ML20062C896
| ML20062C896 | |
| Person / Time | |
|---|---|
| Issue date: | 10/15/1990 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 9011020225 | |
| Download: ML20062C896 (130) | |
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BRIEFING ON REGULATORY IMPACT SURVEY REGULATIONS LOCatiOD:
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D3k6 OCTOBER 15, 1,990 PagGS:
108 PAGES NEALR.GROSSANDCO.,INC.
COURT REPORTERS AND TRANSCRIBISS 1323 Rhode Isladd Avenue,. Northwest Washington, D.C.
20005 (202) 234-4433 l
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l DISCLAIMER This is an unofficial transcript of a meeting of the United States Nuclear Regulatory Commission held' on October 15, 1990, in the Commission's office at One f
White Flint North, Rockville, Maryland.
The meeting was I
open to public attendance and observation.
This transcript has not been reviewed, corrected or edited, and 'it may contain inaccuracies, The transcript is intended solely for general informational purposes.
As provided by 10 CFR 9.103., it is not part of the formal or informal record of decision of the matters discussed.
Expressions of opinion -in this transcript do not necessarily reflect final determination or beliefs.
No pleading or other paper may be filed with l
the Com.nis sion in any proceeding as the result of, or addressed to, any statement or' argument contained herein, except as the Commission may authorize, l
I l
l NEAL R. GROSS COURT RtpoRTits AND TRANSCRl8ER$
l 1323 RHoDt ISLAND AVtHUI, N.W.
l (202) 234 4433 WASHINGToH, D.C.
20005 (202) 232 6600
UNITED STATES OF AMERICA F~]
NUCLEAR REGULATORY COMMISSION i
~
BRIEFING ON REGULATORY IMPACT SURVEY REGULATIONS PUBLIC MEETING Nuclear. Regulatory Commission one White Flint North Rockville, Maryland Monday, October 15, 1990 The Commission met in open
- session, pursuant to notice, at 10:00 a.m.,
Kenneth M; Carr, Chairman, presiding.
COMMISSIONERS PRESENT:
KENNETR M. CARR, Chairman of'the Commission KENNETH C.
ROGERS, Commissioner JAMES H.
CURTISS, Commissioner FORREST J. REMICK, Commissioner 7- _
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STAFF SEATED AT THE COMMISSION TABLE:
SAMUEL J.
CHILK, Secretary WILLIAM C.
PARLER, General Counsel JAMES TAYLOR, Executive Director for Operations DR. THOMAS MURLEY, Director, NRR WILLIAM RUSSELL, Deputy Director, NRR BERT DAVIS, Region III Administrator PRANK GILLESPIE, Director, PMAS/NRR CYNTHIA
- PEDERSON, Chief, Technical Support
- Staff, Region III i
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1 P-R-0-C-E-E-D-I-N-G-S 2
10:00 a.m.
3 CHAIRMAN CARR:
Good morning, ladies and 4
gentlemen.
5 This morning the NRC staff will brief the 6
Commission on recommendations arising from a three 7
part regulatory impact survey completed over the last 8
year.
The survey was an attempt to obtain the views 9
of the industry and the NRC staff with regard to those 10 areas it which NRC requirements and practices might 11 affect the safety of plant operations.
We look 12 forward to hearing some of t he results of this survey, 13 along with the recommendations of the staff to address 14 those areas which may require a
change in NRC's 15 procedures or practices.
1G I understand that copies of the briefing 17 slides are available at the entrance to the meeting 18 room.
19 Do my
. fellow Commissioners have any 20 opening comments?
21 If not, Mr. Taylor, please proceed.
22 MR. TAYLOR:
Good morning.
With me at the i
23 table are, from Region Ill, Cynthia Pederson and the 24 Regional Administrator, Bert Davis.
To my
- right, 25 Doctor Muricy from NRR, Mr. Russell and M, Gillespie, NEAL R.
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1 also from NRR.
2 This effort has been a very useful effort, 3
1 believe, for the staff.
I think importantly besides 4
what is reported in the paper, we have an increased 5
sensitivity to want to listen to feedback where our 6
actions may, although well intentioned, may be causing 7
difficulties in achieving an appropriate level of safe i
8 operation that we think is so important.
9 So, beyond what is in the written paper, I 10 believe that the staff totally is knowledgeable that 11
- ii n has taken place and remains, I believe, open to 12 the important suggestions.
While we try to maintain 13 the balance of the-necessity to take
- action, and
}
14 action for the commission where appropriate, still 15 many of our requirements, criteria and what we do are 10 an imposition to a degree and achieving the balance is 17 what we're going to try to do.
18 So, there are examples where we continue 19 to receive information.
We want to set that process 20 up within the staff.
)
21 With those thoughts, I'll now ask Doctor 22 Murley to begin the formal briefing.
23 DOCTOR HURLEY:
Thank you.
24 Mr. Chairman, commissioners, as you know, 25 these acttvitles have been underway for a year now and u.-
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1 although we've communicated via some papers with the 2
Commission, we haven't actually sat down and briefed 3
you.
So, we appreciate your forbearance while we've 4
been doing this in the past year.
I think now we've 5
got some clear recommendations and we've got some 6
actions underway which we'll describe.
7
- First, though, I'd like to take a
few s
8 minutes and talk about the background to this study to 9
set the stage.
Then I.' l l turn it over to Bert Davis 10 and Cindy who will discuss how the survey of the 11 utilities was actually carried out and some of the 12 highlights of that.
Then we'll quickly move to the l
l 13 recommended actions and some actions that we.iave l
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14 underway and Bill Russell and Frank Gillespie fr om my i
15 staff will talk about those.
16 The roots of this study really go back to 17 the aftermath of TMI.
There, you recall, there were a 18 large number of lessons learned activities where we l
t 19 improved hardware and instrumentation, we improved l
20 operntor qualification and training, we improved the 21 emergency operating procedures for operators, among 1
22 other
- things, and also off site emergency 23 preparedness.
There was a large number of generic 24 requirements - that was coming out of headquarters in i
25 the 1980 and 1981 time period, to the point where a j
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I concern developed that maybe we were overloading the 2
industry.
3 So, there was a task force headed by the 4
Region Il administrator, Jim O'Reilly, from April to 5
July of 1981 that lead to a report of the impact that 6
this large number of generic requirements was having 7
on the plants and plant operations and the management 8
of the utilities in terms of the overwhelming 9
workload.
That led to some changes that you're 10 familinr with, the backfit rule and CRGR and special 11 deputy executive director for operations.
12 The staff believes that these 13 requirements, although they were difficult and Y
14 excessive in some
- cases, nonetheless led to large 15 improvements in safety.
But in spite of those 16 improvements, we still saw occasional events that were 17 serious precursors to serious accidents.
The most 18 significant of those, I'll take a second to discuss 19 because it had a great impact on our thinking, was the 20 Davis-Besse event of June the 9th, 1985.
It was a 21 loss of all feedwater event where both steam 22 generatora dried out within about 13 minutes from the almost heroic 23 onset of the event through quite 24 action by the operators.
They were able to get 25 feedwater back so that the core was not uncovered.
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But had they not done that, they were within probably 2
half an hour of uncovering the core.
3 1 remember, I was a regional administrator 4
at the time, thinking that, my gosh, this was six years after TMI and it was billions of dollars that we t
6 6
had caused to be spent and all these requirements and l
7 yet we came again close to another core damage 8
accident.
We went through then that period of l
9 introspection, I would say, the staff did, looking at 10 our approach to regulating safety.
We decided that we 11 needed to focus more effort on how the plants were being operated and maintained because that was the key 12 13 to-we thought, to preventing these kinds of things.
14 Huny people closely involved with Davis-16 Besse, I was not at the time, but many people who were 16 said that we could have predicted not that particular 17 event but all the signs were there, that we knew that 18 this was not a well operated or well maintained. plant.
19 SALp scores were poor, the maintenance program was 20 poor.
- Also, the design of the auxiliary feedwater 21 system we knew was weak.
In fact, there had been 22 ditnussions for years on getting that improved.
l 23 So, as a
result of
- that, and that 24 introspection that we went through in late 1985 and 26 early
'86, we undertook a better integration of all NEAL R.
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1 the safety information that was available to the staff 2
and we did this by means of the senior management 3
meetings where all the regional administrators and all 4
the key office directors and the key staff get 5
together and bring together all the information we 0
know about a plant and where we see signs of problems, 7
we analyze those in detail and that has come to be 8
known, as you know, as the NRC watchlist or problem 9
plant list.
10 The inspection program has become more i
11 diagnostic in nature.
We're out now looking for 12 problems and particularly we're looking for arean 13 where the management of the plant is not up to snuff.
14 The SALP effort, we think, has become more critical.
15 That is, the evaluations themselves have, over the 1
16 years, become more critical evaluations of the safety 17 management of the plant and not so much a mere rote 18 discuselon of statistics and things like that.
19 So, all in all, I'd say the program has 20 become much more diagnostic in the sense of looking at 21 how plants are being operated and managed.
22 We think we're being effective.
We had 23 a -- well, the precursor indicators, the industry's 24 own precursor performance indicators show that since j
25 1985 or thereabouts, the performance has improved.
We F
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accident I
briefed the Commission on the precursor i
2 precursor information and they show a
steady 3
improvement since 1985.
4 One can't make this a
one to one 5
correlation, but I think the staff uniformly believes 6
that our
- effort, plus INP0's
- effort, plus the 7
industry's own effort together has succeeded in I think there's 8
improving performance and it's no 9
also correlation with the fact that we've had a number 10 of the poorer performing plants shut down.
We had, at 11 one time in 198G and
'8'/,
nine plants in this country 12 shut down because we did not believe their performance 13 was up to the level that we thought it should be, 14 Now, we get to this survey because these
'~
15 changes that we've implemented have had some side 16 effects.
The team inspections that we do, while 17 they're more diagnostic and we think they'ra better 18 inspections, they are also more intrusive in the plant 19 operations.
It is a
bigger impact on the. plant 20 manager and his senior stuf f when an NRC team she'is up 21 on site.
The sal.P reports are more critical, but also 22 we find that they're being used by outside agencies in 23 ways that we had not intended.
Therefore, they're 24 gaining
- much, much more weight in a
utility's 25 organization and a ~ utility's staff, and there is the
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1 danger than that they're being used by our own staff.
2 The effect of a SALP score, for example, can be and in 3
some cases is being used to influence behavior at the 4
plant.
5 The assessment of the safety management of 6
plants leads us to areas that are beyond what our 7
normal inspection and regulatory effort has,been.
So, 8
011 these side effects in the time period I'd say 1988 9
ano 1989 were leading to increased criticism by the 10 industry.
It first really became focused, for me at 11
- least, was in our first Regulatory Information 12 Conference of 1989 where, as you'll recall, this was 13 our attempt to have a dialogue with the industry on i
14 what are the big issues we see_in where we're heading 16 and also to hear back from them in a
kind of a 16 coordinated way.
17 I was troubled by some of the themes that 18 were coming back from the industry._ We'd always heard 19 criticism.
We always do.
But up until that point, it 20 was largely unfocused and it was largely anecdotal.
21 You don't know really how to deal with those.
22 But that summer then of 1989, I went to 23 the EDO and suggested perhaps it was time to_ do 24 another survey like the one we had done in 1981.
We 25 came to the Commission and got the Commission's u --
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guidance and approval for this survey.
I think we 2
basically conclude that we're on the right track in 3
terms of the regulatory activities that we're doing.
4 But, as we'll discuss, there are areas of improvement.
5 I think the NRC staff should, from time to time, take 0
a look at its operations like this.
I don't know if 7
it's every five years or something like that, and get 8
systematic, in-depth feedback so that we can deal with 9
our operations.
10
- Now, with that introduction
- then, I'll 11 turn it to Bert and he'll describe the survey.
12 MR. DAVIS:
Thank you, Tom.
13 Good morning.
Mr.
Chairman and i
14 Commissioners.
15 In my discussion of.the regulatory impact 16 survey today, I plan to discus several topics.
- First, 17 how we conducted the survey; the principal themes 18 developed from the comments received; and briefly the 19 ten entegories into which comments were grouped.
20 We performed the survey at 13 utilities 21 throughout the country, three in Regions I,
II and 22 III, and two in Regions IV and V.
One day was devoted 23 to each utility.
All utilities in a region were 24 visited in the same week.
25 Each team of NRC people consisted of five r--
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1 or six senior managers.
Team members varied from week 2
to
- week, with Cindy pederson and me being the j
3 constants.
Cindy attended all of the sessions.
I 4
excused myself from the sessions with senior managers 6
in Region III.
6 It was valuable, I think, to ',ary the team 7
members because it was important to ha*,e the NRC folks 8
hear firsthand what the licensees hed to say.
I don't 9
think you can capture the apirit that they had in the 10 written word in the report.
11 At most licensees, we held discussions 12 with five separate
- groups, starting with reactor 13 operators, then plant supervisors and engineers, then
'I 14 corpornte managers /engincors, then higher level 15 managers and finally top executives.
Each session IG lasted for about an hour and a half, and most groups 17 would have continued beyond that time if the schedule 18 had permitted.
Basically, we discussed what the 19 people wanted to discuss, asking questions only for 20 clarification and to get examples.
And, I might add, 21 it was pretty hard to get examples of the points that 22 were being made.
23 We did introduce a few topics to make sure 24 that we covered everything that the Commission had 25 given us guidance to cover.
We pledged rn
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confidentiality to the best of our ability to foster 2
candid discussion.
I believe the people expressed 3
their views candidly in all of the discussions we had 4
with all of the groups and all the utilities.
I only 5
thought that there was one group that held back.
1 6
also would say that all of the people who we talked to 7
were appreciative of the effort.
8 We reported what we heard in the report.
9 We did not eliminate what we soy not have agreed with 10 or what we believed to be in error, because I thought 11 it was important to document what the people perceived 12 out there.
In my discussion, I will mention how many 13 licensees made a comment.
These numbers are certainly i
14 not statistically defensible,~but they do give a feel 15 for how often the comment was made.
Others may have l
l 16 had the some view and it just didn't come up during 17 the discussion with them.
f 18 We grouped the comments into ten 19 categories shown on the viewgraph, and we developed 20 two principal themes.
There is a viewgraph that shows 21 the two principal themes.
Those themes are, licensees l
22 acquiesce to NRC requests to avoid poor SALp ratings, 23 and the consequent financial and public perception 24 problems that result, even if the requests require the 25 expenditure of significant resources on matters that I
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1 the licensee believes are of marginal safety s _
2 significance.
3 The second major theme was that NRC so 4
dominates licensee resources through its existing and 5
changing formal and informal requirements that 1
6 licensee believe their
- plants, though not
- unsafe, 7
would be easier to operate, have better reliability, 8
and any even achieve a higher level of safety if they 9
were freer to manage their own resources.
10 Let me move now to briefly discuss the ten 11 categories.
12
- First, requirements and perceived 13 requirements.
Many licensees believe that the NRC 14 issues too many requirements.
The proliferation of 15 these requirements results in NRC managing rather than 16 regulating licensees.
Two licensees stated that the 17 restraint on the issuance of NRC requirements which 18 occurred after the last regulatory impact survey had 19 essentially disappeared.
Two licensees commented that 20 the NRC is trying to solve too many problems without 21 determining which problema needed to be solved.
Two 22 other licensees perceived that although NRC 23 initiatives may cause the plant to be safer in some 24 theoretical context, they make the plants harder to 25 operate and maintain.
The operators felt this way and r-u _.
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1 the managers of the maintenance people felt this way.
2 Regarding quest for excellence, many 3
licensees agree on the need to strive for better 4
performance in all aspects of plant operation and to 5
maintain an ample margin above minimum safety 6
standards.
- However, they believe that the NRC 7
standards and requirements have moved beyond those 8
needed for safety and into the pursuit of excellence 9
and the prevention of precursor events without the NRC 10 having decided or defined how safe is safe enough.
11 Apparently they didn't either agree with our safety l
12 goals or understand chem or perhaps they felt they 13 were too complex or esoteric.
