ML20006F391

Summary of ACRS 890829-30 Meeting W/Nrc in Region I Ofc to Review Activities Under Purview of Region I,Including Restart Panel,Enforcement Policy,Plant Maint Programs & Regional Insp Activities.Viewgraphs Encl

ML20006F391
Person / Time
Issue date:	02/21/1990
From:	Advisory Committee on Reactor Safeguards
To:	Advisory Committee on Reactor Safeguards
References
ACRS-2660, NUDOCS 9002270463
Download: ML20006F391 (41)

Text

{{#Wiki_filter:[~,,f} ' -jfff sa j' &/? Afdllfb 2 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS e REGIONAL PROGRAMS SUBCOMMITTEE MEETING REGION I 0FFICE KING OF PRUSSIA ~, PA -g )%, 3 pg p 1 H pg ' AUGUST 29-30, 1989 h I J WjJ sa: m -PURPOSE: .The purpose of.this meetino was to review the activities under the purview of the NRC Region-.I Office. ATTENDEES: Principal meeting attendees included: ACRS NRC Staff F. Remick, Chairman L'. Russell J. Joyner. J. Carroll, Member T. Martin J. Roth I. Catton, Member W.-Kane J. White W. Kerr, Member S. Collins P. Swetland D. Werd, Member G. Kelly J. Wiggins C. Wylie, Member L. Bettenhausen D. Haverkamp D. Holody R. Conte R. Gallo R. Blough N. Blumberg L. Tripp J. Strosnider P.'Eselgroth P. Eapen C. Cowgill J. Durr~ R. Bores M. Knapp W. Lazarus NEETING HIGHLIGHTS,' AGREEMENTS, AND REQUESTS -1. Dr. Remick noted this was the fifth visit'of the Subcommittee to an NRC regional office. He said the Subcommittee had found the previous - meetings to be very interesting, particularly as a source ~ of information directly related to nuclear operations topics not readily available to .the ACRS at NRC Headequarters. { 2. Mr. W. Russell (Region 1 Office Administrator) introduced his staff and discussed the details of the operations of the Region I Office. Figure 1 shows an overview of the office's organization. Russell noted that the Region I examiners are cross-qualified as inspectors; this is done in part to. vary the workload and challenge for the individual. goi DESICNATED ORIGINAIj 9002270463 900221 hl Cortified By [-- PDR ACRS h s

2660 PDC j

[(; {, ,y - L; NINUTESl-REGIONAL PROGRAHS AUGUST 29-30, 1989 t Figure 2 shews the Region I workscope. There are 27 commercial power + reactor units with full power licenses,15 test and research reactors in operation, and over 3,000 byproduct materials licensees under the region.'s perview. .In response to Mr. Carroll as to why there are so few Agreement States in the region, Mr. Russell said the problem is one of lack of resources and/or reluctence of the states to take on the job. Uriique' activities of Region I include acting as homebase for the mobile NDE facility, operatino the TLD program for the agency's off-site radiation monitoring effort at c11 power plant sites in the country, and use of on-site laboratory facilities for conducting environmental monitoring programs. Majdr office issues noted were the concern over lack of personnel re-l . sources and the associated problems of manpower replacement. The turnover rate.so far this fiscal year is running approximately 15%. l Given that a new inspector requires approximately 18 months to become fully qualified, a significant problem is apparent. L Mr. Russell also discussed the formation of a " restart panel" format to -address the restart of problem plants (ex: Pilgrim, Peach Bottom).- l They have been effective, but are resource intensive. In response to Mr. Carroll, Mr. Russell said Region I piloted the restart panel approach. It was noted by Mr. Russell that problems with materials licensees have been fairly resource intensive. l Maintaining consistency among regions is done by counterpart meetings among the regions' managers. Also, NRC Headqua.rters monitors the re-gions' performance in this regard. Headquarters also coordinates a

j', . 4' ,G A G. MINUTES - REGIONAL PROGRAM 5 AUGUST 29-30, 1989 escalated enforcement actions. In response to Dr. Remick, Mr. Russell said each region does have its own " personality" as directed by the offices' senior management; however from a programmatic standpoint the regions have developed a good measure of consistency. Russell said that Mr. Murley has ordered a survey of regulatory effectiveness, given recent complaints from the industry. The result will be a' report similar to that issued by Mr. O'Reilly (then Director of Region II) in 1982. In response to Dr. Remick, Mr. Russell said some benefit may ccme from consolidation of license examiners resources at headquarters. Mr. Carroli noted that information provided the Subcommittee at'a past regional meeting' indicated that Region I had a low instance of violations issued per site. Mr. Russell indicated that he believes the emphasis.in enforcement should be on the corrective actions ene is-trying to obtain not to have a " bean count"~of the number of violations issued. 3. Mr. L. Bettenhausen detailed the program conducted by Region I to qualify the NRC regional inspecters. There are a number of inspector l " tracks" aveilable such as reactor operations, safeguards, radiological andl reactor engineering disciplines. Inspector candidates are typically experienced personnel with navy nuclear or industry backgrounds and are L degreed (b.S.,M.S.,etc.). In response to Mr. Ward, NRC indicated that approximately 20% of inspectors have industrial backgrounds. Most are J governnient ' hi res. In response to Subcommittee questions, it was noted that there is no program for formal retraining or updating of regulations for the inspectors.

