ML20033C651
| ML20033C651 | |
| Person / Time | |
|---|---|
| Issue date: | 06/30/1981 |
| From: | NRC OFFICE OF INSPECTOR & AUDITOR (OIA) |
| To: | |
| Shared Package | |
| ML20033C638 | List: |
| References | |
| FOIA-81-338 NUDOCS 8112030555 | |
| Download: ML20033C651 (34) | |
Text
, 7 1
l jv* %,
o t
I s
~*
United States l
Nuclear Regulatory Commission
. %,"C*p#
1 i
Report to the Commission t
l NRC's Implementation
~
L of the Three Mile sland Action Plan 1
i
~
l e'
i i
i m
[
9 Office of Inspector and Auditor June 1981 I
,k>
NOT CE t'
Intern ment P
'n e Released RC Oy20g55810910 e;
DANN81-338 POR '
+
~-
.-=x..
maau 8
UNITED STATES 8'
o' NUCLEAR REGULATORY COMMISSION y,
W ASHINGTON, D. C. 20665 June 4, 1981
'+...+-
MEMORANDUM FOR:
Chainnan Hendrie Commissioner Ellinsky Commissioner Bradford Commissioner Ahearne FROM:
James J. Cummings, Director Office of Ir.spector and Auditoi W
AUDITOFNRC'SIMPLEMENTATIONONHETMIA ION PLAN
SUBJECT:
Attached is our report resulting from the second phase of a review of the implementation of the Three Mile Island (TMI) Action Plan.
Our review focused on those Action Plan items relating to utility p'ersonnel licensing and training, but it also addressed a larger issue--inadequate management of-the Action Plan's implementation--which we observed in NRC's attempts to implement the licensing and training action items.
/
The review was perfonned at NRC Headquarters and Regions II, III and V between June and December 1980.
It primarily involved interviews of
~ fficials responsible for implementing the Action Plan and a review of o
pertinent documents, studies, proposed rule changes and regulatory guides. The review buiit on the work and the sample results of phase one of our audit, which related to the development of the Action Plan. Our report on phase one was issued to you on October 3,1980.
Summary of Findings Just as NRC learned many lessons from the accident at TMI, there are a number of lessons to be learned from NRC's early attempts to implement its Action Plan response to the accident.
Our review showed that although some progress was being made in implementing some action items related to utility' personnel licensing and training, problems were being experienced in implementing many others. These problems related generally to the need to:
Develop adequate requirement criteria and consistently apply them; Establish adequate control and followup of licensee actions; Review licensee submittals in a more timely manner; Establish adequate interoffice coordination; and
_ j.' e Report action item status more accurately and timely.
2" CONTACTS:
F. Herr, OIA
~ "
P. Murray, OIA
)
49-27051
.s C
o I
Th2, Comiss' ion j-2 1
We found that, whether or not a specific action item was being effectively I
implemented depended largely ori the initiative of the individual assigned responsibility for that item. While there is a need to resolve problems we identified with specific action items, we believe the specific problems highlight a larger problem, that being the lack of adequate management attention to the implementation of the Action Plan as a whol e.
No overall organizational structure has been established to coordinate and oversee its implementation or to resolve problems.as they arise. Although the Director, Division of Licensing (DOL), Office of Nuclear Reactor Regulation (NRR), initiated a program in December 1980 to oversee and track the implementation of NUREG-0737, " Clarification of TMI Action Plan Requirements," as it relates to operating reactors, no
. comparable organization has been established for the remainder of the Action Plan.
In addition, the system established by the Director, DOL, is an NRR organization. Although memorandums have been exchanged b officials in. DOL and the Office of Inspection and Enforcement.(IE) y to coordinate implementation of NUREG-0737, these agreements were not reached at a level sufficient to bind the resources of either office to the programs to be carried out.
We recognize that the established i
management chain exists for resolving these coordination problems; however, our observations on implementation of TMI related items to date 1
indicate that this system does not always work.1 Conclusion l
Generally speaking, although portions of the Action Plan are being implemented, progress has been slow in many areas because of a lack of management attention to the implementation of the plan.
Imediately following the accident at Three Mile Island and during the development of the Action Plan, NRC put consideraHe time and effort into identifying changes needed in the regulatory process.
No othei program within the agency had a higher priority. On the basis of our review, however, we do not believe the same commitment exists within the agency to implement the Action Plan as existed to prepare it. The agency seems to be implementing TMI requirements through the nonnal business routine; some licensees seem to be questioning the value of their own good faith efforts, in view of NRC's changing schedules and requirements; priorities seem to be getting confused; and no one seems to be really managing or coordinating NRC's efforts. As time goes by and the memories of the accident become clouded by more current problems, the need for an organizational structure that will ensure continued implementation of the Action Plan becomes
_.more important.
1 I For example, see OIA's r po. cs entitled, " Improvements Needed In Coordinating the Development of Related Rules", dated September 18, 1980, and." Inquiry Into NRR's Implementation of Short Term Lessons
~
Learned Category A Requirements": dated November 12, 1980.
a 1
I%.
,[-
~
3 The Commission Recommendations Our review nas shown a need for' greater ma'nagEmen't attention to the implementation of the Action Plan.
However, we do not believe that the existing organizational and management structure can provide the attention to the implementation of the Action Plan which we believe is necessary.
As a result, we recommend that:
1.
The EDO move rapidly to improve the management of the implementa-tion of the Action Plan and documents, such as NUREG-0737, which
~
resulted from it. This should include:
clearly assigning and documenting the responsibilities and a.
auth_ority for implementing the Action Plan; and b.
providing policies, guidance and priorities.necessary to ' carry out those responsibilities.
2.
The ED0 ass;.re that the problems identified in this report relating to specific action items are or have been corrected and that similar problems are avoided in implementing the remainder of the Action Plan.
Agency Comments On June 3, 1981, the EDO provided comments on a draft copy of this report (See Appendix II). Generally, the EDO statef that the report
" accurately reflects a number of the difficulties experienced" during the time period covered by our audit.
He also noted, however, that since completion of the audit, a number of management changes had been undertaken which have substantially brought reporting, coordination and licensee interaction into better control.
These changes have been consolidated into a single document which the EDO distributed to office directors on June 3,1981, (See Enclosure 1 to ED0's comments).
In regard to the problems we noted on specific Action ~ Plan items, the ED0's comments generally acknowledged that problems exist but that actions are completed or underway to correct the problems and avoid them in the future. These actions include: (1) establishing NRR Lead Project Managers for each Action Plan implementatio.n item and processi.ng all Safety Evaluation Reports thror" the Operating Reactors Assessment Branen, NRR, to assure consist:cej of application of requirements; (2)
NRR and MPA working together to develop a system to track the status of each licensee action and identify instances where licensee submittals are not being reviewed in a timely manner; and (3) including IE inspection information in the NRR tracking system so that all infomation on each item is catalogued in one place.
D I
=
.The Comm ss on 4
i i
The actions taken and proposed by the EDO should resolve the problems identified in this report, if properly implemented.
We plan to follow-up on the implementation of the.TMI Action Plan and the actions taken in response to this ~ report in about,four mdnths.