14 G e n e r t.l l y, licensees were appreciative of 15 the information provided to them in generic letters, IG bulletins and information notices since these enable 17 them to improve their operations.
I sense the real 18 desire out there for them to want to improve their 19 operations.
But they don't want to be told they have 20 to do these things, they want to pick and choose and 21 decide what they should do on their own.
While 22 recognizing the legal distinction between rules and 23 informal guidance, many consider informal guidance on 24 documents such as generic correspondence, reports, and 25 inspector and reviewer comments to be nearly as I
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1 binding as formal requirements.
This is because 2
licensees do not want to appear unresponsive to any 3
staff or management level at NRC.
Several licensees 4
stated that they would prefer to have all requirements l
5 imposed by formal rulemaking.
6 Many licensees do not understand or do not 7
agree the NRC process for issuing generic 8
correspondence.
Two licensees objected to the NRC 9
practice of using 50.54(f) to impose backfit 10 requirements by requesting licensecs' schedules for 11 completion of the items covered in the generte letters 12 or bulletins.
Several licensees did not think that 13 NRC did backfit reviews before issuing generic l
14 requirements, and those who recognized that backfit 15 reviews were done thought our dose estimates were low 10 and our cost estientes were not complete and they were 17 underestimated, particularly in the implementation of 18 changes.
19 There was n general view that additional 20
- guidance, however, from the NRC is-needed in some 21 areas to assure that the regulatory position is clear 22 and to avoid requirements being set through 23 inspections and through license reviews.
Examples 24 provided by many licensees of areas where such 25 guidance is needed included engineering judgment as n
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17 r-1 opposed to having to perform detailed calculations, 2
ensuring the commercial grade part dedication.is done
)
3 properly and treating radiation levels that are_below 4
regulatory concern.
5 Let me move to the second category, NRC 6
licensing activities.
A significant number of 7
comments related to the untimely review of plant-8 specific and generic su'omittals to the NRC.
Many 9
believe that these delays create efficiencies for both 10 the licensees and the
- NRC, postpone resolution of 11 important issues and can be costly.
One licensee i
12 acknowledged that although NRC responsiveness has 13 improved, the problem is still so signi'ficant that the r...,,
1 14 licensees avoid making submittals because they don't 15 want to bog down the system.
Two licensees stated an l
16 NRC schedule for review needs to be made predictable l
17 and that the NRC priority system works well for the 18 things NRC wants to get done, but not necessarily for 19 what the licensee thinks is important.
?0 Regarding technical specifications, there l
21 were a
number of comments.
Several licensees 22 considered them to be so poorly written that they 23 require an extensive volume of interpretations.
l 24 Several licensees also stated that related items 25 appear in different places in the technical l
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1 specifications.
The operators were very concerned 1
2 about this because it caused them to make mistakes and 3
they didn't like to make mistakes.
4 Several licensees expressed concern that 5
tech spec surveil' lance testing is excessive and 6
prematurely wearing out equipment.
Diesel generators 7
were discussed, as was excessive surveillance testing 8
that may cause transience or reactor trips.
There 9
were also comments that the tech spec requirements 10 were either too restrictive or not restrictive enough.
11 For example, the NRC auditing requirements prescribed t
12 in the tech specs were considered to be too elaborate.
13 There was also a licensee who tried to train its staff 14 to avoid t r ans ieri ts.
One of the technical 15 specifications did not allow sufficient time for an IG orderly shutdown.
They had to trip the plant from 17 about 18 percent power and;they didn't.like that.
18 On the other hand, one engineer expressed 19 concern that removing equipment from service under an 20 LCO for preventive maintenance was inappropriate 'in 21 that it increases the unavailability of safety 22 equipment.
23 Let me rove on now to the category of NRC
]
24 inspections.
There's a widely shared view among many 25 licensees that the NRC inspection process pushes I
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1 licensees beyond existing regulatory requirements and 2
forces them to exceed to unnecessary requests.
Their 3
perception is that inspectors improperly backfit 4
because of how our inspectors interpret the 5
regulations and because of the accumulative effect of 6
one inspection after another.
7 Other examples of increased standards 8
through inspections include inspectors who use open 9
items as a means of forcing licensees to respond to 10 their wishes.
I,icensees apparently consider open 11 items to be a connotation of badness on their part and 12 their managers feel that way too.
And inspectors also 13 intimidate licensees with the threat of poor SALP 14 ratings if the licensee doesn't do what the inspector 15 wants.
IG Regarding team inspections, there were a 17 number of comments.
Many licensees believe that team 18 inspections are more effective than individual 19 inspections, but when we asked them which they would 20 rather
- have, they were a
little uncertain whether 21 they'd like to have a team inspection and get it all 22 at once or spread it out over the year.
23 The team inspections were also considered 24 to be n significant burden.
One licensee estimated 25 that salaries alone to support a one week NRC team r-NEAL R.
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r-1 inspection cost $100,000.00 and that did not include j
2 any post-inspection activities.
Two licensees said J
3 that they provide approximately three key people to 4
support each inspection team
- member, which is a
6 tremendous burden, particularly during plant outages.
6 Another licensee said that seven team inspections were 7
performed at its facility in an eight month period and 8
another one said the same number were performed in an 9
11 month period.
10 In commenting on NRC's response to 11 significant events, one licensee stated that after an 12 event its personnel were so involved in supporting an 13 AIT that the licensee's independent evaluation of the I
14 event was hampered.
This came from middle managers at 15 this licensee.
The senior managers didn't agree with 16 that.
I personally agreed with or believed what the 17 middle managers were telling me, I think.
18 Another licensee stated that an AIT was on 19 site before the licensee could bring the plant to a 20 stable ~ condition and that's not the purpose of an AIT.
21 And yet another licensee believes that NRC regional 22 offices over react' to events and send AITs because 23 they fear how Headquarters will react.
Several 24 licensees compared the quality of INPO and NRC teams.
25 In
- general, they believed INPO teans and team r--
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inspections were better managed, better planned and
}
2 better implemented, and they were more programmatic in 3
nature as opposed to looking at hardware and specific 4
problems.
5 Many licensees at various organization G
levels consider the resident inspector program to be 7
one of the best things that the NRC has done.
Even 8
so, one licensee questioned why three resident 9
inspectors were assigned to its single unit site that 10 had an INp0 1 rating.
Other comments indicate that 11 licensees' views of resident inspector activities are 12 dependent on the licensee's perception of the quality 13 of the inspector and the communications that have been r_.,
14 establinhad between the inspector and the licensee.
15 Hegarding all inspectors, attitudes and licensees questioned the attitudes or 16 techniques, many 17 techniques of them.
Among the assertions were two 18 licensees stated the NRC has too many inspectors who 19 were zenlots and NHC is not adequately controlling 20 them.
One licensee stated that some inspectors appear reputation for themselves 21 to be trying to make a
rather than to perform fair and objective assessments.
22 23 One licensee observed that inspectors are unreasonable 24 in dealing with licensees when it comes to using 25 engineering judgment as opposed to requiring detailed i
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t 22 t-1 calculations, even when it's otvious that an 2
engineering judgment is sufficient.
Many licensees 3
believe that inspectors want things done their way.
4 They're frustrated to just come out and inspect.
They 5
like to design, they like to operate, and therefore 6
they want to go beyond just an inspection role.
7 Let me move on now to performance 8
evaluntions.
First SALP.
One licensee stated that 9
SALP reports are generally accurate, identify arean 10 for improvement, and clarify what the NRC considers to 11 be important.
Another stated that it learns and 12 improves as a result of the program and incorporates 13 the results into corporate goals to let workers know 14 that management is interested in running a
safe 16 facility.
16 However, many licensees believe that the 17 SALP process is too subjective and that the 18 conclusions renched are not supported by the facts.
19 They also believe that NRC regulatory standards are 20 increasing, thus making it unclear to the licensee and 21 to the NRC what it would take to get a SALP 1 rating.
22 Many believe that SALP reports should not contain 23 numerical ratings, although the narrative portions of 24 the reports are useful to them.
25 With respect to improper use of' SALP, n._
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23 4
l 1
every licensee expressed a concern that SALP is being 2
used by the NRC to obtain better performance..
There 3
is an intense interest by many 'icensees to avoid poor 1
4 SALP ratings because of the impact of these ratings on S
the public, the economic regulators, some states and 6
the financini community.
In view of the importance 7
attached to these ratings, licensees at all levels 8
react very quickly to NRC findings and requests to 9
avoid appearing unresponsive to the NRC and for the 10 various levels of the organization to avoid getting 11 criticized by their management for not being 12 responsive.
13 Let me move now to multiple oversight i
14 organizations.
One senior manager stated that
~
15 collectively the impact of multiple oversight 16 organizations, including his own quality assurance 17 organization, was almost an impossible burden.
At one 18
- plant, four to five senior engineers are needed to 19 address NRC, INPO, NUMARC and owners groups questions 20 and concerns.
Another licensee has a staff of ten to 21 20 per site, this is a multi-site utility, just to 22 handle regulatory issues.
23 One licensee stated that the effect of 24 multiple oversight on its training staff was 25 staggering.
During a six month period, this licensee I
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24 1
had an INPO simulator evaluation, an INPO training I
2 visit, an NRC training inspection, a requalification j
3 training program
- change, a
requalification 4
examination, and an NRC emergency operating procedure 5
inspection.
I think we would a l '4 agree with the 6
licensee that that was staggering.
7 There were comments regarding duplication 8
and conflicting initiatives among the oversight 9
organizations.
Many licensees commented that 10 correspondence on generic issues or
- problems, for 11 example, come from both INPO and NRC, as well as the 12 NSSS nnd sometimes owners groups.
It would help them 13 a lot if these were coordinated so that they could i
14 come up with one response.
They also commented on NRC 15 and INPO reviews being redundant in many-cases, 16 With respect to state involvement, several 17 licensees stated that the NRC should take a tough 18 stand on state intrusion into areas' of NRC 19 jurisdiction since states will not stop at a
20 reasonable point if NRC continues its passive role.
21 This view is prompted by concerns about duplicate 22 regulations since the licensees believe they've got 23 plenty of oversight as it currently exists.
Another 24 licensee felt the NRC's policy statement on state 25 involvement may result in states that are currently I
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25 i
1 less active becoming more involved.
2 There were a
number of comments on 3
economic regulstors.
These regulators are 4
scrutinizing operating and maintenance expenditures 5
more closely each year and are tending to make 6
prudency determinations based on whether expenditures 7
are made for specific requirements.
As a result, 8
several licensees stated that allowances are more 9
likely to be given to meet specific rules as opposed 10 to meeting generic requirements, and that feeds back 11 to why some of them would like to have everything 12 imposed by rules.
13 Moving on to operator licensing, several l
'J 14 licensees feel that the training accreditation program 15 provided by INp0 and the NRC's endorsement of the 10 program should be sufficient for the licensing of 17 operators.
The NRC should monitor the licensee's 18 training and qualification programs rather than 19 actually being involved in the conduct of 20 examinations.
21 We had a
lot of discussion on the 22 requalification examination process and not so much on 23 the initial or replacement exams.
Many licensees 24 believe that the requal program is a
definite 25 improvement over the previous _ program in that 'the 1
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.]
1 previous program required operators to be trained to 2
pass the exam and then trained on how to operate the 3
plant.
They feel that one training does both now.
4
- However, many licensees stated that tae 5
process needs to be stabilized, since the lack of 6
stability is a chronic problem that adds stress to the 7
operators and training personnel and is a
major 8
resource burden.
The guiding NUREG was continually 9
revised and implemented on short notice without formal 10 control and without formal issuance of the revisions.
11 This practice had a major impact on operators and 12 training staff since these changes might come out very 13 soon before on examination was to have been given.
'- U 14 It's a real stress increaser for them.
15 On replacement
- exams, in spite of 16 everything I've just said about the requals now, there 17 weren't a
lot of
- comments, but licensees I
think 18 generally felt -that it would be good to pattern the l
1 19 replacement exam after the requal program.
20 Moving on to enforcement and 21 investigations, several licensees stated that regional 22 offices are inconsistent in their application of 23 enforcement policies.
One senior manager saw a
24 contradiction in that although everyone recognizes 25 that plants are improving since
- 1985, enforcement u-NEAL R.
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e 27 n
d 1
actions have increased over that same period.
2 Responding to enforcement issues causes licensees to 3
expend considerable resources to resolve issues they 4
perceive to be of marginal importance to safety.
I 5
thin-they particularly felt this on severity level 4 0
and severity level 6 violations.
7 Many licensees were particularly critical 8
of enforcement actions taken for violations that were 9
already identified and corrected or that were 10 scheduled to be corrected.
Such enforcement actions 11 may be a disincentive to aggressive licensee self-12 assessment programs and to the-alert licensee employee 13 who identifies a
problem.
Some licensees did 14 recognize the change in'the NRC enforcement policy to 15 give credit for licensee's self-identified items, but 10 they believed that more credit should be granted to 17 them particularly for escalated enforcement actions.
18 On enforcement timeliness, this was a
19 concern to them.
Lnte enforcement causes the same 20 infruction to be hit in the press two different times 21 and this was disconcerting to them.
Late enforcement 22 actions resulting from 01 investigations was also 23 disconcerting to the employees involved.
They must 24 wait in uncertainty about the disposition of their 25 cases and they're quite concerned about that.
c i
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e 28 r-1 On reporting events, the ne>
- category, 2
many licensees believe that the formal reporting 3
threshold is too low.
Reporting criteria cover a wide 4
spectrum of safety significance and all take about the 5
same time and effort.
For exa.uple, one licensee 6
questioned the need to report that a bird on the 7
endangered species list was killed when it flew into a 8
power line.
One licensee observed that the unusual 9
event emergency action level requires that items of 10 low safety significance be reported and when they are 11 the reports are interpreted by the public as another 12 emergency at the nuclear power plant.
13 Many licensees also stated that reporting I
14 requirements needed to be examined since complying 15 with them may adversely effect the ability to respond 16 to an event.
This is because of a requirement to tie 17 up a key licensee individual in the control room to 18 communicate with the NRC.
This had never happened, 19 they said, except one licensee indicated that in one 20 of their simulator drills it would have caused a
21 problem.
22 On communications, the next
- category, 23 positive comments were made regarding visits by I
24 Commissioners, also positive with respect to the 25 regulatory information conference, regional meetings 1
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f 29 T1 J
l with all licensees, and the improved contacts with the 2
Headquarters staff by several licensees.
That's 3
improved contact since the reorganization that was 4
made in 1987.
However, several other licensees object 5
to being called by the Headquarters staff to explain 6
ir. formation that they had previously discussed in full 7
with the resident inspector or with the regional 8
office.
9 With respect to regional management, 10 several licensees stated it was difficult to 11 communicate informally w.ch the region because of 12 their concern of an unpredictable response that they 13 would get on the issue discussed.
One licensee vice I
14 president who had worked at facilities located in two 15 different regions noted that there was good give and IG take in one region, but not in the other.
He said 17 that his views were corroborated by consultants and 18 contractors who had worked in both regions..
19 Communications with inspectors, the 20 quality of communications was viewed as mixed and 21 depended on the inspector's
- style, knowledge, and 22 maturity.
So, the licensee felt that if it had 23 communications problems,- it was inspector dependent, 24 not licensee dependent.
On the other
- hand, two 25 licensees worked very hard to foster good t
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30 r-communications with the inspectors because they 2
believed that regulatory issues are kept in better 3
perspective by the NRC if the senior resident and 4
other inspectors are kept fully informed about the 6
problems.
G One licensee recognized that inspectors 7
are knowledgeable and that they gained important 8
information by visiting different sites that they can 9
share with the licensee.
The licensees appreciated 10 this, provided they weren't forced to adopt the things.
11 that the inspectors told them about.
12 Several licensees believe that they carry 13 an inordinate burden to communicate with the NRC staff a
14 because the staff is unable or unwilling to deal with 15 its own communication problems.