T 1 ,y ~ .e MINUTES - REGIONAL PROGRAMS AUGUST 29-30, 1989 'Mr. Russell noted that there is an ongoing erosion of inspector experience levels because of the federal salary cap. NRC is becoming increasingly less competitive with industry salaries. If this continues, the agency will have to move to an intern program with a correspondingly longer training time. In response to Mr. Ward, Mr. Bettenhausen indicated that NRC does look for certain personnel traits in'its inspector candidates. Mr. Carroll asked if the region has considered use of industrial psychologists for selection of resident inspectors. The Region indicated that the current selection process has served th 1 well. Mr. Martin indicated that the regional inspectors are closely monitored and, in sonie cases, have been recalled from sites sooner than usual (5 years). 4 T. Martin addressed the enforcement program. He.noted the purpose and philosophy behind the program. Martin indicated that the region strives to focus on important issues and not get bogged down with minor infractions. The Region looks upon enforcement actions (Notice of Violation, Order, Civil Penalty, etc.) as tools to enhance safety; there are no quotas for inspectors to meet. Dr. Remick asked if the agency is under duress to recover more of their budget through enforcement, -pursuant to Congressional direction.- Mr. Martin said the NRC does not do this, rather the Congressional mandate applies to the fee system assessed to licensee review requests. The enforcement procedure was detailed (Fig. 3). In response to Dr. Kerr, Mr. Martin said the financial consequences of an enforcement action (s) can be significant via a lowered Systematic Assessment of LicenseePerformance(SALP)ratingandsubsequentrestrictionsvis-vis -the financial markets. Oversight of the enforcement process is conducted by audits (NRC) and the regional management information system (MIS.). The MIS is unique to the Region I Office.

3 .. :i o + ,3 MihUTES - REGIONAL PROGRAMS' AUGUST 29-30, 1989 L*: D. Holody discussed the past history and current problems with enforce-ment. Figure 4 shows the number of escalated enforcement actions ~for Region I.. For FY fa9, the number of violations issued is up from FY 88's level. The same trend is evident for all the regions (Fig. 5). Mr.. Carroll raised the issue of a recent enforcement action at Limerick where plant personnel failec' to properly classify emergency events. Discussion noted that the NRC has been routinely inspecting plants to assure the personnel have the' capability to do so, as their classification actions are key to sttting the EP process in motion. Mr. Holody detailed the latest revisions to the enforcement policy. These changes provide greater incentives, both positive and negative, for the licensee to identify violations and. comprehensively correct -them; also it allom the NRC staff additional authority to exercise discretion in enforcement natters. To date, no problems have been seen' in implementing this policy. A significant increase.in escalated enforcement actions has been seen - particularly for materials licensees. Two suggested changes to enforcement policy'were made: 1. Obtain authority to issue civil penalties and orders against vendors who cause violations at licensed facilities (agency is evaluating this proposal). 2. 0btain authority to issue enforcement action directly against -nonlicensed individuals engaged in wrongdoing which affects licensed activities (Commission has approved this policy and the Headquarters staff is preparing the appropriate rule changes).

p; y [ f; 5 i MINUTES - REGIONAL PROGRAMS AUGUST 29-30,_1989 c. t Item 2 has been a'dopted by the Conraission (ex: Peach Bottom operators, c, materials licensees employees, etc.). 5. R. Cello introduced the topic of plant maintenance programs by discussing.the issue of the proposed maintenance Policy Statement. The Region believes the Policy Statement should address: (1) reliability centeredmaintenance,(2)preventiveandpredictiveprograms,(3) engineering support, (4) root cause analysis, (5) trending, and (6) application of rist significer.t concepts. Other needs that the Region sees in this area include: (1)contractertraining,and(2) dedication of commercial grade parts. In response to Dr. Remick, Mr. Gallo said the' Region believer c maintenance rule is needed in order to provide letdership in the maintenance area. Dr. Kerr questioned how the NRC will identify what will be an acceptable objective of the maintenance rule. He is wary of a strict focus on " maintenance for maintenance's sake" as a key factor of plant performance. .In response to Mr. Carroll, Mr. Gallo said the NRC does not use the INP0 performanceindicators(PIs). Evaluation of eight of the licensees' maintenance programs to date showed five were functioning well overall. One was considered inadeouate. In response to Mr. Carroll, Mr. Gallo said he believes the plant's maintenance programs-are improving, and INp0 is responsible ir, part; NRC inspection is also a big impedus.for improvement. Gallo' detailed the types of program deficiencies seen at plants (Figure 6)_ as a result of the NRC inspections. After some discussion, Messrs. -Ward and Kerr observed that NRC's actions in the maintenance area seem ' to be forcing a particular style of maintenance on utilities. Mr. Ward indicated that it's not clear that such action (forcing a uniform approach) is the preferred way to assure good maintenance will be achieved.

fl 'i h. 6L 'MlliUTES'- REGIONAL PROGRAMS AUGUST 29-30, 1989 i r Turning to the topic of licensee efforts to enhance siill levels / career progression of maintenance personnel, Mr. Gallo indicated such oppor-tunities do exist (Fig. 7). In response to Mr. Ward, the Region in-l dicated some licensees in Region I have maintenance training fceflities comparable to similar facilities seen at plants in Japan for example. Cormenting on the development of maintenance performance indicators, Mr. Blumbero said the Region-has not been involved in their development. Other cocracnts on the maintenance Pl development effort were: hht use of NPRDS to rate licensee performance may effect the relicbility of this oata base (as licensees won't be so forthcoming in the future). PIs should be used to spot adverse trends, not to rank plants. A single indicator may not be sufficient to rank plants. A combination of indicators should be considered: -(a) maintenance-related LERS-(b) " equipment out of service" (c) " unplanned trips due to maintenance," including testing 6. The Subcommittee toured the raobile NDE laboratory and associated labora-tory test. facilities located in the Regional. offices. y 7. The topic of quality assurance programs was addressed by Mr. P. K. i ;T Eapen. Key points noted by Mr. Eapen were: NRC has had a strong emphasis on QA. The effort was directed to -looking at " work" not " paper." This effort.resulted in the

