ML20055H688

Responds to Re Relationship of Mgt & Organization Effectiveness to Nuclear Power Plant Safety Performance. Appreciates Observations Re NRC Diagnostic Evaluation & Special Team Insp Repts

ML20055H688
Person / Time
Issue date:	07/16/1990
From:	Carr K NRC COMMISSION (OCM)
To:	Wagner R AFFILIATION NOT ASSIGNED
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ML20055H689	List: ML20055H688 ML20055H692
References
NUDOCS 9007270164
Download: ML20055H688 (5)

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UNITED STATES

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i',,e NUCLEAR REGULATORY COMMISSION

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.,E WASHINGTON, D. C, l'0555 a

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July 16,1990 CHAIRMAN Mr. Russell Wagner 92 Beacon Drive Harrisburg, Pennsylvania 17112

Dear Mr. Wagner:

Thank you for your letter of May 19, 1990, regarding the relation-ship of management and organization effectiveness to nuclear power plant safety performance.

We found your comments both thoughtful and candid, and especially appreciated your observations regarding the Nuclear Regulatory Commission (NRC) Diagnostic Evaluation and Special Team inspection reports.

We agree with many of your comments.

NRC involvement in the assessment of plant performance in relation to nuclear plant inanagement has steadily increased in the past 10 years.

We have concluded that if there is inadequate management direction, control, and oversight of plant activities, such as operations, maintenance, engineering support, and safety assess-ment, it will have a negative effect on both equipment and human reliability.

In this regard, we have noted that the better performing plants usually have strong corporate and plant manage-ment.

A recent Commission policy statement (copy enclosed) on the corduct of nuclear plant operations also reflects the Commission's view that the working environment within the plant organization has a direct relationship to safety.

A number of programs have been implemented to assess licensee management and organizational ef f ectiveness.

The NRC's Diagnostic Evaluation and Systematic Assessment of Licensee Performance Programs both have as a primary objective the evaluation of licensee. management and organizational environment as it relates to plant safety performance.

Although we are concerned about the possible misuse of our evaluation reports, we believe that our reports have been candid about documenting management weaknesses that our teams have been able to identify.

Further, we ao provide our evaluation findings to the public where such management weaknesses have an important bearing on the identified pcrformance issues.

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9007270164 900716 PDR COMM5 NRCC CORRESPONDENCE PDC DP1 i

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Mr. Russell Wagner i p

It should be emphasized that t;ie NRC cannot " solve" the management issues through regulatory rer,uirements and procedures.

Ultimate-ly, management.effectivenest in ensuring safe operations is the -

responsibility of each liceAsee.

Sincerely, 1

Kenneth M. Carr

Enclosure:

As Stated r

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+

POLICY STATEMENTS i

eon euntos a i=rosmatioes contact:

March 1985 and March 1967. The sta..'s quahhcation of nuclear power plant Ten W Roe. O!hce of Nuclear Re rter esolvation cormsted of participatirig as renonnel Preuzenon U S Nuclear Recuhitory obsersers when utthties trammg Cam n:ss.on. Washmeton. DC 0555.

programs were unoer evaluation by an Amendments to Pohey Statement Telephone f 30114921004 INPO accreditation team. observmg (1)The Commeon recognises that j

sumetsesewtany instonesat:0ec accreciting board actmties and site the Notenal Academy for Nuclear l

Background

inspections as desenbed in SECY Training has expanded its accreditation t

The Ldent Weste Pohey Act tP b.1.

201.8 The staff also developed entena program by estabhahms en eles enth and procedures that were used to assess f'rogram for contmuing trommg of 9*.4:5). sertmn 306 directed the M"0"hN Nuclear Reguietory Commission (NRC) w hether accridated utthly trusnmg programs incude fa e critical siements.

(2) The NRC staff w;ll expand the to promulgatt regulations or other regulatory guidance for the traming and The review critens have been pubbshed methods by which it morutors the as "Trattung Review Centene and mdustry's trammg program and its qualifications of civihari nuclear power Procedures" (NUREG-12:01.* The results by performms post accreditation plant operators supervisors. techmcians critens were apphed by the staffin reviews at selected sites.

and other appropnote operotmg auditing traming programs at eight (3)The secuon of the 1ges policy j

personnel (includmg instructional utshties with accredited traming statement entitled " Enforcement Policy" i

requirements, simulator trainmg programs.The results of these post.

