ML20136D704
| ML20136D704 | |
| Person / Time | |
|---|---|
| Issue date: | 12/24/1985 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Heltemes C NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD) |
| Shared Package | |
| ML20136D710 | List: |
| References | |
| NUDOCS 8601060261 | |
| Download: ML20136D704 (3) | |
Text
_
DEC 2 41985 MEMORANDUM FOR:
C. J..Heltemes, Jr., Director l
Office for Analysis and Evaluation of Operational Data FROM:
. Harold R. Denton, Director Office of Nuclear Reactor Regulation
SUBJECT:
DRAFT PROGRAM PLANT - INCIDENT INVESTIGATION PROGRAM This memo provides our comments on your draft program plan for the Incident Investigation Program, dated December 4, 1985.
Overall, we' find the draft to be a well thought out, quality document. We realize that this program plan is an administrative document which defines the end products and the associated resources and schedule. Some of our comments (enclosed) deal more with the end products than the program plan; however, we believe them to be of sufficient importance to offer at this time.-
'The targeted completion date of July 1986 is desirable. However, in reviewing the schedule of intermediate steps, we find that you will likely need to assign additional resources to have reasonable assurance of a timely completion.
If you have any questions on our comments, the NRR technical contact on this matter is J. T. Beard (EXT. 27465).
i Harold R. Denton, Director Office of Nuclear Reactor Regulation
Enclosure:
As stated f
cc:
J. Taylor, IE DISTRIBUTION: YELLOW TICKET 859335 Central File W/ incoming NRC PDR w/inc NSIC W/ Incoming ORAS Reading DMossberg/w/ incoming JTBeard RWessman GHolahan DEisenhut' HDenton
- Previously concurred ORAS
- ORASiD
- N NRR JTBeard:'mk GHolahan but HDe n
12/19/85 12/19/85 12 85 12
/85
.0
/)J s
)
- d l
f Enclosure NRR COMMENTS ON DRAFT PROGRAM PLAN i
INCIDENT INVESTIGATION PROGRAM i
(DATED DECEMBER 4, 1985) 1.
The plan should highlight that the purpose of the IIP does not include determining any wrongdoing or violation, but rather to detemine the facts alone.
2.
The purpose of quarantining equipment is to assure that all subsequent actions are consistent with a planned systematic troubleshooting effort that provides minimal loss of information and full traceability. This is a major sJpect of the IIP and needs to be highlighted.
3.
The EDO-established IIT is intended to be an objective and independent investigation. Accordingly, the team members assigned to a particular IIT should not have had a major role in the licensing matters of that plant. That is, the NRC Project Manager or the Senior Resident Inspector assigned to the plant would not be assigned to the IIT for an incident at that particular plant.
4 We believe that an IIT should include a senior project manager who is normally assigned to a different but similar plant. This individual would be of great value as liaison for administrative matters, legal questions, contractor assistance, media interface. and other matters.
5.
The program should give explicit consideration to the legal rights of licens2e employees being interviewed (see SECY 85-80).
6.
The IIT should include, to the maximum extent practical, an individual with direct experience with reactor operations (that is, an ex-licensed reactor operator or senior reactor operator, an experiented operator license examiner, or a Senior Resident Inspector) to provide the proptr context for evaluating both the adequacy of procedures and the performance of the operator.
7.
The initial objective of an IIT should be the fomulation and prompt release of a preliminary " sequence of events" for the incident. Such a sequence should be released and distributed widely within a week, if possible.
8.
The format of the report for an AIT is specified to be a "special inspection report". An inspection report is normally intended to document violations of various severity levels and other wrongdoings. This format will need to be overhauled substantially to be appropria.te for a primarily fact-finding effort like the AIT.
9.
The IIT leader should have daily cs munications with the designated point of contact for HQ (and for the rec {lonal office) and the minutes of
{
these status reports should be distributad promptly and widely.
- 10. The goal of the plan should be to upgrade the manner in which the NRC
~ investigates incidents. The plan should make it plain that the NRC has always investigated significant operating events. Contrary to the tone of the plan, the purpose of the IIT is to upgrade investigations, not to establish an investigation program.
)
l i
I 1
f 4
a 11. The interactfon of an IIT with the NRC site emergency team during the time necessary to get the plant to a safe, stable state should be clearly defined. Similarly, for a prolonged incident such as THI-2, an IIT would not be established within the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> as shown in the Table.
- 12. The procedures for the AIT and for the IIT, both being part of the IIP, should both be located in the same overall document. They should not be in separate documents, as is presently indicated in the plan. There could easily be AITs for which IE is not directly involved and a separate IE procedure would not be appropriate.
- 13. The qualifications of the individual IIT members should be based first on a comprehensive understanding of reactor safety principles and reactor transient behavior, and then on technical expertise in a specific area.
- 14. The plan should include the development of standardized general guidance for troubleshootir.g plans that would address all the necessary attributes such as traceability. The general plan developed for Davis-Besse event (included as an appendix in NUREG 1154) should be considered as the starting point for this development.
- 15. We believe that the anticipated personnel needs for IITs (based on 3 such events per year) is low.
It is more likely that something like 7 FTE-years may be needed, not 5.1.
- 10. The plan should recognize that there are situations where cne or two people are dispatched to the plant site to investigate particular aspects of an event but that activity is neither an AIT or related to PATS, CATS, etc.
- 17. Care should be exercised such that the IIP does not interfere with the normal responsibilities of the offices of NRR and IE.
- 18. The authority and responsibility for the establishment of an AIT should be clearly defined.
19.
It should be clarified that members of a AIT are relieved of all nomal duties so as to avoid an undue burden on an individual or interference with the effort of the AIT.
- 20. We can envision plant situations where the issuance of a cal. that
" freezes" plant equipment may be inappropriate. Therefore, the wording (Table 1) would be better if revised from "always" to "usually."
t
--