ML20033F106
| ML20033F106 | |
| Person / Time | |
|---|---|
| Issue date: | 02/27/1990 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Pate Z INSTITUTE OF NUCLEAR POWER OPERATIONS |
| References | |
| NUDOCS 9003160025 | |
| Download: ML20033F106 (9) | |
Text
.
y February 27, 1990 e
si Mr. Zack T. Pate, President Institute of Nuclear Power Operations Suite 1500 1100 Circle 75 Parkway Atlanta, GA 30339-3064
Dear Mr. Pate:
This letter documents the coordination meeting held between INPO and the NRC on December 11, 1989. The meeting was very productive and served to promote a better working relationship between the two organizations in the future. The enclosed meeting minutes document the discussions and will be placed in the NRC public document room in accordance with the INP0/NRC-Memorandum of Agreement dated October 20, 1988. The following is a summary of the agreements for follow up actions made during the meeting:
NRC agreed to brief INP0 on the current status of Human Performance and Management research projects.
INP0 agreed to forward long range schedules of utility visits with their routine updates of quarterly schedules.
NRC agreed to develop principles for guiding insepctors in the evaluation of management related issues.
INP0 was developing similar guidance for their evaluators and offered to provide input to the NRC guidance.
NRC agreed to reemphasize guidance to the staff in utilizing INP0 ratings, findings and generic guidance to utilities as part of the NRC regulatory program.
Please feel.freo to call me if you have any questions or comments concerning this report.
Sincerely, Original fBn M
9003160025 900227 James M. Taylor Executive Director PDR ORG EPSINPD 1 PNU I, for Operations
Enclosure:
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W. Kindley, INPO Distribution:-
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1 MEETING MINUTES On December 11, 1989, members of the NRC staff met with members of the Institute of Huclear Power Operations (INPO) at the NRC office-in Rockville, Maryland. The purpose of the meeting was to provide a forum for the exchange of information as described in the INP0/NRC Memorandum of Agreement dated October 20, 1988. A similar meeting last took place on August 15, 1988. A i
list of the meeting attendees is provided as Attachment 1 to this report.. The
-following topics were discussed:
1.
WorldAssociationforNuclearOperations(WANO)
INPO updated the NRC on WANO activities since the last INP0/NRC meeting.
WANO was established after the Chernobyl event to facilitate the exchange of nuclear operating experience between countries. To date all countries with operating nuclear plants-have joined WANO. Mr. Z. Pate, CEO INPO, is a member of the WANO Governing B,oard.
Personnel exchanges of 1-2 weeks' duration have occurred between countries to provide a familiarization with the different methods of managing commercial nuclear power. A schedule of planned exchanges was provided by INPO to the NRC-and is included as to this report. Additionally, four centers have been established throughout the world to coordinate promulgation of event information. Both the NRC and INPO shared' concerns that the event infor-mation promulgated by WAN0 be accurate and consistent with data provided i
I by other sources.
2.
INP0 Training Program Accreditation and Renewal l-INP0 reviewed the Training Program accreditation of 11 areas and the periodic renewal of accreditation every four years.
INPO also discussed recent findings from evaluation and assist visits to sites. To date, only three sites have had. training problems; all with the implementation of accredited programs.
INP0 reiterated to the NRC that placing a utility's training program on' probation is considered to be a normal corrective action mechanism and not indicative of a significant breakdown of the licensee's overall training program.
INP0 will withdraw accreditation if significant breakdowns in the training program are discovered and the NRC I
1 will be informed by either the licensee or INP0 when withdrawal occurs.
The NRC expressed concern that the 120-day probationary period may inap-propriately rearrange the licensee's priorities for safety significant activities.
INPO stated that the probationary period was not fixed and is negotiated with the licensee based on safet; concerns.
INPO further stated that they did not plan to extend the probationary period when, at the last minute, the licensee decided they were not ready for reevaluation.
The NRC agreed with'this basic approach.
A discussion of the differences between the INP0 operator training accreditation process and the NRC requalification program inspections also took place. Because the INP0 accreditation process concentrates on overall program competency and the NRC requalification exam inspection evaluates specific tasks by selected operators and crews, both the NRC and INP0 agreed that an accredited training program could be declared
i E unsatisfactory during an NRC requalification exam inspection if the program.were poorly implemented.
3.
Status of Shift Supervisor Project INPO reviewed the status of their efforts to develop a training program for Shift Supervisors which emphasizes management, conservative safety decision-making, leadership and team building. This project was initiated af ter a request by NUMARC and recognizes additional pressures placed on shift supervisors that go beyond their training as licensed senior reactor INPO has performed a needs and task analysis of the shift operators.
supervisor position and will keep the NRC informed on the status of the project. When developed, this project may become part of the accreditation process separate from the SR0 qualification area.
4.
General NRC Team Inspection Findings The NRC provided the following summary of team inspection findings:
Maintenance Team Inspections (MTIs) are complete at 38 sites and are scheduled for completion at all sites by April 1991.