le withdrewn. The NRC will conduct requirements, and requirements for accreditation reviews are sneluded in inspections as deemed necessary and requahfication examinations and the "Armuel Status Report on take appropnete enforcement action in operating testsl. On March 20.1985. the implementation of the Commission accordance with the Commtssion's NRC pubbshed a pobey statement which Pohey btstement on Trammg and enforcement pohey in to Cnt Part 2.

a responsive to the mandate of the Quahfication(SECY-46-119) 8 and Appendit C. when regulatory Nuclear Weste Pobey Act for regulatory "The : Year Evaluation on requirements are not met.

guidance on traming and quehfica tions implementetion of the Commission Deted et Rockvine. MD. this 14th dey uf i

of nuclear power plant personnel Pohey Statement on Tralrams and November tasa.

i Regulations or regulatory guidance m Quahficatiert."(SECY-47-1:118 which Fct she Nuclear k 'guistory Cammission.

I the remainmg stres have been provided the findings from the Samvol l. Chilk.

deseloped separately as a revmon to 10 evaluations of the INPO managed Secretory ctrte comm ss,on i

3 CFft Part 56--Operators' Licenses Traming Accreditation Program over the Fouowmg the accident at Three %)e two year eseluation period.

54 FR 3424 Island. Unit 2 (TMI. ), the NRC Based on the staffe evaluation of the Published 1/24/g9

{

contmuully emphesised the ?ced to INPO tra:nmg accreditstion program.

E N M 1/24/s9

^

upgrade trainmg and quehfications of the NRC concludes that the proprem ia nuclear power plant personnel. In the effective in enounns that personnel have 10 CFR Parte 50 and ll "NRC Action Plan Developed as a quahfications commensurste with the Result of the TMI-2 Accident"(NUREG-performance requirements of theit jobs.

'N'Y U""' "" "

"8"'I d 0000 July 1940).* the NRC cited its However. trie Commission has Nucker Power Plant Ope suone ongoms study of accreditation of determmed that the pohey statement tramms as a possible means of should be amended to reflect the mmor Commission.

Acesscy: Nuclear Regulatory upgradmg trammg programs in the modifications made by the National mdustry. Since that time, the Institute of Nuclear Power Operations {lNPO) with Academy for Nuclear Trairung to its

,ey,og 7,nal pohc3 statement.

accreditation program and the NRC ataff its associated National Academy for to the methods by which it monitors the euumany: This pobey statement is bemg Nuclear Traming (Academy), has industry trainmg prostam. In addition.

issued to make clear the Commission s feveloped a tramms accreditation the Commasion has determmed that the espectation of utihiv management and program which the NRC has found to be industry has had sufhcient time to hcenseo operators with respect to the an acceptable meena of self.

estabhsh the accreditation program and conduct of nuclear power plant

[mprovement m training. On March 20.

it is no longer necessary to esercise operations The Commission beheves

.985 the NRC pubbshed the Commission Pohey Statement on extra discretion in enforcement when that it is essential that utibly regulatory requiremente are not met.

management al each nuclear power ai n en ua c on uc or reactor facihty estabhsh and mamiain a Accordmgly, the policy statement is professional workmg environment with p,

amended to eliminate the extra actfvIty w tho discretion currently a focus on safety m control rooms and pohey statement an[rovided in the c

t throughout the plant. The Commission e

to nonnauze introduction of now NRC traming also believes that each mdmdual regulations. The two year evaluation inspections and enforcement actions in hcensed by the NRC to operate the penod ended March 20.1947.

the areas covered by the poheY controls of a nuclear power reactor must The staff evaluated the results of the S t8 tem'ht-INPO accreditation program between The following sets forth the be keenly aware that he or she holds the special trust and confidence of the amendments to the policy of the NRC with respect to training and American people, conferred through the NRC bcense, and that his or her first

• Cap.n of NUksGaneo mer be pwshned mmueh the u s conrment ennuna on,ce Dr responsibihty is to assure that the c.ilms taul trbaceo er my enems se me ut reactor is m a safe condition at all times.

covemmeni Pnntma Ofrice P O nos Fool e * *

• Cap.n et NUREG-122 SECY a6-son.

