to participate in some fashion in this project.
Recommendation 8 - Reliability Assessment The NRC proposes the uce of thorough systematic, integrated, quantitative evaluations of potential accident sequences and system responses.
It is not entirely clear what is intended by this recommendation. Although the NRC proposes that these be used to evaluate system weaknesses, the NRC shculd also recognize and accept the use of this methodology to evaluate system strengths and permit t he relaxation of Reg. Guide and Standard Review Plan requirements when such topics are identified.
Recommenda'. ion 9 - Review of Safety Classifications and Qualifications '
Reviews conducted to identify " systems interactions" inherently have the potential to convolute to the extent that they become almost boundless:
Results c f the recent efforts by Sandia to resolve generic Item A-17 is indicative of this problem. We are endeavoring to review our plants on a limited scope. We would urge caution in embracing this recommendation. -
Recommendation 10 - Design Features for Core Damage and Core Melt Accidents Systems and design features are in place for the purpose of mitigating accidents which could lead to significant core damage. These have already been the subject of rule-making proceedings. What is needed is careful attention to operating proced_res to assure that the systems are allowed to perform their intended functions. The reactor containment is intended as a '
design feature to mitigate the consequences of core damage following loss of coolant incidents.
Because of the containment, the health and safety of the public was protected even at TMI.
Since these design features are in place,,
it seems relatively useless to conduct further rule-making on the subject.
Recommendation 11, 12, 13 Addressed in the forwarding letter.
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