No major safety issues have been identified during the MTIs, but weaknesses with program development and implementation were found at some sites. The NRC concluded that maintenance at nuclear utilities has significantly improved since NRC and industry attention has recently been increased in this area.
Safety System Functional Inspections (SSFIs) and Safety System Outage andModificationInspections(SSOMIs)continuetobeperformedby regions and headquarters.
Inspection results have identified the need for design bases reconstitution and better procurement controls.
Emergency Operating Procedure (EOP) Inspections have continued to identify problems with licensee verification and validation programs and human factor deficiencies. Training of E0Ps has been generally good at the stations.
INP0 noted that their efforts with E0Ps appeared to be complementing the NRC inspection efforts.
5.
Maintenance Rule The NRC discussed the content of the revised maintenance policy statement that was published on December 8, 1989.
Final rulemaking in the maintenance area will be held in abeyance for 18 months to monitor industry initiatives and progress. At the end of this 18 month period, the NRC will reassess the need for rulemaking in this area.
INP0 is developing a maintenance standard that will be made available to the public. The NRC will be offered the opportunity to review the proposed standard and participate in an INPO maintenance star.dard workshop.
INP0 is also developing a maintenance improvement plan for industry use.
INP0 does not intend to accredit utility maintenance programs.
+
- 3 6.
Performance Indicators The NRC discussed the contents of NkC Announcement 200, " Revised Guidance on the Use of Performance Indicators", dated November 28 1989. Announce-ment 200outlinesthevalueandlimitationsoftheuseofperformance indicators (PIs) and provides specific direction to employees to accom-plish the NRC objective of ensuring operational safety at nuclear plants.
Both the NRC and INPO expressed concerns that misuse of PIs by public utility comissions and the financial comunity may not promote nuclear safety. The apparent flattening in performance indicator data compiled by the NRC Office for Analysis and Evaluation of Operational Data (AE00) for 1988 thru the second quarter of 1989 was discussed (Attachment 3). The NRC was concerned that recent examination of INPO Nuclear Plant Reliability Data System (NPRDS) Failure Cause Codes for maintenance effectiveness indicator (MEI) review of selected components dominating outages indicate utilities use vague causes such as wearout or random equipment failure in many instances.
INP0 explained that NPRDS was not designed for MEl use, but anticipated utility enhancements in NPRDS root cause analysis should improve the data base.
INP0 further stated that even with the enhancements, the NPRDS data base would probably not be adequate to evaluate a maintenance program because further root cause analysis is required.
7.
Management and Human Performance Research The NRC provided a summary of ongoing research projects in the area of management and human performance research. These efforts included field evaluation of nuclear and non-nuclear power plants, development of organi-zational performance indicators and various correlation studies of 10 CFR 50.72 reports and Licensee Event Reports with organizational characteris-tics, The NRC agreed to provide a detailed briefing to INP0 on the status of these projects.
8.
Public Actions by INPD Regarding Licensee Performance The NRC questioned INP0 about public disclosures of INP0 evaluation findings by licensees and whether they intended to increase their public INP0 stated that their role continues to be to play behind the exposure.
scenes to urge the nuclear industry to higher levels of excellence and that they did not intend to deal directly with the public.
INPO is encouraging utilities to treat the INPO reports as internal sources for corrective action.
The reports should not be published.
9.
Scheduling of Inspections and Evaluations b
Both INP0 and the NRC were concerned that last-minute changes in the INPO l
_ evaluation and NRC inspection schedules occasionally resulted in situations where both NRC and INP0 teams planned to assess a utility during the same period. This creates an excessive burden on the utility l
l to support both teams and may distract management from ensuring plant safety. The NRC and INPO agreed that some last-minute scheduling changes were inevitable and that early communication of proposed changes was the best way to properly coordinate team visits.
In order to improve scheduling coordination, INP0 agreed to forward a copy of their long range schedule with the routine update to their quarterly schedule.
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10.
Inspector /Ev'aluator Exchanges l
INPO stated that recent accompaniments by their evaluators on NRC inspections have provided valuable insights and training on NRC inspection methodology. The NRC recommended that a future accompaniment be made
-during a trial inspection for development of a new inspection technique so INPO could view this aspect of the inspection process.
- 11. Coordination of Generic Communications The NRC stated that feedback from the industry indicates that redundancy of generic communications between INPO and the NRC is a problem although 1
no quantified data or examples of the problem have been identified.
In some cases the NRC is required to put a regulatory stamp on an issue even though INP0 may already have issued generic guidance.
In this case, both the NRC and INPO agreed that the redundant information was preferable to alternatives such as the NRC following up on the INPO guidance.
The key.
to successful coerdination is to continue and expand communications between cognizant INP0 and NRC groups responsible for issuing generic guidance.
- 12. Differing Signals to Licensees by NRC and INPO There have been instance where NRC assessments of licensee performance as reflected in SALP scores and inspection report conclusions have differed from INP0 evaluations and rankings.
