ML20136D769

Draft Incident Investigation Program Plan

ML20136D769
Person / Time
Issue date:	12/31/1985
From:	NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD)
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ML20136D710	List: ML20136D704 ML20136D732 ML20136D769
References
NUDOCS 8601060283
Download: ML20136D769 (20)

Text

INCIDENT INVESTIGATION PROGRAM PLAN Prepared By:

Incident Investigation Staff Office for Analysis and Evaluation of Operational Data December 1985 8601060283 851224 PDR MISC

• B601060261 PDR-

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TABLE OF CONTENTS

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Page Number I

i 1.0 Introduction.....................................................

1 1.1' Purpose.....................................................

1 1.2 B a c k g ro u n d.................................................. 1 2.0. Incident Investigation Program...................................

3 2.1 Incident Investigation Teams................................

3 2.2 Augmented Investigation Teams...............................

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2.3 Si te Vi si ts by Teams No t Related to IIP..................... 4 3.0 Program Activities and Schedules Related to Investigation

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Program..........................................................

7 3.1 Activities Required for Initial Implementation of i

the IIP.................................................

7 3.1. 1 Preparation of Manual Chapter NRC-0514. "NRC Incident Inves ti ga ti on Program".................................. 7

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3.1.2 Preparation of Personnel' Rosters........................

7 3.1.3 Development of Standard Confirnatory Action Letter or Order,for Freezing Equipment and Data...................

8 3.1.4 Define and Conduct Training for IIT Members.............

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3.1.5 Identification of IIT Administrative Requirements....... 9 4

3.1.5.1 T ra ve l A rra n g eme n ts..................................... 9 I

3.~1.5.2 S t e n o g ra p h e r s........................................... 9 3.1.5.3 E qu i pme n t............................................... 9 i

3.1.6 -

I I T Ma n u a l.............................................. 9 i

3.2 Long-Term Activities Not Required for Initial IIP I mp l eme n ta ti on.......................................... 11

'.2.1 Subpoena Power and Power to Administer Oath and A f fi rma t i o n............................................. 11 1

3.2.2 Authority of IIT to Pre-empt Parallel Investigations....12 3.2.3 Routine Testing for Drugs and Alcohol................... 12 3.2.4' Unsolicited Information from. Plant Personnel............ 12

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6 3.2.5 Develop Procedures for Application of the IIP to 4

i Nonreactor Incidents....................................

13 3.3 A I T P ro c e d u re s.......................................... 13 4.0 Organization............................................

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5.0 Required Resources......................................

13 5.1 Travel..................................................

14 5.2 Training................................................

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5.3 P rog ram. S u ppo rt......................................... 14 5.4 NRC Personnel (FTE).....................................

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6.0 Schedule................................................

15 7.0 R e fe re n c e s............................................. 17 4

Table 1 Comparisons of Incident Invest'igation. Team vs.

Augmented Response' Team.................................

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PROCRAM PLAN FOR FISCAL YEAR 1986 INCIDENT INVESTIGATION STAFF (IIS) 0FFICE FOR ANALYSIS AND EVALUATION OF OPERATIONAL DATA (AE00)

1.0 INTRODUCTION

1.1 Purpose The purpose of this Program Plan is to define the activities and planned accomplishments required to implement the NRC Incident Investigation Program (IIP) described in SECY-85-208 (Ref. 1). The goal of this plan is to have all of the procedures, training, equipment, etc., in place by July 31, 1986 to fully support an Incident Investigation Team (IIT) for a reetor incident.

IITs established prior to that date will use the procedures, eu., established by this plan, to the extent that they are developed.

1.2 Background

In 1977, Harold Lewis, a professor at the University of California, Santa Barbara, suggested in a letter to Representative Morris Udall, Chairman of the House Comittee on Interior and Insular Affairs, the establishment of a Nuclear Safety Board. This suggested organization would be independent of the NRC, patterned after the National Transportation Safety Board (NTSB), and chartered to review and analyze nuclear accident precursors and to recomend actions to prevent similar, potentially, more serious events in the future. Both the NRC Commissioners and the Advisory Comittee on Reactor Safeguards (ACRS) recommended against an NTSB-type organization.

Following the Three Mile Island accident in 1979, the Kemeny Comission and the NRC Special Inquiry Group made recomendations regarding the evaluation and assessment of operating events at nuclear power plants. As a result of the Kemeny Commission recomendation that the NRC establish a program for the systematic assessment of operating experience, AE0D was established in 1979.

