ML20024H148
| ML20024H148 | |
| Person / Time | |
|---|---|
| Issue date: | 05/10/1991 |
| From: | Carr K NRC COMMISSION (OCM) |
| To: | Weiner S NEW JERSEY, STATE OF |
| Shared Package | |
| ML19332J264 | List: |
| References | |
| NUDOCS 9105230053 | |
| Download: ML20024H148 (17) | |
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UNITED STATES s
," i NUCLEAR REGULATORY COMMISSION s
,4J'. j W ASHINGTON. D. C. 20555 w.(
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.,,(, J May 10. 1991 dasRM AN Scott A. Weir.er, Commissioner
- artment of Environmental Protection
- ate of New Jersey 102
-renton, flew Jersey 08625-0402 ser f1r. Weiner; m respcnding to your letter cf April 12, 1991, in which you forwarded a
.=y of fir. Ralph Nader's January 7,1991 letter concerning the Nuclear Pegulatory Commission's policy en disclosing Institute of Nuclear Power kerations (INP0) evaluation reports to the public.
The Commission appreciates "e opportunity your letter affords to explain our policy on this matter and to
ovide you background information to clarify the relationship between the NRC
'rd INP0.
% Commission continues to believe that our policy regarding disclosure of any 70 documents or information considered proprietary is appropriate. That Plicy is based on a Memorandum of Agreement (fl0A) between NRC and INPO, a acy of which is enclosed for your information.
The NRC has agreed in the M0A
+o control within the NRC any It!PO documents and information considered prcprietary that are provided to us by INP0 and to protect them from disclosure insofar as the law permits and subject to case-by-case review.
It is mportant to note, however, that while INP0 does provide certain types of informaticn directly to the NRC, it does not provide copies of its evalua-tion reports directly to the NRC. The NRC does not monitor the distribution of N 0 reports, nor can the NRC control the distribution of INP0 reports by u.rties other than the NRC.
Ey way of background, after the 1979 accident at the Three Mile Island plant, Se 55 utilities owning and operating nuclear power plants created INPO as a private organization whose stated purpose is to upgrade the quality of operations and safety performance at nuclear power plants. The utilities believed that an industry self-improvement effort, operating in parallel with the NRC regulatory program, could substantially' contribute to improved safety perfo mance of the nation's operating nuclear power plants.
The NRC supported this industry initiative as an important and positive step reflecting utility recognition of the NRC's regulatory philosophy, which is based on the principle that the ultimate responsibility for the safety performance of the plant must rest on the utility licensed to operate it.
N of INP0's methods of achieving improved performance is through the conduct d periodic team evaluations at all reactor facilities. After assessing the l
'r. formation gathered from these activities, the INP0 inspection team writes a l
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n th C0 7 W0 6sla hQy Q
AP* W k
' ntt A..'einer urt u the utility documenting the strengths and weaknesses that the team
~re utility is required to report back to INP0 on the steps that the
- ervec.
--'in t'ans to take to address the observed weaknesses.
INPO then reviews m e items curing subsequent evaluation visits.
- rivate organization, INP0 has taken the position that its evaluation
<2 arts are proprietary information and should not be made public.
INP0 member
'lities maintain that the proprietary status of the reports contributes to cancor of the process of self-criticism and self-assessment that is carried
' ' through ine INP0 program.
INP0 does not make its evaluation reports public "a is not required to submit them to the NRC on a routine basis.
The NRC aff, newever, is able to review these reports on site at each reactor rility or at INP0 headquarters in Atlanta. These reviews are normally orducted by one of the NRC's resident inspectors who are assigned full time at ecn licensed power reactor.
NRC reviews are conducted to ensure that INP0
.2 htion reports do not contain any significant adverse safety information it was not previously known by the NRC.
In addition, NRC regulations require tery Ltility to directly notify the NRC of significant matters, including
" se icentified through the INPO evaluation process.
Thus, while INP0 luation reports are private, we believe that the public safety is aided
.nrougn the industry INP0 self-assessment initiative.
- jou may be aware, INPO has taken a similar position with respect to other
' ttegories of documents in a Freedom of Information Act lawsuit captioned critical Mass Energy Project v. NRC et al., 830 F.2d 278 (D.C. Cir.1987).
Dielr. tiff in this action seeks the public disclosure of documents INP0 grerates through its Significant Event Evaluation and Information Network progran and provides voluntarily to the NRC.