4 49 F MINUTES - REGI0l!AL PROGRAMS .8-AUGUST 29-30, 1989 upgrading of the technical competence of licensees' QA organizations. The Region is assessing 0A based on "real life" situations. Appen-dix L violations are now based on hardware-or performance concerns. Problems noted were that no one section of the Region's organization is respcnsible for QA and_the Region's expertise in QA is " fading away" as people leave / retire. NRC needs to assure that " quality" is an integral part of the licensees line organization. In response to Mr. Carroll, Mr. Espen said that the emphasis on performance based QA is more or less consistent across the five regional offices. Mr. Ward nuted that his reaoing of the QA situation, based on the recent ACRS-sponsored meeting on this topic, lead him to conclude that foreign entities rely on the professional integrity,of the working organization to assure QA. The Region indicated that they rely on their' evaluation of the licer.see's management to assure they have instilled quality l the line organizations, j 8. Mr. Ourr addressed the topic of technical specification improvement j programs. He seid this issue has resulted in an effort to reconstitute j 1 the plants' design basis, given the need to establish the engineering basis (es) for plant-life extension. In most cases, the licensees _are initisting the design basis reconstitution / consolidation effort. j -i i

9. -The activities of the Division of Radiation Safety and Safeguards were l

reviewed by Dr. M. Knapp. Dr. Knapp discussed the organization, facil-j I ities, and workload it. the Region. The status of the fuel cycle facilities was reviewed. Figure 8 lists these facilities. Past problems with some of these facilities were noted, including an ongoing concern with the CE facility in Windsor, CT.

i l i^ MINUTES - REGIONAL PROGRAMS AUGUST 29-30, 1989 L It was noted that a SALP was performed on the Windsor site's operations. This SALP was conducted at the initiative of the Region I Office. In response to Dr. Kerr, Mr. Russell indicated that the "visability" of l a SALP seems to have improved the si'.lation in the Windsor case, despite E the fact that a score of "3" doesn't mean that regulations are being broken. Further discursion brought up the fact that for the CE facility, the hRC audits lead to the conclusion that the margin of safety for operations was uncomfortably low and improvement was judged to be necessary. l L. Bettenhausen discusseo the details of the materials licersees located in Region I. There are approximately 3030 materialt licensees; 1200 of these are medical related. Regarding enforcement actions, it was noted the radiography activities have the greatest actual and potential radiatior, exposure risk; continuing attention is necessary. Discussion of the current problem material facility (" Safety Light l Corporation") was given. As a result of corporate maneuvers, the company was, in effect, orphened. The ability to finance necessary decontamination requirements was left in doubt. NRC has issued Orders l: to assure necessary funding will be evailable. Also, a site cleanup plan is under review by the Region. R 10. W. Kane introduced the activities in the " Reactor Projects" division of Region I dealing with Msessment of licensee performance. l G. Kelly reviewed the workload and scope of the Region's inspection activities. Figure 9 shows the breakdown of expenditures for these activities. About 20% of the effort has been devoted to region initia-tives and reactive inspections. A breakdown of inspection time by site is given on Figure 10. About half the effort is devoted to a small set (8 sites) of plants that have, for the most part, had problems.

~,. w V t MINUTES - REGIONAL PkvGP.AMS AUGUST 29-30, 1989 i Discussion ens 9ed regarding the inspection effort vis-a-vis SALP scores. I The debate focussed on whether resources were properly allocated for l " good" vs.

• bad" performers.

The revised inspection performance goals were noted. These goals are: (1) provi<% flexibility to allocate resources based upon performance, (P) increase emphasis on the use of teams, (3) respond to new (or gercric)safetyissues,and(4)focusresourcesonspecificdisciplinary p areas of emphasis. In response to Dr. Catton, the Region indicated that nc inspections are perforrned to check compliance with Generic Letter requirerunts until e "Tl" (temporary instruction) is issued by NRR to the regional offices. Planning for regional inspections is now keyed to a given plant's SALP cycle. The senior resident inspector (RI) is designated as the cogni-zant regier nfficial vis-a-vis all elements of the inspection plan for his plant. P. Swetland discussed the impact of HRC team inspections on licensee performance. Mr. Ward asked why no event in the last 1-2 years has warranted an "IIT" vs. an "AIT." Mr. Russell noted that licensee ( performance has improved and that no event has been considered serious enough to warrant an IIT effort. Figures 11-12 list the team inspections initiated from Headquarters and the Region, respectively. Benefits of team inspections include the diversity of talent a team provides and the higher visability they incur with the licensee. Drawbacks reltte to the extensive resources required by both the NRC and licensee. Discussion of team inspection achievements noted that the Agency is increasingly relying on performance based inspections. Mr. Carroll noted that NRC has, on occasion, inspected beyond the regulations.

V; c: . *r r.g g MINUTES - REGIONAL PROGRAMS - II - AUGUST 29-30, 1989 The benefits /prcblems associated with use of Ris were noted by J. Johnson. On the plus side: Provide real-time cbservations; witness activities as they happen. Ensure emergency response; monitor conditions, provide direct contact with senior NRC officials. 1 Site-specific knowledge. On-site interface with: licer.see, local officials, public. 5 Inspection efficiency higher; less travel time than region based personnel. The cons include: Tencency to be called by or tasked by mt.ny to do work; ex: "Let's have the resident check this." Rotation policy; negative af fect on morale and family stress. high loss rate dilutes experience level and site continuity. t Greater sense of isolation on and off the job. Mr. McKay discussed the move towards performance-based inspections by NRC. Previously, inspections were compliance oriented. Today, inspec-tions are focused on performance or lack thereof. This includes obser-vation of licensee activities and event reconstruction. Examples of a performance-based approach include the use of SALPs, team inspections, resident inspectors, etc. l l

f.. s i V I' F.INUTES - REGIONAL PkOCRAMS AUGUST 29-30, 1989 Dr. Kerr indicated that he is uneasy with the current NRC approach in j

t. sing regulation by subjective judgment via the SALPs, etc., instead of revising the regulations to reflect the change from construction to eperation cf these pit.nts.