Attachment:
As stated cc:
W. Dircks EDO Office Directors Regional Directors 4
I 4
e e
e D
j l
e
TABLE OF CONTENTS P
Page 1
INTRODUCTION 2
Scope 3
- FINDINGS, NEED FOR GREATER MANAGEMENT ATTENTION TO 3
ACTION PLAN IMPLEMENTATION PROBLEMS IDENTIFIED IN IMPLEMENTING SPECIFIC 7
ACTION ITEMS Need to Develop Adequate Requirement Criteria 8
and Consistently Apply'Them Need to Establish Adequate Control and Followup 10 of Licensee Actions Need to Review Licensee Submittals In A More Timely 12 Manner Need to Establish Adequate Interoffice 12 Coordination Need to Report Action Item Status More Accurately and Timely
. 13 15 CONCLUSIONS AND RECOMMENDATIONS 16 Recommendations 16 AGENCY COMMENTS APPENDIX I - Action Items in Phase Two Sample APPENDIX II - Memorandum from EDO Dated June 3. 1981
INTRODUCTION Following the accident at Three Mile Island (TMI) a number of studies were conducted to detennine what lessons could be ' learned from the accident and what actions could be taken to lessen the possibility of
-future accidents. The Kemeny Commission looked at possible changes to improve nuclear safety, NRC's Lessons Learned Task Force considered what actions were required for new or near term operating licenses, and the Rogovin Special Inquiry Group examined all aspects of the accident and its causes. The recommendations of these groups as well as those of the various internal NP.C study groups were compiled in NUREG-0660, "NRC Action Plan Developed as a Result of the TMI Accident."
The Action Plan was developed to provide a comprehensive and integrated plan for those actions deemed appropriate to correct or improve the regulation and operation of nuclear power plants as presented in the various TMI studies. While all of the recommendations were assessed by the Action Plan Steering Committee, not all were adopted verbatim. Some recommendations, because they were very similiar, contradictory, or provided multiple solutions to the same problem, were either rejected or modified.
Some recommendations affecting the safety of operating reactors were judged to be so important that they were implemented immediately, upon Commission approval.
While many of the actions implementing these recommendations had been completed by the time the Action Plan was prepared, the recommendations were included in the Action Plan so that it would remain a comprehensive document.
The Commission, in a series of meetings, approved the various portions of the Action Plan--those items affecting near term operating licenses (NT0Ls), those items affecting all other operating license applicants (Now NUREG-0694, "THI Related Requirements for New Operating Licenses"),
and those remaining items which would be implemented or further considered over time.
(The Commission decided to approve these latter items in
. concept but to defer approval of their implementation until the staff could further clarify the issues and ramifications. This resulted in these items being handled on a case-by-case basis,through the nonnal routine for new requirements.) The Commission considered the Action Plan recommendations and schedules in light of the safety significance and the immediacy of the need for action and, in the long run, the availability of NRC and industry resources. This resulted in the Action Plan presenting a sequence of actions that would gradually improve safety as the long tenn actions supplemented the quick fix remedial actions.
Although the Action Plan contains both actions to be taken and schedules for their implementation, it is basically a conceptual document.
It lays out for the industry and the staff the overall direction in which the Commission hopes to go and the timeframes in which it would like to get there.
It is not a document which can be looked to for specific criteria on what needs to be.done or how to do it.
2 i
The Office of Nuclear Reactor Regulation'(NRR), realizing this, set out
' to clarify.the various action items listed in.the Action Plan.
It L
prepared a draf t clarification letter, held meetings around the country, revised the clarifications and presented the package as NUREG-0737,
" Clarification of TMI. Action Plan Requirements." That document is considered an implementina document of all those action items which have been 'specifically approved by the Commission for implementation.
It-specifies schedules for providing infomation to the NRC and schedules for implementation of items.
It also defines any technical specification requirements and. identifies. items as-pre or post implementation review
,i i
items.
NUREG-0737 in itself is not an enforceable document.
It does, however, require a response by all licensees which NRR will make enforceable by following up with confimatory or show cause orders to licensees.
But implementation does not end with the impositipn of a requirement on the licensees.
It goes well beyond that and includes development of appropriate additional requirements and clarifications, a review of the licensees' proposed actions, inspection of the completion of those t
actions, and taking enforcement action as necessary to ensure that the requirements are met.
Scope Our review of the implementation of the TMI Action Plan has been conducted in two phases. During both phases of our review we concentrated on those TMI lessons learned concerning utility personnel licensing and training. During phase one we made a detailed analysis of a' sample of 22 recommendations and detemined that the Action Plan adequately represented the intent of the original recommendations. Our report on the first phase of our audit was issued to the Commission on October 3,1980.
Based on that phase of our review, however, it was clear that a mcjor effort-was still required to transfom the conceptual framework of the Action, Plan into a viable, understandable, implementable, and enforceable set of requirements.
Phase two of our review was conducted from June through December 1980 and included interviews and discussions with officials directly involved in implementing the Action Plan at NRC headquarters and in Regions II, III and V.
Contact was also made with other NRC officials and some licensee management personnel. We also reviewed pertinent documents, studies, ' proposed rule changes and regulatory guides.
4 t
For this phase we included in our sample all-action items covering the 22' recommendations used in phase one. To that sample we added all decision group A itemsl hat were not cross referenced to our original t
C 1 Action items in the Action Plan were divided into four-categories
'labeledLDecision Groups A through D.
Decision Group A items were those approved for implementation before the. Action Plan was approved.
Decision Group B items were those approved for' implementation.when the Commission approved the Action Plan. - Decision Group.C items were those
., items Lon which the Commi,ssion deferred an : implementation decision..
Decision Group D~ items were those items believed to be adequately covered 'in NRC's ongoing programs and so no special implementation or approval was required.
I 3
sample but which..in our opinion, dealt with utility personnel licensing and training. These were added because they had already been approved by the Conmission, were considered short term, and required actions to be performed during the course of our review.
Our sample for pha'se two included all or a part of 23 of the major Action Plan tasks which encompassed 101 required actions. We performed a detailed review of 40 of these 101 action items which required action prior to August 1980. A more general look was given'to those items which~ did not require action until after August 1980. Appendix I lists these 23 major tasks.
Phase two of our review was designed to focus on how each action item in our sample was being implemented and monitored.
In addition, we expanded phase two to include a review of the management of the Action Plan's implementation.
FINDINGS Our review disclosed that there were a number of lessons to be learned from NRC's early attempts to implement the Action Plan.
During our review of specific Action Plan items, we identified specific problems in their implementation which prevented or delayed their satisfactory resolution. However, we also identified an overall problem, the resolution of which we believe to be critical to solving the problems we identified in implementing specific Action Plan items.
The overall problem relates to the need for greater management attention to the implementation of the Action Plan. We believe this overall problem either caused or allowed the specific problems we noted to exist. The specific problems we noted were the need to:
Develop adequate requirement criteria and consistently apply them; Establish adequate control and followup of licensee actions; Review licensee submittals in a more timely manner; Establish adequate interoffice coordination; and Report action item status more accurately and. timely.
In the following sections of this report we will first discuss the need for greater management attention to implementation of the Action Plan and then discuss the specific problems identified above. These specific problems summarize the results of our review of many specific action items and exemplify the need for greater management attention.
NEED FOR GREATER MANAGEMENT ATTENTION TO ACTION PLAN IMPLEMENTATION Management was deeply involved in NRC's response to the accident at Three Mile Island.
It dedicated resources and manpower, assigned top j
flight people, and gave high priority not only to solving the immediate problems associated with the accident, but also to learning from the accident so that similar errors would not recur.
In addition, considerable time and effort went into the development and approval of the Action Plan, which compiled all the recommendations and " lessons learned" from the TMI studies.
A
-- - ~
4 However, during our review of action items relating to utility personnel licensing and training we found that the same degree of urgency and commitment which was placed on all those actio'ns leading up to the.
approval of the Action Plan, was not being placed on the actual implementa-tian of the plan. More than seven months after the approval of the plan, NRC still had not established an organizational structure to i
manage implementation of the entire Action Plan, nor had it established specific lines of authority and responsibility for the Action Plan's implementation.
The Action Plan, as approved by the Commission, assigned responsibility to implement specific action items to the various offices under the EDO, principally NRR. Within NRR a May 8,1980, memorandum from the Chief, Resource and Scheduling Branch, to division directors, further delegated this responsibility to the lowest management levels--to branch chiefs and section leaders. However, no one official or organization was assigned or assumed overall responsibility to see that the Action Plan was carried out.
In addition, no other significant statements of policy, guidance or priority other than the Action Plan itself, were issued to the responsible individuals.