This litigation has a fairly
,crg history and has twice been before the U.S. Court of Appeals for the District of Columbia-Circuit.
The latest decision of the Court of Appeals,
% nddd down on April 30, 1991, held that the agency's claim that disclosure of 9e relevant reports would be likely to result in a significant impairment of wency efficiency and effectiveness was not supported by the evidence.
Mr.secuently, the case was remanded to the District Court for further factual development.
' want to emphasize that although the NRC supports the industry's self-assessment program and attempts to coordinate NRC and INP0 evaluation activities to minimize unnecessary duplication of effort, we could not delegate, and _have not delegated, as Mr. Nader asserts, any of our statutory Nsponsibilities to INP0.
INP0 evaluations are not a substitute for the NRC's
'tspection program and do not in themselves constitute the basis for the NRC's sa f ety findings.
In addition to the NRC full-time resident inspectors assigned
.c each operating reactor site to monitor licensee performance on a daily u sis, periodic special inspections are conducted by NRC staff assigned to our we regional offices. These inspection efforts may range in scope from an Wpection of a special problem area, such as the perfot' nance of individual
"r. Scott A. Weiner uctor ccmponents or safety systems concucted by a single NRC inspector, to
- verall assessroents of a plant conducted by teams of inspectors. An example of
- hese broader efforts would be NRC's Diagnostic Evaluation Team (DET)
- spections.
Additionally, about once every 15 months, the NRC performs a
'creal assessn:ent of a licensee's performance called the Systematic Assessment Licensee Performance.
The results of this effort are discussed with the
<icensee in a public meeting.
~he licensing of the Seabrook Nuclear Station, cited specifically by fir. Nader in his letter. illustrates the NRC-INP0 relationship.
Both INP0 and the NRC "ad conducted inspections and evaluations of the Seabrook plant as it was being
- enstructed. Some of INP0's evaluation reports were reviewed by our en-site iMpectors at the time that the reports were issued and made available at the niant site. Others were reviewed just prior to licensing.
The Commission's recision to grant an operating license for the Seabrook facility was based on he fiRC staff's analysis and recommendations; however, before the license was trued, the NPC staff conducted a special review of all INP0 evaluation reports Seabrook. The staff, from its review of these evaluation reports, confirmed at it was already cognizant of all the safety issues that had been identifieo dat hv INP0.
A nore detailed explanation of the relationship between the activities of the NRC and INP0 is set forth in the enclosed M0A between the two organizations.
I
- rust that the M0A and the comments we have provided are responsive to your concerns.
Sincerely,
(
Kenneth M. Carr
Enclosure:
"emorandum of Agreement Between NRC and INP0 L
i
ME)CRANDtM OF AGREEMENT
.BETWEEN THE INSTITVTE OF NUCLEAR POWER OPERATIONS AND THE U.S. NUCLEAR REGULATORY CO>NIS$10N This memorandum between the U.S. Nuclear Regulatory C; mission (NRC) and the Institute of Nuclear Power Operations (INPO) reflects the desire for a continuing and cooperative relationship in-the exchange of experience, information, and data related to the safety of nuclear power plants.
The NRC has statutory responsibility for licensing and regulating nuclear f acilities and materials and for conducting research in support of the licensing and regulatory process, as maneated by the Atomic Energy Act of 1954, as amended. the Energy Reorganization Act of 1974, as amenced, and the Nuclear Nonproliferation Act of 1978; and in accordance with the National Enviremental Policy Act of.1959, as amenced, and other applicable statutes.
NRC's responsibilities include protecting public health and safety, protecting the: environment,-protecting and safeguarding materials and plants in the interest of national security, and-assuring conformity with antitrust laws.
INFO is an organization sponsored.by the nuclear utility industry whose Dission is to promote the highest-levels of safety and reliability in the cperation of nuclear electric generating plants. As such NRC and INP0 undertake mutual and complementary activitics, as= defined in appendices to this Agreement. These appendices will help ensure that the goals of both organ 2ations are achieved in the most efficient and effective manner without diminishing or_ interfering with the responsibilities and authorities of the NRC and the goals of INP0.
This Memorandum is not intended to be an enforceable agreement or contract on either party, notwithstanding the occasional use of the term ' agree' or the use-of mandatory language such as 'shall' or 'will" in either the Memorandum or:its appendices.