Mr. Russt.11 indicated that he believes the reg 91ations provide a work-able framework for regulation of operating planti. Further discussion noted that the Region has been told by some lirensees that the SALP reports are valuable to their conduct of operat%ns. 11. .Mr. Lar,e introduced the topic of the Systematic Aneswent of Licensee Performer 4e (SALP) pro;iram. SALPs are conducted every H+18 months for each site. Plents on the " watch list" receive e sat'P every 12 months. SALFs are useo by NRC to aid resource allocetions. fraprove licensee perfornboce, and diegnose performance trerds. The SALP process was noted. Typically, preparattort of the initial SALP report is overseen by the site's senior RI. A SSLP bee.rd is convened and is cheired by the Director of the Division of Reactor Projects of the cognizant regional office. In response to Dr. Retrick, the Region said that NRR ensures that the SALP process is consistent from region-to-region. Figures 13-14 show the steps of the SALP process and the i SALP board composition, respectively. In response to Mr. Carroll, Mr. Kane noted that SALP board members are rotated among the regions in order to help assure consistency and cross-fertilization of experience. Figure 15 shows the functional areas rated for a typical SALP on an operating plent. Figure 16 lists the evaluation criteria used by NRC for the SALP deliberations. Dr. Remick asked if the licensee is contacted, in camera, to get their observations regarding the performance of the RIs. Mr. Kane indicated that he does receive calls from licensees with questions / concerns along

i L o l' MINUTES - REGIONAL PROGRAMS AUGUST 29-30, 1989 a this line. Mr. Russell also noted that he has been contacted by licens-e ees with concerns related to an RI's performance. The definitions applied to the Category ratings (1-3) were noted (Figure l 17). t G. Lelly reviewea the results of the SALPs conducted in Region I. Typically it costs a senior NRC region manager approximately 25% of his time for the SALP process. Figure 18 shows the distribution of the SALP ratings by category for the Region I plants as of August 1989. In response to Mr. Carroll, Mr. Russell said that he does not know how NRC's SALP ratings compare with INP0's ratings. r fir. Kelly saio that a trend in performance usually initiates action sooner than other indicators (e.g., a declining trend will spur in-creased inspection attention). The Region has encouraged licensee self assessment initiatives and their cocrdination of these activities with the SALP effort. NRC hopes to use the self assessment effort to credit a given licensees positive actions vis-a-vis the SALPs. In response to questions from the subcommittee, the Region noted the following: The impact of SALP on licensee performance has been positive. It helps focus NRC's attention on plant operations. SALP has helped spur improved plant performance. Y To the extent of their limited knowledge, the Region has been told by licensees that safety will not be impeded by PUC actions. However, there has been concern that some long-term actions may be impacted. Some utilities have had to cut back nonnuclear expenses 1 under the threat of prudency hearings.

z c pe; L 4 e klNUTES - P,EG10NAL PROCRAMS AUGUST 29-30, 1989 The Region has had to contend with active state involvement in nuclear affairs. Almost all the states containing nuclear plants { are so involved. Mr. Ward asled if the Region has considered a " return" to tradition-al regulations for operating plants. Mr. Russell said the SALP process is functioning as a regulatory mechanism. He also said even if " General Drerating Criteria" existed, one would still require some form of a SALP-like process in order to judge compliance with such criteria.

12. The effectiveness of plant safety review activities was discussed.

It was noted thet the NRC's experience is that utilities with effective self assessnient and corrective action programs achieve better i performance. During discussion, Mr. Carroll said some plant safety review committees cct as " rubber stamps" as a result of being required by technical specifications. He indicated that there are more effective means of providing independent safety oversight. 13. W. Kane discussed the topic of problem plants or plants on the " watch list." To begin, the steps involved in the restart process were dis-cussed (Fiourt 19). It was noted in response to questions that a plant restart can be approveo either by the NRC staff or by Comission vote depending on the Category it is assigned. There was discussion of whether it is safer to operate at full power (per design) rather than at lower power for a long time. Dr. Kerr g maintained that there has not been an analysis of the trade-offs in-b volved for operation at low power, and he would be interested in seeing such an analysis. Mr. Russell maintained that he believes low power operation provides additional margin for such parameters as decay heat load, offsite dose consequences, etc. Mr. Russell did note that he allowed Peach Bottom to operate up to 35% for its initial power plateau, based on problems seen at Pilgrim which was limited to 25% power.

w L. i.' l'IliUTES - REGIONAL pROCRIES AUGUST 29-30, 1989 l I The probleras seen at 1;ine Mile Point Unit 1 were described. In 1988, e NRC issued two Cats requiring a number of corrective actions be per-formed prior to restart. An NRC Restart Assessment Panel was formed in 1-1988. The licensee had submitted a Restart Action Plan which is now unce' review by NRC. In response to !!r. Carroll, Mr. Russell indicated that the decision to shut down plant operations is, in the end, a matter of considered judgment by flRC senior management, i The status of the Pilgrim resttrt effort was noted. Currently, the plant is at the 75; power plateau of its restart power ascension pro-gram. Region I also noted the current status of the Peach Bottom resti.rt effort. Unit 2 is now at 100% power; Unit 3 has yet to restart. There was discussion regaroing involvement of the affected states in the restart process. Mr. Russell indicated that the region's experience to date has been favorable and the state's actions have not been obstructive. L. Tripp detaileo the situation with the Calvert Cliffs plant. It was noted that the plent had a 18-n.cnth history of declining performance in several areas, prior to the May 1989 shutdown of both units. In response to questions, Mr. Russell noted that a complacent attitude, coupled with a cut in resources, combined to result in their getting into trouble. Dr. Kerr asked fron, where the recommendation for shutdown of Calvert Cliffs ensued. Mr. Russell indicated that as a result of problems the licensee identified, they initiated the shutdown in early May, as well as stated their intent not to restart until they had addressed relevant problems to their satisfaction. Messrs. Ward and Remick asked whether the lesson learned" of Calvert Cliffs as seen by the Region (i.e., reliance on talented people to get around procedural inadequacies) applies to the instance of " regulation

