ML19341A528
| ML19341A528 | |
| Person / Time | |
|---|---|
| Issue date: | 10/03/1980 |
| From: | Jamarl Cummings NRC OFFICE OF INSPECTOR & AUDITOR (OIA) |
| To: | Ahearne J, Gilinsky V, Hendrie J NRC COMMISSION (OCM) |
| Shared Package | |
| ML19341A503 | List:
|
| References | |
| FOIA-80-516 NUDOCS 8101260247 | |
| Download: ML19341A528 (5) | |
Text
so -s tia p %'e MG UNM ED STATES
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..C s.u,.d DE 31980
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mU MEl:0RANDUM FOR:
Chainnan Ahearne i
Commissioner Gilinsky Commissioner Hendrie Commissioner Bradford 1
d FROM:
James J. Cummings, Director Office of Inspector and Auditor AUDIT OF THE IMPLEMENTATION OF NRR-RELATED TMI
SUBJECT:
LESSONS LEARNED CONCERNING UTILITY PERSONNEL LICENSING AND TRAINING We have completed the first phase of our audit of the implementation of NRR-related TMI lessons learned focusing on those recommendations concerning utility personnel licensing and training.
Scope This phase of our audit included a review of the recommendations of the major Tl!I studies and how they were brought together in the action plan.
i We evaluated the process used to identify and collate recommer.dations from the major TMI studies, to cross reference and index all action items to the source documents, and to respond to and satisfy the intent of the recommendations.
To accomplish this, we defined, identified, collated and cataloged 108 recommendations concerning utility personnel training and licensing', and tracked them to the action plan, in its draft and final fonns. 'We made a detailed analysis of a 20 percent sample of these recommendations (22 recommendations) and compared them to the action plan items to detennine whether the action items adequately reflected the intent of theyecommendations. We also evaluated whether the action plan's cross references were adequate for the reader to detennine the full intent of el h action item and the original ~ recommendations each was implementing.
We did not judge the adequacy of he recommendations to solve the many
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Rather, we problems and uncertainties raised -by the Till accident.how well the plan br 1
concentrated on recommendations into a coherent package fof management action.
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Contacts:
F. !! err, 0I A P. Murray, 01A 49-27051
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Findings Based o,n our review we believe that:
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the overall action plan was well done and satisfies the intent of the many recommendations of the THI studies; and The group responsible for putting together the action plan did a very commendable job.
Our review disclosed several concerns which dealt generally with assuring that all recommendations were accounted for, and improving the action plan references to ensure that the intent of the actual recommendations was clear to those who will be responsible for implementing the action items. L'e discussed our analysis and evaluation with Dr. Mattson, the chainnan of the group responsible for the action plan.
For the most part, our concerns have been resolved through his clarifications of the items in question or through changes that he agreed to make in the action plan.
However, there were two regommendations which we believe were not adequately addressed:
The Commission's response to SECY-79-330E, Qualifications of Reactor Operators, directed the staff to increase the scop'e of reactor operator and senior reactor operator examinations and to develop and administer all annual requalification examinations, certification examinations and audits of training programs. The tiRR staff had recommended that f1RC administer about 10 percent of the requalification examinations and oral evaluations but the Commission decided that NRC should perfonn all of them in-house.
The action plan included the Commission's recommendations and estimated an expenditure of 0.7 and 1.0 manyears for fiscal years 1980 and 1981 to be used for the development of criteria and proposed rule changes that included the requalification examination program.
The plan stated that funds to implement and administer the requalification program would be included in the fiscal year 1982 budget. In their FY 1982 budget, NRR requested an increase in operator licensing staffing from 26 to 37 manyears, however, none of these positions
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l were for administering the requalification examinations. Alternatively, NRR's budget request for program support for operator licensing increased from $170,000 in FY 1981 to $4 million in FY 1982.
This increase was to administer the annual requalification examinations l
by way of contract.
In spite of NRR's FY 1982 budget request regarding requalification examinations, they are continuing to examine alternative r.ethods for fulfilling the Commission's directive through a contract with Analysis and Technology, Inc. The results of that study should be presented to the Commission as soon as they become available.
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3 The Executive Director for Operations * (EDO) comments on a draft of this report stated that it was impractical to request an increase irl the liRC staff necessary to conduct all requalification examinations id-house.
As a result, fiRR requested staff increases to administer replacement examinations and technical assistance money to contract Following completion of the out the requalification program.
Analysis and Technology, Inc. contract, however, liRR plans to reapportion the people and technical assistance money available The EDO between the replacement and requalification programs.
expects to make a recommendatiun to the Commission on th'e plans and
-c budget for the requalification program in early Spring 1981.
IE's Special Review Group recommended that if a licensee does not meet fiRC's criteria for testing the adequacy of emergency preparedness, liRC should conduct its own test. The action plan does not address the conduct by flRC of its own test should the licensee fail to conduct an adequate test.