In those areas we reviewed, we found the lack of organizational " marching orders" caused significant problems concerning accountability, responsibility, control, reporting and decision making.
Lacking a clear statement of organization, no one could say definitely who had control and who was accountable to whom. Responsible individuals had been named, but it was unclear what exactly they were responsible for.
Some individuals assumed that in the area; in which they had been named the responsible individuals, their only responsiblity was for the development of the criteria or the requirement, but not for the overall implementation of the item.
The responsible individuals needed to know what authority they had; the extent of that authority and responsibility; how to get others to work.
for them, especially in view of poorly defined and competing priorities; and how to control their work which other offices were performing for them. We found that, with no one overseeing the situation for the responsible individuals to turn to, they attempted to function within their normal mode of operation.
They tended to assume that othe NRC organizational elements would do the same and therefore be aware of, and accept responsibility for, the implementation of all appropriate parts of the Action Plan. Questions such as who would make policy decisions and who determined if the work performed to date.was adequate, timely, and on track appeared to be answered on an ad hoc basis, if at all.
Based on the specific work we'did and our discussions with officials throughout NRR we found that no one had a clear understanding of how things were supposed to have worked since the issuance of the Action Plan, how things were supposed to work now, or in the future. With another major milestone, January 1,1981, fast approaching, questions remained as to who was to receive the licensees' input, who would determine the appropriate reviewer, to whom that reviewer would report, who would have final say as to the adequacy of the licensees' submittals, or who would report to whom.
In short, there was no system for managing implementation of the Action Plan.
9
5 Because many of the items in the Action Plan involve several organiza-tions within NRC, there was and still is a need for a great deal of inter and intra-office coordination.
While we found that some coordination was taking place within NRR and among the various NRC offices, we found a number of instances in the areas we reviewed where it had broken down.
They ranged from the interpretation pf the Action Plan requirements to the reporting of inspection results.Z The greatest coordination problems appeared to exist between NRR and the Office of Inspection and Enforcement (IE). Our discussions with IE representatives indicated that little coordination had taken place between the two organizations on any Action Plan items to identify which areas IE was responsible for verifying in their inspections or what criteria IE inspectors were to use in making their reviews of licensee programs. The result was that IE and NRR were working independently without cross checking to assure that the other office had the same understandings and interpretations.
In a December 17, 1980, memorandum to the Director. OIA, responding to 01A's report on implementation of Short Term. Lessons Learned Category A items, the EDO stated that IE and NRR had reached agreement on coordination of the TMI action items requiring IE inspection. He also stated that work began in July 1980 to " establish positive controls to inspect all the inspectable licensee commitments in the TMI Action Plan...and to l
fonnalize the inspection requirements." Our concern about adequate coordination between IE and NRR remains, however. Our discussions with IE Regional and Headquarters officials took place in September and October 1980 and did not indicate that significant progress had ben made in coordinating the two offices' efforts.
Further, memorandums-exchanged between the. Director, Division of Licensing (DOL), NRR, and the Director, Division of Reactor Operations Inspection, IE, in December 1980, showed that agreement had still not been reached on whether IE or NRR was responsible for reviewing certain action items.
(See page 11 for details.)
The need for greater management, organization and coordination in the implementation of the Action Plan has not gone unnoticed within NRR.
In a December 12, 1980, memorandum to IE and NRR division directors, the Director, D0L, NRR, outlined a proposed NRR program for implementation reviews of TMI actions approved by the Commission as included in NUREG-0737, " Clarification of THI Action Plan Requirements." The purpose of the memorandum was to identify the method and schedule by which the NRC 2Two other OIA reports have also identified deficiencies in coordination in the implementation of Action Plan items.
01A's September 18, 1920, report to the Commission entitled " Improvements Needed In Coordinating the Development of Related Rules" identified the need for improved coordination among NRR, the Office of Nuclear Regulatory Research and the Office of Standards Development in developing regulatory changes resulting from post TMI studies. DIA's November 12, 1980, report to the Commission entitled " Inquiry, Into NRR's Implementation of'Short Tenn Lessons Learned Category A Requirements", identified coordination problems between NRR and the Office of Inspection and Enforcement in verifying licensee compliance with the Short Tenn Lessons Learned Category A Requirements.,
6 actions supporting NUREG-0737 requirements must be completed to approve licensees' programs at appropriate times.
Recognizing that implementation of NUREG-0737 will require cooperation and clearly defined work assignments, the memorandum assigned the Operating Reactors Assessment Branch (0RAB),
00L, the overall responsibility for managing the revi'ews'of the action items and maintaining the overall status of safety reviews and licensee commitment schedules. TN memorandum established general responsibilities for the Division of Liunsing and the Technical Branches / Divisions in NRR and identified the role IE was to play in reviewing and verifying licensees' actions. On December 18, 1980, the Director, D0L, finalized the program proposed in his December 12, 1980, memorandum.
We have reviewed the DOL Director's memorandums and discussed the organization with the Chief, ORAB. We believe generally that this organization is a step in the right direction toward resolving the general problems we identified in NRR's implementation of specific acti.n items.
In addition, the memorandums should result in improved coordination between NRR and IE by providing a clearer and documented understanding between the two offices as to what their responsibilities and schedules are for reviewing licensee submittals and verifying licensee actions. They should also open channels of communication between NRR and IE for identification and resolution of new problems as they arise.
Several concerns remain, however, in regard to this NRR program and the overall NRC organization for implementing the Action Plan.
First we are concerned that because the program was established by the Director, D0L, rather than by the Director, NRR, or the EDO, there is no assurance of (1) an office-wide commitment to it, and (2) its continuity in the future.
Our second concern is that the NRR organization is only for implementing NUREG-0737 requirements as they apply to operating reactors. The NUREG-0737 requirements as they apply to construction permit and operating license applications are left to be nandled in the. normal course of NRC business.
In addition, there are other Action Plan items which are still being developed and therefore not included in NUREG-0737. They will also be handled in the normal course of busines;.
No special provision has been made to ensure that these items will be adequately integrated into the nonnal process.
Finally, while we believe the D0L program is a move in the right direction, it remains largely an attempt by one office to carry out a portion of its responsibnities.
We recognize that memorandums have been exchanged between division directors in NRR and IE regarding the relative responsi-bilities of each office, and these agreements are a critical part of an effective system. We believe, however, that the DOL program should be part of a larger system for implementing the entire Action Plan.
Such a system should be developed by the ED0 and the office directors involved since they are t:ltimately responsible for the successful implementation of the Action Plan and for assuring that the resources of the igency are committed to that objective. One way in which such a system could be established would be to assign specific individuals or organizations responsibility for assuring that all, or major parts of, the Action Plan
.c
+ x lare carried out (much like ORAB is responsible for NUREG-0737 for operating
- plants)
- and-provide them with the necessary authority to fulfill that l responsibility. This system could also provide for' an organization such as an implementation -steering committee to assure coordination, resolve -
~
problems affecting more than one office or action item,-and to oversee
- the implementation of.the entire Action Plan.
The Steering. Committee:
could _be-made up of the individuals or, representatives from the organizations assigned responsibility for sections of the Action Plan as well as representatives from other NRC offices such as the EDO, Centroller and the Office of Management and Program Analysis (OMPA).
PROBLEMS IDENTIFIED IN IMPLEMENTING
~
SPECIFIC ACTION ITEMS Our-. review focused primarily on the NRR staff's implementation of specific action items relating to utility personnel licensing and training.- During our review we identified several problems which were being experienced in the implementation of items relating to utility..
personnel licensing and training. Although we believe resolution of the larger management issue, addressed above, should help resolve the individual problems and avoid them in the future, it is important that management be aware ~ of the types of problems experienced so that special attention can be directed to their solution as well as their' identification in other areas.