The NRC Special Inquiry Group in its recomendations proposed a broad NTSB-type organization whose oversight function would include operating experience and investigation of operating events, and also general oversight of selected licensing and other regulatory functions. This ir. dependent organization was also referred to as a Nuclear Safety Board, which is the same title as proposed by Professor Lewis two years earlier, but expanded beyond ev'ent investigation.

In 1980, a bill was introduced into Congress that would have established a Nuclear Safety Board. In discussions, the House Comittee on Interior and Insular Affairs modified the bill significantly; for example, the authority of the proposed Nuclear Safety Board to oversee the performance of the NRC and the resolution of generic safety issues was eliminated. The bill was never introduced for consideration by the House of Representatives.

In April 1984, the ACRS recomended in a memorandum (Ref. 3) to the Commission that AE00 be elevated to the status of a Comission office. In making this recommendation, ACRS believed there was a benefit or need fur an independent review of operating events by an organization reportino directly to the Comission.

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In conjunction with the FY 1985 NRC Appropriations Act, Congress required that the NRC conduct a study, to be submitted to Congress within six months, of the i

need for and, feasibility of an independent organization responsible for conducting investigations of significant safety events including significant operational incidents, at facilities licensed by the Commission. Subsequently, responsibility for the study was assigned to AE00.

In August 1984, AE0D contracted with the Brookhaven National laboratory (BNL) to conduct the study.

In February 1985, BNL issued its report (Ref. 4). BNL concluded that a quasi-independent, statutory Office cf Nuclear Safety headed by a Director reporting to the Commission should be established. This office would have the i

primary responsibility for conducting investigations of significant events at NRC-licensed facilities. BNL further recommended that this new office absorb the current responsibilities of AE0D.

The ACRS provided their comments on the BNL report to the Commission in a memorandum dated March 13, 1985 (Ref. 5). The ACRS endorsed the fonnation of a'new statutory office.

1 The ED0 provided coments on the BNL report to the Commission in a memorandum 4

dated March 28, 1985 (Ref. 6). The ED0 opposed the major BNL conclusion e

indicating that the implementation of the BNL recommendation would entail major i

resource comitments and result in staff and program disruptions. However, he i

agreed that a number of recommendations made by BNL could improve the existing incident investigation process.

On May 9, 1985, the Commission met with the staff and BNL representatives to receive a briefing on BNL's report. Subsequently, the Comission directed the staff to recommend a proposed program to the Commission that incorporated needed improvements that were identified in the BNL report (Ref. 7).

The staff proposed the Incident Investigation Program (IIP) in SECY-85-208 (Pef. -1). Coincidently, the Davis-Besse total loss of feedwater event occurred the day before SECY-85-208 was provided to the Commission for approval. The investigation of the Davis-Besse event followed the policies and practices defined in the Commission Paper and thus served as a model for future in-vestigations and for the development of the Incident Investigation Program.

On October 16, 1985, the Comission approved the staff's proposal described in SECY-85-208, to improve the investigation of significant operating events.

Subsequently, the EDO directed the Director of AE00 to develop, administer, and coordinate the IIP (Ref. 2).

An Incident Investigation Staff (IIS) was established as an organizational element within AE00 to_ respond to the E00's directive. The IIS is responsible for the further development, coordination, and implementation of the IIP as defined.in this plan.

In addition, during investigations of significant operational events, the IIS will participate in and support the IITs as appropriate.

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2.0 INCIDENT INVESTIGATION PROGRAM (IIP)

The IIP is intended to assure that the investigation of significant events is timely, thorough, coordinated and fonnally administered. The scope of the IIP includes the investigation of significant operational events involving reactor and nonreactor activities licensed by the NRC. The primary objective of the IIP is _to ensure that operational events are investigated in a systematic and technically sound manner to gather.information pertaining to the root causes of the events, including any NRC contributions or lapses, and to provide appropriate j

feedback regarding the lessons of experience to the NRC, industry, and the public.

