ML20059L880
| ML20059L880 | |
| Person / Time | |
|---|---|
| Issue date: | 10/19/1993 |
| From: | Rogers K NRC COMMISSION (OCM) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| NUDOCS 9311170471 | |
| Download: ML20059L880 (6) | |
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x RELEASED TO THE POR NOTATION V 0 T E:
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RESPONSE SHEET
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SAMUEL J. CHILK, SECRETARY OF THE C0044ISSION FROM:
COM4ISSIONER ROGERS
SUBJECT:
SECY-93-274 - ACCIDENT REVIEW GROUPS REPORTING TO THE COM4ISSION smut 1.
APPROVED *C****W *- DISAPPROVED ABSTAIN NOT PARTICIPATING REQUEST DISem 3 ION COR4ENTS:
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[8Rae8$3e@eena SIGNATURE RELEASE VOTE
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df'ML,lIr [ P.3 DATE.
WITHHOLD VOTE
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ENTERED ON "AS" YES !NO QS ' i 170020
COMMISSIONER ROGERS' COMMENTS ON SECY-93-274 The staff has produced a well thought out set of guidelines for establishing Accident Review Groups (ARG) reporting to the Commission and I approve the guidance contained in Management Directive 8.9,
" Accident Investigation" including Handbook 8.9 subject to the following comments:
1.
In order to obtain the best expertise available, the Commission made it clear in the SRM (3/19/93) that representatives of the licensee or selected industry representatives not be precluded from membership in the ARG.
The staff provides an excellent elaboration of this position on page 2 of the SECY; however, this position does not seem to be present in the Management Directive (MD) itself.
On page 3 of the MD, under the definition of the Accident Review Group, membership would be excluded for those who had "significant involvement with licensing, inspection, enforcement, operational, or response activities at the affected facility."
Similar words appear on pages 10 and 11 of the Handbook, under Group Composition and Membership, including in addition the restriction from involvement in " activities associated with issues that had a direct Dearing on the cause or the course of the event."
While there should clearly be a restriction for members of the specific operating crew or other persons with direct involvement in 'he event, it is not clear why members of other shift crews shr.uld necessarily be restricted.
Furthermora, members of the licensee's engineering staff or other persons who are experts in the issues associated with the event should not necessarily be restricted.
The words in the MD and Handbook-would seem to preclude these types of people.
The words should be revised to more accurately reflect the intent of the Commission.
I have included suggested markups to pages 3,
10, and 11 for consideration.
2.
An important task that must be accomplished following an accident is the preservation of information and data related to the event.
This is accomplished, in part, with the use of a quarantined list of equipment and areas.
The Handbook properly assigns the responsibility for initially setting up this list to the Regional Administrator (RA) via a Confirmatory Action Letter.
The RA then must coordinate this list with the Director, ARG, which is also reasonable.
However, one of the duties of the Director, ARG, described on page 12 of the Handbook, is to identify, add, and remove equipment and areas from the quarantined list.
Since the Director, ARG may not even be an NRC employee, and since he may not have detailed knowledge and expertise about the plant equipment and areas, this duty does not seem to be appropriate.
Rather than actually make changes to the quarantined list, it would be more reasonable that the Director, ARG only be required to ensure that the appropriate changes are made.
I have suggested a markup to page 12 to accomplish this.
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M Volume 8, Licensee Oversight Programs Accident Investigation Directive 8.9 Definitions (8.9-04)
Accident Investigation (041)
A formal process conducted for the purpose of preventing accident recurrence that involves the gathering and analysis of information; the determination of findings and conclusions of fact, including the determination of probable cause(s) of the accident; and dissemination of the investigation results for review by NRC, the nuclear industry, the licensee, and the public.
Accident Review Group (042) nd A group of expe o do not and have not had previous significant o c-lh, !p-o M,m)or )
involvement with I nsing, inspection $enforcementy 29rrrt r WO._ activities at the affected facimpn;elWho perform the NRC's7 M '
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diiVestigation or tne accioent,eAn mamauai oumis ac NRC usually
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d rr o ly D leads the ARG. The memoers of the ARG are composed of NRC staff y o e u.i e or Coq -
experts and experts from outside the NRC. Because the ARG reports i
e n h n, c r t. /4 T.
directly to the Commission, the activities of the ARG are independent
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of regional and headquarters office management.
l Event of Extraordinary Safety Significance (043)
Any radiological. safeguards, or other safety-related operational event at an NRC-licensed facility that poses a significant hazard to public health and safety, or the environment, or involves high public, media, congressional, or executive branch interest. An event of extraordinary safety significance may be referred to as an accident.
Such an event generally has very serious safety implications and may have profound regulatory implications.