It should be noted that our, review of the.implemehtation of specific action item *, within NRR was completed before the Operating Reactors Assessment. Branch (6RAB). 00L,' was assigned ' responsibility to see' that all NUREG-0737 requirements are applied to operating reactors. To the extent possible we have recognized actions taken by ORAB, however. the program had not been fully implemented when our review was completed.
On the surface the actions taken by DOL appear good,.however, ORAB's effectiveness will depend ~1argely on how' it corrects past problems and avoids lsimilar-problems in the future.
The measure of their true value will have to; await further implementation.of the Action Plan.
The specific problems we found in the implementation of the Action Plan highlighted a need to:
Develop adequate' requirement criteria and consistently: apply them;-
Establish adequate control and followup of licensee actions;
't Review licensee submittals in a more timely manner; Establish adequate interoffice coordination; and
. Report action item status more accurately and timely.
N s-u,
r 8
Need to Develop _ Adequate Requirement Criteria and Consistently Apply Them.
To have an adequate regulatory program, regulatory requirements and their underlying criteria must be laid out in enough detail so that licensees know what they have to do to fulfill the requirements. The criteria also have to be specific enough that inspectors can inspect and verify the licensees' programs to fulfill the requirements and take appropriate enforcement action if the licensees' attempts are not satisfactory. Without adequate requirement criteria, enforcement is tenuous at best.
Although NR has established requirement criteria for the implementation of many of the action items, the following are examples of areas where we believe the criteria needed to be more specific or applied more consistently.
Action Item I.A.l.1, required that shift technical adiisors be fully trained by Osnuary 1981.
The responsible individual was under consid-erable pressure from licensees to provide specifics as to what con-stituted minimum criteria for being fully trained.
Because the due date for implementation was drawing near, the responsible individual told the licensees to use the criteria set out in INP0 (the Institute for Nuclear Power Operations) document " Nuclear Power Plant Shift Technical Advisor (STA)--Recommendations for Position Description, Qualifications, Education and Training." Meanwhile, on June 23, 1980, he submitted the INP0 document to DOL through the Division of Human Factors Safety, asking that 00L endorse it and send it to the licensees as a guide for STA training.
However,' DOL did not directly endorse it, but in its September 5, 1980, draft clarification letter, now NUREG-0737, D0L altered the Action Plan requirement by directing each licensee to develop its own training program, compare it with the criteria contained in the INPO document, and submit it by January 1981. 00L officials have stated that after they receive _and review that data, they will then finalize the official criteria.
Because no policy had been established and the timeframes were closing in on the licensees, two problems resulted:
(1) licensees had little time lef t to meet the requirements, and (2) each licensee could meet the requirements by simply establishing criteria which it could easily meet.
Action Item II.B.4 involving training to mitigate core damage, was first applied to licensees in the NRR Director's March 28, 1980, letter to all power reactor applicants and licensees. That letter required licensees to submit revised training programs to the Operator Licensing Branch, NRR, for review by August 1,1980. The official responsible for this action item told us that as of the August 1,1980, due date.he was not aware of any licensee commitments to this requirement.
He pointed out, however, that the Action Plan called for licensees' training programs not to be submitted to NRR, but rather to be inspected by IE.
This situation was further confused in November 1980 when NUREG-0737 was issued endorsing the Action Plan position for this item.
Licensees now had two contradictory requirements for the same item; one requiring them to cet NRC approval before implementing their programs and the second requiring them to implement their programs before NRC would approve them.
It was unclear what ~ licensees were expected to do.
O 9
In addition, NRR had not provided IE with any definitive acceptance criteria for this action.
Now if NRR doesn't review the revised program and doesn't provide adequate criteria to IE, each IE inspector will have to use his own judgment to. determine the adequacy of each revised program being inspected.
IE has initiated, on its own volition, plans to develop a Temporary Instruction which would provide inspectors some guidance for reviewing these training programs.
IE officials told us, however, that without adequate acceptance criteria developed by NRR, the inspectors will have to rely on whatever commitments, if any, the licensees have made. They stated that without adequate criteria IE will have little basis to evaluate the depth and extent of the licensees' programs, and this could result in a review that verifies that a training program exists in name only.
To attempt more extensive reviews would pit the professional judgments of IE inspectors against the licensees and very possibly NRR on these issues.
Action Item I. A.2.3 required that instructors who teach systems, integrated responses, transients and simulator courses at training centers and facilities are to be enrolled and successfully participating in requalification programs to retain their instructor status.
The requalification programs were to be initiated by May 1, 1980, and the programs were to be submitted to NRR by August 1,1980. The NRR Director's March 28, 1980, letter to all power reactor applicants and licensees, and his April 29, 1980, memorandum to the Commissioners stated that this is to assure that the instructors "... are cognizant of current o'perating history, problems and changes to procedures and administrative limitations."
We found that as of the datt submittals were due, NRR had not determined what constituted an acceptable instructor requalification program. The NRR individual responsible for this action item stated that NRR had not and does not intend to develop long tenn acceptance criteria, but rather intends to rely on future certification by INPO as ~ provided for in the Action Plan.
However, the Action Plan states that pending hRC acceptance of an INPO certification program or the accreditation of training institutions, these instructors must be enrolled.and successfully participating in a requalification program.
Beca'use long term acceptance criteria have not been developed NRC cannot now review or inspect for -
adequacy nor can it reasonably contract the review.out to a national laboratory or contractor until adequate criteria are established.
Action Item I. A.2.3. required that these same instructors demonstrate their competence to NRC by successfully completing a senior reactor operator (SRO) examination. The Action Plan called for applications for 7
the examinations to be submitted not later than August 1,1980, for those instructors who did not already hold an SR0 license.
Although the NRR Director's March 28, 1980, letter and his April 29, 1980, memorandum to the Commissioners clearly intended to include training center instructors, as well as facility instructors, we found that training centers were not infonned of either this requirement or the requalification enrollment requirement mentioned above.
As of the due date for submittals, no infonnation had been received from the training centers.
10 We also identified problems involving application of this requirement to instructors at licensed facilities.-IE inspectcrs.detennined that three instructors, at three. separate facilities, held expired SRO licenses and that these instructors stated they did not intehd to renew their licenses or take the SR0 examination.
Only one of these instructors had been told by NRC, however, that he would not have to take the examination.
According to the responsible NRR official, the rationale for'not making this instructor take the SR0 examination was that the intent of the requirement was to show competency and since the instructor had passed the examination once, that was sufficient evidence of competency.
An NRR official stai.ed that inadequate or non-existent acceptance criteria is not an unusual situation.
Regional officials informed us that without' adequate and specific criteria provided by headquarters, they are forced to establish their own acceptance criteria, using their best professional judgment. This may often result.in inconsistent enforcement and untenable potitions because the professional judgment of various inspectors will differ.
There is considerable controversy over how specific NRR should be in establishing criteria and laying out how the licensees could or should go about meeting that criteria. Regardless, NRC must establish and consistently apply requirement criteria specific enough for licensees to know what is expected of them and for IE to be able to inspect against and enforce.
Need to Establish Adequate Control and Followup of Licensee Actions Certain basic infonnation is needed to manage a compliance-type regulatory program such as the implementation of the Action Plan. This includes a a
clear knowledge of which licensees must comply, which have or have not.
complied, and what should be done about the non-compliance.
In the case of the implementation of the action items, this can be roughly translated into a need for a system to' ensure that licensees are submitting the required documentation on time and a system to follow up on licensee action or inaction. We found many situations in which NRC was getting licensee compliance to the myriad requirements which have been levied.
However, we also found a number of situations where NRR did not have an adequate system to ensure that licensees were submitting documents, or to follow u9 on those who had not submitted them.
Following are several examples in which the responsible individuals did not have the basic infonnation necessary to control and follow up on the action items for which they were responsible.
