ML20137T324
| ML20137T324 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse, 05000000 |
| Issue date: | 01/24/1986 |
| From: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| To: | Cotter B, Stello V Atomic Safety and Licensing Board Panel, NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20137T320 | List: |
| References | |
| TAC-60569, NUDOCS 8602180324 | |
| Download: ML20137T324 (19) | |
Text
.
.#. s o '%,
UNITED STATES
[h
[*.
NUCLSAR REGULATORY COMMISSION
.i..i.k ' o I i u-~
s
- AsmacioN.3 0 :0555 b
[
5,45,?
January 24, le s :,
s OFFICE OF THE SECR ETA A Y "EFCFANDCM FCP:
E.
Paul Cetter, Jr.
Chief' Administrative Judge, ASL??
Victor Stello, Jr. (Acting)
ExecutiveDirectorfar0,I htions FRCM:
Samuel J. Chilk, Secret'c SU3 JECT:
ESTABLISHMENT OF AN AD HOC REVIEW GROUP ON THE DAVIS-BESSE 15CIDENT (SECY-85-165)
The Ccmmission has approved the establishment of an independent Ad Ecc Review Group to review issues arising cut of the June 9, TTa5 incident at Davis-Besse, to identify' additional lessons that might be learned from the incident and to reccmmend hcw NRC's internal procedures and its oversight cf reacter licens-ees may be impreved.
A copy of the charter for the Group is attached.
The Cc=missien has approved the.folicwing rembership of the Grcuo:
a.
Judce James Gleascn, (NRC), Chairman b.
Judge Peter Morris (NRC) c.
Dennis K. Rathbun (NRC) d.
Joseph H. Levine (NASA) e.
All members have been contacted.
Judge Gleason is prepared te initiate the Group's activity immediately.
The Commission has determined that responsibility for adminis-trative supper: of the Group is assigned to the ASLFP staff.
An administrative efficer and lead secretary should be appoint-ed frcm the Panel's staff.
(ASLBP) (SECY SCS?E3*SE:
1/23/SG) 8602180324 860206 CDMMS NRCC PDR CDRRESPONDENCE PDR
c-
, The Commissicn has also determined that additicnal suppcrt funds and persennel shculd be detailed from the EDO staff as required by the Group.
(EDC) (SECY SUSPENSE:
as required)
Attachment:
As Stated Copies:
Chairman Palladino Ccmmissioner Pcherts
-Commissioner Asselstine Commissioner P,ernthal Ccmmissioner Zech Judce Gleason OGC l
l i
i l
l'
CHARTER AD HCC INDEPENDENT REVIE*4 GROUP CN THE DAVIS-3 ESSE INCICENT The Nuclear Regulatory Commission has decided to establish an independent g hoc group (the review group) to review issues arising cut of the June 9, 1985, incident at the Davis-Eesse nuclear power plant. The purpose of this review grcup is to identify additional lessons that might be learned frca the incident, and frem these to make reccmmendations as to how NRC's inter-nal precedures and its oversight of reactor licensees may be improved.
The review group shall have the authority necessary to perform the tasks and acccmplish the purposes of this charter. By this and other reviews and the implementation of the reccmmendations arising frcm them, the Commission intends to reduce the possibility of future similar occurrences.
To this end the review group will undertake the following studies:
Examine the process of analysis, review, and interaction between the a.
Itcensee and the NRC that tcok place preceding the event ccncerning the reliability of, and the need and schedule for modification of, the Davis-Besse auxiliary feedwater system and associated systems; and make raccmmendaticns as to hcw the regulatory precess may be improved in light of the findings resulting frem this examination.
b.
Examine pre-event pectabilistic assessments of the reliability of the Davis-Besse plant safety systems, the NRC review of these assessments,
2.
and the use to which these analyses were put in the regulatcry decisionmaking prccess; and make reccmmendations as to how the use of this sort of reliability analysis in the regulatory process might be improved.
Examine the licensee's transgement, cperation and maintenance programs c.
to the extent that they may have concributed to the equipment failures that caused or exacerbated the ir.cident; examine the flRC's require-ments for, and oversight of, such licensee programs; and make recem-mendations as to how the NRC may improve its regulatcry processes and its oversight of reactor licensees in these areas.
Examine the mandate, capabilities of members,' operation, and results d.
of the Davis-Besse incident investigation team, and the use to which its report was put by the regulatcry staff; and make recccmendations as to how the incident investigation peccess may be improved.
This review is not a vehicle for determining whether Davis-Eesse can be The operated in the future without undue risk to public health and safety.
Commission will make that decision tir;tgh its normal regulatory procedures which are in no way dependent upcn the werk of this review group.
Therefore, the timing of that decisicn is in no way related to the work of this review grcup. Mcwever, if the review grcup identifies information bearing on a significant safety deficiency at Davis-Besse or other licensed facilities, it should bring this to the attentien of the ECO.
Similarly, this review should not assess respcnsibility for the incident cn the part of individual licensee er MC staff members.
That assessment is,
the responsibility of our Offices of In'spection and Enforcement, Investigations, and Inspector and Auditor. However, the Ccmmission expects that, if the review group receives any evidence relevant to the issues of culpable responsibility of individuals, such evidence will be provided pec:ngt1y to the Cctmission.
The group will determine for itself what methods and procedures other than adjudicatory it will use to gather data.