Some differences should be expected since INPO and NRC assessments are independent, but both INP0 and the NRC were concerned that inconsistent signals to the utilities could result in a poor response to an identified problem. Based on their informal review of these differences, INPO stated that the lower assessment is most often the best indicator of future utility performance. As a result, INP0 has been recommending that utilities take corrective actions based on the most critical report, whether issued by INP0 or the NRC.
- 13. Regulating to Excellence INP0 summarized part of the 1986 Sillin Report which concluded that achiev-ing excellence was the responsibility of utility line management.
Neither INPO nor the NRC could regulate a utility to excellent performance and it was important for both the NRC and INPO to operate in their intended roles: INPO to assist the utilities to achieve excellence and the NRC as an industry regulator. The NRC stated that it would continue to pursue regulation of activities detennined to affect nuclear safety and not be constrained to strictly compliance inspections.
INP0 did not take issue with the NRC approach, but offered some non-specific examples where the NRC was recommending solutions to licensee problems and methods of managing programs to accomplish safety objectives. The NRC agreed that the roles of INP0 and the NRC should be kept separate and that management should reiterate policies to prevent the NRC employees from providing
" consultant" services to licensees on management issues.
INPO is developing a set of principles for their evaluators to prevent usurping utility management's prerogative to run the plant and agreed to forward a copy to the NRC when complete.
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-14.
Activities of NRC Field Personnel-INP0 raised concerns that NRC field personnel are following up on INP0 findings and generic guidance and placing pressure on utilities to tell 1
them the results of INPO evaluations and the overall ratings in each area.
INPO stated that they would prefer future requests for INPO information be directed to them and they would coordinate release of the information with the industry. The NRC stated that further guidance to field offices would be issued. The NRC reiterated a previous request that either INPO or the utility inform the cognizant NRC Regional office if ratings of 4 or 5 were received by a licensee.
INP0 stated that they were encouraging the utilities to notify the NRC when a 4 rating was received and that INP0 would notify the NRC when a 5 rating was issued.
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a ATTACHMENT 1 Attendees INP0/NRC Coordination Meating-December 11, 1989 NRC J. M. Taylor Executive Director for Operations H. L. Thompson Deputy Executive Director for Materials Safety.
Safeguards and Operational Support T. E. Murley Director, Office of Nuclear Reactor Regulations J. H. Sniezek Deputy Director, Office of Nuclear Reactor Regulations i
E. S. Beckjord Director, Office of Nuclear Regulatory Research i
L. J. Chandler Assistant General Counsel W. T. Russell Regional Administrator, Region I S. D. Ebneter Regional Administrator, Region II J
E. L. Jordan Director, Office of Analysis and Evaluation of i
Operational Data J. E. Dyer Office of the Executive Director for Operations j
INPO-L Z. T. Pate President and CEO L
W. R. Kindley Vice President, Government Relations K. A. Strahm Group Vice President, Evaluation and Assistance j
T. J. Sullivan Group Vice President, Analysis and Engineering l-W. J. Coakley Group Vice President, Training and Education A. C. Tollison Vice President and Director, Plant Operations Division J. F. Groth Director, Analysis Division y
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ATTACHMENT 2 November 29. 1989 Schedule for WAN0 AC Exchan9e Visits
-a (To Support WAN0 AC Goal Number 5. Long Ters Objective 1)
Auaust. 1989 - December. 1990 VISIT TO VISIT TO AC SITE /MC SITE ATLANTA CENTER MOSCOW CENTER 11&ly.1 Catawba /Zaporozhye 18 October '89-26 August '89-both visits complete-01 November '89 10 September '89 I
Prairie Island /
07-18 December '89 Complete visit to Prairie Leningrad 09-16 September '89 Island scheduled
' Ontario Hydro /
14-21 January '90 Complete visit ~to Ontario Smolensk 11-21 November '89 Hydro scheduled Canadian PHWR/ Kola 02 or 23 April '90 12 June '90 dates proposed to i
Moscow Center 11/8/89 TMI/Chernobyl 23 or 30 April '90 26 March '90 or dates proposed to 2 April '90 Moscow Center 10/6/89-2nd memo 11/7/89 Philadelphia Electric / May/ June '90 August / September '90 phone call from G.
Paks Hunger 11/20/89-l working on setting dates Byron /Rovno May '90 Complete 27 October '89-06 November '89 Susquehanna/Kursk 04 June '90 23 April '90 dates proposed to Moscow Center 11/29/89 Palisades /Kozloduy 18 June '90 07 or 14 May '90 dates proposed to Moscow Center 11/20/89 Carolina P&L/
July '90 September '90 letter to S. Smith Kalinin 9/21/89 Grand Gulf /Dukovany 06 or 13 August '90 04 or 11 June '90 dates proposed to Moscow Center 11/17/89 Laguna Verde /Juragua September '90 November '90 acceptance from J. Eibenschutz 10/9/89
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