I; ~ s' MINUTES - REGIONAL PROGRAMS AUGUST 29-30, 1989 ? by SALP" that is now ongoing at NRC. Mr. Russell agreed there is a good point here and indicated that his problem of declining resources adds weight to the issue Mr. Carroll posed a hypothetical case where the licensee of a SALP " Category 1" plant decides to go to a " Category 2" level due to the pressure of economics. He asked: is this acceptable? The Region indicated that this would put then in an uncomfortable situation, and may be difficult for the licersee to pull off (i.e., starting down a " slippery slope"). 14. R. Gallo discussed plant operator licensing. He detailed the Region's resources for operator examinations. There are 16 certified examiners; six of these have held commercial reactor operator licenses. To date, in F' 1989, 159 requalification exams and 219 initial exams have been conducted by the Regiun. In response to Dr. Kerr, Mr. Gallo said approximately 17% of requalification applicants fail the exam. The impacts of revision to 10 CFR Part 55 were noted. These include: Operator licenses extended to six-year terms from two year licenses. Sito-specific simulator mandated: is considered an invaluable training / examination tool. Forced licensee middle and upper level management attention and involvement to licensed operator requalification training program. Substantial NRC resources are being dedicated to requalification exams in order to support six-year license renewals. l L Dr. Remick asked if the Region has considered moving to an audit func-tion for operator licensing examinations. Mr. Gallo indicated that once l l l

's 4 a .t L ~ lilhUTES - REGIO!;AL PROGR415 AUGUST 29-30, 1989 a " steady-state" workload is achieved, there won't be any significant problems. He was relutterit to see NRC surrender its current role here. As a result of further discussion, Mr. Russell indicated that he is on record as advocating the utilities conduct the exairs, provided the failure rates cene down to reasonable levels. Dr. Remick indicated that his understanding is that industry considers the new performance-based rec,ualification exam tc be a fair and valid test. The high failure rates beir9 seen are believed to be caused by older operators whose original operator licenses were grandfathered under part 55 and who are r.cw being forced to upgrade their still levels. Dr. Catton suggesteo that the Region investigate whether there is/are ptoblems with the operator training programs a la: lack of INPO accreditation, etc. Dr. Catton questioned how a training program can successfully train an operator for en initial exam but do poorly preparing an operator for a requalific6 tion exam. Mr. Russell inoicated that differences in sched-uling, training elements, etc., impact requalification efforts. Further discussion resulted in noting that the requalification failure rate may well drop in the future, as utilities complete the switchover to fully l performance-based training. Discussion of the plant simulator capabilities brought out the fact that 1 the simulator must be certified by comparison to actual test data from the plant in question. The national theory examination (generic fundamentals) was discussed. i The test is standcrdized based on common knowledge related to the theory I of nuclear power operations. Itisspecifictoplanttype(BWR&PWR) and is given three times a year. Grading is by pass / fail grade (numerical-greaterthan70%). A pilot program was conducted and considered highly successful. i

m t. j [' 4 h' MINUTES - REGIONAL PROGRAMS AUGUST 29-30, 1989 Mr. Esclgroth discussed the steps taken to assure operator emminations are consistent among the regions. Consistency is maintained by use of examinerstandards(NUREG-1021), audits,andinter-regionexaminer training. Regarding the need for degreed operators, the Region indicated that they believe there should be at least one degreed operator on each shift crew. Mr. Russell indicated that he supports the Consnission's Policy 5tAtement on tN. matter and noted that the industry is moving towards having more and more degreed operators. In respense to Dr. Lerr, Mr. Russell indicated that he feels the perfor-mance based operator examination is the right approach. Regarding ensuring operators have the correct attributes (good attitude, etc.), Mr. Russell seid this has to be determined by other (indirect) means. 15. The topic of radiological controls was discussed. Details of the HP inspection areas and ALARA program elements reviewed by the region were noted. Regarding ALARA, Mr. Ward indicated some utilities have stated that they are spending money far in excess of $1000/ man-rem to reduce 4 personnel exposure. The Region indicated that such a decision is the licensees, ano the SALP scores are not based on such expenditures. L l Details of the Region I radiological inspection programs and associated laboratory facilities were provided. Among the unique activities of the Region is providing and monitoring all the TLDs NRC places around the 72 l U.S. reactor sites. The Region is responsible for continuous monitoring of these TLDs. Counting facilities are located in the Region I offices. Another service provided is to assist some of the state environmental monitoring programs. 16. W. Lazarus discussed the Region's emergency planning (EP) programs. The details of the procedures involved in the exercising the licensees' i i

n. i o 6 MINUTES - REGIONAL PROGRAMS AUGUST 29-30, 1989 l emergency plan were noted. Figure 20 shows the key areas evaluated. i Strengths and weaknesses of the EP programs were noted. Key problems cited included: i Nor. uniform emergency classification systems. i Lack of ciren verification systems -- few licensees have currently installed one. hethod(s) for public alerting need upgrading, Lack of cooperation of offsite authorities, i I Lack of reclism of EP exercises results in some negative training. The burden of EP exercises on local governments was discussed. In general, the largest impact falls on the local volunteers. Some volun-teers have dropped out of the program, persuant to FEMA's post-exercise critique (s),whichwastakenascriticismoftheirefforts'. i The case of an inadvertent siren actuation near TMI was noted. In response to Mr. Vylie, it w6s stated that such events are not rare, and it was agreed th6t more explicit public directions are needed for this-type of incident. Details of the Region's incident response program were discussed. In response to Dr. Remick, it was noted that FEMA does interact with NRC g only during an actual event. It was also noted that the authority to (. issue an evacuation order currently rests with the Chairman of the NRC, l

17. The Subcommittee thanked Mr. Russell and his staff for two days of l-excellent presentations.

Dr. Remick said he appreciated the candor of 1

r c J N MINUTES - REGIONAL PROGRAMS AUGUST 29-30, 1989 the presenters in response to the Subcommittee's inquiries. Mr. Russell returned the Chairman's compliments and said he believed the meeting was quite productive for c11 concerned.