By focusing on root causes of operating events and identification of agsociated corrective actions, the results of the IIP process should improve nuclear safety i

by minimizing repetition of similar events. The IIP has two investigatory i

initiatives based on the safety significance of the operational events. Both initiatives involve responses by a team of headquarters personnel to determine the circumstances and causes of an operational event. For a more significant event, an Incident Investigation Team (IIT) will be dispatched by the EDO to investigate the event in a manner similar to the NRC response to the Davis-Besse event. The responses of headquarters teams to less sinnificant opera-tional events are designated Aucmented Investigation Teams (AITs) which complement and enhance regional expertise and response to the event. This section describes and contrasts these two integral parts of the IIP.

l 2.1 Incident Investigation Teams For those events with potentially serious implications for public health and safety, the EDO would promptly establish and dispatch to the site an Incident Investigation Team (IIT) consisting of multi-disciplinary technical experts with a Team Leader selected from the Senior Executive Service (SES). The team is to obtain factual information as to what happened, identify the probable causes as to why the event occurred, and to develop findings and conclusions for possible follow-on actions by the NRC or other organizations. It is expected that a recommendation to form teams will originate with the Director of NRR, HMSS IE, AE0D, or the Regional Administrator, j

In the event of a serious incident, the NRC regional office would ensure that the^ plant is placed and maintained in a safe configuration and stable condition.

The Region would also isste to the licensee an immediately effective Confirmatory 1

Action Letter or Order, as appropriate, that required " freezing" or " quarantining" of equipment and other evidence and information relevant to the event consistent with protecting and ensuring public health and safety. Once the plant is in a safe configuration and the emergency is over, an IIT would then be responsible for investigation of the event. An IIT investigation is intended to be the single investigation of the event by the NRC.

I The IIT will collect and analyze pertinent evidence -- interviews, documentary physical evidence -- germane to the event being investigated. The results of an IIT investigation will be documented in a report issued sinultaneously to the r

Commission and the EDO. Following issuance of the report, the EDO will initiate appropriate follow-on actions based on the team report.

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i An IIP Manual Chapter will include criteria providing guidance on the type of event warranting an IIT. The definition of the investigative process, approach I,

and methodology to be used by an IIT will be developed into procedures and included in an IIT manual.

2.2 Augmented Investigation Teams i

The second initiative of the IIP involves operational events with lower safety significance than those investigated by an IIT, but nonetheless warrant special attention through augmentation of the Region's investigation of the event by headquarters personnel. NRC responses to these types of events are defined as Augmented Investigation Teams (AITs).

The purposes of the AITs are to augment regional expertise and improve conenication of infonnation to headquarters concerning the root causes, potential implications, and corrective actions (to the extent known) related to the event. In general, the AIT inspection will be under regional supervision and will prepare a special inspection report. This report will document the results of the team's activities including the input from the headquarters team members.

Criteria guiding the determination of which events warrant an AIT will be included in the NRC Manual Chapter for the IIP. The specific AIT procedures to i

be followed will be developed by the Office of Inspection and Enforcement.

AE00 will monitor AIT activities as part of its overall responsibility for i

the IIP. An AIT can be initiated by the Regional Administrator or the l

Directors of IE, NRR, or HMSS and does not require the approval of the EDO.

Depending on the nature of the event, available resources, or the expected outcome of the fact-finding response, it may be agreed that the responsibility for an AIT should be shifted from the region to one of the Program Offices.

In this case, the team leader may be selected from the Program Office, which would then assume responsibility for the team's activities and documentation of its investigation.

Table 1 shows a comparison of the similarities and differences between the i

responses by an IIT or an AIT to an operational event.

2.3 Site Visits by Teams Not Related to IIP As discussed in the previous two sections, the IIP has two initiatives that involve event investigation at licensed facilities by an IIT or AIT. In addition, however, there are site visits by other NRC headquarters personnel which are not part of the IIP. For example, headquarters personnel visit facilities for numerous reasons such as Performance Appraisal Teams, generic i

issues task forces, Construction Appraisal Teams, operational readiness teams, Outage Program Teams and CRGR visits. Generally, these team visits are not associated with a specific operational event and thus their objective or scope is not to fact-find the root causes or safety implications of the facility's operational experience. These visits are nct within the scope of the IIP.

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-TABLE 1 j

Comparisons of Incident Investigation Team vs Augmented Inspection / Investigation Team IIT AIT Team Purpose Investigate an operating Same, but may identify f

event at a facility or specific actions that an activity licer. sed by should be taken by the the NRC to determine what Regions or Program happened, why it happened.

Offices.

and document findings and conclusions for possible follow-on activities.

i Team Activation EDO activates IIT based AIT established based on input by Regional on input and coordination Administrator or Director by Regional Administrator l

of NRR, IE, NMSS or AE0D.

or Director of NRR, NMSS, or IE.

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Team Composition I

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-Team Leader SES selected by ED0 Generally not SES.

from IIP roster.