In particular, insofar as this Memorandum or its-appendices indicate that the Comission will take or refrain from-taking a
-particular action in discharge of its regulatory responsibilities, such an indication is intended only to reflect the Comission's current policy-intentions inlthis regard. Since this Memorandum is not legally binding, the Comission any depart from its tems whenever it deems it:necessary or 4;propriate to do so in the discharge of its regulatory responsibilities.
- except that in the interests of cooperation the Comission will, if.
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appropriate and practical, advise INPD of any intention to depart from the terns of this Memorandus prior.to doing so.
It is intended that this Memorandum of-Agreement and its companion appendices complement one another. Appendices are utilized to delineate detailed and specific areas for cooperative agreements which exist between the parties of this Agreement and which may be amended from. time to time. The appendices are not interpreted as restrictive to only those areas specified in the document.
l but serve as keystones of the Agreement for the exchange of information to support the comen goals of both organizations.
_ ENCLOSURE
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we crancum of Agreement Eetween INP0/NRC Fage Two lhPD and the NRC agree to c:nsult with each other with regard to the availability of tecnnical information which would be useful in areas of mutual inte*tst; and to promote and encourage a free flow of such information.
In
-this regard, INPO will provice plant specific information on a case-by-case basis c0nsistent with the other provisions of this Agreement. Both parties recc;nize the need for excluding from this Agreement fragmentary information related to work in progress and/or which has been received on a-privileged basis. _However. as information is verified and found to be necessary or it;;rtant to findings upon which significant safety-related conclusions and rect rendations are based, the party holding such information will take a;;r:;riate and timely ste:s to remove it from the fragmentary, privileged or ctherwise restricted status. However, the NRC cannot provide information to INPO that is required by law to be withheld.
Each prty rece;nizes the need, on s:me occasions, to be able to accept and protect privileged information
'where such infortation could not be made available otherwise.
It is rec:gnized that the parties to this Agreement may not be fully aware of the extent of each-cther's kn:wledge and thus, this-Agreement requires _only the parties' best efforts and a reasonable degree of care in assuring that significant safety-related information is provided in a timely manner to the other party.
The parties to the Agreement will meet periodically to exchange information and keep each other apprised of the major activities underway and planned in each area of agreement. The meetings are an effort to avoid unnecessary and unintentional duplication of activities, while providing a means to. identify these areas where independent activities by another organization may be-uarranted.
C::rcination meetings are for infersation exchange only. Meetings are not to be c nstrued as requests or opportunities for (or used by the-NRC for obtaining) the advice or reccmmendations of INPO or its personnel _en policy or
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regulatory issues within the scope of the NRC's responsibilities.
!NPO advice or recerrnendations-to the Comission on regulatory or policy matters, if any, are to be made through established procedures of the Comission and will be censidered by the Coernission in the same manner as other offers of advice or ree:mendations made through established Comission procedures.--Minutes of all c crdination meetings will be placed in the NRC public document room.
These need not be verbatia transcripts of coordination meetings, but should include a list of the meeting participants and-agenda items discussed at meetings, with-brief sumaries of the discussions held by meeting participants.
In addition to meetings, it is expected frequent, informal comunications will exist among the parties that will be limited to exchanging information and providing updates on the status of activities in progress or planned.
The appendices to this agreement provide for NRC access to selected IMPO pre;rietary documents and infomation. Such documents and information provided to the NRC will be appropriately identified as Limited or Restricted Distribution.
Consistent with previous legal decisions sanctioning the exchange of proprietary infortation between INP0 and NRC and in the interest cf improving nuclear plant safety, NRC will' control distribution of IMPO
- exranc.? of Agreement Ee: ten IkF0/hRC Fage Three pre:rittary documents and information within the agency and will exert best efforts to prete:t it from unauthorized disclosure.
Exceptions to this policy fer centrol of INPO proprietary documents and inferr.ation will be addressed by the parties to this agreement on a case-by case basis.
This Agree. ment supersedes the previous Agreement dated December 18, 1985.
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Ticz I. Pate S
Ext:utive ITire:+
or 0:erations President U.S. Nu: lear R ' latory Comission Institute of Nuclear Fewer Operati:ns Iffe:tive Date: 0:tecer 20, 1988
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APPENDIX NtDEER ONE COORDINATION PLAN FOR NRC/INPO EXCMNGE OF OPERATIOKAL EXPERIENCE DATA
=1.