In commenting on a draft of this report the EDO stated that fiRC's participation with the Federal Emergency !!anagement Agency in reviews and evaluations of licensees' emergency exercises, and the fact that a licensee's failure to comply with Part 50 requirements for conducting drills and exercises could result in suspension or modification of his licensq satisfied the IE Special Review Group's recommendation.
Other Observations _
Based on our review to date of the actions related to utility personnel licensing and training, we have the following observations relating to the action plan as a whole that we feel are important to a better understanding of the action plan.
Many recommendations of the THI studies are not addressed by action When the committee collated and consolidated recommendations items per se.
for the action plan they had to make many detenninations regarding which to address by action items.
The problem arose with recommendations which were very similar, contradictory, provided two different solutions to the same problem, or were beyond the scope of fiRC's authority.
We believe however that the recommendations from the I
major studies were adequately considered in the plan.
The committee's charter was unclear and changed considerably since it was established in ?!ovember 1979, causing the expenditure of additional time and resources to complete the project.
At first the charter was simply to collate or catalog all the recommendations made by the various groups investigating the accident.
It later grew to include an evaluation of each recommendation as to its relative impact on safety, its requirement for fiRC and licensee resources, and its immediacy. Despite the difficulties arising from this situation, the committee did a very good job in bringing the ve rieus-s4xd ies-together-intoe-eean i ngit 1-and-ma nageabl e -pa cta ge.
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,y A clear, fim charter would h::ve allowed a more straightfontard development and presentation of the action plan.
For exampls, the cr.osscuts, which would assure that the major recommendations have been adequately covered, were done as an afterthought--after the plan was in its third revision--rather than as the action plan took fonn.
The plan started out as a shopping list with everyone putting in his favorite project.
?!any were deleted based on input from the.
various office directors or on the committee's own initiative.
. because they were not TMI related or the pros and cons of the proposed project had been argued before. Those decisions are not always set forth clearly in the action plan although many are on the record of Commission meetings and meetings of the Advisory Committee on Reactor Safeguards.
The action plan is brief, by design. To obtain the additional data necessary to detennine the full intent of each action item and the recommendations that each is implementing, the reader and action official must use the references, crosscuts, and comparisons of action items to recommendations providad in the action plan. They are an integral part of the plan. The introduction to the action plan attempted to convey this message, but in our opinion, failed.
The first printing of the final ' report states that "The references...had to be considered in the process of developing the requirements, studies and other actions in the plan." This indicates that the references have already been considered and the reader need not go further than the action plan. The. appropriate wording should have been that the references "must be considered," thus showing the reader that.he must go back to the referenced documents.
It must be clearly, understood that the reference material is a critical and integral part of the plan. Dr. !!attson told us this was an editorial
- liowever, error which was corrected in Revision 1 of the action plan.
because an errata sheet with this correction was not issued for the first printing of the action plan, there are many copies of the action plan in circulation in which the corr'ection has not been made.
There is feedback from industry that some remedial actions as set
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forth in the action plan are too prescriptive and thut industry may have other " fixes" that are just as reasonable.
An example heard most often concerned inerting containment.
Generally speaking, both itRC and industry agree that there is a problem, but industry believes flRC should set general requirements and let industry decide how to meet those requirements. He believe that all proposed alternatives should be considered by the responsibic office, and if l
it deems that an alternative is better than that set forth in the action plan, it should bring that alternative to the attention of the Commission.
The action plan should not be so inflexible as to i
deny I;RC the ability to adapt as new infomation becomes available.
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,x, The action plan is only the first step toward satisfying! he t
reconmendations of the major TMI studies.
The implementation of the action items contained in the plan is the key to NRC's response to the accident.
And, by implementation we mean more than making open-ended studies; we mean the action taken based on the results of those studies.
Because the implementation will not be easy to manage or monitor, and because of the significance of the issues involved, we will review that implementation during the second phase of our audit.
...s EDO Comments A copy of the ED0's comments on a draft of this report is attached. The EDO. generally agreed with the contents of this report.
His specific comments relating to THI study recommendations which we believed were are included in the report not adequately addressed in the Action Plan sections dealing with those recommendations. We have no objections to the ED0's comments but believe the Commission should closely monitor NRR's proposals for meeting the Commission's directive relating to reactor operator requalification examinations.
We are continuing our review of actions being taken by NRR as a result of the accident at Three Mile Island.
At the present time we are reviewing NRR's implementation of items included in the action plan relatedsto utility personnel licensing and training including an evaluation of the management structure within NRR to monitor and assure timely completion of the recommended corrective actions.
Attachment:
As Stated W. Dircks, EDO cc:
H. Denton, NRR T. Rehm l
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