10. The meeting was adjourned at 3:40 p.m. on August 30, 1989.

j _S_UMF/.RY OF AGREEMENTS, ASSIGNMENTS, REQUESTS, AND FUTbRE ACTIVITIES The Subcommittee discussed a variety of topics with the Region I repre-sentatives. These topics, with a few exceptions, were similar/ identical to issues discussed with the other four NRC region offices. There appears to be a growing problem with attracting and maintaining skilled personnel due to the federal salary limits. This issue is being felt most acutely at the region offices because of their "first line" basis vis-a-vis competition for job skills with the industry. Mr. Russell indicated that his office's overall skill level is dropping sharply due to a high turnover rate and delays associated with government hiring procedures. There was extensive discussion of the impact of the SALP program on plant licensees. The Subcommittee indicated thac the use of SALP as a form of defacto regulation may not be in the best interests of nuclear safety. Rather, it was suggested that NRC should consider whether the current regulations are in need of substantial revision, given the NRC's shift in its rission to regulation of operating plants. In the aggregate, the Subcommittee has found these meetings useful and informative. In particular, it was noted that the regions possess a unique store of direct information regarding the state of plant opera-tions that is not readily available to the ACRS at the Headquarters level. The Subconmittee has also been favorably impressed with the competence and dedication evidenced by the region offices' personnel. 1

MINUTES - REGIONAL-PROGRAMS AUGUST 29-30, 1989 The Subconsittee has completed a " tour" of all five region offices. Dr. Remick has indicated that the ACRS should continue its contacts with the regions through future meetings of this Subconnittce. Committee Members are encouraged to contribute discussion topics / issues for future meet-

ings, NOTE:

Additional nieeting deteils can be obtained from a transcript of this meeting 6veilable in the NRC Public Document Room. 2120 L Street, N.W., Washington, D.C. 20006, (202) 634-3273, or can be purchased from Heritage Reporting Corporation, 1220 L Street N.W., Suite 600 Washington, D.C. 20005 (202) 628-4888.

y Office of investigation i RegionaI (Field Office) I l ~ Ad ministrator l ~ l I i Public state and Regional Government i Enforcement Affairs i Affairs Counsel I i I I I I DMelon of Resource Monocement Division of N N Division of ond Reactor Projects Reactor Safety I j g J 3 Administrative Resident Emergency Reactor Support inspectors Planning inspection Incident Resp. Specialists Budget and Reactor Rod. Protect. Engineering Procurement inspect, ion Rx/ Fuel Support Program Facilities Safeguards Operator Personnel Salp UC'"M"9 g' o ote l. ~ u.e, } Ucensing & Amendments inspection ] s N W 9-Y v +--a ww-

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'O l L REGION I UCENSEES l L 1 a7d UNITS UCENSED TO OPERATE AT FULL POWER 22 SITES: 7 DUAL UNITS; 14 SINGLE UNITS INCLUDING ONE 3 UNIT SITE (WILLSTONE UNITS 1,2 & 3} 1 POWER ASCENSION PROGRAW (UWERICK UNIT 2) l 2 SEABROOK & SHOREHAW I - l 17 UCENSED TEST & RESEARCH REACTORS INCLUDING COLUWBIA AND SAXTON 5 FUEL FACIUTIES 3,030 BYPRODUCT WATERIALS-UCENSEES ) EXCLUDING AGREEWENT STATES: WARYLAND, NEW HAMPSHIRE, NEW YORK'AND RH0DE ISLAND .I

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a s j PAST EXPERIENCES / CURRENT PROBLEMS ) 1 ESCALATED ENFORCEMENT (CIVIL PENALTIES /0RDERS) FOR POWER REACTORS IN REGION I HAS INCREASED OVER THE PAST YEAR, BUT IS CLOSE TO PREVIOUS YEARS IF EQUIPMENT QUALIFICATION CIVIL PENALTIES ARE NOT INCLUDED AVERAGE NO. FY 89 NO. FY 84 - FY 88 TO DATE (REGION I) (REGION I) POWER REACTORS CIVIL PENALTIES 8 13

• i ORDERS 2

0 l ) MATERIALS / FUEL FACILITIES /RESEARCH RXs CIVIL PENALTIES II 16 ORDERS 4 5 INCLUDES 4 EQUIPMENT QUALIFICATION CIVIL PENALTIES h-lMd

~ J l,, ; i I t PAST EXPERIENCES / CURRENT PROBLEMS 1

• ESCALATED ENFORCEMENT (CIVIL PENALTIES / ORDERS) FOR POWER REACTORS NATIONWIDE HAS INCREASED SLIGHTLY OVER THE PAST YEAR, BUT IS ACTUALLY LESS IF EQUIPMENT QUALIFICATION CIVIL PENALTIES ARE NOT INCLUDED

'l AVERAGE NO. FY 89 NO. FY 84 - FY 88 TO DATE i (ALL REGIONS) 'ALL REGIONS) i POWER REACTORS CIVIL PENALTIES 45 50

• ORDERS 4

1 MATERIALS / FUEL FACILITIES /RESEARCH RXs CIVIL PENALTIES 35 51 ORDERS 11 12 INCLUDES 10 EQUIPMENT QUALIFICATION CIVIL PENALTIES i

4.A.2 SLIDE 3 i TYPES OF DEFICIENCIES OBSERVED Dt91NG MTI'S ) i (1) INADEQUATE OR UNCLEAR MillTENANCE PROGRAM DESCRIPTIONS, (2) LACK OF VENDOR MNUAL C0f@DL, ND UPDATES, to SYSTEM, (3) DO NOT USE RISK ANALYSIS FOR PM OR WORK PRIORITIZATION, (4) EQUIPENT HISTORIES LACKING OR HARD TO USE, (5) NO TRENDING OR FAILURE ANALYSIS SYSTEMS, (6) MAINTENANCE PROCEDURES HARD TO FOLLOW OR ARE T00 GEERAL. (7) LITTLE OR N0 OC INVOLVEElff AT SOME PLANTS. I (8) SYSTEM ENGINEEPS t0T IfELVED IN MAINTENANCE, l l WJ)