EACKGROUND
.The purp:se of this plan is to coordinate selected NRC and INPO activities related to the collection and feteback of operational experience, infomation and data related to the safety and reliability of nuclear pc.er plants. There are'several underlying assumptions, including the following:
a.
NRC as the goverreent entity has statutory responsibilities and authorities which are paramount.
Nothing in this plan dilutes that resconsibility and authority to take aciton in accoreance with acplicaole statutes.
b.
Recognizing the ability of INPO to contribute to safe and reliable c;eration with a resulting benefit to public health and safety, the following statements apply:
(1) NRC and INPO share the coneon objectives that reporting of operational experience infomation and data be efficient and that caplicative or inconsistent reporting be minimized.
(2) NRC and INPO agree that the validity of analysis results may depend upon the completeness and quality of input infomation.
(3) HRC and INPO agree that the effectiveness of operational data feedback-is dependent upon a proper understanding of the significant lessons learned from industry operating experience.
2.
OVERALL C00RDIKATION a.
MRC and INPO will regularly exchange, on a timely basis, the results of completed and formally documented generic analysis and event evaluation cf operational data.
b.
INP0 will provide the NRC with timely listings of the significant events that have been identified by the SEE-IN screening process as significant events for analysis. Similarly, the NRC will provide INPO in a timely manner with the results of its significant event screening procedure that identifies events for engineering evaluation or a case study and for Information Motices or Bulletins.
c.
Infomation and data obtained by the NRC from foreign sources. that do not include restrictions on further distribution, will be entered l
into a computerized data bank and will be made available for INPO analysis activities. Foreign information and data obtr.ined by INP0 i
that does not include restrictions on further dissemination will
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A;;encia Nu.cer One Cecrcitation Plan fcr NRC/INPO Exca.ange cf Operational Experience Data Fa;e Two similarly be entered into an INPO data base and will be rade available for NRC analysis activities.
d.
INPO will provide the NRC access to and use of the Nuclear Plant Reliability Data System (NFRDS) coerated and maintained by INPO.
Additional-agreements regarding NPRDS access and usage are contained in a contract between NRC and INPO that is separate from this agreement.
e.
NRC and INPO intend to have periodic informal technical discussions en generic Or-event-related studies in progress tnat are of mutual interest.
f.
Prior to issuing to the industry an Information Notice or other ccmpleted and formally documented analysis on a specific event at a nuclear power plant, the NRC agrees to make reasonable efforts to review available INPO SEE-!N products to determine if the Inforsation Notice or other analysis is needed and, if so, that it is technically accurate. Similarly, INPO agrees to make reasonable efforts to review available NRC Information Notices or other completed analysis to determine if an INPO SEE-IN product is needed and, if 50, that it is technically accurate.
Unless a compelling safety concern dictates otherwise, the party identifying technical inaccuracies, if any, will give the other party reasonable advance notification of the inaccuracies and seek resolution before formally issuing the information to the industry.
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Victor ' te)
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T. Pate Executh wire t for Operations President U.S. Nuclear ulatory Comission Institute of Nuclear Power Operations-Effective Date:
Octcher 20, 1988 r
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l-I APPENDIX NUMEER TVO COORDIKATION PLAN FOR NRC/INPO APPRAIS.AL AND EVALUATION ACTIVITIES 1.
B&CKORDUND The purpose of this plan is to coordinate selected NRC and INPO utility a;;raisal and evaluation activities.
It is also intended to provide a etenanism and a basis for NRC to recognize INPO efforts in this area.
There are several uncerlying assumptions, including the following:
o INFO recognizes NRC's regulatory responsibilities and authority.
o NRC recognizes INFO's efforts to promote excellence in nuclear plant operations.
o NRC desires to recognize INPO evaluation activities to the extent that these activities are effectivt in helping meet NRC's responsibilities as well as lessen the burden imposed on the incustry by duplicative appraisal activities.
o NRC recuires access to selected INPO documents and information as well as the opportunity to observe selected INPO activities in order to be able to give credit for 1HPO activities and to thereby avoid unnecessary duplication.
2.
INPO ACTIVITIES This section outlines current and planned INPO evaluation activities.
a.
INPO will conduct evaluations of operating nuclear plants on a periodic basis. The interval batween plant evaluations will average about 16 months, b.
INPO will conduct evaluations or assistance visits related to corporate support of nuclear stations. This phase of INPO activities will usually be conducted coincident with (in close time proximity to) an evaluation of the utility's plants.
c.-
INPD will prepare a written report for each evaluation. These reports will include appropriate utility responses in each area identified by INPO as needing improvement.