One licensee stated 18 that the NRC communications with the public are often 17 done by people who lack the needed communication 18 ills and this was of concern to them because if the 19
.< C goes out and does a poor job in public meetings, 20 it's not only an adverse reflection o r.
the NRC, but l
21 it's also an adverso reflection ~
the licensee in on 22 that area as well as on nuclear power.
23
- Finally, the last area was qualification 24 of NRC personnel.
Several managers stated that NRC is 25 much more professional, responsive' and technically r-l NEAL R.
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1 31 r
I competent than other federal and state ' agencies.
2 Senior management from one licensee said that industry 3
needs a strong, competent NRC for nuclear plant safety 4
and for public acceptance'of nuclear energy.
The NRC 5
organization and its people were praised for the 6
ability to address and resolve difficult issues in 7
licensing and operations and they felt as work on 8
SSFIs and design basis reconstitution progressed they 9
would need that to continue, a good responsive NRC.
10 Many licensees at various organization 11 levels believe that NRC people are competent but they l
12 lack the knowledge and experience needed to perform 13 inspections in some areas.
Primarily the area they 14 mentioned was our ability to analyze management 15 systems and evaluate management.
Another manager 16 stated that resident inspector staff lack important i
17 technical knowledge, evaluation-techniques and 18 communication skills.
Many of them 'believe that 19 although we're pretty good' engineers, we don't 20 understand the-plants very well and-we're-not as 21 knowledgeable about the plants as their licensed 22 operators are.
Some licensees felt that we should be 23 that knowledgeable.
24 There were a ' number of views that NRC-25 inspectors require a great deal of education and that l
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32 m
.J l
that education turns out to be a
burden on the 2
licensees because-the inspectors are not willing to 3
dig into the drawings and the specifications and so 1
4 forth to educate themselves.
6 That's a
brief discussion of. the ten 6
categories.
If you've seen the report, there are 7
many, many examples.
If you have any questions, Cindy 8
is here to help answer them.
That concludes what I 9
have to say.
10 COMMISSIONER REMICK:
- Bert, I
have one 11 question.
You indicated that licensees spoke 12 positivisly about Commissioner visits.
I've always 13 felt welcome and made to feel welcome-when I went.
i 14 But I know that it's an expenditure of a large number 15 of high level management resources when I do go.
Did
-i 16 you get any comments at all from that standpoint. that.
17 a
Commissioner visit requires-too.many of their 18 resources?
19 MR. DAVIS:
We asked.that and the answer 20 was no.
It was not a major. burden'on them and they i
21 thought that the payback was much more than any affect 22 that it had on them.
23 COMMISSIONER ROGERS:
Bert, did ~ you find.
24 any evidence of orchestration of responses?
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a 33 I
1 kind of industry-wide complaint building that led us 2
to decide that we ought to do such a survey.
Did you 3
find any evidence that the responses that you were 4
getting were canned in some ways --
5 HR. DAVIS:
Not a lot.
6 COMMISSIONER ROGERS:
-- orchestrated more 1
7 broadly?
8 MR.
DAVIS:
I really felt that in most the people were being very sincere and they'were 9
cases 10 telling us what they thought.
There was one group at 11 one licensee where the operations manager came in with 12 the operators.
He dominated the discussion session was going to say.
13 and he had already planned what he m
1 14 That was-orchestrated.
15 Do you have any other --
10 MS. pEDERSON:
Also, one utility who went i
17 to a great extent to prepare what they've documented, 18 approximately an inch thick-their entire 19 presentation.
However, I think' most of them, it was 20 not that well prepared as far'as formally prepared.
2)
COMMISSIONER ROGERS:
- Well, I
wasn't 22 thinking so much of that because it seems to me that 23 that still could be very candid.
The question of 24 whether you're hearing exactly the-same words and 25 exactly the same points at totally different' plants.
r-
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a 34 t-1 DOCTOR MURLEY:
No.
Let me comment on 2
that, Commissioner.
I was somewhat concerned about 3
this before we started.
So, Jim Sniezek and I went after the Commission had approved going-4 down ' to 5
ahead with this survey, Jim and I went down to NUMARC 6
and talked with them and told them generally what-we 7
were
- doing, and asked them not to orchestrate a
8 response because it would defeat the purpose of it.
9 They immediately recognized that that would _ be the 10 case.
So, they talked with their utility members and.
11 agreed to be spontaneous.
I felt on the five 12 utilities that I went to that it was, that there: had 13 not been an orchestration of views.
14
.MR. DAVIS: 'One licensee did' indicate that i
15 some contractor had called them and offered to come 16 and help
- but they didn't take them up on it.
17 COMMISSIONER ROGERS:
Well, we,are a free 18 enterprise system.
Everybody looks for opportunities.
i 19 MR.
TAYLOR:
I believe there was a
l 20 sufficient sprrsd of types of comments that if it 21 occurred, it was very minimal.
22 COMMISSIONER REMICK:
What is the answer
(
23 to the three residents being at a singlesunit utility 24 that apparently had high INPO rating 7.
What's - the 25 answer to that.
r--
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1 MR. T AY I,0R :
I don't know the specifics on 2
that one.
We'll get back to you.
3 COMMISSIONER ROGERS:
Probably overlapping 4
tours or something.
S COMMISSIONER CURTISS:
I have, before we 6
go on, just a couple of questions.
As you look at the 7
findings that this report uncovered and the comments
~
I 8
that the licensees had and compare-and contrast them 9
to the fi4 dings of the O'Reilly report back in 1981, 10 recognizing that it was a different point in time and 11 different considerations perhaps led to the O'Reilly 12 conclusions, are we hearing e lot of the~same comments 13 and concerns or is this just on the spectrum of.new r_..,
l 14 comments versus same old complaints?
How would you 15 rank this survey in the context of.
the O'Reilly 16 report?
17 MR.
DAVIS:
There were a
number of 18 similarities bet ween the findings in both reports.
I 19 think the imposition of
- a. lot of new requirements was 20 discussed by O'Reilly, inspectors not being 21 controlled.
22 What were some of the other ones, do you 23 remember?
24 MS. PEDERSON:
I think the main one Bert 25 already_ hit on was the requirements and the numbers of i
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36 1
them.
We did hear some indication during the survey 2
that some people felt there was initial control placed 3
on the Agency after the 1981 survey, but thaf has 4
somewhat disappeared.
I think that was really the 5
main tbrust.
6
. DOCTOR MURLEY:
I'd like.to add a-comment 7
and then perhaps Jim.
8 There are, to my mind, two differences 9
between the situation now in this survey and the 10 situation in 1981 in that survey.
Even though some of 11 the individual comments were the same, - in 1981 the i
12 problem was viewed
- strictly, almost totally as a.
13 Headquarters problem out of control.
The Headquarters W
14 staff was out of control at issuing new requirements.
15 This time 1 think, although there was still some of 16 that, the theme was that the regional inspections are 17 "out of control."
So, to me. there was that i
18 difference, 19 The second thing is'I heard from at least 20 a
coup) ntilities and I've heard' them in other 21 conversutions that in 1981 the industry. felt that 22 there was almost a crisis in terms of them being.able 23 to stay on-top of or-even up.with the massive 24 requirements - that were coming out.
Last year, they-25 did not feel it was a crisis.
I didn't hear anyone 1
E
- i. _
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4 l
37 1
1 say that.
Did you, Bert?
But they felt that it was 2
something that needed to be addressed.
3 My own view is that the industry is much, i
4 much better prepared now.
Their staffs are much S
- larger, they're
- stronger, they're more capable of 6
dealing with the regulatory situation.
That's partly 7
the explanation.
I did kind of-Jus t 8
But if I had. to 9
summarize my thoughts and views.
Those were the two 10 differences I noticed the most.
11 MR.
DAVIS:
We did have one senior 12
- manager, Tom, who made a statement similar to the 13 major conclusion that was reached in the 1981 report 14 and that is that the amount of requirements was a 15 safety problem of unknown dimension.
It was along 10 those lines.
That was pretty much the theme that Jim I
17 0'Reilly had come up with in the 1981 survey.
I 18 MR. TAYLOR:
That was maybe one manager.
10 I think that was a predominant theme out of that early 20 survey.
I think that we in the Agency who were here i
21 and working then looked at what had happened in the 22 post-TMI period when
- many, many requirements were-23 being imposed through the TMI action plan.
It became 24 quite clear that that was the predominant message.
i 25 The inspection program at that time and the resident-r-
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1 inspection program was new and in its earliest stages.
2 The inspection program was being adequately revised.
3 So, I think there are differences.
It was a much--
4 that was the beginning - of the resident program.
It g
5 really got going after TMI.
6 So, although it was some of that, I agree 7
with Doctor Murley that I _ don' t think we got out of 8
this survey the same crisis sense.
There was a broad 9
opinion of the proliferation of requirements back in 10 those early 1980 days.
11 COMMISSIONER CURTISS:
One other question.
12 I
- realize, 11 e r t,
that you just recited sort of an 13 objective summary of what you heard without any l
'a 14 conscious effort to reflect upon-the correctness of 15 the observations.
I guess one of the questions that 16 I've always had as I've gone around to the sites and 17 comments have been raised. I find on occasion that the 18 comment or the concern that is raised by a licensee 19 will be in large part because of the lack of the 20 licensee's knowledge or understanding..
You touched on 21 a couple of them.
The fact.that generic. letters go 22 through the CRGR-process,
for instance,'you alluded 23 to, wasn't very well understood.
24 If you look at the range of comments that 25 you got in this survey and recognizing that you 6-NEAL R.
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1 haven't yet put a spin on them, would you care to L
2 comment on maybe where the emphasis-was, comments that 3
- were, when you get down to it, a
legitimate and 4
objective and well considered critiques of the way we s
5 do business versus comments that reflected perhaps.
6 less of an understanding about the way the process in 7
a particular area worked or what the framework is in a f
8 particular aren?
9 MR.
DAVIS:
I guess I believe that the 10 majority of the comments that were made were probably 11 good comments, in spite of the fact that we couldn't 12 in many canos get good examples.
If.I were to go into i
13 the appendix of the report-I think, and go through
.y 14 and say, "Yes, this is right," or, "no, this-isn't," I 15 think the majority of them, I would say,-were probably.
16 right.
Therefore, the corrective actions that ~you'll 17 hear about later are appropriate to take.
18 COMMISSIONER-ROGERS:
One question I have.
i 19 You focused your remarks, Bert, on the 13 plant study.
l 20
- Now, have you got anything. to say about the more i
21 ganeral survey that was done, the-Generic Letter 90 22 that looked at the licensee management involvement in l
2a inspections and audits?
It seems to me.that some very 24 interesting observations-could be made on the data l
25 that came out of that little survey..
I wonder-if you i
(
l
~
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40 1
would add anything to do that.
s _
1 have any --
2 DOCTOR MUHLEY:
Yes.
That was conducted 3-primarily by the Headquarters staff.
There were two that Bert has mentioned.
4 other surveys besides the one 5
As you said, Commissioner, there was a written survey 6
of all licensees asking for their. views on how much 1
j 7
time the senior management -- well, all the management 8
of the utility and the plant spent on responding to.
~
t 9
NRC and other outside auditors.
That survey did come 10 back.
It was, I
th~ought, quite interesting.
It 11 showed that perhaps 25 percent of their time, from the 12 plant manager to senior managers on site, was spent 13 responding to outside influences.
The NRC portion of i
14 t h..., as I recall, was only about perhaps ten percent, i
i 16 not the full 25 percent.
16 00MMISSIONER ROGERS:
Well.. yes,
of the 17 total time, but of the inspections it was less than 18 hulf senior management time.
Of the -time devoted'to 19 inspections, it was less than half.--
20 DOCTOR MURLEY:
That's correct.
went to NRC 21 COMMISSIONER ROGERS:
22 inspections.
23 DOCTOR MURLEY:
Right.
24 COMMISSIONER ROGERS:
As a matter of. fact, 25 supervisors, it was 70 percent was non-NRC involved.
7.__
L -
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e 41 I-1 So, it seems to me that this.very interesting concern, 2
legitimate concern that we have if we're concerned 3
about the impact of inspections, excessive numbers of 4
inspections or excessive time spent on these things, i
5 then I think we need to look at all of them, not just if something can be done 6
NRC, and perhaps try to see 7
to alleviate that total burden because less than half =
8 of the time spent on top-management or middle 9
management on these inspections' is related ' to NRC' 10 activities.
11 DOCTOR MURLEY:
Yes.
That survey, as well 12 as the survey -of the staff that the Commission asked 4
13
.us, I
think we've taken all of those into 14 consideration here in our thoughts and in our
- ~
15 recommendations on where we - go.
Should I move into 16 that area now of --
17 COMMISSIONER CURTISS:
Just one other i
i 18 quick question, Tom, on the survey that you did and 19 that Commissioner Rogers has referred to.
As. you-i 20 break down in Table 1 the total impact of the various l
21 inspections, EPA, OSHA, the insurers and so forth, and and I think our interesting 22 then in more detail s
23 attachments talk about what, for example, the average 24 NRC team inspection occurs 4.6 times' per year, 6.7 25 people lasts about. ten - days- -- is there anything in-i r-NEAL R.
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I the statistics that came out of that that from. an 2
inspection perspective surprised you or that indicated 3
that things were-significantly different then-you 4
thought they were as you during the course of the 5
- year, for
- example, evaluate and assign inspection G
resources?
7
-DOCTOR MURLEY:
I personally expected an 8
outcome like this.
9 Let me ask Frank Gillespie if you have any 10 thoughts or insights from-this, 11 MR. GILLESPIE:
I think.the insight we got 12 from the combination of the three surveys was not 13 necessarily that the objection was to the 4.6, but the 14 objection seemed to come at particular sites when, for 15 whatever
- reasons, we'd pile
.up three of our 16 inspections a long with an ' INPO one.
Inspections, 17 when I cover that, we focus now very-heavily on how we 18 pace these inspections to a SALP period and how do we 19 get early feedback if we're going to collide with some i
l 20 other planned activity from a thirdL. party, because we l
21 do recognize that the impact from the third party, 22 when it coincides with
- ours, is a very important' 23 consideration.
l 24 So, it's not the number as much, I think, 25 as the scheduling that we've'tried to focus on here.
l L
u _
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1 43 I
Okay.
1 COMMISSIONER CURTISS:
2 COMMISSIONER REMICK:
I'd like to pursue 3
two points before we leave this subject.
4
- Tom, I
agree in generel-with.
your 5
characterization of the difference between the earlier 6
survey and this one except for where -you said the 7
carlier one was primarily Headquarters out of control, 8
second region out of. control.
The area where I---
9 DOCTOR MURLEY:
That may have been --
10 COMMISSIONER REMICK:
Yes.
slightly an' 11 DOCTOR MURLEY:
12 overstatement.
13 COMMISSIONER REMICK:
The point I'd like l
14 to make, and the area where I would disagree is in the-15 team inspections.
In my going around to the regions 16 and talking to regional staff, as well as some input
(
17 from licensees,
'it's a
question of the-team 18 inspections which are Headquarters types of 19 inspections.
I get the sense that-once we establish 20 teams, they have to'have something to do.
'So, there's 21 a tendency for them to call the region and say, "We 22 have a team available.
Where would you like them to 23 go in the next two weeks?
That was. one area which 24 came out in the survey where we are really utilizing-25 licensee resources in team-inspections.
I f
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s -
1 So, when we come to~the subject of talking l
2 about improvements, where we talk about controlling 3
inspections, I think we also have-to consider very j
i 4
carefully the need f or some of th'ese team inspections.
j i
5 Once we get them going, do they perpetuate themselves?
l 1
6 Do we have people that are dedicated to this and 7
therefore they have to find something to do?
l 8
One other
- comment, going back to
- you, 9
Bert.
You mentioned something like' maybe licensees 10 don't understand or agree.with our safety goals and I i
11 can't help out ask the question do we, meaning the j
12
- Agency, understand and agree with our safety goals?.
i 13 In other words, it isn't Junt a cese, I. think, of-l 14 licensees perhaps not understanding implications, of i
15 that, but iraybo we don't fully understand what that f
16 means.
