ML20132C886

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Comments on Study of Need for Independent Safety Organization.Organization Unnecessary
ML20132C886
Person / Time
Issue date: 03/21/1985
From: Grace J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To: Heltemes C
NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD)
Shared Package
ML20132C621 List:
References
FOIA-85-427 NUDOCS 8504080401
Download: ML20132C886 (2)


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  • ,^ NUCLEAR REGULATORY COMMISslON REcl!N 11 0*I PII o 101 MA21ETTA STREET.N.W.

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MAR 211985 MEMORANDUM FOR: Clemens J. Heltemes, Jr., Director, Office for Analysis and Evaluation of Operational Data FROM: J. Nelson Grace, Regional Administrator

SUBJECT:

STUDY OF THE NEED FOR AN INDEPENDENT AGENCY TO INVESTIGATE INCIDENTS AT NUCLEAR POWER PLANTS

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It appears that the argument in the report against the establishment of an independent government agency to investigate events are at least as strong as those arguments in favor of it. The report concludes that the NRC investigations 1

are carried out in a generally professional and competent manner, with some

, exceptions, and appear to satisfy their regulatory objective. The report then

! identified three main areas for possible improvement. Given the overall conclu-sion of the report, and recognizing thr.t improvements will always be of value, it is highly questionable whether establishment of another organization is warranted or desirable.

Three areas identified for possible improvement in the report included the timeliness of identification of events and investigation reports; the overlap and interference with each other of the various NRC, INPO, licensee, and equipment vendor investigations; and the perceived adversarial nature of the NRC investi-i gations resulting from their being conducted by the regulation and enfo'rcement i

i staff of the NRC.

t Improvement in the timeliness of ide'ntification of events and investigation reports can be expected through additional training of and experience gained by those organizational elements already in place to followup on events. Specifi-i cally, each Region has established an Operational Programs Section to supplement the Resident Inspectors in event followup. For that matter, the entire Regional 1 Office and other Offices, on request, are available for that support. A Task Interface Agreement establishes the lead office responsible for event followup where more than one office is involved except for the case of AEOD. In the case of AEOD, AE00 has chosen to review certain events independently.

It would seem that timeliness could best be improved through gaining experience

! 'and additional training of those organizational elements already in place.

. not by the addition of another orguizational entity. .,-

As for the criticism concerning overlap and interference because of various agencies or parts of agencies being involved, it appears that adding yet another entity would only compound any perceived problems. In addition to the NRC i organizational elemants already mentioned ACRS, INPO, ANS, FEMA, DOE, and local

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) .Clemen; J. Heltemes, Jr. 2 and State governments could all be involved at one time or another. It is doubtful that any of these entities would relinquish their statutory rights or

responsibilities with the establishment of an independent safety organization, i In any case, questions from these other organizations have proved helpful mainly because of the different view they may have related to their responsibilities.

i As far as the perceived adverserial nature of the current NRC investigations, the l

report did note that no instance of this type of problem had been identified.

The other comments in regard to greater operating experience and training for the

investigators, as well as more timely feedback of the results of investigations j

,~ are issues which, we believe, could be and should be dealt with in the present organization.

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In summary, we agree that improvements could be made in the system by better
training and as a result of better guidance. Guidance to the industry and our

! evaluation of post-trip reviews, for instance, have resulted in improvements in i this area. Additional guidance in the area of event followup in general could be 1

expected to also yield positive results. Nothing in the report wou1J 1ead us to r I

the conclusion that an independent safety organization would be needed to solve j these perceived problems, e #

J. Nelson Grace .

] cc: V. Stello, DEDROGR i J. Taylor, IE '

T. Murley, RI l

J. Keppler, RIII .

R. Martin, RIV l

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J. Martin,' RV I I

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