Action Item I. A.2.1, required licensees to revise their training programs for licensed operators to include specific areas of training and to submit their revised training programs to NRC by August 1,1980. The NRR Director's March 28, 1980& letter transmitted this requirement to
~ he licensees.
t s
.m.
r
e,,
11 O
j Even. though an' embryonic system was put together in the Operator Licensing 1 Branch, NRR, ~ 1n preparation for. handling the submittals, we found that.
as of the due date,';1t' was not working. We.found.that basic procedures were not being followed in'that submittals were merely stacked in a corner and their receipt not recorded. As a result, NRR officials did not know which licensees had submitted the revised programs, or if any had requested more time to comply.
Our analysis shortly after August 1,1980, also showed that at least s,-
five facilities.had not been included.in the list to be used to track ilicensees' submittals and, of those 90 that were listed, only six had submitted revised programs. We found no indication that'any action was taken to follow up on those who had not. submitted programs.
^
Two months.after the due date we again checked on the scatus of this item and were informed that 19 licensees still had not submitted revised Although follow up calls had been made, the responsible programs.
individuals were not encouraged by.the licensees' responses and suggested to their management that follow-up letters be sent.
~ Action Item I. A.2.3 required that certain instructors pass the SRO examination and be enrolled and successfully participating in appropriate requalification training programs. The handling of licensee submittals for these requirements was almost duplicative of the revised training program for operators discussed above.
Again, NRR did not follow their basic procedures in handling submittals.
As of the due date, they.did
~
not know to whom the requirements appl _ied, or who had submitted the appropriate documentation. We found, two months later, that a number of licensees ~ had not complied and it was unclear what NRR would do 'about it.
Action Item II.B.4 stated that NRR required a training program to be developed to " instruct all operating personnel in the use of safety and nonsafety systems to control and mitigate accidents in which the core may be severely damaged". The problem of control and followup for this item stems from a misunderstanding of.who was actually responsible for the implementation of this action item.
As.was noted in the previous-section, the NRR. Director's March 28, 1980, letter to licensees instructed them to submit their programs by August 1,1980, for NRR review. However, the Action Plan states that the licensees should not submit their programs for NRR-review but that IE will inspect them. At any rate, by the end of.0ctober 1980,'NRR officials were unaware of 'any licensee commitment to this training. We found that in late December 1980 NRR and IE were still exchanging memorandums on who is to be responsible for the review
- i of these programs. We-believe that until the question of responsibility 1
s
-is decided, there will be no control over. the implementation of this ;
1
' action ~ item and no follow'up to a'ssure licensees' compliance.
L Many of the~ action l1tems are being implemented and NRC is attempting to control and followup on them.
However, a number of the items appear to
.be getting implemented almost on their own, in spite of NRC's lack' of
[
attention to'them,' or the amount of time NRC takes in getting to them.
A: system for adequate. control 'and follcwp is necessary to ensure appropriate and timely! implementation of all action items, u
y.
L L
~
b n
__u.._-,
=..
12-e c
- Need to Review Licensee'Submittals j
in a More Timely Manner
' A good regulatory program requires timely review of licensees'.submittals and-appropriate feedback by NRC as to the acceptability of the submittals.
Without these, neither NRC nor the111tensee knows if.the licensee has-complied with the requirements. if additional changes are.necessary, or if the licensee should. proceed with implementing the work proposed in the submittal.
If the reviev and feedback ane not timely, the licensee.
mayLhave.to make implementation decisions involving considerable expenditures
- to meet NRC deadlines, without knowing NRC's position on the acceptability of its course of action. Although NRR has made efforts to review submittals '
and.to keep licensees informed. the following' examples highlight two areas where the review was not performed, or not performed in a timely manner, and licensees were not informed of the status of their submittals..
4 i-Action Items I. A.2.3 and I. A.2.1' required submittal of requalification training programs for instructors, and revised training programs for l
licensed operators, respectively.
Licensee programs for both items were 4
to be submitted by' Augus t 1,1980.
Shortly after that date and again more.than two months later we found that none of the programs had been reviewed. The NRR official responsible for these items stated that,.
because of limited manpower, NRR would not be able to review the submittals, but would contract out for their review,' as soon as funds become available and a contractor is selected. The official added that he had no idea when that might occur.
We realize that NRR's review resources are overwhelmed with a consider-able backlog of licensing amendments and other issues to be reviewed.
However, given the importance of action item implementation, we believe '
that NRR should be reviewing these submittals, and keeping licensees informed of their acceptability, in a more timely fashion.
t Need to Establish Adequate Interoffice Coordination Throughout our review, +nt observed that interoffice coordination, especially between NRR and IE, was taking place on a hit-or-miss basis.
In those cases where the responsible official' initiated action, a very coordinated
.e and effective management of the action item resulted.
One example of good coordination involves a training requirement for low
_ power testing, Action Item I.G.I.
The applicant-had to define,' develop and conduct trainingc to increase shift crew capabilities. To determine
_i
that the training was being conducted, the responsible NRR individual
- coordinated with IE.
As a result, IE~1nspectors ob. rved the-low power
_ testing conducted for; training purposes at selected sites and reported.
Ltheir-observations to the. responsible ~1ndividual in NRR to be used in i'
- the' development of the acceptance. criteria for that action item.
w rmw r'~-
9---rw w
s--
a T--
t-
' ~ + +
- r w
M-'
4-we w
-T
- z-w w
t T
-e+--
=W-
13 As -is-shown in the following examples, where the responsible individuals did not take the initiative, regardless of the reason, the offices simply failed to coordinate.
One individual in NRR was responsible for determining if licensees have developed adequate training programs for mitigating degraded core accidents, as required by Action Item II.B.4.
Although he had worked on and reviewed the Action Plan requirements, he was under the impression that his duty, as the responsible individual, ended once the requirements were written.
He felt that further responsibility would rest with IE, as a nonnal operating practice.
He did not believe it was his responsibility to coordinate with IE as to where or when his responsibility ended and IE's began or who, if anyone, had responsibility for the overall implementation of this actior, item.
Anc*,her example involved the NRR Director's March 28, 1980, letter to all power reactor applicants and licensees requiring numerous licensee actions and setting timeframes for those actions.
While NRR considered this a major step in the implementation of the Action Plan, shortly after its issuance some responsible individuals and regional inspectors began getting feedback that some licensees did not consider the letter a requi rement.
Even some IE officials told us they did not believe the letter was a requirement.
It appears that these individuals assumed that everyone would know about this interpretation and so decided that it was not necessary to coordinate with anyone concerning what steps, if any, should be taken. As it turned out, some management officials were not aware of the situation until much later.
A third example involved the requirement in the NRR Director's March 28, 1980, letter to licensees that instructors be enrolled in appropriate requalification programs which were to be initiated by May 1,1980. Over
- oor months after this due date, IE officials informed us that NRR had not coordinated with them concerning the need to inspect against this requirement, and that IE had not initiated any action on its own to inspect against this requirement at operating facilities.
One regional official stated that coordination between NRR and IE has never been very good, and that the early stages of implementing the Action Plan were no exception. He added, however, that there are signs of improving coordination between NRR and IE on the Action Plan.
Another regional official stated that the lack of coordination is often manifested in NRR, on its own, writing generic letters which commit IE to some form of action.
He felt that without IE coordination and agreement, actions which commit IE should not come from NRR but from the EDO.
The subject of coordination in implementing the Action Plan has been discussed in detail in two other 01A reports (see footnote on page 5).
l Need to Report Action Item Status More
. Accurately and Timely l
l The timely reporting of current and correct information in a usable format to-those who need it is critical to coordinating and managing the implementation of the Action Plan, whether the recipient has broad NRC management responsibility or responsibility for a single action item.
i
. - -.. ~
e-
_j4
' We found that no fomal reporting system to track the implementation of' the action items was established until 0HPA at the Chaiman's request, L
. developed a system'and issued its first official quarterly report in
. November 1980.
u i
- Prior to this time, management was not getting timely and correct data.