Do we put thou on a shelf?
17 MR.
TAYLOP.:
We've corresponded in the l
-I 18 past six months with the Commission on.that.
We're l
l 19 trying to cleave closer to the - guidance which the
.l l
20 Commission agreed to for safety goals, for the CRGR 21 and so forth that were, I think, the measure --
I 22 COMMISSIONER REMICK:
I'd appreciate'that i
23 if you'd address it.
24-MR.
TAYLOR:
l' don' t think we're there, 25 but 1 think we're.trying to take the measure-more than r-L.
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we have.
a 2
COMMISSIONER ROGERS:
Well, it seemed to 3
me from just reviewing these. = comments and thinking 4
about them just only a little bit that maybe they were 5
asking for something else in how safe is safe enough, 6
rather than --
7 COMMISSIONER REMICK:
I think' it's 8
something very simple.
9 COMMISSIONER. ROGERS:
Something simple, 10 less global, more practical that they could turn-to in 11 making decisions.
And that our -clarifying our 12 position witIn respect to the safety goals, of course, 13 should be something ' that we do complete, but. that i
14 that's not exactly what they're looking for.
15 COMMISSIONER REMICK:
I would agree with 16 you, Ken.
17 MR. TAYLOR:
I believe that the fact that i
18 as we've continued the efforts to identify those j
19 utilities or plants that are-having operational 20 difficulties for whatever the reasons and causes, I'm 21 reminded that we have - seen the problem plant list 22 decrease.
I look at that as a positive sign and also 23 an attempt by the management to.not over react:to some and 24
-what I'll call normal problems, but to~ try to 25
' plants have improved.
I think that's the tie.
I r-NEAL'R. GROSS j
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r-s _
1 believe as plants improve their performance and have 2
been removed, that's a sign that we're acknowledging 3
that it's okay in whatever way we're able to do that.
~
CHAIRMAN CARR:
All right.
Let's proceed.
4 5
DOCTOR MURLEY:
We'll address some of 6
these issues as we get into improvements as well.
7 The staff survey that was done of.our own 8
staff in SECY-90-250I would say generally confirmed the broad findings with a few different examples and a
(
9 10 few changes.
But by and large, it was, I would say, 11 the same lessons.
12 Some activities -to address these areas ongoing independent of the survey.
That is, we'd 13 were 14 had SALP program revisions underway.
We had backfit-i 15 training underway.
We had team lesder-training.
For 16
- example, the maintenance tenm leaders were trained.
17 All this was being done.
So, we have some of the 18 improvements dealing with the problems that we've 19 found on the survey had already been underway.
20 But : we felt that more was needed.
So, 21 we've collected -- more was needed - in three areas.
22 The quantity of NRC' requirements is the first one.
23 The second-one is the amount of' NRC on-site 24 activities.
And the third area, broad area, are the:
25 int eract ions. between the NRC staff and the licensee e-u -
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personnel.
1 2
There's a
viewgraph entitled number 1,
3 cumulative effect of NRC generic requirements.
Here.
and we - use - loosely " generic 4
we're not talking 6
requirements,"
the phrase.
We're not tal' king of i
6 rules, license ' amendments or orders.
A better phrase 7
would be probably "NRC requested safety enhancements 8
as developed in bulletins or generic letters,"
or 9
something.like that.
10 Bill Russell and his staff are developing 11 some innovative ideas on how to deal with this and 4
12 l'Il let Bill discuss this one, 13 MR.
RUSSELL:-
With respect to the r--
14 cumulative effect of generic requirements, I'd like to
'~
15 break this into two broad areas:
those things which 16 relate to identification, evnluation, communication 17 and promulgation of a new requirement, the front end 18 of the process; and then those things which relate to 19 the back end of the process, that' is the ~ licensee's 20 implementation of these -requirements which' pass the 21 backfit test.
22 In the- -area of identification of 23 requirements, we are-now, and have been'for some time, 24 prioritizing generic' issues.
We promulgate semi-25 annually NUREG-0933.
We are also' coordinating from NEAL R.
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1 the standpoint of exchange of information with 2
- industry, with biweekly correspondence with-the 3
Institute of Nuclear Power Operation.
And as Mr.
we are. incorporating into the CRGR 4
Taylor-mentioned, 5
process and the staff review of potential new 6
requirements the safety goal as we relate to our 7
evaluation and review.
8 At the end of that process, we feel it's 9
important to articulate concisely in the.
new-10 requirement when it's issued the reason.
Is this a 11 cost effective backfit?
Is it required to ' achieve 12 adequate protection, or is it required to comply with 13 NRC rules, regulations that already exist?
We are r.,
14 clearly articulating that in communications that 'we,
15 issue at this time.
16 Doctor Murley mentioned the backfitting 17 workshops.
We actually have an AEOD study that was l
18 ongoing that looked into the backfitting' process.-
19 There is a NUREG-1409 on backfitting guidelines, and 20 the workshops have two audiences.
One is internal to 21 staff to make sure-the staff understand the process, 22 and the second audience is
- external, to get the 23 information out to the industry.
24 The third aren which' relates to the 25 quality of regulatory.
- analyses,
'Research has u.-
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1 activities underway to revise and update the value 2
impact handbooks.
3 All of those address improving the quality 4
of the staff's evaluation leading up to the issuance 5
of a new requirement.
6 The area that has not been handled well, 7
and we've had earlier attempts at handling it, is the.
8 back end of the process.
That is when it gets down to 9
a specific licensee.
We had an integrated safety 10 assessment program which was a follow-on to the SEP 11 which develops new techniques for looking at numerous 12 requirements in a generic way.
It had some elements 13 to it which caused it to not be endorsed by a number i
14 of utilities.
It was'a voluntary program, required a 15 plant specific safety
- analysis, required factoring 16 operating experience-in and also it required 17 addressing some of tire specific technical issues that 18 were lessons learned from SEP.
19 We had a
second effort-at trying t'o 20-control these impacts,
the living schedules or the 21 integrated schedule activities.
One of the 22 shortcomings -with that was :that it was a requirement 23 to incorporate licensee = initiatives into that and it 24 got some type of
- a. regulatory stamp on it once you.
2C were through with it.
So, licensees did not, by.and I
i J
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1 large, endorse that.
2 The staff has conceptually developed what 3
we call the regulatory requirements implementation 4
schedules.
This would be a voluntary program with 5
licensees.
Conceptually, it would be a
periodic 6
review on the part of a licensee of those things 7
required by NRC which do not relate to meeting an -
8 adequate protection standard or compliance with 9
existing rules and regulations, broadly 51.09 backfit s.
10 They would be reviewed and prioritized based upon 11 their safety value and consideration of impacts',
12 scheduling other things gcing on,-
- time, et 13 cetera.
14 1,icensees would then propose to the staff, i
15 and I'll use the example of a one year cycle, but 16 propose approximately one year be-re-the outage which 17 items would be implemented during that :next outage.
18 The staff would then have n period of time for review 19 and absent a negative finding by'the staff within say 20 60 to 90 days, that schedule by.the licensee would 21 become frozen.
It would constitute agreement that 22 those. items' would be the items to be-implemented 23 during the next outage and no others would be added.
24 This would provide stability in planning during the 25 period of time when engineering and-other activities r-L -
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1 of the licensee are focusing on the next outage.
The 2
process would then be updated,- depending upon the-3 scheduled refueling cycle, every 12 to 18 months.
l 4
_That's essentially the concept.
We are 1
5 looking at a pilot program because clearly the key _
j 6
issue is going to be how you prioritize based upon
[
i 7
safety and significance and how we develop guidance l
8 back for the staff to conduct those reviews.
We would i
0 like to keep it in a negative consent context with the 10 licensees proposing land, absent-staff objection, that
}
i 11 would become the schedule.
12 We're looking at a
pilot program that 4
13 would involve licensees from each of the regions to
-. q 14 work over a
period of 18 months to ' two years to 15 develop that guidance by actually using it.
That is, f
1G develop it, try it on a
pilot
- basis, and then 17 formalize that. guidance for project managers such that 18 the program could be implemented more broadly.
We 19 feel that this will control the impacts of
')
20 implementation of new requirements and get those 21 implemented earliest which have the greatest potential' 22 safety benefit for that particular licensee.
23 COMMISSIONER CURTISS:
Bill, before_you go 24 on, just a couple of mechanical questions on what you 4
.f 25 propose in _here.
_You indicated ' that the previous I
q i
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1 programs ISAP and totegrated schedule hit the shoals 2
because in the case of ISAP a PRA'was required, in the 3
case of integrated schedules' it was part of the or was viewed to be part of the operating 4
license 5
license.
Is this going to require either of those G
two?
7 MR. RUSSELL:
No.
Since all licensees are 8
doing PRAs essentially to support the IPE process, 9
with one exception, they would have the tools to do 10 the integration, to judge them.
-In fact, I've spoken--
11 to one licensee'to determine whether he felt that this 12 proposal that the staff was looking at would be 13 responsive to the broad concerns that. had been 14 described in the regulatory impact survey.
The long way to doing that.
15 feeling was that it would go a 16 It would provide stability for planning, would not 17 impact engineering resources at a time when they're 18 critical-because you would have reached agreement on 19 those things to be done in the next outage.
20 There is a
potential that some items-21 through this process, if you go through it, the items 22 that are on the bottom of the list -that are not 23 particularly safety significant. on that f acility-may 24 not be done and that some items may have very extended j
25 schedules on some facilities because we'd be i
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53 t-1 prioritizing on a
plant-specific
- basis, not 2
necessarily to complete all of ' a particular. item to 3
get it off of our books.
4 COMMISSIONER CURTISS:
- Now, conceivably, 5
that would be true for so-called backfits that we 6
impose through regulation.
If, as a generic matter, a 7
regulation makes it through the CRGR processand the 8
Commission says, "Go out and require hardened vents 9
for all MARK-1 containments,"
for
- instance, this 10 plant-speci fic evaluation under this
- program, I
L 11 gather, could lead to the conclusion.that requirements.
i 12 imposed with the regulations might not be of 13 sufficiently high priority toward doing and could
'J 14 threfore be dropped?
15 MR. RUSSELL:
No.
As I commented earlier, 16 this applies to those things which are not required 17 for compliance with the regulations-or for-an adequate 18 protection standard.
In the instances =
you've 19 described, that may provide a basis for a licensee to 20 request an exemption to not have to. implement that 21 particular regulation.
But we'would not see this as a 22 part of that process.
23 COMMISSIONER CURTISS:- Okay.
l 24 DOCTOR MURLEY:
Yes.
The hardened vent, 25 for example, is really a safety' enhancement and it's i
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I not needed for adequate protection.
It would be one-I 2
of the items we would propose be included in this-3 prioritization kind of scheme.
It's conceivable that 4
as we get ~into this it may.f all down further on the i
5 list than some other important items.
CHAIRMAN CARR:
I think that was the 6
7 intent of Commissioner Curtiss' question.-
It may get t
l
~
8 so low on the priority list, it may never get done, 9
even though it is a requirement.
DOCTOR MURLEY:
That's one area-we have to I
10 11 look at.
I don't think we have a good answer now as 12 to whether some of these might get delayed so long 13 because they're tied to outages, which only come every 1
14 year and-a half.
Could it be delayed so much that you 15 have to ask yourself whether it's worth doing anymore?
16 We haven't really got an answer to that question.
17 COMMISSIONER ROGERS:
Well,-
it's the 18 classic problem that you.always have when you 19 prioritize.
20 DOCTOR MURLEY:
Yes.
e 21 COMMISSIONER ROGERS:
There's always l
1 22 something at the bottom.
How do'you ever get at those 3
23 things?
The usual way is that you add-- another 24 category.
You pick a certain. number of-those'end you 25 Just do them every now and. ' then,
regardless of the r-6.
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1 fact that they're low priority.
Otherwise you'll 2
never get to them.
You'll always have this--
3 something at the bottom that -never gets tended to.
l-4 Although everybody agrees it should be done sometime, 5
it just never gets done.
It's just the classical-G problem of prioritization and-there are standard ways 7
of doing that.
8 The 18 to 24 month pilot program, when do 9
you expect that to begin, Bill?
10 MR. RUSSELL:
We'll get to the point, but 11 I would expect it after we've received public comment 12 back on the paper.
I'm getting into Tom's-conclusion 13-somewhat.
So, if we can defer that until my boss has
~
7.__,
J 14 given you sort of a punchline from the1 presentation.
15 COMMISSIONER ROGERS:
Okay.
Fine.
I'm 16 happy with that.
But this program, is this focusing 17 really on just those items which would.be done during 18 an outage?
Is. that where you're starting?
Do - you
~ 19 expect it to --
20 MR. RUSSELL:
There are things that can be 21 done between outages.
It turns.out that the impacts 22 of those are quite -small.
We had the Gent i.
23 Communications Branch look at items which we 24 imposed that would be subject to this kind o2 25 prioritization.
We looked at whether they could be i
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1 implemented on-line or during out' ages and we 2
arbitrarily assumed if it was an outage they would be 3
done at one time.
We used May and then we spread-the 4
others uniformly.
5 The
_ impacts during' outages by far 6
dominated that which could be done and we use the 7
results from our regulatory analyses in supporting of 8
these as to what the impacts were.
The impacts, when 9
converted to dollars, were on'the order of $100,000.00 10 per month during operation and they were in the. few 11 millions during outages.
- Again, this is regulatory 12 dollars.
We need to improve that process as well, to i
13 make sure that we are measuring.them the same way.
t-14 But even by our own analysis, we showed a significant 15 burden during outages and less so during operation.
16 CHAIRMAN CARR:
What's really going to 17 happen here is you're going t o -- the things that 18 require an appreciable amount of time are going to 19 coincide with those outages that the utility already j
20 requires an appreciable amount of time, like a steam-21 generator replacement or something that-requires a-22 whole focus'and you're going to stuff more into that 23 because it's a longer one.
So, it'scnot going to be 24 easy.
25 MR. RUSSELL:
We envision that there may i
i_
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t 1
be items that the utility wishes to do or needs-to do-2 that would have significant impact that would make the 3
list shorter during a particular outage and that is 4
part of the reason for developing the criteria.
If a 5
major item such as a steam generator replacement was G
planned, then the amount of activity you could conduct 7
inside containment is going to be very limited.
That 8
may be the basis for reducing or - scheduling other 9
items until later.
10 COMMISSIONER CURTISS:
The-focus on the 11 outage-related aspect of this seems to suggest that 12 this program, this IRRIS program I guess, is primarily 13 hardware related.
Is~that a correct conclusien?
14 MR. RUSSEl.L:
Not necessarily.
When' one 15 implements. changes to emergency operating-procedures, 16 for example, if you were going to go from one revision 17 to the next revision, the ideal time to do that is to 18 train the people and start up from. an outage with i
19 that, so you don't have different crews with different 20 levels of understanding about the procedures that are 21 in use.
So, procedure, programmatic changes could.
22 occur.
If it were a change in your.-work procedure or 23 work controls that we would require, you'd clearly 24 want to do-that when you're on-line and not in the 25 middle of an outage to change your'mechaniam for work
.\\
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a 58
- 7. _
i) 1 control.
2 Each one would have to be looked at, but the area that we see needs controlled l
3 the emphasis r
4
_ outages.-
5 COMMISSIONER CURT'iSS:
Take one that's not 6
so logically related to an outage like Part 20, for
~
7 instance.
I guess you could conceivably do it any 8
time and which would fall unde, this program because adequate protection requirement the way 9
it's not an 10 we've approached that.
I guess what you're saying is 11 that this program wouldn't result in the scheduling of 12 Part 20 changes at a given plant if they fall within 13 the outage, within the scope of things done during an 14 outage?
15 MR. RUSSELL:
I'm not able to address the 10 Part 20 example explicitly.
But for other examples, 17 for instance what the staff has ongoing now in the 18 area of motor operated
- valves, with-the generic 19 letters that we have, with the programs that are being-20 developed, there may be thinga that can be done to 21 complete a portion of that program during an outage.
