ML19322A548
| ML19322A548 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/30/1979 |
| From: | Mattson R NRC - TMI-2 LESSONS LEARNED TASK FORCE |
| To: | Case E Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7911120430 | |
| Download: ML19322A548 (8) | |
Text
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OCT 3 01979 Docket No. 50-320 MEMORANDUM FOR:
E. G. Case, Deputy Director Office of Nuclear Reactor Regulation FROM:
Roger J. Mattson, Director Lessons Learned Task Force, NRR
SUBJECT:
OBSERVATIONS OF R. H. WESSMAN RELATING TO PERSONNEL, PRO-CEDURES AND ORGANIZATION RESULTING FROM THREE MILE ISLAND Your note to me of September 12, 1979 forwarded a memorandum from R. H. Wessman (IE-Region II) for Lessons Learned Task Force consideration.
You stated unless there are very persuasive reasons to the contrary you would support all of them.
The Task Force in NUREG-0578 and NUREG-0585 has addressed most of the items raised in R. H. Wessman's May 2, 1979 memorandum.
A response to each item in the Wessman memo is attached.
Orte at s:;,ed by R: cr ).Ma38W)
Roger J. Mattson, Director Lessons Learned Task Force
Enclosure:
As stated Distribution:
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ATTACHMENT Lessons Learned Task Force Response to R. H. Wessman Observations Relating to Persorael, Procedures, and Organizations Resulting from Three Mile Island 1.
Increase Control Room Manning R. Wessman Comment:
" Requiring the addition of one licensed operator (RO) to the control room staff of each unit assures that there will be two men at the console at all times to cope with transients or emergencies.
It is my belief that the control room is too big a place for one can, particularly when transients occur.
Under current regulations, Technical Specifications could be satisfied with one man at the console and other licensed personnel elsewhere in the plant.
Examples include Browns Ferry 3 or Crystal River 3.
"It may also be appropriate to require that the shift supervisor (SRO) remain in the control room (or shift supervisor's office) at all times to assure a If the shift supervisor is to go managed / directed response to casualties.
elsewhere in the plant, an assistant shift supervisor (SRO) could be required to remain in the control rodm/ shift supervisor's office.
The additional personnel in the control room area would assist in supporting the administrative activities, conduct of surveillance, or training when not directly supporting accident response."
Response
Minimum requirements for control room manning by licensed reactcr operators was addressed in a May 18, 1979 memorandum from H. Denton to Commissioner Kennedy.
It was concluded no change from present staffing requirements Commissioner Kennedy,in response to H. Denton's May 18, was necessary.
1979 memo, requested NRR to explicity include the subject of minimum requirements for control room manning as part of its lessons learned studies.
The subject is addressed by the Task Force in NUREG-0585 and NUREG-0578.
In NUREG-0585 it is recommended the Commission's regulations be revised to more clearly state present staff requirements (as described in the Standard Review Plan Section 13.1.2) for minimum shift staffing of licensed reactor The Task Force also recommended that in developing the revision operators.
to the regulations, consideration should be given to requiring the presence in the control room at all times during normal operations of two reactor The Task Force further stated operators and one senior reactor cperator.
that provisions for tours of the plant by operators will probably need to be made if the staffing proposal is adopted.
2 In NUREG-0578 it was recommended each licensee provide an on-shift technical advisor to the shift supervisor as a step toward correcting an identified weakness in the operating staff's ability to understand and diagnose complex transients.
In NUREG-0578 it is also stated the shift supervisor, until properly relieved, shall remain in the control -oom at all times during accident situations to direct the activities of control room operators.
2.
Require Biannual Operator Exams Administered by the NRC R. Wessman Comment:
"Present reliance on the utility's approved requalification program seems insufficient.
A reliance on the utility's inhouse requalification program (even though it's inspected) and relatively automatic reissue of an operator's license may tend toward complacency. An independent NRC exam may also provide greater assurance of operator quality.
The Navy's nuclear power program does not rely solely on the individual shipboard training and requalification program.
The Navy uses outside examiners (from the fleet commander or Naval Reactors Division) to administer an Operational Reactor Safeguards Exam (ORSE) on a 1-2 year basis.
This incentive (and threat of failure) keeps operators at a higher state of readiness."
Response
We assume Mr. Wessman' intended biennial exams vice biannual exams.
In any case, SECY 79-330E provides recommendations on operator requalification programs which are responsive to Mr. Wessman's observations such as:
a.
Annual simulator training of all operators b.
Explicit requirements regarding exercises to be included in simulator requalification program.
c.
Increased level of confidence in the effectiveness of requalification programs provided by NRC examiners administering approximately 10% of the annual requalification examinations.