A::encix Number Two C rcination Plan for NRC/INPO A::raisal anc Evaluation Activities Fage Two d.
Each succeeding evaluation will include follow-up on the responses ceveloped during the preceding evaluation.
e.
INPO will conduct appropriate visits to Near Term Operating License plants and their corporate organizations to assist in their preparation for operation.
3.
NRC REVIEV 0F INPO ACTIVITIES a.
INPO expects its eember utilities to make c;erating plant evaluation reports available to the NRC for review or reading.
Further, INPO will eake final evaluation reports available to the NRC for review or reading by appropriate NRC canagement personnel at the INPO offices in Atlanta.
b.
Current copies of, and any changes to, INPO evaluation criteria will te provided to NRC, c.
NRC may, on recuest, have a representative observe an INPO evaluation.
INPO will obtain the necessary concurrence from the host utility. While specifying a maximum number to be observed is not considered necessary by either party, it is anticipated that an NRC representative ray observe INPO evaluations several times annually.
Where NRC Regional personnel participate as observers, they would not nortally accompany an INPO team on an evaluation in their own Region.
d.
INPO will brief personnel of the NRC Division of Reactor Inspection and Safeguards, Office of Nuclear Reactor Regulation (NRR) periodically on all aspects of INP0's evaluation and assistance program.
e.
NRC review of INPO evaluation activities will be coordinated by the NRC Office of the Executive Director for Operations. Since INPO has its own system for obtaining member corrective action, NRC's role in pursuing correction of INPO evaluation findings will primarily involve only those potentially significant safety problefts for which NRC has no other reasonthle alternative in meeting its legislated responsibilities. Any other NRC follow-up enforcement action would be in accordance with paragraph 4.c. below.
4.
NRC RECOGNITION OF THE INPO EVALUATION PROGRAM a.
Subject to the continued development and success of the INPO program as outlined above and HRC's ability to effectively review the program, NRC intends to recognize INPO evaluations and, in those
Accencia Nuc er Two C;;rcination Plan for NRC/INPO Accraisal and Evaluation Activities Fage Three artes deemed apprceritte, to minimize NRC-sponsored evaluations or a;praisals that duplicate INPO evaluations.
b.
NRC and INPD will coordinate NRC inspections (involving two or more inspectors) and INFO evaluations to minimize the 1e: pact on the utility involved. Where feasible. NRC and INPO will coordinate event related or other emergent on-site activities such as NRC aug'mented inspection teams (AITs), incident investigation teams (!!Ts).
diagnostic evaluation teams (OETs) and INPO event investigations, alth:vgh each party recognizes that it may not be possible to c::rcinate all of these efforts.-
c.
The FRC will apply the established Comission enforcement policy fer licensee identified non-comoliances to those non-coeroliances icentified by utilities as a result of INPO evaluations.
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. Pate Execu M 0ir.t for Operations President U.S. Nuclear R ulatory Comission Institute of Nuclear Power Operatiens Effective Date: October 20, 1988 l
APPENDIX NLDEER THRIE CDORDIKATION PLAX FOR NRC/ IMP 0 TPAINING-RELATED ACTIVITIES 1.
BACKGRDUND The curpose of this plan is to coordinatt f elected NRC and INPO activities related to nuclear power industry training.
It is also intended to pr: vide a mechanism and a basis for information sharing and MRC re:c;nition of INPO efforts in this area.
4 There are several underlying assumptions:
o INPO recognizes NRC's regulatory responsibility and authority, o
NRC and INPO share the goal of imoroving and maintaining the quality of nuclear utility training.
o NRC recognizes the industry's initiative and commitment to INPO programs that promote high quality training through development of integrated training and cualification systems, including accrecitation of key training programs, o
NRC recognizes INPO accreditation and associated training evaluation activities (see also Appendix 2, ' Con <ination Plan for NRC/INPO Appraisal and Evaluation Activities ; as an acceptable means of self-improvement in training. Such recognition encourages industry initiative and reducts duplicate program review and appraisal activities.
I o
INPO recognizes that the NRC requires access to selected INFO documents and information, as well as the opportunity to observe selected INPO activities related to training and accreditation, in order to ensure that the NRC meets its obligations to the public and the Congress.
o Coordination of NRC and INPO training-related activities and sharing of information will increase overall effectiveness as well as lessen the burden imposed on the industry by duplication of activities.