w eerunstort DC au1Most Cop.n mer eieo to SECY-a6-tle sad stCY.a?.tri may be purthewd This ohcy statement specifically ihrough the u s conenment Printing ott.ca ey describes the Commission's two we two the NeueneiTechnicalinformouon ceilms (sori stkaoso or tiv wnune to the UA etpectations of utihty management and 5.nics. u s Deperunent of Commerce. sue Pon cournment ermune ornce P o, aos ont RoyalRoad Sennafwit vA 2:1e1. A cceyis Washinstort DC ace +ront cop.ee me, ei o t*

hcensed operators m fulfilling NRC eniieble for inspection and/or copying for a fee in purchased I,om the Neiional Technicalinformanon reculations and prior guidance regarding

• • NRC Put,he Document Room 2Go L strut NW.,

Serme U S Department of Commerce sue Po,,

the conduct of control room operetions.

wanmeim DC-Real Road Seansfeld V A 221st Copies m The pohc) statement further provides

• Cammimon Pobey Sisieswnt on fremme and

"*'464 for mopecuane and/or coorms for e in in Quear6ceuen of Nucint Power Plant Pereenneliso the NRC Pubhe Docun=ni anon ano L Suoei NW.

the Commission's endorsement of ni mawere m tenst wahav% oc.

mdustry mitia1iVe: 1o enhance Apell28,1989 (reset)

PS-PR 80 m

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POUCY STATEMENTS l

[_

profession 4hsm by both management standards for htensing nuclear power toward estabbshing 'nanagement

' - and plant operators piant operators prmcipies for enhancing professionabsm The Commissmn has addressed of noclear personneh The Commission teFact#ve oats:lanuar) R 1989 operator traming and quahlicahons and beheses that such an operator code of pon Fuatman topoematica contact:

fitness for duty m pohey statements 8 conduct developed by operators and

(

Jack W Roe. Office of Nuclear Reactor The pohey statement on training and supporied by utilit) manseement can l

Rerulation. V S Nuclear Retu!atorF quahfications endorsed the institute of contribute to operator professionsham Commission. Washineton. DC 20555.

Nuclear Power Operations llNPO)-

and commends the vadustry and s

Telephone t3011492-1t04 manageo Traming Accreditmoon especially the operators who

' suPPct wtwtane twronasAteow:

program. The poke) statement on fitness contributed to these efforts. The for duty endorsed the concept that the Commission encourages and supports

Background

workplace at nuclear power plants is to the prompt and effective implementahon it is essential that control room be drug and alcohol free. Fitness for-of these industry mitiatives at each operators are (!! well trained and duty rulemaking is under consideration licensed power reactor, quahhed. (:) physically and mentally fit by the Commission >

The Commission has decided to issue to carry out their duties and (3)

Cuidance regarding the conduct of

. this pohey statement to help foster the attentne to plant status'relegant to their licensed operator and control room development and mamtenance of a responsibihties to ensure the contmued opersuons has been addressed in an safety culture at every facihty hcensed NRC Circular and m NRC Mformanon sale operation of nuclear facihties it is by the NRC, and to make cleat its also essential that management at each Notices

• SP'C8I'C8 I IE Inf f*81' n espectations of utility management and F

nuclear powet reactor facihty estabbsh Notice No. Reusion I, emphasized beensed operators m fulfilhng NRC and maintain a professional workme that onh bcensed operators are regulations and prior guidance regardmg environment m which the hcensed permitted to manipulate controls (10 the conduct of control room opershons operator may be fully successfulin CFR 50540)) and that a heensed duhartma his or her safety operator is required to be present at the Y

'esponsibihties c ntr is durine f aciuty opersoon(to The Commission beheses that the Circular 8102 provided workme enuronment provided for the O. a number of occasions. the NRC has receased reports and has found the foil wing guidance l1) Kn wiedge of conduct of operations at nuclear power e

instances of operator mantenueness b * * ""

• EU"

• 8 6" **M M u 2 an a

• 8 safety. Management has a duty and and uriprofessional behavior in control turnos er and rehef. l:) bcensed obbeation to foster the developer ent of a g'"

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'ted ns nc[s d

bne perators must be alert and attentise to

" safety culture ' at each facility and to operators observed to be apParently instruments and controls, p) potentially provide a professional workmg distracnng actmties m the control room environment in the control room and must be prohibited. (4) access to the throughout the facihty, that assures safe om or o h rw se b ng natten to tontrol room must be hmited. and (5) operations. Management must provide theit hcense obbea tions. l:1 operators eatiria and tramms activities should not the lea tership that nurtures and usmg entertamment devices llor compromise operator attentneness or a perpe stes the safety culture. In this esample. radios. tape players. and sideo professional atmosphere Information contest. the term "sately culture 'is gameslin the control room in a way that Notice 85-33 resterated the guidante of defmed as follows:

might distract their attenoon from lE Circular 81-02.

