ML20132C883
| ML20132C883 | |
| Person / Time | |
|---|---|
| Issue date: | 03/22/1985 |
| From: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| 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 8504080394 | |
| Download: ML20132C883 (5) | |
Text
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- EW21/85 17821 FRC REG 1 NO. 877 002 "Og uwn m a m us
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March 22, 1985 1
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MO ORANDLM FOR:
Clemens J. Heltasias. Jr.. Dimetor. Office for Analysis j
and Evaluation of Operational Data Thomas E. Murley, Regional Administrator, RI FROM:
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SUBJECT:
STUDY OF THE NEED FOR AN INDEPENDENT A&ENCY TO INVESTIGATE 4
INCIDENTS AT KUCLEAR POL'ER PLANTS Rsference:
Your memorandum on this subject. dated February 15, 1985
)
We have reviewed the BKL report titled, "An Independent safety Organization.
KUREG/CR 4152." generally support the six (6) task force suggestions for l
inroveacnts in the NRC approach to investigation of nuclear events, and aclaweledge the theoretical appsal of the recommended course of action.
I Despite these views, tre do not concur with the recournendations.
i The study was undertaken to determine the need for, and feasibility of, hn independent safety organization to investigate and assess operational events.
3 j
The CKL study detennined that NRC event investigations are generally carried i
out in a professional and competent sanner, and that no evidence of bias or ccnflict of interest was identified in the investigation reviewed. The BNL
]
study also acknowledged that their suggestions for improvements could be J
acm edated by the present NRC organization. The evidence does not support the need for radical char 7es in current MRC practices or organizational i
structure. Weviewthesix(6)suggestedimprovementsappropriateenhance-i cents of current NRC event investigation practices and reconnend action be taken to incorporate these suggestions.
i Ue are concerned that the BNL study has not adequately explored the nega'tive censequences of implementation of their reccamendations. In particular, we are concerned that the study does not discuss the impact of reassignment of thirty technical staff positions from existing regulatory activities to the j
" Office of Nuclear Safety (OiiS)"; that DNS review of event reports may impede i
notification and activation of regional emergency response personnel; that pro::pt event reviews will be delayed by regional staff awaiting an ONS decision on who has the lead; and, that the morale and sense of responsibility of the regional staff will be adversely impacted by preemption of investi-i gation activity by ONS.
Finally, we believe the utilization of licensee i
ecployees as " designated representatives
- for significant event identification i
will adversely effect the public perception of the qualit;y of our programs.
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BJV21/85 17:23 tRC REG 1 M3.029 001 e
i Clemens J. Heltames 2
Our specific consunts on the BNL suggested improvements in NRC operational' event investigation practices are attached. Should you have any questions conceming our coceents, please contact us.
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[ Regional Administrator s E. Murley Attach:rnt: As stated cc w/attachsent:
ncgional Atinistrators RII-V Office Directors. IE, NRR. WES e
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EV21/95 17:24 MRC REH i K). B28 m
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C019ENTS ON NUREG/CR 4I52 SU6GESTED IMPROYDENT 3
IN NRG DPERATIONAL Ehni INVtsIIGATION PRACTICE 5 l
1.
A structur'ed and cochHnated approach is warranted for init'f al event review. identification of significant events, conduct of event investiga.
l tions. communications of event review findings and closure of event related reconnandations. The approach selected should arinimize msource expanditums and take advantage of the placement, organization, experi-ence and competence of existing NRC resources. To these ends, we recom-i eend:
i i
the establishment of an NRC wide program for event review 1
and investigation, that clearly defines responsibilities and authorities.
(The program should endorse the use of 4
culti-office investigation task forces specifically tailored i
to the needs of the onvestigation. establish requirements for i
investigation charters agreed to by Office Directors and the 1
involved Regional Administrator, and promote the concept of j
one thorough investigation with one definitive report.)
the elimination of duplication of authorities and respon-sibilities for event review and investigation, currently i
assigned to regional offices. IE. NRR. fGtSS and AE00.
(The j
adainistrative. technical and managerial resources thus l
released from overlapping and sometimes conflicting activities could be better utilized to provide additional cycrsight of licensed activities.)
the utilization of existing regional office staff for 4
initial event review and identification of significant l
events, participation in event investigation task forces.
1 review of investigation findings for enforcement l
considerations, and tracking of closure of itcensee l
connitments for corrective action.
the ut111 ration of existing NRR and NHSS staff for j
i participation in event investigation task forces, and review of investigation findings for identification of necessary l
changes in Itcenses and the licensing programs.
1 the utilization of existing IE staff for participation in event investigation task forces, mytew of preliminary 4
investigation findings for prompt dissemination of event i
descriptions. and review of final investigation findings for identification of necessary changes in the inspection 4
l and enforcement programs.
4
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ev21e 17:25 NRC REG 1 NO. BN gm
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the establishment of authority to preempt parallel investigations by the licensee. INPO. NSAC. EPRI or others, duct of an effective and thorough eventwhere those investigations mig l
the con I
investigation by MRC.
(Consideration should be given to l
encouragerant of limited participation in event investiga-t i
tion task forces, by representatives of precceted organtrations, when those representatives are technically qualified and could enhance the effectiveness and credibility of the task force findings.)
2.
The capture and prevention of loss of event m1ated infomation is critical to sustaining the credibility of investigation findfngs. The importance of this issue is second only to the licensee's duty to protect i
t j
the public, employees, environment and plant facilities.
In the absence 4
of a conflict with the licenseo's prisery duty to safety, the licensee should be required to prostptly inform ERC of significant events, " freeze" plant conditions at a stable point until released by the WRC, secure event related records and obtain written statements of event involvement i
fran plant staff cumbers.
l 3.
The procedures for the conduct of event investigations and reporting must 1
establish a perception of avoidance of conflict of interest or the introduction of bias. To these ends,we recosamend:
that the pmcedures for estabitshing event investiga-tion task force membership must eliminate nominees having current or prior direct responsibility for inspection.
l licensing, operation or constmction of the activity involved in the event.
i that separata documents be utilized to report the results of the investigation, recommend corrective actions, and propose enforcement actions.
that the report of the event investigation task force l
should be limited to documentation of significant facts.
repeatable analysis and supportable conclusions.
(The report itself should evidence an exercise in ob.tectivity, require only the concurrence of task force==mhars and the organization vested with the responsibility to manage that particular event investigation, and be disseminated l
l to the pubite promptly without delay.)
4 that the report of recommendations for corrective action be processed in a stallar manner to that proposed above, but that this report must be reviewed and concurred with by W M.
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Ew2245 17:26
>5tC REG 1 NO.028 gM 3
that organizations responsible for activities addressed by the recoseendations be required to respond to the ED0 in j
writing with their plans within a specif,1ed short period.
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that the proposed enforcement actions be developed by the responsible regional office with final concurrence in the enforcemnt action provided by IE.
l 4.
We agree that event investigations would be enhanced by assuring the investigation task forces have members with related operating experience and specific training in the conduct of technical investigations. The NRC mploys a large cadre of technically competent multi-disciplined inspectors and license reviewers, many of which have related operations experience and/or fonnal training as technical investigators.
In short, we believe the NRC probably has the appropriata resources to conduct competent professional investigations. What NRC lacks is a register from 3
which to select task force members. We support MORT and A/I training for all inspectors and license reviewers, particularly those who evidence the ability to think critically and to communicate clearly.
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