. For example, the many instances where licensees had.not responded by the due dates or where they had detemined that.they would not respond 9ere not renorted, or not reported on a timely basis, to management.
1 r
The OMPA system includes a current _. status summary prepared by the responsible individual and fowarded to OMPA through management channels.
OMPA does not verify _the input but simply assembles it for the report.
The report is distributed to upper management in NRC as well as all i '
those designated as responsible individuals-for the Action Plan.
i.
p NRC Manual Chapter 0123,. dated May 23, 1980, states that the responsibility for coordinating items and monitoring technical progress relating to NRR items rests' with the Generic Issues Branch of the Division of Safety Technology.
At the time _of our review, however, we were told by an official in that Branch that this branch had performed no analysis of the data or of slippages, or followed up in any way to ensure that the F
items were being implemented. The branch had simply acted as a funnel l
for data from the responsible individuals to OMPA for its report. Although the data may have been reviewed up the management chain, that review was for information rather than analysis.
The following examples point out a number of instances where the infomation provided for the OMPA-system was incorrect or-possibly misleading to management because it was not analyzed.
The status reported in OMPA's-November 1980 report for action item I. A.2.1, Immediate Upgrading of Operator and Senior Operator Training and Qualification,'was that action is completed and there 'are no unresolved issues.
However, we believe that since some of the training programs had not been submitted, as discussed on page 10, the implementation of this item would not be complete until all training programs have been i
received and reviewed by NRC.
This was also true for item II.B.4, Training to Mitigate. Core Damage.
The reported status was that the programs were in effect at all operating.
plants as of August 1,1980, and that reviews were being scheduled. We 4
believe that this may be misleading in that we found that 1) NRR had not
-received or reviewed all the programs and 2) IE and NRR had not agreed on'who is going to perform the reviews.
The status reported for item I.A.2.3, Administration of Training _ Programs',
- which in part involves a requirement that instructors be accredited, was that the. item was on schedule and no issues-were involved. This may be l
misleading because there are no accrediting institutions, and NRC's action item I.A.2.7 which involves accrediting training' institutions'was L
inactive. The. Action Plan also states that pending accreditation of training institutions, NRR will require-that certain training centers L
and facility instructors;successfully complete an SRO examination and
~
-. - -. - ~ - -. -.
- -.-. L,
15 participate in requalification programs. These interim requirements are not addressed in the OMPA tracking system report. We believe that significant interim requirements and any circumstance, such as the inactivity on accrediting institutions, which would likely impact on the schedules should be inc W in the report.
The responsibility for monitoring, coordinating and analyzing technical progress on NUREG-0737 items has recently been given to the Operating Reactors Assessment Branch, NRR, via the December 18, 1980, memorandum
'i of the Director, DOL.
The Chief, ORAB, told us that because the OMPA system is not sufficient for his needs, he is developing his own system based on the tracking system designed under an NRR contract with the Franklin Research Center.
Although he expects difficulty in getting the system operational because of the 5,000 items involved, he believed that the system would be operational by March 1981. He is also coordinating with OMPA to see if the data which will be provided by his system will satisfy the input needed from responsible individuals in NRR for the OMPA system.
Another area where the me;iagement of the program has suffered because of a lack of current data involves the feedback from IE inspections of the licensees' implementation of a required action. With only one exception, we found that no data was fed back directly to the responsible individual.
IE inspectors continue to report the results of their inspections in the normal inspection report format. The inspection reports continue to get their normal distribution, which typically would include NRR but not the individual responsible for the particular action item included in the report.
The only exception we found was a temporary instruction on Item I.A.2.3, which requested that data obtained by the inspectors be forwarded directly to the responsible individual, who was named in the temporary instruction.
At least one region realiz W the value of knowing the current status of action item inspection and took it upon itself to track via computer the work perfonned on each action item and the status of those items. The data is kept and used in the region, awaiting headquarters' inquiries on action item status.
Currently action is underway to establish a computerized tracking system at IE headquarters with input directly from the regional offices.
CONCLUSIONS AND RECOMMENDATIONS Our. review has shown that there have been two distinct stages in the implementation of the TMI Action Plan to date.
Stage 1, which ran from t
the issuance of the Action Plan until about December 1980, can be charac-terized as a time of little coordination, no organization aad a great deal of confus'.on as to how the Action Plan would be implemented. Stage 2 began in about December 1980 and is most notably marked by the Director, 00L's December 12, 1980, memorandum proposing a plan for implementing NUREG-0737.
16 While some progress was made in implementing the Action Plan during Stage 1, our review showed that problems were being experienced which delayed and frustrated implementation.
A significant step has been taken in Stage 2 toward effective and timely implementation of a portion of the Action Plan, i.e.4 the NUREG-0737 requirements on operating plants.
Although we believe the recen't moves in NRR to organize and coordinate the NUREG-0737 requirements are good, they are limited by the level at which they were initiated and their scope of coverage. As a result, we believe additional actions are required to assure an effective, timely, and coordinated agency emphasis or implementing the entire Action Plan. The most significant change we believe is needed, is for the E00 to fonnally assign specific responsibilities to an individual or group for implementation of each major section of the Action Plan. We believe one way to improve the management of the Action Plan's implementation is to establish an Action Plan Steering Committee to coordinate and oversee implementation of the entire Action Plan.
Recommenda tions Our review has shown a need for greater management attention to the implementation of the Action Plan.
Howaver, we do not believe that the existing organizational ~and management structure can provide the attention to the implementation of the Action Plan which we believe is necessary.
As a result, we recommend that:
1.
The EDO move rapidly to improve the management of the impleoenta-tion of the Action Plan and documents, such as NUREG-0737, which resulted from it. This should include:
clearly assigning and documenting the responsibilities and a.
authority for implementing the Action Plan; and b.
providing policies, guidance and priorities'necessary to carry out those responsibilities.
2.
The EDO assure that the problems identified in this report relating to specific action items are or have been corrected and that similar problems are avoided in implementing the remainder of the Action Plan.
AGENCY COMMENTS On June 3, 1981, the EDO provided comments on a draft copy of this report (See Appendix II). Generally, the EDO stated that the report
" accurately reflects a number of the difficulties experienced" during the time period covered by our audit.
He also noted, however, that since completion of the audit, a number of management changes had been undertaken which have substantially brought reporting, coordination and licensee interaction ~into better control. These changes have been.
consolidated into a single document which the ED0 distributed to office directors on June 3,1981, (See Enclosure 1 to ED0's comments).
17 In regard to the problems we noted on specific Action Plan items, the ED0's canments generally acknowledged that problems exist but that actions are completed or underway to correct the problems and avoid them in the future. These actions include: (1) establishing NRR Lead Project Managers for each Action Plan implementation item and processing all Safety Evaluation Reports through the Operating Reactors Assessment Branch, NRR, to assure consistency of application of requirements; (2)
NRR and MPA working together to develop a system to track the status of each licensee action and identify instances where licensee submittals are not being reviewed in a timely manner; and (3) including IE inspection information in the NRR tracking system so that all information on each item is catalogued in one place.
The actions taken and proposed by the EDO should resolve the problems
~
identified in this report, if properly implemented. We plan to follow-up on the implementation of the TMI Action Plan and the actions taken in response to this report in about four months.
e 9
i B
Appendix I Action Items In Phase Two Sample Decision Group A Item Short Title Action Items Involved IA1.1 Shift Technical Advisor 9
I Al.3 Shift Manning 4
IA2.l(2)
Immediate Upgrade of R0 & SR0 6
i Training and Qualifications
.IA2.3 Administration of Training 4
Programs - Instructors IA3.1 Revised Scope & Criteria 4
for Licensing Exams IC.2 Shift and Relief Turnover Procedures 3
IC.3 Shif t Supervisors Responsibility 3
IC.5 Procedures for Feedback of 4
Operating Experience IG.1 Training Requirements 3
IIB.4 Training for Mitigating Core Damage 4
IIK.2 Commission Orders on B&W' Plants 4
IIAI.)