22 There may be other things that are done 'by way of 23 analysis during the course of a year.
Those schedules 24 for how much is done during.that review could clearly 25 be incorporated into-this program.-
Some things may be l
1
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$9 r-I do. e during the year, others will be deferred to an 2
outage.
3 CHAIRMAN CARR:
Isn't this really a
4 formalization of what's been going on informally 5
anyway?
6 MR. RUSSELL:
I hope so, yes, sir.
7 CHAIRMAN CARR:
I would assume that we're 8
talking to the utilities about what
? hey're doing I
9 during their outages and what 10 DOCTOR MURLEY:
Yes.
But this goes a 11 little further than that in the sense that this allows 12 us to take into consideration things that they may 13 find more important and even more. safety significant 14 that are their own initiatives.
They I
think la uniformly told ut, that their own initintIves tske back 16 seat to NRC initiatives.
One that comes to mind.and 17 1 can't remember who told us this, but the recording 18 charts in a control room needed to be really replaced l
19 hecause they were so unreliable, they were out of 20 service a lot.
Yet they never were able to get around 21 to it because they were slways working on something 22 that NRC required that probably is not as safety 23 significant.
When we put thos's on the same kind of 24
- chart, we may agree with them that ours could go 25 further on down the list.
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1 CHAIRMAN CARR:
Then I'm surprised they 2
haven't-been bringing it up before.
3 DOCTOR MURLEY:
- Well, they acquiesce, as 4
Bert said.
5 MR. RUSSELL:
We also have cases where the 6
staff has accepted longer schedules.
You've seen that 7
in our recent paper on some of the TMI items where a
D schedules have slipped because of other things going 9
on or licensee's ability to implement the changes.
10 COMMISSIONER REMICK:
Before going on to 11 the next improvement, I've always been disappointed 12 that the ISAP and living schedule weren't more 13 successful.
So, I really hope that the IRRIS program i
14 is successful.
15 One other comment I wanted to make, you 16 were talking about reviting the value impact handbook.
17 I
think that the Office of Research will be doing 18 that.
I hope they're cognizant of a government-wide 19 effort looking at value impact and use of risk l
20 assessment.
21 I
brought along with me-today a
very 22 recent OMB report.
I'd just like to, if. you' d bear 23 with me one minute, read three observations that I 24 think we should carefully consider when we do our 25 value impact, r-i- __
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1 It
- says, "The continued reliance on 2
conservative or worst case assumption distorts risk 3
a s s e s s a ti n t,
yielding estimates that may overstate 4
likely risks by several orders of magnitude."
5 Another observation, " Conservative biases I
6 embedded in risk assessment impart a
substantial 7
margin of safety.
The choice of an appropriate margin j
8 of safety should remain the province of responsible 9
risk management officials and should not be precepted 10 through biased risk assessments."
T 11
- Third,
" Conservatism in risk assessment 12 distorts the regulatory priorities of the federal 13 government, directing societal resources to reduce I
14 what are often trivial risks while failing to address 15 more substantial threats to life and health."
16 I
think it captures some of the things 17 that Bert talked about here and what Ken and I were 18 talking about.
It isn't so much understanding the 19 safety goals, it's some of the things we en.ph a s i z e to 20 cause resources to be utilized and therefore ruources 21 aren't available for the more important safety 22 significant type of things.
23 So, I
would just ask that Office of 24 Research, if they're not already familiar, be familiar 25 with what has been done. and is being done by the r
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1 Office of Science and Technology Policy in this area 2
government-wide.
They're particularly critical of EPA 3
on inconsistencies.
4 COMMISSIONER CURTISS:
I just have three 5
other quick questions on this.
I gather the first 6
step in this process is for us to go through and list 7
all the requirements other then the adequate 8
protection requirements that t,re applicable to a given 9
facility.
Do we have that list today for plants or is 10 that something that we would have to prepare?
Could 11 we go to, say, Plant X is Region III and pull out a 12 list of things that are all considered generic 13
- letters, information
- notices, regulations, resident 14 inspector preferences, that kind of thing, and put 15 together a list of things that we are expecting the 16 licensee to do?
17 MR. RUSSELL:
We have pieces of the list, 18 clearly those things which are unimplemented, and we're 19 tracking them through the safety issues management 20 system.
We have also the NRR process, the WIr program 21 which includes those things which are requests from 22 licensees that are not yet implemented where you 23 follow implementation of generic letters, bulletins, 24 things like that.
So, they are in different places 25 and there may be some that a licensee would propose to I
u -
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I be considered that may be a fullout of an inspection 2
activity which may fall into that category.
3 So, we don't have a list consolidated at 4
this point in time, but we believe we can identify 5
such a list 6
COMMISSIONER CURTISS:
That's the first 7
thing we'd need to do.
and that would be the 8
MR.
RUSSELL:
9 first step in the activity.
10 COMMISSIONER CURTISS:
Then we send it off l's 11 to the licensee a year ahead of time and they 12 sorry, we send it off to the licensee and they take 13 all the things that they'd like to do and they plug it y
i 14 in and they give it to us a
year prior to the
~
15 refueling outage 7 16 MR. RUSSELL:
If the licensee proposed to 17 identify some things that they wished to do that were 18 higher priority and that constituted the basis for not 19 doing something that was on the regulatory 20 requirements
- list, we would accept that.
But in 21 general, it would be an activity to prioritize those 22 things which NRC has required only.
23 COMMISSIONER CURTISS:
And then during a 24 certain period of time after.we get that, unless we i
25 object, sort of a negative consent posture, then the t--
i NEAL R.
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)
1 requirements to be addressed at the upcoming refueling i
2 outage would be set?
3 MR. RUSSELL:
That's correct.
4 CilAIRMAN CARR:
We keep throwing the word 5
" requirements" around in this.
You've got to remember 6
these aren't requirements per se.
Some of them are 7
requests for safety enhancements.
8 COMMISSIONER CURTISS:
Anything other than 9
adequate protection requirements, I guess, is what I'm 10 using that to refer to.
11 Just a critical path question.
The scope 12 of the outage for some of these licensees is set quite 13 e ways ahead of Aime.
Are we on the critical path for 14 setting the scope under this program, or is it going 15 to be far enough ahead of time that we'll be off of 16 that?
17 MR.
RUSSELL:
We think generically the 18 licennee should have probably on the order of two 19 outages to implement the requirement.
If someone 20 chose not to volunteer to participate in-this kind of 21 a program, they would generally have a two outage 22 window to implement the regulatory requirement.
The 23 prioritization, the consideration _ of your activities 24 with staff activities would only accrue to a licensee 25 that participated in the IRRIS program.
r, s.
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1 COMMISSIONER CURTISS:
Okay.
One final us you have a
sense yet of what the 2
question.
3 resource impact of the program will be7 4
DOCTOR MURLEY:
We've talked about it.
It 5
could be a fairly substantial impact to start up for G
the staff because, for example, we'd have to give the 7
staff guidance on priorities.
We couldn't have one 8
project manager
- saying, "This is important,"
and 9
another one saying it's not important.
So, the 10 management and the staff is going to have to develop 11 some guidelines on how to implement this program.
12 CHAIRMAN CARR:
But it's not inconceivable 13 it could be more important at one plant than another
)
14 one.
15 DOCTOR HURLEY:
That's possible.
That's 10 possible, yes.
17 So, that's why, Commissioner, we'd like to
,18 do the pilot programs first, so we don't undertake 19 something without fully knowing the impact on us.
20 COMMISSIONER CURTISS:
I think it's a--
21 l'm pleased to see that you're recommending something 22 like that.
I guess the comment that I've heard most 23 frequently as I've gone from site to site is it's 24 difficult to drink from the regulatory' fire hose.
You 25 need to have a sense of what's important and what's NEAL R.
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1 not.
Not just in terms of what we require or request, 2
but in terms of what the licensee also thinks is 3
important, the strip recorder chart example, Tom, that 4
you gave.
So,-the concept here that you've developed, 5
it seems to me, is a most interesting one and I hope 6
it works.
7 Having said that, I hope we can approach 8
it in a way that addresses the apparent shortcomings 9
of the two previous efforts, ISAp, which I too was 10 disappointed hasn't been pursued, and the integrated 11 schedule program.
For those licensees that repeatedly 12 expressed concerns like this, and there are a number 13 of them, that they'll know that they have this program U
14 available to them to pursue.
15 DOCTOR MURLEY:
Yas.
10 MR.
GILLESPIE:
Commissioner, let-se 17 clarify one.
We do have a list for every plant and 18 project manager report.
It's all generic letters, 19 bulletins and rule requested actions and their 20 implementation status, as well as a reference to any 21 correspondence that's come in on when they said they'd 22 have it implemented.
23 COMMISSIONER CURTISS:
Okay.
24 MR.
GILLESPIE:
So, we.today have the-25 list, but it doesn't include compliance items'that are
- i. __
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o 67 r-1 developed in tts region.
It's strictly the regulatory 2
actions we requested generically.
i 3
COMMISSIONER CURTISS:
Okay.
4 DOCTOR MURLEY:
Let me move on then to a 5
second area where we felt improvement was needed.
6 This is scheduling and control of inspections.
It 7
gets to, at least
- partly, the comment that 8
Commissioner Remick had on team inspections.
9 The view that we got uniformly, I believe, 10 and hert can help me, was that the licensees feel that 11 team inspections are better quality inspections than 12 individuals coming out one at a time.
They were most 13 concerned about the impact that the team was having on 14 utilities management and this is perhaps the most
~
15 straightforward one to deal with.
We have taken step 6 16 in the pant year to deal with the problem that you 17 mentioned, of Headquarter's teams looking for work out 18 in the regions.
I don't think that is going on now.
19 Still, if it is, we'll take steps to fix it again.
20 Frank Gillespie's going to talk about this 21 issue.
22 MR. GILLESPIE:
To give you a background, 23 following the reorganization and folding-in of ILE 24 into NRR, we looked at the program and did somewhat of 25 a
restructuring, and the restructuring along the r
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e 68 s-1 philosophical of those plants which presented the 2
biggest safety
. problems should have the avat 3
inspection.
And that was kind of our in-going 4
assumption.
5 Since
- then, our most current list of 6
inspection hours per plant shows that we're spending 7
in a range of from 2,500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> in a 32 month period at 8
our least inspected plant or unit to about 10,000 9
hours nt our most inspected
- unit, which is a
10 significant change from three years ago.
So, we now 11 do have a spectrum and it's not a step function.
If 12 you sort these by least to most, you'll see a fairly 13 smooth curve, so it's not dominated by the high end or I
14 the low end.
There is a definite transition.
So, I 15 think the regions and Headquarters working together 16 have made some significant progress as far as the 17 distribution of effort relative to safety.
18 This last year we made a major change in 19 the programmatic operating plans the regions have that 20 NRR concurs in, which has these same elements as a 21 higher level objective for the regions to reach in our 22 program.
So, we are now going with some success, 23 which means when you do go up to some facilities and 24 they say that we're getting all this inspection, they 25 may in fact be very, very right.
Introspectively,.
I mJ NEAL R.
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69 I
they should ask why are we getting all this 2
inspection, because there are some facilities which j
3 basically have only the resident at the facility.
4 In doing this restructuring we came up 5
with the master inspection program, which was merely a 6
tool.
It's a
computer
- database, but it has the 7
regions and Headenarters all working together to keep 8
track of in the end what is a site-specific activity 9
schedule for each site of all NHC activities in 10 addition to NRC activities the regions do put on them, 11 when they expect to have major INPO visits we happen 12 to know about, unjor refueling outages, Commissioner 13 visit s. So we're starting to get a very, very good are and how 14 handle collectively on what our activities 15 we're planning them.
16 The next extension to this internally is a 17 speed limit, I'll call it, and this is being developed 18 right now between the ED0's office and NRR and the 19 regions, starting with the ED0's field policy manual.
20 words to the effect that we would foresee no more than 21 four major team inspections at any facility during a 22 SALP cycle unless the deputy regional administrator and 23 our associate director for projects confer. on it and-24 decide that, yes, this is a plant that falls into that 25 higher end, that bigger safety problem.
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1 CHAIRMAN CARR:
What do you define as a 2
major inspection?
3 MR. GILLESPIE:
We haven't really put a 4
definition on it.
We've generally viewed it as 5
something that has more than three people, but we see G
the program changing in that we're doing more multi-7 discipline inspections as we have more junior people 8
coming into the program.
In some regions, we have 9
team leaders being assigned and multi-discipline 10 inspections being done in lieu of individual separate 11 inspections, and team leader training is one thing 12 l'Il cover in another section to help provide more 13 supervision for those types of inspections with the 14 senior person.
15 CHAIRMAN CARR:
But there's no doubt a 10 maintenance inspection or a diagnostic is a major 17 inspection.
18 MR.
Oh, that's major.
That 19 fits the four.
That fits the four, yes'.
20 CHAIRMAN CARR:
Well, my personal opinion, 21 four is too many.
Seems to me there's a great degree 22 of overlap in the major inspections, and in my opinion I don't know what you want to call it.
23 you can do 24 but you can do one of those major inspections that's 25 nearly across the board.
And you really do do that.
r --
t u.-
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1 from my viewpoint,
- anyway, the diagnostic and the 2
maintenance have got a lot of overlap, and I think the 3
thoroughness of those major inspections and the 4
follow-up thereafter get most of the work done.
5 So, I
just throw that
- out, that four 6
inspections in a
- cycle, having been on the 7
inspected end and been an inspector, you-can just go 8
from one to another.
I mean, you know, and it keeps 9
you from getting your work done.
I sympathize with 10 those people who have a good number of inspections.
11 And this ignores those little AITs you say. drop in on 12 them because of an incident.
It ignores quite a few as you say, if it's less than three 13 things that we --
l 14 guys, we don't really count it.
We better give it 15 some consideration.
16 MR. GILLESpIE:
Well, the specifies in how 17 to implement this, we hcve a list of team inspections 18
- which, by definition within the program had been 19 developed ne teams, which are the ones we're going to 20 focus on the four.
They include such things as 21 SSOMIs, SSFIs, the maintenance team inspections, EOPs.
22 All of those would be considered major..
You are 23 right.
It does --
24 CHAIRMAN CARR:
That's one every four 25 months or five.
I J
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1 DOCTOR MURLEY:
This is a ceiling, not a 2
- floor, t
3 MR. GILLESPIE:-
It's a ceiling.
4 DOCTOR MURLEY:
So, it may not get to 5
four, but we are dealing with the problem where --
6 CHAIRMAN CARR:
Say it's three.
It's one 7
every five m or. t h s.
I mean, by the time you get the 8
report written, the next inspection is going on.
9 DOCTOR HURLEY:
But in terms of impact on 10 the plant, though, generally it's only the weeks that 11 the team is there, and that's what we wanted to deal 12 with first.
13 CHAIRMAN CARR:
But that extends over as 14 much as four weeks.
15 DOCTOR MURLEY:
it can be four weeks, yes.
16 And we were seeing cases of six to 18 inspections in a 17 year and that's what we wanted to deal with right 18 away.
I think we'll clearly take your guidance.
Four 19 muy be too many, but we wanted to put a ceiling on it.
20 CHAIRMAN CARR:
- Well, I
think the 21 thoroughness and the overlap, I guess,.is what I think 22 are important to take a look at.
23 MR. GILLESPIE:
And I think we're doing 24 that.
I need to emphasize, four, as Tom said, is a 25 ceiling.
We don't have enough resources to do four at u._
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73 I
1 every plant in the country.
It's truly a ceiling.
If 2
someone gets four, someone else only gets one.
So 3
averages can be deceiving.
4 COMMISSIONER CURTISS:
Your average today J
5
- for, let's
- say, an 18 month SALP
- cycle, if 1
6 understand the materials in the SECY paper 205, was 7
about seven per SALP cycle, an 18 month cycle. 4.6 a 8
year, seven major team inspections.
9 DOCTOR HURLEY:
That's the historical 10 record.
11 MR.
GILLESPIE:
That's the historic 12 record.
13 CHAIRMAN CARR:
That's average.