~ ~~ r I 4,A,3 LICENSEE EFFORTS TO ENHANCE SKILL LEVELS / CAREER PROGRESSION OF SINTENANCE PERSONNEL BASED ON MINTEtiANCE TEAMS. l PLANT CAPACITY AND PLANT LIFE EXIDiSION EPPHASIS CREATE NEED FOR MDE AND BETTER TRAINED MINTDIANCE ERS0tfEL AND ENGlEERS i TPAINING PROGRAMS ARE P0RE FORML AND ACCREDITED j USE IPPf0/ED FACILITIES, M)CK-UPS AND SPARE EQUIPPENT FORHANDS-OtlTRAINING i ARE GEARED FOR TECHNICAL SKILL VPGRADE l INCLUDE mlNTDMNCE ASSIST EXPERIENCE FACILITY SPONSORED EDUCATION CREATES OPPORTlfilTIES FOR I ADVANCEENT l L l. MIRENANCE WORKER TO ENGIEERING TEONICIAN l TO STAFF ENGINEER NRC EXPECTS COLLEGE DEGREES FOR MNAGERS (ANS 3.1) 1 L

CURRErlT REGION I INSPECTIOf I E';'.PENDITURES B'( PROGPAM ELEMENT (65,127 HOURS AS OF 5 /20/89) ;j CORE

1. 69%

l / ~~ / l 10 i TEAMS #w/opa) l SAFETY ISSUES < 1% INITIATIVES AND REACT E ~ 1 N[ Less than one year of experience with core .{ %i Conservative in core completion 2 Half of the 20% discretionary really isn't 4 i J .. -~-,. ..~..

--~m_ .ly j... MAJOR REGION I FUEL CYCLE FACILITIES-STATUS UNITED NUCLEAR CORPORATION-NAVAL PRODUCTS OPERATIONAL UNITED NUCLEAR CORPORATION-RECOVERY SYSTEMS DECOMMISSIONING COMBUSTION ENGINEERING OPERATIONAL l. BABCOCK AND WILCOX-APOLLO DECOMMISSIONING BABCOCK AND WILCOX-PARKS TOWNSHIP REACTOR EQUIPMENT REFURBISHMENT CINTICHEM OPERATIONAL DOE-WEST VALLEY SUPERNATANT REMOVAL FROM TANK BD-1 1 9 [m ij

~ ~ REGION 1 FY 1989 ocr as neu se se TOTAL PROJECTED: 98,000 HRS BUDGET: 82,500 HRS 3.5 - 4.5 FTE / SITE UMERCK 1 VERMONT 33% < 3 FTE / SITE g m ~ DN 1 GNNA 16% N . FITZPATRC HOPE NECK BEAVER VAMEY gg ~ seeROOK lauSTONE 1 leuSTONE 2 RAMSTOS. 3 f 51% > 5 FTE'/ SIT.E- -. - PetiRBA. 9 FIE INDIAN POINT 3 1 l, n. 9 nE n v,,- S.,,, CAsVI9IT 08IFF3 - 7 FIF INnuel POINT 7 asm am une 1 1

i 5 REGIONAL TEAM INSPECTIONS AUGMENTED 4NSPECT10N TEAM (alt) REGIONAL RESPONSE 70 SELECTED NON-EMERGENCY EVENTS ' INDEPENDENT PERFORMANQE. ASSESSMENT TEAM (IPAT) '[' flet $ DENT EVALUATION OF THE UNDERLYING CAUSES FOR GE8Eth LICENSEE PERFORMANCE (600D OR BAD) i i

,.:c.,..,

OPERATIONAL SAFETY. TEAM INSPECTION (OSTI/0AT) COMPREHENSIVE REYlEW 0F OPERATIONS AND SUPPORT ' ACTIVITIES, INCLUDING SHIFT COVERAGE OPERAT)0NAL READINESS ASSESSMENT (ORA / RAT /lATI) EVALUATION OF LICEllSEE READillESS TO OPERATE A FACILITY (NEW CONSTRUCTICl4 OR FOLLOWING A LEl4GTHY SHUTDOWN) l' OUTAGE / START-UP INSPECTIONS TEAM COVERAGE OF REFUELING OUTAGE ACTIVITIES AND/OR FACILITY READINESS FOR START-UP FROM AN OUTAGE \\ \\

i 'l T HEADQUARTERS ' TEAM INSPECTIONS INCIDENT.. INVESTIGATION TEAM (IIT) AGENCV-NIDE RESPONSE TO A. $1GNIFICANT NON-EME.RGENCY EVENT y l. DIAGIOSTIC EVALUATION TEAM (DET) , TVAL'uATION CF UNDERLYING CAUSES FOR POOR ' Lietssqts.RPG INDEPE CE i MANDATORY TEAM INSPECTION (MTI) I COMPREHENSIVE INSRECTION OF AN AGENCY-SELECTED PROGRAM AREA AT ALL FACILITIES j. CURRENT MT! C0 VERS MAINTENANCE I SAFETY SYSTEM FUNCTIONAL INSPECTION (SSF1) "VERTICLE SLICE" APPROACH TO ALL PRCGRAM AREAS AS THEY APF.Y l TO ONE OR MORE SELECTED SYSTEMS SAFETY SYSTEM OUTAGE MODIFICATION INSPECTION (SSOMI) COMPREHENSIVE REVIEW OF SYSTEM MODIFICATIONS AND THEIR r IMPACT ON SYSTEM OPERABILITY e RE6ULATORY EFFECTIVENESS REVIEW (RER) g l EVALUATION OF SECURITY PROGRAM EFFECTIVENESS THROUGH PRACTICAL CHALLENGES TO PHYSICAL SECURITY SYS,TEMS fM. ) ' ' ' ' ~ ..-,,,-n. v

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SUMMARY

0F PROCESS P INPUTS TO SALP REPORT FROM SR!, DRS, DRSS AND M R,. , REPORT PREPARED BY SRI r j-INIT!AL REVIEW Bi S/d AND 8/C T.? Y REPORT REVIEWED BY SALP BOARD r .;,c BOARD REPORT ISSUED BY REGIONAL ADMINISTRATOR ~ i MANAGEMENT MEETING LETTER FROM LICENSEE FINAL REPORT ISSUED BY REGIONAL ADMINISTRATOR P g. g s e b Y