required safety related duties. and 131 The phrase safety culture reins to a sen

" O..

unauthuraed mdisiduais bems allowed ven"ai mann ne pns sai deoicanon anc to manipulate reactivity controls Such informed all nuclear power reactor accountabiliis of allandniduals engagedin,

conduct is unacceptable and faciht es and heensed operators about any activity which has a beantis on the inconsistent with the operators hcensed unam licensed operators obsersed to safei, of nuclear power planis The startine dunes be apparently sleepmg while on duty.

point for the necessars full attention to saien The Commission has previously The nonce reaffirmed the necessity for matiers is niin the senior manasemeni of asi addressed its espectations of operator high standards of control room organisanons concerned Pohcies are conduct in Commission requiations and professionabsm and operator estabbshed ann implemented which ensure n veness to ensure safe opernon

'8"8"'"""h'h8"*"'h

regulatory guidance. Under 10 CFR

• '"'"*"'""h""**"*""

i 50.541k l. "An operator or senior operator of nuclear Power facilities. Further.

themsenes but also in the environment on hcensed pursuant to Part 55 of this Informahon Nohce 66-20 reiterated the

,,g,,y,,n.c,ousness which they create chapter shall be present at the controls concern about unauthorized indniduals Clear imes of responsibihn and at all times during the operation of the manipulating controls and performing communicanon are estabhshed sound facihty." 1 The contmuous presence of a control room acuvities.

procedures are deseloped. si ict adherence to senior operator in the control room to The Commission is aware that the

,hese procedures is demand < d. miernal ensure that the operator at the controls mdustry has taken action to foster the

'"iews are Performed of sa.ety related is able to perform the actions and/or development of professional codes of ac i tin a e aI si tr ne nd

,, n

, hind ihe metisate an accident as required by conduct by operators and has worked sareiy practices estabhshed. toveiher with

! 50 54tm)(2116ul. Commission the consequences for saf. y of shortfalls m regulations irl 10 CFR Part 55 estabbsh

' Polg, Siaiemeni en Tramms and Ovalitasion personal performance, of Nuclear Power Plani PersonneilSo F1t 1t147' The e matters are especially important for i Copies of Lue 10 Cude o' Fedev Reptonona

• ",20 a

e on Fiin,is operating organisations and the staff directis for Du y of Nuclear Power Ptani Personnel tst ilt erigaged m plane operauen. For the latter at n

m t tie re ased I o he Su en eni r Doumenis L $ Gescenmeni Preurs Off.ce in P9:1 Aveuni t 19liol alileweis trairiine emphasites the

' P oppsed Rule on to CHt Part 2a hiness for-cainme (20:4 2%;ono or b, wrinne to the U S Dui,' Programs iss FR Wss Sesiember ::

significance of their individual tasks from the 19eal standpomt of basic understandmg and Governmeni Pemame Offne P O Bos TDa:

washmaion. DC QutMos. Cop <es sede assa be

• IE Circu6ar mo2 dated February s isot knowledge of the plant and the equipment at purchased from the Naienal TechnicalInformation Informaison Noisce 75-20 Revision 1. daied their command, with special emphasis On the

%rme 5:35 Port Roval Road. Spemefieid s A sepiember 719'e Intermahon Noine av Si dated

Jist 4 corm oi to CFR is a.ailable for mapecnon tvis 12.19as informanon Nohce s'.!) dated Mat reasons unoerlung safety hmits and the

.end or (H)arii lot a see m ine %I PwlAc "I W ano 6ftformahon %0ine sea-lo Jaicif Mai 6 g

g Document Room 21 o L Sireet NW. Wathinston 19aa tavaustue siihe MC Pubnc Document Room aiutuces are required in such staff to ensure DC.

at 212o L Siteet. NW. W ash.nsion. DCl.

that mformation relevant to plant safety is PS PR.81 April 28,1989 (t***4

POUCY STATEMENTS

.e

% omm n..uro w n n erm m er.i we "at the controls", must be secure from proude guidance to hcensees in v

e se umtyce +eir.ammion 4 o.rta.. era

.ritrusion Access should be strictis improung ano assessing the conduct of

• wravro th enese means a mi cen.mrie controlled by a designated authoritt operations in the control rooms of ws nma,r v 4 c.i.u a.* " d'i ents authorized personriel should be -

riucitar powet piants. The Commission NcI pnminea to be present in the control beheses that utshty management should a

mrmemto m enenic.N ihe tn ireme of wn perivei 4

• • d NEW

" O "" *Medd 4 < wnie.m.rurpnr.oe nen.revu..uun cmumng marupul40cn of the controls operations at the plant. particularly in weig