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Team Members Normally a minimum of Nonnally a maximum of l

3-4 interoffice, 3-4.

multiple discipline j

members.

May involve multiple disciplines.

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No prior licensing /

inspection activities 4

related to licensee.

Selected from IIT roster.

i Relieved of regular duties.

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Administrative / Logistics I

Team response time after Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

an event.

I Travel funds and AE00 Program Offices / Regions.

administrative support.

I Procedures for implemen.

AE00 IE ta tion.

Regional Administrator Always Sometimes issues Confirmatory i

Action Letter to "fraeze" equipment.

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TABLE 1 (continued)

IIT AIT Administrative / Logistics Licensee personnel Always Not Likely interviews transcribed Duration of activity Weeks Days Press release Usually Not Likely Team establishment Yes Yes highlighted in ED0 daily staff notes Investigation Scope

- Fact-finding;

- Fact-finding;

- Findings and

- Could include inspection conclusions; activities related to regulatory requirements

- No recommendations;

- Findings and conclusions;

- Excludes possible violations and

- May suggest follow-on enforcement actions; actions.

- Single NRC investiga-tion.

Documentation NUREG issued Team activities reported simultaneously to ED0 in special Inspection Report.

and Commission.

Follow-up Actions Initiated by EDO Initiated by Region or Program Offices.

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3.0 FROGRAM ACTIVITIES AND SCHEDULES RELATED TO INVESTTGATION PROGRAM In order to ensure that the investigatinn of events is structured, coordinated, and fonnally administered, AE00 has undertaken a number of activities towards i

developing the'necessary guidance documents for an expanded program of significant event investigation. This section identifies the activities associated with the IIT that will be completed during FY 1986.

3.1 Activities Required For Initial Implementation o'f the IIP j

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The following activities will be completed by July 31, 1986 and will be used i

for all IITs established after that date.

4 3.1.1 Preparation of Manual Chapter NRC-0514, "NRC Incident Investigation i

Program" A new NRC Manual Chapter will be prepared by AE00 that will define specific objectives, responsibilities, and authorities, and establish basic requirements for planning, investigation, and follow-on actions to be taken in response to significant operational events involving NRC reactor and nonreactor licensees.

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The manual chapter will define the agency wide program, including the scope and functions of individual offices for both Incident Investigation Teams and Augmented Investigation Teams. Included in the manual chapter will be g'uidance on the nature and type of events warranting an IIT or an AIT.

l 3.1.2 Preparation of Personnel Rosters I

The IIS will develop and maintain two personnel rosters of candidates for

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participation.in IITs. The rosters may also be used to select team members for AITs. One roster will include only SES level personnel from which the EDO, a

with AE00 assistance, can select an IIT leader. The other roster will include j

senior personnel who may serve as expert members on the IIT.

l AE00 will identify candidates for membership on the IITs and obtain office review and coments. Background information will be developed for each

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candidate that includes areas of expertise and work activities related to licensed facilities. Arrangements will be made to ensure appropriate training 3

is provided.

i Qualifications and characteristics of. team leaders im-lude:

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- SES level employee.

Broad knowledge of nuclear technology, operating safety practices and procedures, operation and design of power reactors or fuel cycle facilities, NRC policies and procedures, and incident investigation.

Demonstrated administrative and management abilities in problem solving and meeting schedules adequate to independently direct the efforts of numerous staff personnel working in many technical disciplines for assigned investigation teams, i

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- Skill at communicating complex technical information to such diverse groups as the Commission, staff engineers and management, utility engineers and management, the press, and members of the public.

The qualifications and characteristics of expert members of an IIT include technical expertise in one or more of the disciplines represented in nuclear power plant design and operation with a broad ' understanding of reactor systems and safety or nuclear material safety and safeguards. They must have demonstrated ability to solve problems and produce an acceptable product within a demanding schedule. The roster of candidates will be categorized according to disciplines and areas of special expertise, including engineering (e.g.,

reactor systems, electrical, instrumentation and control), operations, human 1

factors, health physicist, and safeguards and security.

3.1.3 Development of Standard Confirmatory Action Letter or Order for Freezing Equipment and Data The purpose of'this activity is to prepare standardized language as input into a Confirmatory Action Letter (CAL) or Order that, within the constraints of maintaining plant safety, equipment be left in the "as found" condition and information and data concerning the event are retained.