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Ac;encix Mue:er Three Cocr:inatien Plan for NRC/INPD Training Related Activities Page T=c 2.
OVE%.L CDCUr lRATION a
In erder to promote overall coordinatien of HRC and INPO training-relatec activities, the following actions will be taken:
a.
NRC/INPO Cecrdination meetings sill be held periodically with representatives frc: NRC's Divisien of Licensee Perfomance and Quality Evaluatien (NRR) anc INPO's Training and Education Group.
At these etetings, infer atten en engeing projects and plans will be exchanged. Written reports cf pt:.gress and results may be exchange:.
b.
INPO will provide the NRC with access to selected INPO documents anc inferration, anc will provide uccated ceptes of the INPO training guicelines anc Training System Devticyment Manual.
INPO will also previce the NRC, en a case-by-case basis, with access to the jed and task analysis cata stored in the IMP 3 computer data base.
c.
(cerdination regarding accrecitation of training progra:es is covered by Attachment 1.
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Tte# I. Pate Executive Utret.e-for Operations President U.S. Nuclear Regulatory Comission Institute of Nuclear Power Operatiens Effective Date: Otteber 20, 1988 i
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NRC/INPD C::reinstien Plan attachment 1 A :en:1x Three Page One ACCREDITATION OF TRAINING PROGRMS 1.
BAttGROUND The purpose of this plan is to provide for coordination of selected NRC an: INPD activities related to the accreditation of performance-based training programs. This plan also provides for continued industry initiative with NRC monitoring in this area and serves as a basis for NRC re::;nition'of INPO's efforts. This coordination plan is consistent with the Comission Policy Statement en Training and Qualification of Nuclear Pe=er Plant Personnel.
In carrying out this plan INPO recognizes NRC's res;:nsibility and authority.
2.
INDO ACTIVITIES This se: tion cutlines current and planned INPO activities related to the at: recitation cf cerformance-based progr us for the training and cualification of nuclear power plant personnel. The INPO point of c crcination for the implementation of this plan is the Group Vice President. Training and Education, a.
INPO will centinue to manage the accreditation of utility training programs including:
o self-evaluations by member utilities, with assistance from the INPO staff; o
on-site rtviews of training and qualification progrus by teus of INPO and utility personnel; o
preparation of a report for each accreditation tem visit; o
follow-up on recomendations developed during the accreditation process; awarding, deferring or placing on probation of accreditation by o
the National Nuclear Accrediting Board; and o
reviewing accreditation of utility training programs approximately every four years (accreditation will be renewed, continued in a probat1onary status, or withdrawn).
b.
INPO will continue to conduct periodic performance-oriented evaluations of tratning and qualification programs as part of its operating plant evaluations and as follow-up to accreditation.
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NRC/INPD Cecrcination Plan A::encix Three Page Two c.
INP0 will provide upcated copies of the accreditation procedures and criteria cocument as it is revised. This document will be made publicly available.
d.
INP0 will review and consider NRC recommendations regarding INPO-managed training-related programs, documents, and criteria.
e.
INPO will provide periodic detailed briefings on accreditation to appropriate NRC management personnel, including review of the activities described in 2.4 above and documentation of industrywide accreditation status.
f.-
INPO intends to brief the Commission periodically on program status.
3.
WRC ACTIVITIES This section outlines the NRC's continuing efforts to monitor INPO activities as part of NRC's assessment of the effectiveness of industry's training and qualification-program improvements; The NRC point of ccercination for implementation of this plan is the Director Division of Licensee Performance and Quality Evaluation, NRR.
a.
NRC will not issue documents that duplicate INPO training documents and will not refer to INPO documents as a means of satisfying NRC recuirements so as to avoid ' codifying" or the appearance of
" codifying" IKPD documents.
b.
NRC-will assess the effectiveness of industry's training and qualification progrsm improvements as follows:
o conduct aparator licensing exams; o -
conduct operator requalification exams, consistent with Commission policy and 10 CFR Part 55;
.o conduct reviews of's sample of utility training programs to ensure use of-performance-based training principles; o
monitor plant and industry trends and events involving personnel
. errors; o
continue irraluation of industrywide training and qualification program effectiveness; and o
conduct performance-oriented training inspections to assess the-level of knowledge and qualifications of plant personnel.