,,n,,,

a must be meticulously obsersed the control room, and reuew their Nuc[rer power plant operators have d 4C M

PMW W Win # M cduct professior.ni responsibihtc to ensure the immediate supers.sor, must be of operahons. Considering the guidance

' hat the facuits is operate'd safelt and tuntitiu ush alert to plant conoitions of this pokcy statement, to assure they within the requirements of the Incilits s uppod an enuronmnt br pdssional bcense. incluoine its technical operelions. including conditions coriduct.

nterial t the plant such as grid Nothing in this pokey statement hmits spcWications end the reaulaisons and urcers of the N RC. Slechanical and stability. meteoroloeical condshons. and the authority of the NRC to take electrical s) stems and components chance in support eouipment status; appropriate enfortement action for required for safety can and do fail op"8h na occum(e8 8 uolations of Commission requirements lloweser. the autometed safety features enticipated, alarms and off normal or on matters otherwise effecting the of the plant. together with the operator' c ndihons should be promptly safe coeration of the plant and thus the can identifs et an early state Unpunded to, and problems affecung pubhc health and safety, degradstion in plani systems that cc vid E'

ly g, Daied at RoepiHe. Mar) land. this Stih day affect reactor safety The operator can ide action to militate the situation within the controt room Therefore nucient power plant gg g

g Frir the Nucient Regulsiory Commission oper.itors on each shift must hase the saic operation ul the plant.

Samuell Chik.

Secreron v ee Ccemissron r

knowleCee of those aspects of plent

\\tanseement should proude the status reiesont to their responsibilines mainteiri trieir worune ensironment frr, of distractions and usine all their g

g wnses be. ert to tresent et mmeate

- Activines outsice the control room

.ns operation 1 problems Each with the potenhal to affect plant indaiduas brensed bs the NRC to pneuons such an on hne mamtenance operate the controis of a nucteer power and surseillatice. should be fully reactor must tie keenly aware that he or m dmand M W m d m a she holds the special trust and Effective methods for commumcation

' confidence of the American people.

with or notification of the operator at tunierred through the NRC heense, and the controls should be estabbshed and that his or ner hrst responssbihty is to maintamed throughout each evolution.

ante :n.i nw re4ctar is.n. 34fr

-Written :ccords ci pien! curata..s conciuon at mil times must be carefull) prepared and The followine cnteria reflect the mamtamed m accordance with Commission s espectanons concermne requirements for such records and in ne concoct of operations m control sufficient detail to proude e full rooms and licensed operators at nuclear understanding of operationally reactors consistent with 10 CFR $0 54 sigmficant matters.

and guidance prouded m an NPC

-The workme enuronment m the C rcur ano information Nonces control room should be mamtamed to

-Conduct wiihm the control room mmimite distractions to the operators.

shouid always be professional and Stansgement should act to remose proper redecima a safelpminded distractions thet would mterfere with approacn to routme operations. The the operator s abihty to momtor the opstator 'ai the controls

• and the plant either audibly or visually, immediate superusor must never mcludmg work activities that are not rehnquish their safety responsibihhes related to the operator s immediale unless properly rehesed. includmg a responsibility for safe plant operation.

thorough turnoser briefing. by a Considerahon should be given lo quahfied operator, reducing enuronmental distractions

-Actiunes withm the control room such as hghted alarms that are not should be performed with formahty-operanonally signihcant, or alarms that Operator actions must be m accordance sigmfy normal operating conditions with appres eo procedures, Verbei

-Foreign obiects and materials not commumcations should be clear and necessary for plant operations. ongoing concise. Appropriate consideration mamtepance. or surveillance testm) should be unen to the need for should be restricted from the area "at dCkdowledgment and vehfiCatton of the controls" to preclude madvertent

.nstructions recened actuauon of the controis or

-The control room of a nuclear contammation of control deuces power plant. and m parucular the area implementation of Policy The Commission intends this Pohc3 y e v e u,, v,i, u w, m oe g,,,,,,n,, o y, g, c i,,, 3 3,

.u m c m+n w %.e Commission s expectations and to April 28,1989 (reset)

PS PR 82