Upgrade Emergency Preparedness 4
Decision Group B.
IA2.5 Plant Drills 4
IA4.1 Initial Simulator Improvement 2
A4.2 Long Term Training Simulator Upgrade 4
11103.1 Radiation Protection Plans 11 Decision Group C IA2.6(1)
Long Term Upgrading of 10 Training & Qualifications IA3.2 Operator Licensing Program Changes 3
IA3.4 Licensing of Additional Operations 1
Personnel 181.1 Organization & Management 10 Long Term Improvements IIIA2.1 Amend 10 CFR 50 & 10 CFR 50 Appendix E 2 l
IIIA2.2 Development of Guidance & Criteria 1
Decision Group D IA3.5 Establish Statement of 1
Understanding with INP0 & DOE i
gS3 8 8 C g, UNITED STATES
) 4,( 'k
,,4 NUCLEAR REGULATORY COMMISSION
,y g
WASHINGTON, D. C. 20555 Appendix II 7-f
%*..% A /
JUN 0 31981 MEMORANDUM FOR:
James J. Cummings, Director Office of Inspector and Auditor FROM:
Wil?iam J. Dircks Executive Director for Operations
SUBJECT:
COMMENTS ON OIA DRAFT REPORT In response to your request of April 9, we have reviewed your draft report,
" Audit of NRR's Implementation of the TMI Action Plan."
We note that the time period audited covered June 1980 through December In general, we believe your report accurately reflects a number 1980.
of the difficulties ' experienced during that time period by the NRC in implementing the TMI Action Plan. Although your report's title suggests that you audited only NRR's efforts, your report is actually an audit We have comented assuming your intentions were of overall NRC efforts.
NRC generic in nature and recomend that the title be changed.
Since the completion of the audit, a number of management changes have been undertaken which have substantially brought reporting, coordination and licensee interaction into better control. Your report has caused the staff, however, to review and consolidate the changes into a single l
document.
Your specific recommendations are responded to below:
Recommendation 1: The EDO move rapidly to improve the management of the implementation of the Action Plan and documents, such This should as NUREG-0737, which resulted from it.
include:
clearly assign and document the responsibilities a.
and authority for implementing the Action Plan.
Comment Responsibility for each of the Action Plan items is now' clearly assigned in the Action Plan Tracking System; transition from development to imple-mentation is also documented therein.
Appropriate authority for necessary-action is vested in the appropriate Office Director.
g a
e t
- ~.....
J.J. Cummings.
b.
provide policy guidance and priorities' necessary to carry out these responsibilities.
Comment Guidance to offices has been reviewed and summarized in the memo attached 4
as Enclosure 1.
A principle issue is the use of the Action Plan Tracking System to document shifts of responsibility from one office to another.
Recommendation 2:
The EDO assure that the problems identified in this report relating to specific action items are or have been corrected and that similar problems are avoided in implementing the remainder of the Action Plan.
Comment is a general response to specified concerns noted in the OIA report.
It is anticipated that management controls now in effect will preclude further probi' ems.
~
[
[
William J. Dircks Executive Director for Operations
Enclosures:
- 1. Memo to Office Directors with attachment
- 2. Response to Specific OIA Concerns 1
9 l
I
e.a at cw UNITED STATES ff NUCLEAR REGULATORY COMMISSION y y 3.y y g WASHINGTON D. C. 20555 g
g )
- ,, e
,g',
/
JUN 0 31981 MEMORANDUM FOR:
Office' Directors FROM:-
William J. Dircks Executive Director for Operations
SUBJECT:
MANAGEMENT OF THE TMI ACTION PLAN The purpose of this memorandum is to consolidate the guidance on staff activities related to management of the TMI Action Plan (NUREG-0660) in response to Recom-mendation 1.b of the Office of Inspector and Auditor's Audit of NRR's Implementa-tion of the TMI Action Plan, dated April 9,1981.
The Action Plan (NUREG-0660) approved by the Comission established priorities, requirements, and schedules for the staff as well as for applicants and licensees.
The Comission in approving NUREG-0737 clarified and, to some extent, amended these requirements and schedules.
NUREG-0718 " Licensing Requirements for ?ending Appli-cations for Construction Permits and Manufacturing License", further clarified the Office Directors should follow role of the Action Plan in the licensing process.
the priorities and schedules established in the Comission-approved NUREG's cited above.
The Comission is currently considering conversion of selected items of the Action Plan into rulemaking, specifically NUREG-0718 (for pending CP's and Offshore Power applications) and NUREG-0737 (both for OL applications and for operating reactors)
When such rules become final, the schedules contained therein cannot be modified except by further rulemaking or by exemption. Adherence to schedules for these rules is especially critical.
Once the regulatory requirements are established from the Action Plan, they must be i
Therefore,(fortracking1) thos integrated into the Commission regulations and practices.
purposes, the Action Plan tasks should be considered in two phase mental), and (2) those tasks which have matured to a stage requiring licensee and applicant implementation.
Status of tasks in the developmental phase will be tracked solely in the Action Plan Tracking System (APTS) which is managed by MPA, with cooperation and support from The APTS, which is updated quarterly, is the formal all of the Program Offices.
system of tracking status, measuring progress, documenting responsibilities, flagging problems for management attention in the developmental stage, and documenting trans-fer of requirements to the cognizant office for implementation.
4
n_.
a
's.
Office Directors 2
Status of tasks in the implementation phase will be reported in your office systems designed to track case-by-case progress (e.g., IE-TMI Tracking System i
in IE and the Project Action Tracking System, PATS, in NRR), with a brief Requirements being implemented in Construction sumary(entered into APTS.CP) and Operating License (OL) reviews will be part of Pemit Review Plan (SRP) and normal casework activities and will not be specifically tracked.
The following actions will be taken in regard to management of the Action Plan:
)
r 1.
Office Directors will appoint an Action Plan Coordinator to serve as contact for Action Plan management.
It should be the specific responsi-bility of this individual to coordinate shifts of responsibility for actions internally within your office, or between offices, and to coor-dinate and exercise quality control on data provided to MPA.
Please infom MPA of the name, mail stop, and extension of this individual.
Changes in the office responsible for an Action Plan item will be documented 2.
by memorandum to MPA (copies to program office directors and ELD).
Reassign-ments within an office should also be reported to MPA.
Close out of all compieted developmental Action Plan items will be accom-3.
plished by a memorandum to the CD0 (copies to program office directors, ELD, and MPA).
Include a sumary of work accomplished and a statement clearly stating the nature of follow-up work and to whom the work is assigned and the priority which should be given to it.
4.
Office Directors will assure that major changes (which specifically includes Action Plan items incorporated into rules) to the Action Plan--substantive or schedular--have prior Comission approval.
Proposals for change should be fully justified in a Comission papar (Attachment 1 is a sample fomat for justifying a major modification). Minor changes should be brought to the attention of the EDO at the discretion of the responsible Office Director.
MPA will convene a meeting of Office Action Plan Coordinators quarterly--at 5.
a minimum semi-annually--to coincide with publication of the APTS report to review status of items and to verify that an orderly transfer of items from developmental phase to implementation has been made.
Questions of priority should be addressed at this meeting.
A sumary will be provided EDO by MPA, to include recomendations for ED0 action where necessary.