The IIS will work with ELD to draft suitable language and procedures for issuing and removing an' immediately effective Order or CAL. The IIS will develop procedural guidance for the IIT's handling of " quarantined equipment during its investigation. The procedure will address the identification of equipment, removal of equipment from the quarantined list, regional 4;sistance in providing oversight of the troubleshooting activities, required documentation of root causes, etc.

i 3.1.4 Define and Conduct Training for IIT Members a

Each candidate on the team leader roster and expert member roster will receive formal training in incident investigation. To the extent possible, training plans will take advantage of existing courses related to incident investigation.

4 Discussions are being held with representatives of NTSB, FAA, ar.d other organi-zations (Ontario Hydro) to identify appropriate courses and their availability.

In addition, the IIS will hold an IIT seminar describing the IIP and its procedures. Thus, a preliminary training plan could include the following:

- Accident / Incident Investigation Concepts and Techniques (two weeks)

- Overview of 91 Investigation Procedures (1 day)

- Interviewing Techniques ~ (1/2 day)

- IIT Procedures (2 days)

At this time, it is estimated that personnel listed on the rosters will receive approximately 3-staff weeks of training before participating in an IIT. Initially, IITs may be formed with members who have not completed all IIT training.

i However, eventually all IIT members will have completed the training before assignment to an IIT.

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3.1.5 Identification of IIT Administrative Requirements The purpose of this activity is to identify, establish, and maintain administrative support for'the IITs.

3.1.5.1 Travel Arrangements The Incident Investigation Staff (IIS) will develop a procedure to ensure that all travel arrangements are completed in a timely and complete manner. It is currently planned that all travel associated with an IIT will be funded by AE0D.

This activity includes:

- Ability to process travel authorizations and obtain travel advances on short' notice regardless of day or time. The use of credit cards and blanket authorizations will be evaluated.

- Determining the proximity of the major airports and available lodging to sites. The IIS will develop a computerized listing of reactor site addresses and directions from a major airport.

- Ability to process travel claims in a timely fashion.

3.1.5.2 ~ Stenographers This activity will involve coordination with the ASLB Panel who administers the NRC contract for court reporters. Arrangements will be made to ensure overnight delivery of three copies of the transcribed interviews to the team at the site. The original.will be sent to the IIS and will be placed in the PDR when the IIT report is issued.

3.1.5.3 Equipment This activity will identify and obtain all equipment and supplies required by the IIT to perform its investigation. The equipment identified to date includes cameras and accessories, tape recorders, and transcribing equipment.

An additional task is an evaluation of the need fo'r a portable IBM-PC for the IIT while onsite.

3.l.6 IIT Manual This activity involves the development and compilation of procedures that govern and guide the IIT. The procedures will draw on the experience gained in the Davis-Besse IIT investigation and other pertinent investigations. In response to a menorandum (Ref. 9) from C. J. Heltemes, Jr., Program Office Directors and Regional Administrators provided comments (Refs. 10 to 18) that will be used in preparing the IIT procedures. In addition, the comments provided by the Davis-Besse team in Reference 19 will be used in developing

.the procedures.

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Issues that will be addressed in the IIT Procedures Manual will include:

Conduct of Investigations 4

- Responsibilities of Team Leader Specific responsibilities of the team leader including directing /

managing team, focusing investigations, spokesman for IIT, partici-pating' in press conferences,- preparing status reports, meeting schedules, etc.-

- Communications / Interfaces

' Requirements for timely flow of information and establishes the IIT as single source of incident information.

- Headquarters and region interface contacts and responsibilities.

- Interfaces between the IIT and the regions, headquarters, press, licensee, and other agencies.

- Unsolicited information from plant personnel.

Interfaces and coordination with other organizations, e.g.,

INPO.

- Scope of Investigation / Schedule Guidance for the investigation.

- Major milestones.

- Guidance for requesting additienal expertise (staff or contractors).

i Transcripts

. Guidance for conducting interviews and selecting interviewees.

- Guidance for handling the transcripts and access by other parties.

- Attendance of third parties at interviews.

Records and Documentation Need to account for documents and data.

- Guidance for accepting, referencing, and sharing draft documents.

Treatment of Quarantined Equipment Guidance for identifying equipment for_ quarantine.

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- Task action plans for determining root causes of equipment failures.

- Guidance for. quarantined equipment which is addressed by technical specifications.

- Role of regional office. in oversight of licensee troubleshooting root causes o.f equipment failures.

Procedure for third party examination equipnent.

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- Report Preparation

- Administrative procedures for preparation.

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- IIT report as NUREG.

An outline', including use of appendices.

- Editorial assistance and typing.