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3:C/ INFO C::rcination Pian 4::escir Three
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NRC will monitor INPO activities in training and accreditation as follows:
o receive periodic briefings and/or reports from INP0 and reytew'a-sample of applicable INPO documentst o
nominate individuals who are not on the NRC staff to serve as memoers of the National Nuclear Accrediting Board with full voting privilegest-o have an NRC staff member attend and observe selected National Nuclear Accrediting feard meetings with the INPO staff and/or the utility representativest o
en recuest and with concurrence of the utility, have NRC emoleyees esserve INP0 accreditation team site visits for the pur;:se of-m nitoring the-effectiveness of the accreditation process.
Since accreditation teams are relatively small in size, it-is anticipated the NRC would typically send only one-observer on any visit.
However, in certain circumstances, it-may be appropriate to send more than one.
INPO will obtain the necessary concurrence from the host utility. While specifying a maximum number to be observed is not considered necessary by either' party, it is anticipated that NRC' employees would observe approximately'20 percent of INFO accreditation team visits; and o
- accompany INPO on selected operating plant evaluations (see
' Appendix 2).
d.
NRC will continue to provide INPO copies of NRC's performance-oriented inspection program including applicarle inspection guidelines, e.
NRC will coordinate any team inspections with INPO accreditation team
-visits and evaluations so as to minimize.the impact on the utility
' involved. On request and with concurrence of the utility..an INPD-employee may occasionally observe an NRC inspection in this area.
f.
Since !NPD has its own system for obtaining member corrective action.
NRC's role in pursuing corrective action of-INPD-identified training and qualification recomendations will involve only significant safety problems for which NRC has no other reasonable alternative in meeting its. legislated responsibilities. The NRC intends to exercise discretion in enforcement matters related to training as described in the Comission Policy Statement on Training and Qualification of Nuclear Power Plant Personnel.
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APPENDIX NUMBER FOUR COORDINATION PLAN FOR INDO/ INDUSTRY PARTICIPATION IN NRC INCIDENT INVESTIGATION TEAMS 1.
The purpose of this plan is to establish guidance for. !NPO or other incustry representatives involvement with NRC Incident Investigation Teams
(!!Ts).
It is also intended to minimize duplication of event investigation efforts to reduce the impact on the affected utility and to prc cte dissemination ~of accurate operating experience information to the incustry.
s 2.
NRC and INPO recognize the importance of NRC's incident investigation activities in identifying significant operational experience
-infermatien.
Participation by industry representatives on an IIT should resu_1_t in a more complett and thorougn understanding of the factors centributing to the incident and actions needed to prevent recurrence.
In carrying out this plan, INPD recognizes NRC's responsibility and authority.
3.
In view of these considerations. INPO and NRC agree on the following:
a.
INPO or other industry representatives' participation on an IIT will be coordinated between the Director of the Office for Analysis and Evaluation of_ Operational Data (fl0D) for.the NRC and the Vice Fresident for Government Relations. INPO. A request for participation by an industry representative can be initiated by either-party to this agreement.
b.
NRC will provide INPD-with a reasonable number of copies of the
-current Incident-Investigation Manual and any other procedures which apply to the operation of an IIT.
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c.
NRC will notify.!NPO promptly when an !!T is being activated anJ provide all necessary information to enable INPD to facilitate industry participation.
d.
INPO will serve as the central point of contact.for coordination of all. issues and procedures regarding industry participation on 11Ts.
e.-
INPO will-recornend industry participants to the NRC.
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Appencix Nue.ber four Cc:reination Plan for In:1 dent Investigation Activities Page Two f.
IMP 0 will re;utst each industry nominee to sign a statta nt regarding proprietary information, conflicts of interest, and waiver of compensation.
In adattion, each industry nominee will be requested which include procedures for handling differences in pr opinion and the release of investigation information.
statement will be provided to the NRC as part of the nominationThis signed process.
5 1HPO will provide assistance in coordinating with the affected g.
utility to obtain site access for the incustry representative (s).
h.
INPO will work with the affected utility ard the IIT so that the Significant Event Report (SER), if any, being prepared by INPO on the event unser investigation by an IIT is factually correct.
To this end, INPO will request that the affected utility coordinate a review of the draf t SER with the IIT and provide coments to IMPO.
JW 4fes:r St u11e Jr 4'
. Pate Exe:utive DTree or Operations rresident U.S. Nuclear Re atory Comission Institute of Nuclear Power Operations
- Iffective Date: October 20, 1988