14 COMMISSIONER CURTISS:
That's average, and 3
15 what you're propos'ng here is no more than half'that.
16 CHAIRMAN CARR:
No.
They should average--
17 if four is the max, the aeerage ought to be somewhere 18 around two, I'd hope.
19 COMMISSIONER CURTISS:
Yes.
You're 20 talking about going down from an average of seven to 21 an average of two.
22 MR. GILLESPIE:
The speed limit of four is 23 a significant change'from the historic data.
24 CHAIRMAN CARR:
Okay.
Let's go on.
l 25 MR. TAYLOR:
I think we'll take this into I
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e 74 r--
1 account.
2 DOCTOR HURLEY:
I should say, before we 3
leave
- that, those statistics in SECY
- 205, 4
Commissioner, may include AITs and some diagnostic 5
types.
I'm not sure.
6 Frank?
7 CHAIRMAN CARR:
Okay.
Let's proceed.
8 MR. GILLESPIE:
The last part of this was 9
that we would take this site-specific activity 10 schedule as it relates to what we perceive to be the 11 major activities of the licensee and what we perceive 12 as our significant activities and publish it on some 13 periodic basis, potentially publishing it to cover six 14 months, but publish it quarterly.
Because, our plans 15 within the regions actually get re-reviewed about 16 quarterly to make sure how the regions want to focus 17 their resources and where it's at in order to allow 18 the licensee time to communicate back to the region if 19 they see something that's going to be a
major 20 impediment that we don't know about, in particular the 21 third party type inspections which we may not have.
22 Although the major INpo visits we do have some iden 23 on, insurance visits, state, other things we wouldn't.
24 And that's the end of this area.
25 DOCTOR MURLEY:
Did'you mention the notion 1
i_
1 1
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s o
75 r~d of publishing periodically?
i 1
2 MR. GILLESPIE:
That's what I just said.
3 DOCTOR MURLEY:
Oh, excuse me.
4 MR.
GILLESPIE:
We'd publish it 5
periodically.
6 DOCTOR MURLEY:
Good.
7 CHAIRMAN CARR:
I've got one-question.
In 8
your enclosure 4,
- there, you talk about a proposed 9
process through which an assigned resident inspector 10 staff at a plant with exceptional performance would be 11 reduced to less than N plus 1,
and of course that 12 caught my attention immediately.
13 MR. GILLESPIE:
What we're proposing in I
14 enclosure 4 on that is that much like the staff's 15 proposal on extending the SALP period from 18 to 24 IG months for exceptional performers, that the regional 17 administrator at a similar type exceptional performer 18 that goes through the same process would have the 19 flexibility of using the plus 1 that's assigned for 20 other regional purposes, for engineering inspections 21 or at other planta for the time that that plant is 22 considered to be that exceptional performer.
23 CHAIRMAN CARR:
But you'd leave them 24 there?
F 25 MR. TAYLOR:
Yes.
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e 76 r-1 CHAIRMAN CARR:
I
- mean, you
- know, if 2
there's only one guy there. he can't go on leave.
He 3
can't train.
He can't do anything.
4 MR. GILLESPIE:
Well, yes.
The N plus 1 5
we're focusing on is not the N plus 1 at a single unit 6
facility, which we had in place before we went to sf o 7
into a plus 1 at multiple units.
8 CHAIRMAN CARR:
Doesn't may that.
9 MR.
GILLESPIE:
We've incorrectly 10 articulated our concept.
Our concept was the N plus I 11 at two and three unit sites where we already have 12 multiple people with coverage.
13 CHAIRMAN CARR All right.
Let's go 14 ahead.
15 DOCTOR MllRLEY:
Okay.
The last major 16 hroad area for improvement, and in some ways the 17
- toughest, I
- think, is getting to the question of 18 giving guidance and expectations and training and 10 stuff to our inspectors who, after all, are the ones 20 that are out there everyday interfacing with the 21 licensees.
We have some programs underway.
We've had 22 some underway and Frank Gillespie is going to talk 23 about this item.
24 MR. GILLESPIE:
I think what we're seeing 25 here is a growth.
In the paper itself, it references i
- s. -
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77 r
I a number of courses dealing with interview techniques, 2
how to conduct en exit meeting, which are offered now 3
as optional courses, many of them on a one time basis.
4 The only thing right now that is absolutely mandatory 5
is the fundamentals of inspection course that touches 6
upon how we expect an inspector to conduct himself 7
relative to things like informal backfits, what. he 8
includes and how he phrases things in his inspection 9
reports.
10 What we're proposing here is to take these 11 various courses and training elements that have been 12 developed nnd factor them into a more systematic and 13 mandatory and continuing program.
It would go that I
14 first it would be fundamentals of inspection where we 15 do touch upon what's included in inspection report.
10 This would come normally six to eigi t months into 17 someone's employment with the NRC.
They're fairly 18 junior who generally go out and accompany someone on 19 an inspection.
[
t 20 After about two years into his career, the 21 inspector is more senior, will tend to go out more on 1
22 his own now.
We think we need something more l
1 l
23 advanced, more analytical, more dealing with how he 1
24 should be conducting hirself-with major findings and 25 how he would present things, what our expectations of i
i f
i l
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'i 1323 Rhode Island Avenue, N.W.
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r-78 I
him are and how he would supervise someone else who i 2
s junior with him.
In particular, this would also 3
reinforce the points of the fundamentals inspection 4
because it did come out of the survey that many 5
licensees view an open item as just as severe as an 6
item of non-compliance.
So, how we
- tone, how we 7
articulate and communicate becomes 8
- very, very l
important, particularly as someone gets more senior.
9 Then sometime after that, possibly another 10 year, we'd view doing something equivalent to what we 11 now have for IIT team leader training, which includes 12 videotaping, how to conduct a meeting, how to deal in 13 en adversarial condition, what's acceptable, what's 14 not acceptable rolative to conduct and professional 15 conduct.
16 So, we feel comfortable with the technical 17 competence of our inspectors.
A lot has been done by 18 AEOD in this area for us and for.the program over the 19 last neveral years.
There's been major revisions to 20 our inspection manual chapter covering this to'make it 21 more consistent.
Based on the comments received.. we 22 feel comfortable that our inspectors at a system and 23 plant level are very knowledgeable and very qualified 24 With more junior inspectors coming in, with -more 25 junior people coming in, the need to emphasize and NEAI, R.
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79 I
1 focus on the professional, the conduct, the attitude 2
side of things, how do conduct an adversarial meeting, 3
is very important.
4 The second element to this section is an 5
introspective look that we've taken at what do we 6
expect of a regional section chief?
What do we expect j
7 of the managers in the regions?
Are what they're 8
doing what we expect them to do?
9 An example of this which -- and we focused i
10 a lot on this in discussions is at the section 11 chief level, the first line supervisor.
As he's grown l
12 in the type of job he has over the last ten years, he i
13 now has a
diverse number of people in resident i
14 inspectors.
He's supervising now from a distance.
- ~
15 How does he supervise?
When goes to a plant, does he 16 spend his time working with the licensee on technical 17 issues or does he spend time supervising his staff?
18 The first wave of residents that we had go 19 out, and I was in Region II at the timo, were very 20 senior people.
We're now introducing
- many, many 21
- people, and I've been to several plants this year, 22 with people with less than one year experience.
j 23 CHAIP. MAN CARR:
As the senior resident?
i 24 MR. GILLESPIE:
No, as a resident.
Our 25 experience level is now going down.
So, we want to NEAL R.
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=
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8) s _
1 focus on what do we expect as a section chief and then 2
what do we expect of his manager and how do they 3
supervise their people?
Are we giving them enough 4
time to supervise their people or are our technical 5
expectations of them and what they're doing so all 6
time consuming that they're not having enough time to 7
be out there and making sure that there aren't 8
informal backfits taking place, that the types of 9
communications they're having with the licensees or 10 subordinates are having are the correct types.
11 In
- addition, we'd have an expectation 12 possibly that when a supervisor goes out, he should be l
13 meeting with his peer at the licensee, asking them, U
14 "How is it going,"
giving them an opportunity to 15 communicate back and at the same time dispelling the 10 iden that the supervisor will also carry on the 17 attitude that was seen of retribution.
So, we have to 18 also be responsive.
Even if we disagree with what the 19 licensee says. I think we owe it to him to at least 20 think about it and get back to him and say, "I've 21 thought about that and no, I think my inspector was 22 really on firm ground," in each way, up through the 23 whole
- level, within the regions and within each 24 licensee to promote that kind of communication.
25 It should be interesting to note that c __
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81 R
1 regional administrators and residents were discussed 2
in detail in Bert's survey and there was a relative 3
absence of discussion of the roles of the various peer 4
levels in between.
So, we really would like to focus 5
on promoting the communications at those peer levels G
so that every issue does not have to rise to the 7
regional administrator.
When you take cart of 8
- problems, communication is at the lowest level 9
possible.
This means looking at elements and 10 standards, it means looking at position descriptions 11 and going in and saying, "What do we expect of our 12 people out there?"
This kind of look hasn't been done 13 in a long time.
14 CilAIRMAN CARR:
When we take those 15
" junior" inspectors along, is there a conscious effort 16 to decide who's going to be a good inspector and who some peoplo have a knack 17 isn't just by virtue of 18 for inspecting and do a better job of it than others, 19 given equal technical skills.
-1 guess what I'm saying 20 is are we grooming people to be good inspectors 7 21 MR. GII.LESPIE:
We believe we are.
22 CllAIRMAN CARR:
Or do we just assign an 23 inspector because he's got a job code that says he's 24 here and therefore he can be a chief inspector on a 25 team or are we carefully --
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1 MR. GILLESPIE:
No, no, no.
There's many, 2
man: details in the paper.
There's a chart in there 3
whic has lists of things that we're doing.
The new 4
inspector that comes into a region, every region and 5
Headquarter's new inspectors has a very, very formal 6
qualification program to go through.
7 CHAIRMAN CARR:
That's not what I'm 8
talking about.
I'm talking about his evaluation.
9 MR. GILLESPIE:
Well, he has a supervisor 10 and he gets evaluated, 11 CHAIRMAN CARR:-
Okay.
But --
12 MR. GILLESPIE:
Now --
13 CHAIRMAN CARR:
I mean if their
'~l his evaluation
- says, "This guy 14 recommendution 15 should be groomed.
He's an outstanding inspector and 16 some day he should be the best inspector in the 17 agency."
18 MR.
GILLESPIE:
There's no deliberate 19 effort to --
20 CHAIRMAN CARR:
Okay.
do that outside the 21 MR.
GILLESPIE:
22 normal evaluation process.
23 CHAIRMAN CARR:
One thing I think we've 24 got to make sure neross the board is objectivity and 25 lack of bias in the inspectors.
You can't teach that.
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a 83 f~
1 Some have it and some don't have it.
Judgment, of 2
course, is always important.
But I'm not sure we're 3
achieving regional consistency.
I guess that's what 4
worries me more than anything else is that the guy who 5
inspects a plant in Region I and the guy who inspects 6
a plant in Region IV have got the same kind of 7
objective look, they're looking for the same kinds of we're requiring the same kind of 8
things and they 9
things out of t hem.
10 MR. GILLESPIE:
Well, programmatically we I
11 try that.
We very, very much try to do that.
Any 12 time something new gets promulgated programmatically, 13 it has guidance that goes with it as well as the 14 requirements.
1 think we're forever going to have 15 some inconsistencies.
In major elements, such as 16 maintenance team inspections and
- E0Ps, we have 17 specific training for those which are centrally j
i 18 controlled to try to bring that consistently.
The 19 team leaders are specifically trained.
20 MR.
TAYLOR:
I'd like to add that I
21 frequently talk with regional administrators about 22 individual inspectors, to try to get an assessment of l
23 their performance.
24 Bert, would you like to add to that?
I 25 thinD you keep a sort of running tally in your own l
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1 head about your view from your managers of how 2
individual inspectors are rertorming.
That's part of 3
the process.
4 MR. DAVIS:
And when we aske a selection, 5
we poet the job and we get a lot of people apply.
Of pick the person we think is going to be the 6
course, we 7
best inspector.
Now, sometimes you'd maybe not like 8
to pick any of them, but that's rare, I would say.
9 DOCTOR MURLEY:
Other ways of dealing with 10 this, Mr. Chairman, is the policy of rotation that we I view that as probably the 11 have.
I think that is 12 best way of -- by rotating managers --
13 CHAIRMAN CARR:
It's healthy.
14 DOCTOR MURLEY:
Yes.
15 CHAIRMAN CARR:
Too long
- current, but IG that's all right.
There's nothing like having a broad 17 background.
I mean a guy who has seen 15 plants is 18 going to be a better guy than one who has only seen i
19 two or three.
20 Okay.
Let's go on.
I've hammered that 21 enough.
22 COMMISSIONER REMICK:
Just picking up on 23 that point, I'd like to add that UCLS about a year and 24 a half, two years ago, made a recommendation that we 25 need to know more what it takes to be a good inspector i
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ij 1
and suggested perhaps some research be done.
There 2
are things other than technical competence that was 3
being referred to, personality traits and so forth, 4
which are very difficult to evaluate.
But the 5
question was do we know enough to know what makes a 6
good resident inepector, t
7 MR. DAVIS:
We're doing a fair amount.
I 8
can only speak for my region, but we try to make sure 9
that the inspectors are pretty good, the selection 10 that I
mentioned.
But what we also have is that 11 periodically the inspectors in a branch will have a 12 meeting at a location adjacent to another facility and 13 then all those inspectors will go out to that facility 14 together and walk through some inspections saying,
~'
15 "Well, now here's how I do this.
How do you do it?"
16 We're getting s o.n e pretty good cross fertilization, I 17
- ihink, among our inspectors in trying to get some 18 uniformity.
19 We also, of course, have the oral boards 20 that the inspectors have to go through and that sort 21 of thing.
As Frank said, each inspection procedure 22 that comes out has in it a
section on
- guidance, 23 "Here's how you ought to go about looking at this 24 thing."
So, all that helps.
25 COMMISSIONER ROGERS:
Well, at the risk of r
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prolonging this business unnecessarily, I think there r-2 is an important point here that the Chairrean broaght J
3 out about the personal characteristics of the 4
individuals.
One of the things that struck me in my 5
visiting plants is the enormous spectrum of 6
educational backgrounds of our inspectors, experience 7
and education, enormous spectrum.
I don't know if we 8
have any thnt have doctorates, but I
wouldn't be 9
surprised, and we have some that are just high school 10 graduntes.
Yet somehow there's a commonality in that 11 very diverse group of what it takes to be a good 12 inspector.
13 I would think it would p a'y us to try to 14 look at this from a human factors point of view and a 15 personality profile point of view, to try to pick out 16 in some way at the beginning those people that seem to 17 have those common features that our best inspectors 18
- share, if that's possible.
I don't know.
I don't 19 know if one can identify that.
20 But I would think it would pay for us to 21 try to do that because you just don't know when you 22 put somebody in the program how they're going to 23 function.
They may be intelligent.
They may be 24 technically knowledgeable, but some of these more 25 subtle aspects of the
- job, sliplomacy,
- firmness, 7
u_
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1 ability to funct. ton when you're out in the sticks 2
someplace all by yourself, it seems - to me those are 3
things you're not going to train for.
They're people 4
who either have those qualities or not.
5 CHAIRMAN CARR:
There's no doubt the
)
G senior resident is going to have a major impact on 7
those juniors where they start.
Similarly', the team 8
leader is going to have a major. impact on the junior 9
people in those inspections.
Those positions are 10 critical in how we do our business, 11 MR.
TAYLOR:
Why don't we take your 12 suggestion, take a look at it beyond what we're trying 13 to improve in the training.
You go to the heart of I
i 14 selection and the factors and what make an individual 15 perform and we'll take a look at that.-
16 CHAIRMAN CARR:
Okay.
Let's proceed.
17 DOCTOR MURLEY:
Those are the three major a
18 areas for improvement that we've talked about.
The 19 paper, of course, lists some other actions which are 20 largely ongoing.