Need to safeguard.draf t versions.

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- Review process.

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- Commission /ACRS Briefings

- Team leader will present report.

Release of report.

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- EDO Followup Procedures

- EDO response to IIT reports.

- Team's assistance in highlighting staff followup actions.

3.2 Long-Term Activities Not Required for Initial IIP Implementation The following long-term activities will be completed after July 31, 1986.

The resolution of these issues will be incorporated in IIP procedures.

"3.2.1 Subpoena Power and Power to Administer Oath and Affirmation The objective of.this activity is to determine what powers the IIT should possess and under what conditions or circumstances they need such powers.

The tasks. involved in resolving this issue include:

-. Identify situations that warrant subpoena power (e.g., licensee personnel refuse to be interviewed, licensee or its contractors withhold reports or data).

- Determine whether the IIT should be given subpoena power or whether a third person could perform this functior,.

- Evaluate the advantages and disadvantages of depositions versus interviews for obtaining information related to personnel actions.

Transcripts will be taken in either case.

ELD.will be requested to take the lead in completing this activity.

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3.2.2 Authors ty of IIT to Pre-empt Parallel Investigations The objective of this activity is to evaluate the fe esibility of and necessity for the IIT to request, direct, or order other investigations of the event to terminate their activities. Such an action may be necessary if a parallel investigation was delaying or otherwise adversely affecting the IIT investiga-tion. This activity primarily addresses concurrent industry or licensee investigations because SECY-85-208 clearly states that the IIT will be the single NRC investigation. At Davis-Besse, parallel investigations performed by industry groups did not interfere with the activities of the NRC fact-

. finding activities.

The tasks involved in this activity are:

- Evaluate the circumstances where parallel investigations may constitute interference with the IIT.

- Determine the legal bases that the IIT must possess to pre-empt parallel investigations.

ELD will be requested to perform the legal analyses for such a requirement.

3.2.3. Routine Testing for Drugs and Alcohol This activity addresses the issue of whether the IIT scope of investigations i

should provide for testing for the presence of drugs and alcohol of licensee personnel involved in an incident, particularly those which involved significant

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human factor. questions. This activity deals with a potentially controversial issue and is related to " Fitness foi Duty." However, there is presently no NRC requirement that prohibits the use of alcohol and controlled substances by licensee employees. The Federal Aviation Administration and the Federal Railroad Acueinistration have requirements for testing for drugs and alcohol.

The tasks involved with this issue are primarily legal in nature and the resolution of this issue will involve:

- Determine whether such testing is required as part of the IIP.

- Determine the status and relationship of ongoing NRC activities.

- Evaluate various methods for including a drug / alcohol testing program within the IIP (e.g., voluntary testing, voluntary licensee requirement for testing, rulemaking, apply existing or proposed requirements).

ELD will be requested to perform the. legal analyses for such a requirement.

3.2.4 Unsolicited Information From Plant Personnel This activity involves developing ~a method for IITs to receive unsolicited information, perhaps anonymously, from plant personnel. The Davis-Besse team primarily interviewed operators and their supervisors. However, there may be personnel who possess relevant information concerning the event or circumstances existing prior to the event who would not be. identified for an interview.

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Identify and evaluate methods for obtaining relevant information from licensee employees on a voluntary basis.

Evaluate whether confidentiality is necessary and how it could be achieved.

- Develop an IIT procedure.

3.2.5 Develop Procedures for Appifcation of the IIP to Nonreactor Incidents This activity involves the necessary additional development and revision necessary for the IIP, including IITs and AITs, to investigate incidents at nonreactor facilities (e.g., radiography incidents, incidents at fuel fabrication facilities, medical misadministrations). It is anticipated that specific additional guidance may be necessary including implementing procedures.

3.3 AIT Procedures IE will prepare separate AIT procedures which will be incorporated into the IE Inspection Manual.

4.0 ORGANIZATION An Incident Investigation Staff (ITS) was established as an organizational element with AE00. The staff includes a Chief, a Management Assistant, and an Incident Investigation Engineer. Wayne.Lanning was selected as Chief of IIS and reports directly to the Director of AE0D. Recruitment activities are focused on selecting the Management Assistant and Incident Investigation Engineer which should be completed in February 1986 The IIS will develop policy, program requirements, and procedures for IIT investigations of significant operating events. An IIS staff member will accompany each IIT to provide administrative support liaison and technical cuidance to ensure that the IIT activities are consistent with established procedures and coordinated with NRC offices and other organizations. The IIS will maintain and integrate plans, procedures, team rosters and training, and coordinate staff activities to achieve IIP objectives.

