ML20132C849
| ML20132C849 | |
| Person / Time | |
|---|---|
| Issue date: | 03/22/1985 |
| From: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Heltemes C NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD) |
| Shared Package | |
| ML20132C621 | List: |
| References | |
| FOIA-85-427, RTR-NUREG-CR-4152 NUDOCS 8504080367 | |
| Download: ML20132C849 (3) | |
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MAR 2 21985 l
MEMORANDUM FOR:
C. J. Heltemes, Jr., Director Office for Analysis and Evaluation of Operational Data FROM:
James M. Taylor, Director Office of Inspection and Enforcement
SUBJECT:
STUDY OF THE NEED FOR'AN INDEPENDENT AGENCY TO INVESTIGATE INCIDENTS AT NUCLEAR POWER PLANTS We find the study to have been generally thorough and we have little argument with the facts as presented. However, we do question the use of certain facts as a basis for findings and recommendations.
Second, we question the omission of other relevant facts which'could refute or negate some of the findings presented in the report and subsequently alter recommendations made therein.
Third, we also question certain very significant assumptions or hypothesis
- which were.used without a factual basis to support recommendations.
Specifics
' with respect to each of these as well as other general comments are enclosed.
Overall, I am concerned that the bureaucratic nature of an independent' or quasi-independent investigative organizstion would inhibit and delay event review and followup. Benefit from such an organization would accrue from investi-gation of significant events not from real time or onsite screening and evalua-tion of lesser events. We agree that strong argument is provided for increased independence of an AE0D type organization to focus industry and federal agency conduct of the 10-12 significant events per year.
We see serious safety impacts, however, if responsibility for screening, evaluating, and reporting the several thousand events per year were taken from licensees. The line organizations in NRC would be severely handicapped if event reviews were only done by an AE0D type organization.
I am concerned that tFe study significantly 1
underestimates the resources applied to event review by licensees and NRC and does not fully comprehend the beneficial ways that this information is used to upgrade individual licensee performance and to resolve multi-plant problems.
/
f a es M. Taylo, Director 0 fice of Inspection and Enforcement
Enclosure:
As Stated
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3 Specific Coments on NUREG/CR-4152, "An Independent Safety O ga in zation" r
i 1.
Use of Certain Facts It is stated in the report that the NRC failed to recognize the Hatch 2 l
l event in a timely manner, and " designated representatives" similar to the FAA plus regional-assigned independent or quasi-independent personnel 1
would solve this problem.
Although the report correctly recognized that AE0D identified this problem,
' the NRC was criticized for not identifying it sooner.
The report failed l
to recognize that identification of this event by AEOD was exactly why i
AEOD was established. Therefore, this event should be counted as a success. A more careful examination of the record of NRC response to events could argue that identification of significant events is adequate.
Addition of personnel from an independent or quasi-independent organization to the regional offices to assume responsibility for identifying signifi-cant events is naive especially if one follows the NTSB patterns of responsibility for reviewing all events.
Careful reading of the FAA material shows that NTSB delegates responsibility for many investigations, especially of general aviation accidents, to the FAA.
Designated repre-sentatives may or may not solve the problem at hand. The NRC staff l
investigated the FAA Designated Representative Program in conjunction I
with the preparation of the QA Report to Congress (NUREG 1055) and the l
Commission decided not to go forward with legislative changes viewed to be necessary if such a program were to be required by the NRC. The Comission did express a desire to test a Designated Representative Program for reactors under construction if a utility were to voluntarily accept a designated representative arrangement. As of this date, no j
volunteers have come forward.
m 2.
Omitted Findings
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The NRC record of feeding back operational experiences thru Bulletins and Information Notices and utilizing industry Regulatory Response Groups and Owners Groups has been highly successful in identifying and communicating problems and their causes and obtaining appropriate corrective actions.
It is most doubtful that an independent or quasi-independent organization i
could have done a better job on the 8WR pipe crack problem based on findings of cracked pipe at Nine Mile Point or in identifying the cause j
and communicating the Hatch torus header cracking problem or the more recent Farley tendon anchor failure.
Comparison of success stories with NTSB's. record would have been beneficial.
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1 Additionally, the study stated that there are some problems with the NRC's present method of investigating significant safety events, but correction l
of existing problems to provide an improved method of investigation was not specifically addressed or considered as an alternative to reorganization.
3.
Assumptions Without Factual Basis 4
The report states that the NRC staff may have a conflict of interest when investigating a significant operational event because it may have been i
caused in part by a previous licensing, regulatory, or enforcement action or inaction.
Despite the statement in the report that there were no cases in which this occurred, this problem appeared to weigh heavily in the recomendations.
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i Further, the study stated that a problem with the present system involved the fact that an inspector investigating the cause of an event may also be l
involved in preparing enforcement action for the same event. Our experience l
to date has not identified this as a problem.
i Additionally, the study states that a disadvantage of having the proposed l
Office of Nuclear Safety (ONS) report to the EDO is that ONS would not be in a position to ensure prompt consideration of its recommendations by i
No basis is given in the report to support that i
position.
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i 4.
General Comments I
The study emphasizes the issuance of a final report at the conclusion of deliberations by ONS. Presently those issues. that may have safety impli-l cations are identified to applicable licensees early in the investigation for this action prior to the issuance of a final report. This philosophy A
should be maintained.
The study states that ONS will investigate significant safety events; how-ever, no definition is given for significant safety events except in broad l
terms. A clear definition of significant safety events should be stated.
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