21 CHAIRMAN CARR:
Before we leave that a 22
- minute, I
-heard all those words about our 23 professionalism and we are happy with ' our technical 24 performance, but we still see those comments that came y
25 in that said,
" Hey, we spend all our time teaching 1
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1 those guys our systems and-how our plant works when 1
2 they get there and we spend too much time doing that."
P 3
MR.
GILLESPIE:
In
- addition, there was 4
some more comments in there which said, "If they went 5
through our SRO trcining, they wouldn't'ask all these 6
questions."
I think our comfort feeling is that. the 7
training that our people get on systems, granted on 8
the generic plant nt TTC and on the simulator, is good 9
systems
- training, and that there is some advantage 10 that every three to five years when a resident rotates 11 that the atypicalities of a plant be questioned.
12 On those
- comments, we do see some 13 advantages on challenging those things where. that l
14 plant is so atypical that it's got uniquenesses --
f
- i 15 CHAIRMAN CARR:
I didn't read it as a 16 challenge.
'I read it as,
" Hey, ' = the guy can' t even 17 come out and inspect until we' educate L ;m on our l
18 plant."
I got it as kind of the arrival position'was
(
19 he didn't know.enough when he got there to be able-to maybe'I read it wrong, 20 do the inspection.
Is that 21 but that's the way'it came through.
22 DOCTOR MURLEY:
Insofar as w,
send people 23 out to inspect to BWR-and.they've only had PWR 24 training, then I think we do need and we are planning 25 to improve our training ' programs.
But some of it I
)
u l
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1 heard I
didn't think was really much we could do 2
about.
We have 81 different designs out' there that 3
we've got to inspect and there's no way we can train 4
our people on that.
They have to take some time to 5
understand the nuances and idiosyncracies of the 6
plant.
t 7
CHAIRMAN CARR:
- Well, I don't have any 8
problem, for instance, with our junior residents out 9
there.
I t hink 'one of_the responsibilities of that 10 plant in to make sure that they train that junior 11 resident in how that plant is different_from what they 12 started with.
13 DOCTOR'MURLEY:
Yes.
I 14 COMMISSIONER REMICK:
Before we leave the 15 training, one question that I would have, you know the 16 Commission has a policy statement espousing systematic 17 approach to performance-based training.
I look at 18 Bill because of h'is past backgroun'd.
I' assume when we 19 do our training or consider it, we consider the 20 positive aspects of systematic ' approach. to. training?
21 MR. RUSSELL:
In fact, I-think it's.back 22 on on earlier slide.
The training advisory group and 23 the senior level oversight that we're having, some.of 24 those elements of review are there.
We are not using 25 specific job and task analysis, the other I
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i s _
1 techniques --
2 COMMISSIONER REMICK:
Row about needs 3
analysis?
4 MR. TAYLOR:
Ed Jordan is here.
5 COMMISSIONER REMICK:
Okay.
l 1
6 MR. JORDAN:
Ed Jordan, AEOD.
q 7
As you're aware, we have recently gone 8
through with the program offices and identified 9
training needs-against particular positions and.then i
10 structured our courses to support fulfilling those 11 needs.
So, for
- instance, for NRR for licensing 12 project manager, there is a set of training needs and 13 then courses that will
. satisfy those needs -with L "{
14 respect to that technical position.
15 Is.that what you're trying to --
16-COMMISSIONER REMICK:
Yes.
To' be more I
17 specific in the needs, are those needs established:by 18
_ people who are performing the job currently'or they're 19 immediate supervisors-so they know what they actually 1
20 have to do on a day toJday basis and_therefore the 21 training is directed-toward providing that information 22 in.whatever format?
23 MR. JORDAN:
The needs were' established by 24 the program of fices.
NHSS did it by a-job and task 25 analysis principally and NRR did it by expert opinion r--
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and job and task analysis.
So, it was a combination 2
and it's a continually evolving process.
Now that P
3 we've done it with the program offices, we're going.
4 back to the regional offices and upgrading those 5
training programs.
6 COMMISSIONER REMICK:
I'm glad to hear it.
7 DOCTOR MURLEY:
Okay.
That concludes then 8
the discussion of the three major areas where we're 9
proposing staff actions to improve.
The paper lists 10 other actions which are largely ongoing that we don't i
11 plan to discuss today.
The commission is generally 12 aware of those.
13 This has been an important initiative _ for i
14 the staff.
I believe.
Senior staff, both regional 15 staff and - Headquarters staff, has devoted a lot-of 16 time to this activity.
The reason is that it's going 17 to affect how the staff carries out the Commission's 18 mission in the. coming years regarding regulation of.
19 operating reactors.
i 20 We have recommendations for the Commission 21 and that is that we issue a rederal Register notice on seeks - public : comment, 1
22 this paper which requests 23 that-we evaluate those
- comments, niak e - changes if 24 they're appropriate in our plans and then return.to 25 the Commission once-those changes are made for a final NEAL R.
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publication of all of these reports with the final 2
actions.
3 MR.
TAYLOR:
Mr.-
- Chairman, before we 4
conclude from the staff,-I'd like to acknowledge the 5
contribution of Cindy Pederson and Bert Davis, who in 6
addition to their normal duties took on a great deal 7
of' the work for the field work in the regulatory 8
impact survey.
That was deeply appreciated by the 1
9 ataff.
10 That concludes our presentation.
11 CHAIRMAN CARR:
Questions?
Commissioner 12 Remick?
13 COMMISSIONER REMICK:
One.
I'd like to 14 applaud those who conceived the idea of these surveys 15 and for those who conducted it and reported it and as 16 you heard it because I think;that clear on the report.
17 And also for the staff, for making a sincere effort to 18 suggest improvements.
I personally favor going out 19 for public comment on that,-to gain from that.
20 One question I would have, and I raised it l
21 somewhere in the past, this was so successful', I can't 22 help but wonder if we should not consider it in the 23 other areas of our licensing activity, perhaps major l
l 24 fuel facilities or large irradiators or something like l
25 that or maybe a questionnaire to some of our byproduct r--
i_._
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93.
I 1
I material people using-s t a t~is t i c al
- approach, since 2
they're so large a number.
But I wonder what we would 3
find if we went into those materials areas, if we 4
wouldn't get some helpful suggestions about our I
5 regulatory process there.
6 So, I just throw.that out as a thought 7
anyhow.
8 CilAIRMAN CARR:
Commissioner Rogers?
9 COMMISSIONER ROGERS:
Oh, thank you.
- Yes, 10 a couple of questions.
11 I don't'think I heard, or maybe I missed 12 it, about what you're doing about these complaints of 13 untimely responses to l i c e ns i.i g submittals.
I keep 14 hearing them as I go around, long delays in our acting
'~
15 on n submittal for a license amendment.
I know it's 16 been a longstanding question and there are problems 17 that aren't always so obvious about it, but I still l
18 hear rather long delays.and kind of exasperated point 19 of view from many licensees.
20 CHAIRMAN CARR:
You don't think we could 21 stand up to an inspection of'our backlog?
22 COMMISSIONER ROGERS:
No, I don't think 23 so.
24 DOCTOR MURLEY:.
I think we're going to get 25 one and I think we-can stand up:to it in terms of what 1
i l
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we know is in there.
Now, some of the actions are s -
2 probably 17 and 18 years old.
So,. we can't excuse i
3 that.
But this is an old issue,- Commissioner, and 4
we've dealt with it.
Perhaps= we can inform the 5
Commission. separately of where we're at because we are G
making stridos._
Hut there's some of.these old ones 7
that are pretty tough.
8 COMMISSIONER ROGERS:- Okay.
I Just didn't 9
hear anything about it and I know that was in there 10
'very clearly, c
11 Another comment that I
didn't hear 12 anything about was the-lack of clarity of NRC 13 communications.
It seems to me that we do have a m
14 problem there.
There are times when communications, 15 because of the constraints that they have' to be 16 technically correct and legally correct create-a 17 situation in which they tend not to be very 18 comprehensible when you're-finished..
trying to 19 understand what they say.
It's a problem -that's as 20 old as the hills, but there it is.
Specialists very 21 often are not very good writers for the - uninformed.- - We 22 always assume that people know what, we' re writing -
23 about when we write, but it's not always'so clear.
24 I wonder if you're trying to do anything 25
-to address this problem of whether a: communication is-r-
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1 really understandable and intelligible to whoever is 2
going to get it.
I'm not necessarily talking about 3
the lay public.'
That was another complaint.
I'm 4
talking about communications to our licensees that may 5
not be as clear as we think they are and whether we G
have any way of checking on those.
If someone reads l
7
- them, and I'm not suggesting another long delay 8
process, but someone who doesn't know anything about 9
it reads them and -understands - them, then they're 10 probably clear.
But it is a problem and technical 11 people are well known not to be good writers in 12 general, even though they may have all the technical 13 content correct.
14 So, this problem of clear-writing is a 15 problem every agency has for all kinds -of different 16 reasons.
But can we try to do a little something here
'17 to' improve on that problem?
18 MR. HUSSELL:
One of the objectives at the 19 time of the reorganization, when we created the 20 Generic Communications Branch in NRR was to have all 21 of the communications go through that branch,.
22 information notices, generic letters, et cetera.
We 23 are not presently using technical editors or applying 24 that kind of a standard to those communications.
We 25 have-a central place that they go.through and we would I
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consider that.
2 COMMISSIONER ROGERS:
- Well, I'm kind of 3
unhappy with that' approach..
It really ought to be cut-4 off.at the_ source.
Thef-ought to be clear'where they 5
originate, Rat he r - *.han having - another; office that~
6 things have to circulate through and another place 7
where they can oe_ delayed, I wonder if there's. Just 8
some simple things,that can b.e done.within individual 9
offices to try to make sure that ' things are clear, 10 just by other people in the. office taking a look at it 11 or something.
12 MR.
GILLESPIE:
.I think there's.
two-13 elements to the communications, the written-products 14 we put out.
One is the Headquarters and the other is 15 the regions.
We've been working diligently with-the 16 regions trying to do those little things to clear up 17 the manual -- chapter that we have in_the - inspection 18 manual,.what should be and howcan inspection report is 19 written.
We've sent out examples - of well' written 20 inspection
- reports, examples _
of poorly written 21 inspection reports.
We've probably reached the point 22 of saying, "We'll continue to keep trying," and that's 23 about what we can do.
l 24 I think the regions have
- a. lot of peoP e 25 already reading it.
I'd be very hesitant to_say the-u-
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1 regions would want more people to read every report.
2 It's a continuing' problem.
We continue to change it, 3
put more guidance out, and we're going to have to do I
4 it possibly somewhat more formally as we get into what 5
do we expect of an inspector.
It may mean-a writing 6
course.
7 MR. DAVIS:
We tried a number of things, 8
including a clear writing-course for our. people.
I'm 9
appalled at how somebody can' graduate from college - and 10 not know how to speak or-write, but.there are sure a-11 lot of them.
12 COMMISSIONER ROGERS:
You can graduate 13 from graduate school with u Ph.D.
and not be able to c._ _,
14 speak or write.
15 MR. DAVIS:
But we are doing-a couple of 16 things in Region III.
We-have our SALP reports sent i
17 in to be-looked at by a technical writer.
This NUREG 18 was reviewed by a technical writer and I was' amazed'st 19 how many good changen we got on that.-
.I also have my 20 deputy looking at three inspection reports
- a. month, 21 and we pick them at random, to determine whether or 22 not they are technically sound.
Probably we're l
23 looking more technically than we are at the grammar 24 and that sort of thing.
-But that's had an impact on 25 the staff.
When they don't know if their inspection I
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,'l J._,
1 report is going to be picked and loni:ed at, I thinkL 2
that's raised the quality a little= bit.
3 DOCTOR 'MURLEY:
The ones I'm most.
4 concerned about are the generic communications to
-i 5
licensees.
I think it's very'important that they be 6
clear, that we don't have to go back with --
7 CHAIRMAN CARR:
Well, then you eliminate-8 this inspector's interpretation out' there who
.is' 9
. leaning on the licensee t'o do it the way he thought it 10 meant.
'l 11 DOCTOR MURLEY:
. Wel'1, let's pick that up 12 and then continue to-work on it.
I'might add, if I 13 could, I was reading.this weekend a Civil War book of i
i he put the 14 a general in the Union Army who had 15 dumbest colonel that-he knew on his staff so that--
16 he made the colonel read every order that went out and l
17 he wouldn't' send it out until-that colonel understood I'm not proposing that.
18 exactly 19 CHAIRMAN C ARR:
I'll volunteer for that 20 job.
21 COMMISSIONER ROGERS:
Just one other point-
'l 22 before I leave it.'o,d that is what are we doing as l
23 some kind of a follow-up on.how well we've addressed 24 these problems.
After we put these changes in place, 25
-are we going to take a look another two years from now i
i _.
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1 and see whether they've been effective or not?
I'm 2
not suggesting we redo the survey.
This was too big 3
an effort.
But what are we doing to check to see.how 4
well we are succeeding with whatever_ steps we're 5
taking to alleviate some of these problems?
6 Secondly, whether we can put something in 7
place that is on a more regular basis to get this kind 8
of feedback without having to conduct a great big 9
survey.
10 MR.
TAYLOR:
Well, we are going out-for 11 public comment and in his int roduction -Tom talked-12 about looking at periodically.
This is a big resource 13 expenditure.
I don't want to overdo it.
I think i
14 that's a course we're going to have to come back to 15 the Commission on-over the long period.
This was a 16 big time consumer.
I think it's worth doing.
But how 17 often.is the question.
t 18 CHAIRMAN CARR:
- Well, that's the same 19 problem I hammered.at the utilities-on.
If you don't i
20 tell us what the problems are,.we can't fix them.
We 1
I 21 have to'go out and survey to find them out.
l 22 MR.
TAYLOR:
We started this because l
l 23 people -- we began getting that drift.
1~
24 CHAIRMAN CARR:
We need those' guys to be 25 frank with us when they come in and talk to us, l
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rosy at my plant."
1 instead of saying, "Everything's 2
MR.
TAYLOR:
It's not an answer, but I 3
think we're-mindful of the benefit.-
4 COMMISSIONER ROGERS:
Yes.
Okay.
Fine.
5 Thank you.
6 CRAIRMAN CARR:
Commissioner Curtiss?
7 COMMISSIONER CURTISS:
I just have really 8
one comment and one questior..
First, I thought the 9
work that was represented in the three SECY papers.was 10 very thorough and comprehensive and I do think it's.
11 healthy to do this every so often.
I don't know if-12 nine years is the right period of time or' five or two 13 or what have you.
But it does seem to meLas painful 14 as some of the observations must be when we get them, 15 and they do strike me as very frank, that the three 16 SECY papers really did lay out some consistent _ themes 17 and trends that you've identified here and focused'on 18 in the initiatives that you've laid out.
19 on the initiatives, I t hink -- with one 20 exception I thought they seemed to get at the same 21 kinds of problems that as I.go around from the plants 22 and talk to people you hear repeatedly at the 23 in'dividual plan t s,. f rom the-CEO right on 'down to the 24 fellow who is out there in the plant-trying to-25 understand a generic letter.
u -
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1 One area that the Chairman raised that I 2
hear more often than others has to do with the-3 consistency of requirements from region to region and 4
inspector to inspector and team leader to team leader.
5 It's a rare case when I come back from a site visit G
that somebody hasn't commented on how = they did X at 7
their site, thought they could.do Y or they had talked 8
to somebody else in another region or another plant.
9 It seems to suggest a need in that area to take a 10 hard, critical look at what we can do to, in addition 11 to the training initiatives, Frank,'that you outlined 12 and, Bert, maybe some of the things that you talked 13 about that you're doing in-Region
- III, that's a.
I 14 particular area that you continue to hear about.
15 By far and away the-most predominant 16 comment that I get is in the requal' area where the-17 teams are going around and perhaps because the 18 evolution in the revisions to~ the guidelines on 19 conducting requal.
But you also hear.
in the 20 enforcement area increasingly recently design basis 21 documentation, questions about reportability and 22 operability, to take two examples that I've heard 23 about at sites frequently.