Characteristics of an event for which an ARG response might be considered may include one or more of the following:
1 ne event led to a general emerges, j at a reactor facility. (1)
The event ifrvolved an external release of radioactive material that resulted in at least partial implementation of radiologically jneined protective measures for the public. (2)
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Volume 8, Licensee Oversight Programs Accident Investigation Handbook 8.9 Part U Schedule (C)(continued) approves the initiation of onsite activities. The ARG should proside periodic reports outlining the status, plans, and significant safety findings. (1)
The Commission and the Director, ARG, shall agree upon the schedule for completing the investigation and submitting the ARG's final written report. As a guideline, the final report should be transmitted to the Office of the Secretary (SECY) for distribution to the Commission and the EDO about 75 days after completion'of the field investigation. (2)
After distribution of the final report, SECY should normally schedule a meeting for the ARG to brief the Commission on the results of the investigation. Information contained in the report will not to be released until a copy of the final report is placed in'the Public Document Room (PDR), which usually occurs during the day of the Commission briefing. If deemed necessary, SECY should forward a copy of the final report to the affected licensee before the Commission briefing and should promptly forward a copy of the final report to the PDR. Following the Commission briefing, SECY will transmit a copy of the final report to the licensee and the EDO for staff review and comment before the Commission defines and assigns NRC followup actions. (3)
Group Composition and Membership (D)
The number of members and the areas of expertise required for the ARG will be determined on the basis of the type of facilityinvolved, the characteristics of the accident, and the ARG charter. Areas of expertise will include the requisite technical, legal, and management disciplines and such other areas of specialization as may be necessary, such as financial expertise. ARG members are selected on the basis of their expertise, their potential contributions to the investigation, and their freedom from significant involvement in the licensing [
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inspecuon finderemsies of the faciji involved or e&x M"5 G
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& lhh oP'd %/pJA"O direc(tearing on the cause or course of the accident. (1)
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Volume 8, Licensee Oversight Programs Accident Investigation Handbook 8.9 Part II i
i Group Composition and Membership (D)(continued)
The membership of the ARG should be composed,in part, of expert staff from the NRC. Appropriate outside individuals will be requested to participate as members in the investigation. The Director, ARG, will usually be an individual from outside NRC. Other outside individuals will be selected on the basis of their unique knowl
_ exnert seJand sh also be independe m sig nt prior i
involvement activities associated
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issues had a direct bearing the cause or the cou the ey t.Nine ARG slictrtti O' consist of a larger proportion of non-NRC representation than is normally the case for an Incident Investigation Team. (2)
The background of each candidate member of the ARG will be carefully evaluated before selection to ensure impartiality and independence. Individuals possessing a high degree of ingsnuity and resourcefulness should be selected to ensure that the investigation is conducted in a timely, professional, thorough, and coordinated manner. (3)
Duties (E)
The ARG carries out the NRC fact-Ending investigation of the 1
accident and is authorized and responsible for pursuing all aspects of I
an accident that are within its scope as defined in this directive and the ARG charter. NRC response personnel onsite shall provide support as needed to ensure the efficient and effective transition from response to investigation of the accident in a manner that will not interfere with safety at the site of the event. (1)
The following duties of the Director ARG, are in addition to the duties defined elsewhere in this directive and handbook: (2)
Selects the members and concurs on the charter and schedule of the ARG. (a)
Directs and manages the ARG in its investigation and ensures that the objectives and schedules are met for the investigation as defined in this directive and handbook'End the ARG charter. (b) su u
s Volume 8, Licensee Oversight Programs Accident Investigation Handbook 8.9 Part II Duties (E)(continued) 1
- Receives general direc* ion and supenision from the Commission. (c) 9.wn n e aie.,0 P.tdm lJd. k d "~~I * ~o p e. '
egiAudf cs, adds, And removes equipment and areas from the quarantined list, within the constraints of ensuring plant safety, equipment testing, maintenance requirements, and determining causes for equipment anomalies, after arriving onsite. (d)
Serves as principal spokesperson for the ARG activities in interacting with the licensee, the Commission, NRC offices, the Advisory Committee on Reactor Safeguards (ACRS), the Advisory Committee on Nuclear Waste (ACNW), or the Advisory l
Committee on Medical Uses of Isotopes (ACMUI), the news media, and other organizations on matters involving the investigation. (e)
Provides status reports, as requested, documenting ARG activities and significant safety findings that may require timely remedial actions or issuance of information notices, bulletins, or orders. (f)
Identifies and requests that the Commission provide additional ARG resources (e.g., additional members, consultants, contractor assistance), as needed. (g)
Ensures,in cooperation with the ARG members and the technical e
writer / editor, preparation of the final report within the timeframe agreed upt n by the Commission. (h)
Works with the Office of Public Affairs in providing the news e
media with information on ARG activities. (i)
Conduct of an Accident Investigation (F) j The investigation process used by the ARG must be structured to maintainindependence, objectivity,and thoroughness.The ARG may use as guidance the investigation principles and practices of incident j
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Annroved: fDraft 09123!911