The proposal for the composition of the IIS included an additional incident investigation engineer and a secretary, but were not budgeted. Hence, AE00 will provide additional support for-the IIS, particularly during early stages of IIP development and during an IIT investigation.

.5.0 REQUIRED RESOURCES The FY 1986 budget did not include funding for the IIP beyond the 3 FTE assigned to AE00 for the IIS. Thus, the IIP requirements (e.g., travel, training, program support, FTE) constitute additional needs to be accommodated within the appropriated FY 1986 NRC budget.

The information provided below addresses the principal resource needs for the j

IIT portion of the IIP. These estimates are based, in part, on the resources associated with the Davis-Besse investigation. For planning purposes, three i

IITs are expected for FY 1986, and each IIT would consist of five NRC staff.

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The required resources during FY 1986 are as follows:

5.1 Travel 4

- IIP Development Activities (IIS/AE0D staff)

$ 4K

- -IIT Travel (each team of five persons would 35K spend 2 weeks onsite and would make one 3-day followup visit) 5.2 Training It is not clear.yet whether this training will be funded by MDTS through a separate program support contract, etc. Detailed requirements will be developed and implemented as part of the program activities.

- Conduct of IIT Training Courses

$45K i

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5.3 Program Support Provide specialized expertise or analysis

$200K to support an IIT (AEOD)

Stenographer contractor (ASLP) 65K

. Equipment (portable PC, cacwras, tape 6K recorders and supplies) (AE09/RM)

TOTAL

$355K 5.4 NRC Personnel (FTE)

The following resources were required for the Davis-Besse IIT. It is assumed-that three IITs of similar scope will be required in.FY86.

Davis-Besse IIT FY86 (staff-years)

(3 IITs)

(sta f f-yea rs)

Team Members 1.0 3.0 Management and Supervision 0.1 0.-3

. Support AE00 (Adm/ Tech) 0.2 0.6 ADM (Cress / Tech Ed/Sec) 0.3 0.9 Region (Adm/Sec) 0.1 0_. 3 3

TOTAL 1.6 5.1 J

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In addition, the personnel will be required to prepare, review, and implement 1

the various activities required to establish and maintain the IIP. The resources

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include:

i FY86 (staff-years)

AE00 2.5 IE (AIT) 0.5 Other Offices and Regions (e.g., prepare and review the IIP manual chapter, participate in IIP training) 1.5 U

l 6.0 SCHEDULE ACTIVITIES REQUIRED FOR INITIAL IMPLEMENTATION OF AN IIT IIP Program Plan Target Schedule Issue interim program for comment 12/85 Issue final program plan 12/85 NRC Manual Chapter Issue draft for connent 2/86 Receive connents 3/86 Issue for concurrence 4/86 Issue final 5/86 Personnel Rosters j

Develop a list of candidate team members 1/86 i

Receive comments and develop background information 2/86 Rnsters complete 3/86 l

)

Training Plans

.i Hold discussions with FAA, NTSB, DOE, Ontario Hydro, and others to identify relevant training 12/85 Oraft training plans 1/86 i

Schedule training (funds, contracts, locations, co.sultants) 2/86 Stort training j

Team leaders 4/86 Team members 4/86

{

Initial IIT candidates' training complete 7/86 i

Administrative Requirements 1

Develop procedure for handling emergency travel 2/86 including authorizations, advances, tickets, i

vouchers, and use of credit cards i

Develop motel and site data bank 4/86 i

15 -

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Develop memorandum of understanding with ASLBP 3/86 regarding stenographers / transcripts Identify and requisition equipment required by IIT 3/86 including tape recorders, cameras, and miscellaneous supplies. Evaluate and justify need for portable PC equipment IIT PROCEDURES Prepare draft IIT procedures manual 4/86 Issue IIT procedures manual for comment 5/86 Issue final IIT procedures nanual 7/86 STANDARDIZED LANGUAGE FOR FREEZING EQUIPMENT Draft language 2/86 ELD review 2/86 Issue for region / headquarters review 3/86 Incorporate comments 4/86 Issue to regions 5/86 LONC-TERM ACTIVITIES NOT REQUIRED FOR INITIAL IIT IMPLEMENTATION Subpoena Power / Power to Administer Oath Meet with ELD to scope, issue, and assign responsibilities 4/86 Draft resolution of issue complete 7/86 Incorporate into procedures 9/86 Authority of IIT to Pre-empt Parallel Investigations Identify authority 7/86 Request ELD for legal analysis 9/86 Routine Testino for Drugs and Alcohol Evaluate need for testing as part of IIP 6/86 Determine status of related activities 7/86 Evaluate various methods for achieving objectives Meet / discuss / plan with ELD 8/86 8/86 Draft resolution 10/86 UNSOLICITED INFORMATION FROM PLANT PERSONNEL Identify and evaluate methnds 4/86 Determir.e need for confidentiality 5/86 Develop IIT procedure (milestone) 7/86 -

4

7.0 REFERENCES

1

'1.