With regard to operator requalification programs, the Task Force in NUREG-0585 also recommended that (1) prior to assuming initial shift assignment as shift super-V uor or shift technical advisor and on a biennial basis thereafter, individuals should be interviewed by an interdisciplinary group of NRC staff, and (2) the NRR operator licensing program personnel sponsor an annual workshop for licensed operators to be attended by at least one representative of the licensed shift personnel at each unit.
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3 3.
Increase the IE/0LB Interface R. Wessman Comment:
"1..a presence of aF0T6 examiner in the region has improved the exchange of information betwecn the two organizations, although it has been frequently informal in nature.
Sharing observations and experiences have been beneficial to both groups.
It is suggested that the NRC consider the following:
Provide specific training to IE inspectors so that they can better inspect operator performance (IE inspector simulator training is a step in this direction).
Increase OLB representation in all regions.
Provide specific direction / guidance to the Resident Inspector to inspect in the area of licensed operator activity.
Emphasize (such as via regional instruction) feedback mechanisms to assure that observations concerning operator performance are added to an individual's docket file.
Look more closely at LER's for events attributable to operator error."
The Task Force in NUREG-0585 recommended the following items which are responsive to Mr. Wessman's observations.
a.
"As part of the inspector training program of the Office of Inspection and Enforcement (IE), operator licensing program personnel of the Office of Nuclear Reactor Regulation should (a) provide information to IE inspectors on the operator licensing program, and (b) identify the types of information the IE inspectors should provide to assist NRR in making decisions with regard to the renewal of operator licenses."
b.
"The NRC staff should establish a mechanism whereby individuals committing operational errors are identified in Licensee Event Reports.
Such a mechanism should include provisions for protection of the privacy of the individual.
The intent of this recommendation is to provide additional information to operator licensing program personnel to assist them in determining the continued qualification of operators in the review of operator license renewal applications.
Due consideration should be given to whether such reporting will affect.the quality of reports received by the NRC."
c.
" Consideration should be given to placing resident operator ing examiners in each of the major geographical areas where there i concentration of training centers using nuclear power plant simulators."
4 4.
Expand Scope of Licensing for Plant Personnel R. Wessman Comment:
"There are several groups of individuals whose activities affect plant operations, as well as public health and safety, who could be subject to NRC licensing.
Examples are auxiliary operators (operating waste processing equipment and nuclear auxiliaries), chemists, or health phyicists.
They are all subject to the constraints of ANSI N18.1 (Standard for the Selection and Training of Nuclear Power Plant Personnel).
Additional training ar.d qualification may currently be specified by the utility and/or union agreements.
A specific NRC license, separate and distinct to the R0 license, appears as an appropriate additional requirement."
Response
The Task Force stated in NUREG-0585 the staff should decide which plant personnel, other than reactor operators and Senior reactor operators, should be licensed.
Additional Task Force recommendations in this area are provided in Section 1.8 of the Appendix to NUREG-0585, 5.
Enhance Communication of Industry / Regulatory Experience to the Operator Level R. Wessman Comment:
'It is not clear that information vehicles such as IE Bulletins, Circulars, and Notices reach the operators, when appropriate.
These documents are seen by plant supervision but, based on my own experience, are not always passed on to the operators.
The same' may be true for industry vehicles from vendors, EPRI, or AIF."
Response
In NUREG-0585 the Task Force recommended that each licensee should be required to review, within 90 days, its administrative procedures to assure that a mechanism exists through which lessons learned from operating experiences contained in various publications (such as IE Bulletins, Circulars and Notices, and applicable Licensee Event Reports) and from the licensee's own operating experience evaluation group are conveyed to reactor operators and other affected operations personnel.
6.
Require Simulator Refresher Training for R0's and SR0's R. Wessman Comment:
" Requiring simulator refresher training will main'tain operator capabilities for accident response.
This is the only place to " practice" for transients and accidents.
An annual requirement of one week at the simulator seems appropriate and could be made part of the requalification program."
V 5
Response
See item 2 above.
7.
Require More In plant Drills R. Wessman Comment:
"An annual emergency drill and an occasional fire drill seem insufficient.
Operating Naval reactors hold drills on a far more frequent basis.
Various in plant casualties, such as pump trips, instrumentation failures, failures of automatic control systems, and radiological " accidents" can be simulated to enhance proficiency and procedures."
Response
The 00R letter of September 13, 1979 requires test exercises of the approved emergency plans.
Task Force recommendations concerning in plant drills are addressed in Section 1.3 of Appendix A to NUREG-0585 as follows:
"Each licensee should be required to review, within 90 days, its training program with respect to the conduct of in plant drills.