24 If there is something that we can-do, and 25 I'll reflect upon this-when we consider and vote on-r- -
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i I
the SECY paper, but if 'there are thoughts that the 2
staff has that are specifically focused beyond the 3
general training initiatives at getting af ter that 4
- problem, consistency from region to region on SALPs 5
and consistency from inspector to inspector-on DBD 6
inspections and requals and so forth, that's an area maybe I'm missing it.in 7
that I still have a sense 8
what you've - presented, but I still have a sense that 9
we're coming up short on in terms of really driving 10 home the point that we need to.be consistent region to 11 region and inspector =to inspector.
12.
COMMISSIONER ROGERS:
Could I
just say 1
13 something?
It relates to whenever I hear these
,y 14 complaints, I try to track them down and find out what 15 the incident was and what really did. happen.
I have 16 to say that so for I find very frequently that the i
17 allegation that a particular situation was dealt with 18 in totally different ways in two different regions, it 19 turns out to-be much more complicated than the 20 licensee's perception of the situation, that they were-21 not identical-at all, and that there were very good 22 reasons why. there were ' differences and significant 23 differences in how the staff dealt with the two 24 situations in the two regions.
25 I'm not just saying that we don't ever 4
- i. _
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1 make a mistake on this, but I'm sayin-that very'often 2
when 1 hear about it and try to track it down, the 3.
problem is a misperception of the actuality of the 4
situation.
Therefore, the way you're going to correct 5
that is by better communication on these things.
The 6
licensee has to communicate to us their unhappiness 7
with what they thought was an inconsistency and then 8
we have to correct that misconception of what or l:
9 misperception of what the actuality was.
Sometimes 10 these things are separated in time by year or so.
So, 11 it's not obvious that you put out something 12 immediately to correct the situation.
They fester a 13 little bit and then there it is.
.It comes up.
q 14 So, I would say that this is a little more
- ~
15 complex than just our being inconsistent.
I'm sure-16 there 'are times when we are.
It's also. trying to 17 correct and get the information out. to licensees of 18 how we are dealing with situations--and that something 19 that looks to be identical is not on identical 20 situation at all.
21 CilAIRMAN CARR:
Let me give you the other 22 side of that.
I was just at the --
23 COMMISSIONER CURTISS:
I was going to just 24 jump in, but'go ahead.
25 I
CllAIRMAN CARR:
-- sys t ems ecology group i
~
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1 meeting down in Knoxville and talked to a guy who does 2
laundry in all the regions of the country, and he 3
says, "If you think licensing a laundry is the same in l
4 all regions, you can como and talk to me."
He says, 5
"I've got_a laundry list of differences."
So, there's 6
no doubt they're out there.
7 COMMISSIONER CURTISS:
- Yes, I'll give you t
8 a couple,of examples, because there are instances that 9
I've come across that I have in fact followed up on 10 and even understanding the important points that I
11 think Commissioner Rogers raises that do seem to me to 12 fall into this category.
13 I was at one plant recently that_ on the
. _q i
14 requal exam, for instance, was told that they have to i
15 test on exam the tech spec minimum crew that they 16 have.
So it it's-two SRos and two R0s, that's what 17 was required, even though they may run-an additional 18 SRO and an additional R0 'on the crew.
And in checking.
19 with other regions, it's-clear they found out and we 20 determined that there are other regions or other crews 21 out inspecting where tech spec minimum-is not the 22 limitation, that you can test with the-crew as you run 23 your crew.normally at the site.
24 I'll give you another example.
I.was at a.
- i 25 plant recently where a fitness for-duty inspection was i
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1 undertaken and to the great ' consternation of the 2
licensee they were told that they ought to take a look 3
at having drug dogs for fitness for duty with the 4
particular inspection.
5 CHAIRMAN CARR:
I visited that plant to.
6 MR. TAYLOR:
We've worked on that one.
7 COMMISSIONER CURTISS:
-That one has been I
8 resolved, but it comes up and it's been raised because.
9 of visits like the one that I've identified.
10 I'll just give you another interesting 11 observation in an area that I know ACRS and others 12 have commented on, and that's SALP consistency region 13 to region.
The staff NUREG that comes out most l
14 recently that gives the summary of SALP scores over a 15 period of time came out just recently,and I've gone 10 through and actually taken a look at t he'- S ALP scores 17 region to region to be able to try to determine 18 whether there is any merit to the argument that there 19 is inconsistency: a SALP 1 in one region is different 20 from a
SALP 1
in another region.
Of' the seven i
21 categories that we rate' in the -SALP category, one 22 region is the toughest rater in-five of the seven 23 categories.
I don't know if that's statistically 24 significant or the variation that.you see --
1 25 CHAIRMAN CARR:
Got the lousiest plants, s
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I maybe.
j is statistically 2
COMMISSIONER CURTISS:
3 significant.
I'm-not ' sure it.'s that they have. the 1
4 lousiest plants either.
But-those kinds of questions l
5 are, I think, in some cases attributable to the need G
for clarification-that Commissioner Rogers has l
7 emphasized.
In fact, there have been instances where 8
we've gone.out and there is n complaint or a concern 4
9 about-a particular issue-and when you dig into it with 10 the resident there on site or come back and ask the 11 project management here at NRR what'the situation is, 12 in many cases those issues.get resolved because they 13 don't fully understand the situation or, as t
'd 14 Commissioner Rogers emphasized, it's more complex than 15 might appear at first blush.
16 But I
must say that and ~ maybe it's 17 because of the requal -process. skewing what we're 18 hearing right now -- there ' does. seem to me to be a-19 greater number of instances where a consistency from' 20 site to site or resident to resident or region to 21 region would be deserving of greater attention.
22 DOCTOR MURLEY:
Yes.
Let me comment on 23 that.
That's a very good observation, because the 24
- survey, the ~
did it, probably would not have way we 25 picked up, certainly not focused on regional kinds of
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o 107 F-1 differences because they were focusing on their own 2
problems.
And we do -- we're certainly aware -that-we 3
need to do this.
It's NRR's job, quite frankly, to 4
make sure there is consistency on requal programs and-5 we'll just have to -- we know it.
We'll just have to-6 make sure we redouble our efforts.
I'm glad to hear; 7
of these cases and --
81 CHAIRMAN CARR:
You can't do it without 9
feed-back.
10 DOCTOR MURLEY:
Yes.
11 CHAIRMAN CARR:
My problem-is we've got to 12 go out and dig out the feed-back instead of getting it 13 gratuitously, if you will.
l 14 DOCTOR MURLEY:
Yes.
If CHAIRMAN CARR:
And the implication is, 16 "if we grouch about it, why, you guys'take it out on 17 us,"
and that's the implication I'm trying to. destroy, 1
l 18 you know.
19 DOCTOR MURLEY:
Yes.
l 20 COMMISSIONER CURTISS:
I'll give you
[
21 another good example.
I do think this runs the~ risk l
22 of being the kind of anecdotal thing, Tom and Bert, 23 that you'd referred to earlier.
It's difficult to l
24 rely on.
l l
25
- But, the idea of LCO maintenance, for l
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example, is one where I've gone around from region to 2
region and talked to, not just the plants who had 3
different philosophies, but to the residents in the i
4 regions who have different philosophies on a topic r
5 like that.
I don't want to go through all the 6
examples that I've heard of as I've gone from site to 7
site, but there are in +ances out there that, when you 8
get down to it, 1t's more than just a problem of this 9
case being different from that case.
It's an issue 10 that, it seems to me, goes to the consistency of the 11 way we approach and interpret and apply requirements 12 from the site.on up here to Headquarters.
13 MR. TAYLOR:
That's.en important --
I 14 DOCTOR MllRLEY:
As you pointed out in your I F.,
- trips, one utility does it -one way-on one site and 16 another way on another site, so one sees a lot of 17 variations like that too.
But we'll-look into that as 18 well, and I accept the comments because I think that 19 is something we have to always pay attention to, 20 consistency.
21 CHAIRMAN CARR:
Any other comments?
22 Well,. I'd like to thank the staff for this 23 informative briefing.
24 The Commission currently has before it a 25 more detailed discussion of the regulatory ' impact u
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'4 O.i 109 I
l 1
survey recommendations.
I strongly support the 2
proposal of publishing these recommendations for 3
public comment before a final set of recommendations.
4 is sent to the Commission.
I also believe the views 5
of the Advisory Committee on Reactor Safeguards would 6
be valuable to the Commission.
7 I would urge my fellow Commissioners to 8
promptly consider and vote on SECY-90-347.
9 Any other comments?
10 If not, we stand adjourned.
11 (Whereupon, at 12:20 p.m.,
the above-12 entitled matter was adjourned.)
13 I
34
_m 15 16 17 18 19 20 21 22 23 24 25 4
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.o r l
l CERTIFICATE OF TRANSCRIBER This is to certify that the attached events of a meeting
)
j of the United States Nuclear Regulatory Commission entitled:
TITLE OF MEETING:
BRI'EFING ON REGULATORY IMPACT SURVEY REGULATIONS j
PLACE OF MEETING:
ROCKVILLE, MARYLAND DATE OF MEETING:
OCTOBER 15, 1990 were transcribed'by me. I further certify that said transcription is accurate and complete, to the best of my ability, and that the transcript is a true and accurate record of the foregoing events.
.fL to '. '~
Laws t) w Reporter's name:
Peter Lynch i
1 t
HEAL R. GROSS COURT RipoRTER$ AND TRAH5CR10ER$
1333 RHODE 15 LAND AVENUE, N.W.
(202) 234 4433 W ASHINGTON, D.C.
20005:
(202) 232-6600 l
W
- REGULATORY IMPACT SURVEY OCTOBER 15,1990
~
1 REGULATORY IMPACT
- l i
MILESTONES
\\
i LICENSEE SURVEYS FALL 1989
- GL 90-01 JANUARY 12,1990
- STAFF SURVEYS SPRING 1990 l
- SECY 90-080 MARCH 9,1990 i
j
- SECY 90-205 JUNE 7,1990
- SECY 90-250 JULY.16,1990 1
I' E. a.
~
i REGULATORY IMPACT
. LICENSEE SURVEYS CONDUCTED SEPTEMBER 25 - DECEMBER 1,1989 BY SENIOR NRC MANAGEMENT TEAMS
- 5 TO 6 MEMBERS PER TEAM 13 LICENSEES VISITED j
- AT LEAST 2 LICENSEES PER REGION APPROX. 5 DISCUSSION GROUP SESSIONS PER VISIT
- OPERATORS
- CORPORATE PERSONNEL
- ENGINEERS
- MANAGERS
- SENIOR MANAGEMENT l
i l
REGULATORY IMPACT SURVEY 1
s a
1.
Principal Themes 2.
Requirements and Perceived 4
Requirements
)
q 3.
NRC Licensing Activities l
4.
NRC Inspection Activities i
S.
Performance Evaluations.
1
.4_.
I i
i 4
4 i
I 1
i REGULATORY IMPACT SURVEY (cont) i 6.
Multiple Oversight Organizations l
7.
Operator Licensing 1
8.
Enforcement and investigations 9.
Reporting Events t
i 10.
Communications 11.
Qualification of NRC Personnel
\\
e i
i
l 1
l PRINCIPAL THEMES i
t
?
l I
Licensees Acquiesce to NRC Requests i
i I
[
NRC Dominates Licensee I
Resources l
i f:
i 5
a REGULATORYIMPACT MAJOR AREAS FOR IMPROVEMENT
- 1. CONSIDERATION OF THE CUMULATIVE EFFECT OF NRC GENERIC REQUIREMENTS
- 2. SCHEDULING AND CONTROL OF INSPECTIONS, ESPECIALLY TEAM INSPECTIONS
-- 3. MANAGEMENT EXPECTATIONS, TRAINING AND OVERSIGHT OF INSPECTORS
.x
l 1
-REGUL.ATORY IMPACT l
- 1. CUMULATIVE EFFECTS OF NRC l
GENERIC REQUIREMENTS
- ADDED BACKFIT DISCUSSION TO GENERIC CORRESPONDENCE
-NUREG 1409 BACKFITTING GUIDEUNES
- REVISING VALUE IMPACT HANDBOOK
- INTEGRATED REGULATORY REQUIREMENT IMPLEMENTATION SCHEDULE (IRRIS)
1 i
REGUL.ATORY IMPACT 4
1 i
i i
i I
i i
IRRIS 1
l l
l l
_ VOLUNTARY UCENSEE PARTICIPATION i
i i
- APPUES TO UNIMPLEMENTED SAFETY ENHANCEMENTS, NOT i
l i
TO ADEQUATE PROTECTION OR COMPLEANCE REQUIREMENTS j
I
- PRIORITIZED AND SCHEDULED BASED ON SAFETY AND IMPACT 1
i
(
- FROZEN IN ADVANCE OF OUTAGE l
4 i
REGUALTORY IMPACT
- 2. SCHEDULING AND CONTROL OF INSPECTIONS i
i I
- RESTRUCTURING OF INSPECTION PROGRAM i
[
i i
- EMPHASIS ON INSPECTION PLANNING I
j (MIPS)
- POLICY FOR COORDINATING SITE VISITS l
l
- ADDITIONAL PROGRAMMATIC IMPROVEMENTS i
I
(
f
-T-m
- +. -
REGULATORY IMPACT PROGRAMMATIC IMPROVEMENTS FOSTER BETTER TEAM AND ROUTINE INSPECTION PLANNING NEED ESTABLISHED BASED ON LICENSEE PERFORMANCE OR GENERIC SAFETY ANNOUNCE TEAM INSPECTIONS CONTROLS ON NUMBER OF TEAM INSPECTIONS ( < 4 PER SALP CYCLE)
___m--
--.-s-
"r
7
\\
i REGULATORYIMPACT PROGRAMMATIC IMPROVEMENTS oBETTER SCHEDULING OF NRC SITE ACTIVITIES UNIT SPECIFIC PLANS MAINTAINED BY REGIONS
- UPDATED QUARTERLY
- CONSIDER ALL MAJOR SITE ACTIVITIES
- TO BE PUBLISHED PERIODICALLY
" ' - ~ ~
' ~
REGULATORY IMPACT
- 3. MANAGEMENT EXPECTATIONS, TRAINING AND OVERSIGHT i
l
- EMPHASIS ON PROFESSIONALISM L
q
- SPECIALIZED TRAINING FOR STAFF l
q
- TRAINING ADVISORY GROUP i
i:
- TEAM LEADER POSITIONS i
- ENHANCE TRAINING p
1 1
{
I j
~
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REGULATORYIMPACT ENHANCED TRAINING
- REFINE FUNDAMENTALS & ADD REFRESHER
- ROLE / CONDUCT OF INSPECTOR
- INTERPERSONAL SKILLS TRAINING
- COMMUNICATIONS, INTERVIEWING, MEETINGS
- PROBLEM SOLVING AND DECISION MAKING
--- -.~ =-
....- ~. ~...
.,a
i 4
i REGULATORYIMPACT s
i j
PROFESSIONALISM i
i j
- MANAGERS AND SUPERVISORS j
i
- COMMUNICATE EXPECTATIONS i
(
- SOLICIT FEEDBACK l
l l
- OVERSIGHT / ACTION
~
-INSPECTORS
- PROFESSIONALISM IN ALL ACTIVITIES
~.. ~
~
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REGULATORY IMPACT OTHER ACTIONS
- NRC LICENSING ACTIVITIES i
- NRC INSPECTION ACTIVITIES
- PERFORMANCE EVALUATIONS 1
- MULTIPLE OVERSIGHT ORGANIZATIONS i
- OPERATOR LICENSING 4
- ENFORCEMENT
- EVENT REPORTING 1
i
M
~ ~
}
r REGULATORYIMPACT CONCLUSIONS
- RECOGNIZED AREAS FOR IMPROVEMENT
- INITIATED CORRECTIVE ACTIONS
- SOLICIT & EVALUATE PUBLIC COMMENTS
- ADJUST ACTION PLANS
- FINALIZE NUREG 1395
.