U.S. Nuclear Regulatory Commission, " Incident Investigation Program,"

SECY-85-208, June 10, 1985.*

2.

Memorandum from W. J. Dircks, to C. J. Heltemes, Jr., NRC,

Subject:

l Implementation of a Revised Program for the Investigation of Significant Operating Events, November 14, 1985.*

3.

Letter from J. C. Ebersole, ACRS, to N. J. Palladino, NRC,

Subject:

ACRS Comments on the Possibility of an Organization Like the National Transportation Safety Board (NTSB) for Nuclear Safety, April 11, 1984.*

i j

4.

W. Y. Kato, et al, Brookhaven National Laboratory, "An Independent Safety Organization," U.S. NRC Report NUREG/CR-4152, February 18, 1985.*

5.

Letter from H. W. Lewis, ACRS, to N. J. Palladino, NRC,

Subject:

ACRS

' Comments on the Possibility of an Organization Like the National Transportation Safety Board (NTSB) for Nuclear SafeSy, March 13, 1985.*

1 6.

MemorandumfromW.J.DirckstotheCommissioners,NRC,

Subject:

Comments on the Brookhaven National Laboratory Study dated February 15, 1985

. entitled, "An Independent Safety Organization," March 28, 1985.*

4, Memorandum from S. J. Chilk NRC to W. J. Dircks and J. E. Zerbe, NRC, 7.

Subject:

Staff Requirements--Briefing' on Brookhaven Report on Independent i

Safety Organization, May 21, 1985.*

8.

Memorandum from S. J. Chilk to W. J. Dircks, NRC,

Subject:

SECY-85-208, Incident Investigation Program, October 16, 1985.*

9.

Memorandum from C. J. Heltemes, Jr. to H. R. Denton, NRC et' al,

Subject:

Lessons from the Davis-besse Investigation Effort, August 22, 1985.*

~

~

i

10. Memorandum-from J. M. Taylor to C.- J. Heltemes, Jr., NRC,

Subject:

Lessons from Davis-Besse Investigation Effort, October 21, 1985.*

11. Memorandum from J. G. Keppler to C. J. Heltemes, Jr., NRC,

Subject:

i Lessons fron Davis-Besse Investigation Effort, October 21, 1985.*

}

12. Memorandum from J. G. Davis to C. J. Heltemes, Jr., NRC,

Subject:

Lessons from Davis-Besse Investigation Effort, September 4,1985.*

13. Memorandum from J. B. Martin to C. J. Heltemes, Jr., NRC,

Subject:

Lessons fron Davis-Besse Investigation Effort, September 9,1985.*

i

14. Memorandum from R. D. Martin to C. J. Heltemes, NRC,

Subject:

Lessons j

from Davis-Besse Inv~estigation Effort, September 28, 1985.*

15. Memorandum from T. E. Murley to C. J. Heltemes, Jr., NRC,

Subject:

j l

Lessons from Davis-Besse -Investigation Effort, Statember 16, 1985.*

j l !

i i

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,., -.. - - ~ - - -,

r

16. Memorandum from J. N. Grace to C. J. Heltemes, Jr., NRC,

Subject:

Lessons from Davis-Besse Investigation Effort, October 1,1985.

17. Memorandum from G. H. Cunningham, III to C. J. Heltemes, Jr., NRC,

Subject:

Lessons from Davis-Besse Investigation Effort, September 6, 1985.*

18. Memorandum from H. R. Denton to C. J. Heltemes, Jr., NPC,

Subject:

Lessons from Davis-Besse Investigation Effort, October 9, 1985.*

19. Memorandum from C. E. Rossi to W. J. Dircks, NRC,

Subject:

NRC Davis-Besse Team Comments on Event Fact Finding Methodology, August 20, 1985.*

• Available in PDR for inspection and copying for a fee. 1