For tasks performed by shift operating personnel in response to off-normal or accident situations, licensees should assure that sufficient in plant drills are conducted to enable personnel to maintain proficiency in those tasks.
The Task Force considers drills of a walk-through nature acceptable and does not mean to imply the actual manipulation of controls or equipment or initiation of an even; (such as by the opening or closing of valves or tripping breakers or pumps).
The Task Force considers that drills requiring the physical manipula-tion of controls are also important but can be more efficiently and safely conducted using an appropriate nuclear power plant simulator. With this in mind, each licensee should develop a schedule for in plant drills.
This schedule should be a part of a disciplined training program for each station.
It need not be submitted to the NRC for review; however, it should be avail-able at the site for inspection."
8.
Development of Post-Accident Procedures R. Wessman Comment:
)
"Many of the procedures developed during the recovery from the TMI accident have applicability at all facilities and may.be required regardless of the initial accident. These should be postulated and developed in advance to avoid the extensive procedural generation effort in the midst of a casualty.
Examples are:
Loss of critical instrumentation Sampling when fission products are present
6 High auxiliary building radiation levels limiting access to critical components Plant operations with high level contamination in the reactor building atmosphere Reactor coolant pump operations when solid or under limiting / accident conditions Handling of high level waste"
Response
R. Wessman's observations are specific and as such can be incorporated into Regulatory Guide 1.33 which is presently being revised.
Standards Development has a copy of R. Wessman's letter.
In addition the Task Force has provided a recommendation for review by the NRC of emergency procedures for all nuclear power plants.
(See Section 4 of
- Appendix A to NUREG-0585).
9.
Development of Post-Accident Command, Control, and Communications Structure R. Wessman Comment:
"For each utility / facility the post-accident command, control, and communications structure needs development.
Three Mile Island demonstrated the magnitude of such an organization and revealed various organizational weaknesses.
Such a structure must identify interfaces between groups such as the NRC, the facility, the utility's corporate organization, vendors, the A-E, and other state.or federal bodies.
Communication and control paths require definition.
Plans must exist in advance to coordinate the actions of large numbers of personnel and diverse organizations into a directed accident response team. The NRC's role (and the role of various NRC offices) requires clarification."
Response
Onsite accident command and control structure is addressed in NUREG-0578, Section 2.2.1.a and Sections 2.2.2.a, b, and c.
The 00R September 13, 1979 letter to all operating nuclear power plants require the upgrading of licensee emergency plans to satisfy Regulatory Guide 1.101.
We agree that the NRC's role requires clarification but this is outside the scope of the Lessons Learned Task Force.
10.
System Lineup Verification on Safety-Related Systems R. Wessman Comment:
" Current practice does not require an independent verification of system lineup subsequent to surveillance testing on safety-related systems.
This extra check seems appropriate.
The NRC has required this type of independent
. verification upon the installation or removal of jumpers and upon initial i
7 system lineup.
Currently, we only rely on the surveillance test procedure, which may be fully executed by one person.
Naval submarine practice has been to require such an independent verification upon " rig-for-dive" and whenever the rig-for-dive is broken and then restored, to assure ship safety."
Response
Present Regulatory guidance on the subject of equipment control which includes independent verification of correct implementation of measures provided for control of equipment is covered in Regulatory Guide 1.33, " Quality Assurance Program Requirements (Operation)," through endorsement of ANSI N18.7-1976/ANS 3.2,
" Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants." Section 5.2.6 of the ANSI N18.7-1976/ANS 3.2 standard addresses eauipnent control procedures in general terms. With regard to align. ment of valves, the ANSI N18.7-1976/ANS 3.2 standard states that procedures shall be provided for control of equipment to maintain personnel and reactor safety and to avoid unauthorized operation of equipment and shall require independent verifications, where appropriate, to ensure that necessary measures such as tagging equipment have been properly implemented.
The latest revision of Regulatory Guide 1.33, issued for public comment on October 6, 1979, states that independent verification of correct implementation of measures provided for control of equipment should be performed in all instances.
General guidance is available; however, a problem exists in implementation of the general guidance with one problem being the specificity of the guidance available.
The Lessons Learned Task Force addressed the subject of verification of correct performance of operating activities in NUREG-0585.
The Task Force concluded a more effective system of verification of correct performance of operating activities is needed in order to provide a means of reducing human errors and improving the quality of normal operations, thereby reducing the frequency of occurrence of situations that could result in or contribute to accidents and that such a verification system should include automatic system status monitor-ing and human verification of operations and maintenance activities independent of the people performing the activity. Additional discussion is provided in Section 5 of Appendix A to NUREG-0585.
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