1 \\ 1

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.d...*.. ..6 4 e ) s l-1 le ] i l SALP BOARD COMPOSITION l-t CHAIRMAN DIRECTOR, DRP l t

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^ ' DIRECTOR, DRS. ; '... MEMBERS DIRECTOR, DRSS l DEPUTY DIRECTOR, 'DRP - l BRANCH CHlfF, DRP ' i SECTION CHIEF, DRP SENIOR RESIDENT INSPECTOR PROJECT MANAGER, NRR l SES-LEVEL MANAGER, NRR g g* G l k I Y

.+ r .. i,. = t..4...~- .g.,, n i....,... .o r t...: EUNCTIONAL AREAS - OPERATING REACTORS i - PLANT OPERATIONS f;.. !;'.)Y:$.. i ~ .E'@,fl..- - RADIOLOGICAL CONTROLS .s - MAINTENANCEfSURVEILLANCE. ... s...... ,. l': "~ ' - EMERGENCY PREPAREDNESS s .a. '~ - SECURITY / - ENGINEERING / TECHNICAL SUPPORT - SAFETY ASSESSMENT / QUALITY VERIFICATJON. - OTHERS AS NEEDED e. g D* I \\ Y L F4 /.C

1, s r t-r u EVALUATION CRITERIA ASSURANCE OF QUAllTY INCLUDING MANAGEMENT. INVOLVEMU. AND CONTROL APPROACH T0.' IDENTIFICATION AND RESOLUTION OF TECMIC FROM A SAFETY. STANDPOINT RESPONSIVENESS TO NRC INITIATIVES ENFORCEMENT HISTORY l OPERATIONAL AND CONSTRUCTION EVENTS (INCLUDING RESPONSE 70, REPORTING OF, AND CORRECTIVE ACTIONS FOR) STAFFING (INCLUDING MANAGEMENT)- EFFECTIVENESS OF TRAINING AND QUAllFICATION p 4 I J 4

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. J '~

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.y.- .,c j L t L PERFORM &bCER4 TIRES CATEGORY 1 - llCENSEE' MMA40Wrf ATflarties Ast, tuvet,M....a. mg 'l". READILY EVIDENT As PLACE temS$1s em sumaler.Ptarg,.gr-l, -(, .a .c. NUCLEAR SAFETY et RAFl40Af$$ ACTfTITitS, W115 TWE 'RSSIGLTINS V PERFORMAlltE SUD$TANTI AtLY IAl GEGULA79H .I St$.$. Licin$EE RE500R.CES ARE AMLE AIS EFFECTIVELY M 44.13Et.g',((/ q. 3 a. HIGH LEVEL OF PLANT AND PERSOISIEL MRFeeMNCE IS 34.lM -Atsflhtp. 2 7 REDUCED MC ATTENTION MAY BE APPROPRIATE. CATEGORY 2 - LICENSEE MANAGEMENT ATTENTION Te AND IWYetVEMIri IN 1 THE PERFORMANCE OF NUCLEAR SAFETY OR SAFE 6uARDS ACT!YlTIES ARE GOOD. THE LICENSEE HAS ATTAINED A LEVEL OF PERFeAM41CE ABWE. THAT NEEDED TO MEET REGULATORY REQUIREMENTS. LICEN$5E M SCURCES ARE ADE00 ATE AND REASONABLY ALLOCATED 40 THAT SOOD M ANT. AS.. PERSONNEL PERFORMANCE IS BEllIG ACHIEVED. SC ATTENT10R 90tRiLD BE MINTA!NED AT NORMAL LEVELS. CATE6ORY 3 - LICENSEE MANAGEMENT ATTENTION 10 AND IlWOLVEMNT IN THE PERFORAMNCE OF IIUCLEAR SAFiTY OR SAFEeuAkDS *4CTIhlTIES. ARE.100T k SUFFICIENT'. INE-LICENSEE'S PERFORMNCE DOES NOT SletlFICANTLY EXCEED THAT IIEEDED TO MEET MINIML RESULATidtY REENIINEMETS. LICENSEE RESOURCES APPEAR TO DE STRAINED Of ROT EFFECTIVELT,USED. MRC ATTENTION SHOULD BE INCREASED AD0YE NOIML LEVELS. T 1 hw 2

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} f. 82E l STEPS IN THE RESTART PROCESS ISSUE CAL TO DEFINE EXPECTED LICENSEE ACTIONS RESTART PANEL CONSTITUTED LICENSEE SUBMITS A-RESTART ACTION PLAN PANEL REVIEWS AND APPROVES THE RESTART ACTION PLAN p F PANEL REVIEWStTHE LICENSEE'S SELF-ASSESSMENT PROGRAM PANEL REVIEWS.THE LICENSEE'S POWER ASCENSION TESTING PROGRAM i LICENSEE SUBMITS A READINESS FOR RESTART REPORT NRC CONDUCTS AN INTEGRATED ASSESSMENT TEAM INSPECTION PANEL RECOMMENDS.T0 SENIOR MANAGEMENT THE LIFTING OF THE CAL CAL IS LIFTED NRC AUGMENTED' INSPECTION TO MONITOR RESTART OF THE FACILITY-AND .THE POWER ASCENSION TESTING ACTIVITIES T .s i = :..::

c yf -=- - ~ q 7 :.,,. '{;j *p ~ - * {Ij -

I i.

g,*' j KEY AREAS OF EVALUATION 1 o fi' l, CLASSIFICATION OF EVENTS NOTIFICATIONS TIMELY AND COMPLETE ACTIVATION OF EMERGENCY RESPONSE g { ORGANIZATION. i EFFORTS TO, MITIGATE THE ACCIDENT DOSE ASSESSMENT l-PROTECTIVE ACTION RECOMMENDATIONS BASED ON PLANT CONDITIONS AS WELL AS DOSE PROJECTIONS \\ i INTERFACE WITH OFF-SITE AGENCIES l l!.- . h. - '9 w'- w . _, _ _.,, _ _ __ _ ___ __}}