William J. Dircks Executive Director for Operations
Attachment:
Justification for Change in TMI Action Plan
n
. :s!
s
/
,T
+
( !
w, s
su L
t ta t
S :
y t t ni e r r o i
ri u r C P 1
e s
NAL P
e N
n O
o I
t T
s C
e A
l i
I M
M 8
T N
I EG N
AHC RO F
l i0 I
TAC I
F I
T S
U J
e i
ta D
- c s
i t
4
~
i T
n
,e e
s o
v l
ugt' i
i u
t e
d e
a i,
t e
e'-
eh s s c
c v
l p
u e
i h
i t
o c
d 4
e f
j b
c c
O e
S p
S -
e i
h t
o 0
b 0
c 0
c s
j e,6 se s' S
su 6
O 6
S 6
j d
l 0-d 6
6 0
d U
u
~-
e e
e e
d C
s d
s G
s
' G >,
e E
i b
u i
E i
E R
v R
v h
mR v
l e
c U
e O
e c
U i
R S
.N R
n s
I R
f l
I m
e S
6 t
2 3
4 I
1
r
.e<
',- ['-
cy
'.k. '. -
.7 l
s-L t
m a
C E
e Ou t
QJ
-n.
A W W W es 4
a a a a www www g e e e
a)
O O O O L
- O t "O V "O 't3 W
C C C CC C 3
mmm o e ao mW hbb bbb u
- c. c. c.
c c. c.
L cr 3
0 3
m
- O C8 G3 m8 I I I I I cg 4O D
OmN OmN N ~ tD CO CO CO CQ CD.
4 C
W
' h p >=
>= >= >-
O Q.
s,.
0 O
A.6 u. L 6WW
- r=
+J U
's W
O V
e V
V 0
a:C GD IJ M
CY.
t*=
or=
m D
C)
>=a
>g;
=.
U-L m
+J Cg C
3 W
C m
8.=
O U
g
'm L
c
.ht O
.. O C3 0 4
3 m
O h CD e:C O CC O
m C-
.m C)
O 3
s0
-O W
m ar=
c cf m
a V
r==
l e'
a::
- 6 St N D
O-C L >
W a
4 O
e CJ a
t.2 -
m O
4 C.
L
.4 e4
r
m r==
'W I"L '
e==
ud Q.'
O.
L.
D.
S3 D.
.O E
K
'Cc a.
.- =-
ce ta y-(,
- ?.
~.,-
e' e
e F
b M
.O e==
^
e 6-e
>[-
.y]
e
e w\\'
ENCLOSURE 2
' RESPONSE TO SPECIFIC OIA CONCERNS
-s
-Need for Greater Management Attention to Action Plan Implementation
~
In response to the OIA Report, the EDO office has developed a consolidated set of policies and procedures for use by the staff in managing the action plan as discussed in Enclosure 1 to this memorandum.
~
Recr nizing the need for management of NRR's portion of the THI Action Plan, the Director of HRR in a January 7, 1981 memorandum to the Division Directors established guidelines for managing the action plan.
The guide-lines were aimed at assuring completica of NRR's portion of the action plan in accordance with the established purpose, scope and schedules.
The guid21ines also provided a system for early identification of deviations from the plan. They established:
(1) a single focus for
< accomplishing the action plan; (2) reporting requirements and responsi-bilities; (3) mechanisms for periodic review of the status end progress; and (4) procedures for developing resource needs.
Need to Develop Adequate Requirement Criteria and Consistently Apply Them There is no question that criteria should be clear and consistently applied.
Implementation of Action Plan requirements -is basically no different from implementation of other requirements that have been previously implemented.
Once a basic requiremeAt is established, it is necessary to provide criteria and guidance'(perhaps a Regult. tory Guide) on acceptable methods to implement the requirements. The guidelines or guidance have changed and have bEen updated and expanded in tb Et, and we would expect to see the same type of development with TMI
- s An plan items.
The purpose of updating is not and has not been to z N !e a " moving target'," but rather ways of accomplishing the same to promulgate different and perh w r # M tted that updating of this However, it ny.,c i basic requirement.
kind is of ten perceived.by both 1.sustry atd individual NRC reviewers as providing a moving target. The answer, of cpurse, is to manage the reviews to avoid inappropriate ratcheting of requirements.
We believe that active communications paths are in effect now to feedIn back questions from various sources including resident 1;d.pectors.
addition to providing'an answer to a particular question, t5e communication of the question itself has been valuable to indicate potential areas where additional criteria may be needed.
To date, OIE has issued seven Temporary Instructions as guidance to inspectors performing inspection of Tiil Action Plan items.
Each of these-Temporary Instructions provides guidance,on inspection of several Action Plan requirements.
4
_____._____._____E
O S
In order to ensure consistency in the application of criteria, NRR Lead Project Managers have been established for each Action Plan implementation item, and a central branch (Operating Reactors Assessment Branch, OL) has Ond of the been established through which all SERs will be processed.
primary purposes of these groups.is to ensure a consistency in application of requirements.
Certain Action Plan items were used to illustrate the need to' develop adequate requirement criteria and consistently apply them.
The report is correct in identifying that work is needed in these areas. To accomplish this work, professionals have been assigned as task managers for each of the tasks in the Action Plan including those identified in the Draft Report, and progress has been made towards meeting objectives.
Specifically, Task I. A.1.1 segarding shift technical advisor (STA) requires a sigaificant amount of further study and industry feedback prior to formalizing prescriptive guide-
~
lines. The staff is receiving this information from licensees and studies underway.
Task I.A.2.3 regarding accreditation and evaluation of
- a. s training centers is in the development phase with emphasis being placed on the formulation of acceptance criteria and of methods to assure overall adequacy in responding to training requirements.
Task II.B.4 on training to mitigate core damage,is in the review process.
Further, as reactor operators and senior reactor operators are undergoing reexamination, questions are always asked regarding mitigation of core damage thus emphasizing its importance to operators.
Need to Establish Adeqiia'te Control and Followup of Licensee Actions and Need to Report Action Plan Item Status More Accurately and Timely We have been slow in establishing systems to establish adequate control and followup of licensee actions. The general problem has been that a system did not exist that could enable tracking the implementation of Action Plan items such that the status of each licensee action could reasonably be tracked. When each licensee action is counted, the total number of items being tracked is in excess of 5,000.
NRR and OMPA have worked together closely to implement a tracking system developed by Franklin Research Center and presently being used by the Division of Licensing /NRR to track certair technical assistance work.
This system has now been incorporated into OMPA facilities and initial data input is continuing on a priority basis. The initial input into the system is time-consuming with about 15 items of information being inputted for each of the over 5000 items being tracked. The purpose of the system is, of course, to indicate the status of each licensee submittal as it is being reviewed by NRR. There are over 20 different status steps that can be reflected in the system.
Although the initial establishment of the system and input into the system is costly in terms of resour ces and time, it is believed that in t*1e long run the tracking system will provide an excellent management and audit tool.
It will be a simple system to update, and it will allrew adequate tracking of TMI implementation actions while other high priority actions are also being completed.
r c
i.
It should be pointed out that OIE also has a tracking system to track inspection of TMI related items.
The OIE inspection is included as one
- of the inputs to the NRR system so 'that all rermining NRC actions on an implementation items are cataloged in one place.
i f
Need to Review Licensee Submittals in a ISrely Timely Mr.nner The concern noted is acknowledged, and we believe that steps are being The taken to imp nve the timeliness of reviews of licensee submittals.
tracking systr.m discussed previously will be able to identify instances Identifi-where submittals are not being reviewed in a timely manner.
cation of these areas in the past has been a problem because of the Implementation of TMI Action Plan items continues number of submittals.
to be a high NRC priority and will be given the attention and resources necessary to complete the NRC actions required based on its priority and the priority of other requirements awaiting NRC action.
Need to Establish Adequate Inter-Office' Coordination We think that significant steps have been taken to establish inter-6ffice coordinetion of THI Action Plan items. OIE has been assigned responsibility for implementation of certain Action Plan items in addition to the normal OIE inspection responsibilities. These responsibilities have been identified in the D.G. Eisenhut December 18, 1980 memorandum on this subject.
Additionally,' communication has been active between NRR and OIE on these matters.
As an additional check, the NRR tracking system reflects the branches / offices responsible for review of each item.
As the status is tracked, areas of unsatisfactory progress will be readily identified and will be resolved with the responsible branch / office.
e e
4