Insofar as the review group believes previcus reviews and analyses to be adequate, they should not
. duplicate the existing work. The ECO is instructed to provide additional technical data regarding the incident as it beccmes available.
Given 6he potential ccmplexity of task (b) above, the Ccemissicn will, if the group wishes, provide contractor support funds to assist the review group in its technical analysis of the various probabilistic analyses and the staff reviews thereof. The General Counsel and Secretary of the Ccmmission will be available for censultation in precedural matters.
Facilities and admin-istrative and clerical support will be p'rovided through the rescurces of the ASLB Panel, with additional support funds and personnel provided through detailing from the E00 staff. The review grcup shall determine the non-adjudicatory methods, procedures, and schedule it will follow to acccmplish its responsibilities, and notify the Commissicn thereof within two weeks of the issuance'of this charter'. Within 90 days the review group is to report in writing its findings and reccmmendations, and to brief the Cc. mission at a public meeting as soon thereafter as practicable.
i CUESTION 8.
INSTITUTE OF NUCLEAR POWER OPERATIONS (A). TO WHAT' EXTENT IS THE COMMISSION DEPENDING ON THE SERVICES OF THE INSTITUTE OF NUCLEAR POWER OPERATIONS TO RESOLVE GENERIC SAFETY ISSUES?
WHAT CRITERIA DOES THE COMMISSION EMPLOY IN DECIDING WHETHER TO RELY ON INP0 RATHER THAN THE COMMISSION'S OFFICE OF INSPECTION AND ENFORCEMENT?
ANSWER.
THE COMMISSION DOES NOT DEPEND UPON INPO TO RESOLVE. GENERIC SAFETY ISSUES.
HOWEVER, IT IS COMMISSION POLICY THAT NRC'S REGULATORY ACTIVITIES RECOGNIZE AND ENCOURAGE INDUSTRY INITIATIVES TO IMPROVE l-l' NUCLEAR SAFETY.
IN EAPLY 1984, INDUSTRY FORMED THE NUCLEAR UTILITY MANAGEMENT AND RESOURCES CGMMITTEE (NUMARC), AN ORGANIZATION OF SENIOR UTILITY OFFICIALS WHOSE GOAL IS TO REVIEW MAtlAGEMENT AND OTHER ISSUES IN NUCLEAR PLANT OPERATIONS'AND DEVELOP INDUSTRY WIDE
~ ESOLUTIONS.
SINCE THAT TIME, NUMARC HAS BECOME A MAJOR VEHICLE R
FOR ARTICULATING INDUSTRY SELF-IMPROVEMENT ACTIVITIES TO THE COMMISSION.
QUESTION 8(A).
(CONTINUED),
f THE RESOURCES OF INPO ARE USED BY THE INDUSTRY IN FURTHER
~
DEVELOPING NUMARC INITIATIVES AND IN EVALUATING THE PROGRESS OFEINDIVIDUAL UTILITIES IN IMPLEMENTING INDUSTRY SOLUTIONS.
WHERE NUMARC INITIATIVES ADDRESS GENERIC-SAFETY ISSUES FOR WHICH THE COMMISSION IS CONSIDERING THE NEED FOR ADDITIONAL REGULATORY REQUIREMENTS, OUR PROGRAMS ARE STRUCTURED TO RECOGNIZE INDUSTRY'S ~ INITIATIVE WHILE MAINTAINING PROVISION FOR NRC EVALUATION OF THE COMPLETENESS AND EFFECTIVENESS OF THE INDUSTRY PROGRAM.
FOR EXAMPLE, THE COMMISSION RECENTLY DEFERRED NEW RULEMAKING ON THE TRAINING OF NUCLEAR-POWER PLANT-PERSONNEL IN RECOGNITION OF THE' INDUSTRY INITIATIVE UNDERWAY TO UPGRADE TRAINING PROGRAMS.
THE COMMISSION ENDORSED THE INPO MANAGED TRAINING ACCREDITATION PROGRAM IN THAT IT ENCOMPASSED THE ELEMENTS OF PERFORMANCE-BASED TRAINING WHICH HAD BEEN ENVISIONED IN THE NRC STAFFS' PLAMS FOR RULEMAKING.
IN TAKING THIS ACTION, THE COMMISSION EXPECTS INPO, TOGETHER WITH EACH NUCLEAR UTILITY, TO PLAY A MAJOR ROLE IN SUCCE.SSFULLY RESOLVING THIS ISSUE.
- HOWEVER, WHILE INPO HAS TAKEN THE INITIATIVE IN THIS AREA, PROGRAMS bAVEBEENESTABLISHEDWITHINTHEOFFICEOFINSPECTIOMAND
a 00ESTION 8(A).
(CONTINUED). 1 ENFORCEMENT (IE) AND THE OFFICE OF NUCLEAR REACTOR REGULATION (NRR) TO GATHER INF'ORMATION ON THE STATUS OF THE INP0 PROGRAM AND TO' INDEPENDENTLY EVALUATE ITS EFFECTIVENESS THROUGH PERIODIC INSFECTIONS AND AUDITS.
IN
SUMMARY
,-THE COMMISSION DOES NOT RELY UPON INDUSTRY (NUMARC/-
INP0) RATHER THAN ITS OWN STAFF TO RESOLVE SAFE.TY ISSUES.
AS NOTED ABOVE, THE COMMISSION HAS IN INSTANCES SUCH AS THE INP0 MANAGED ACCREDITATION PROGRAM RELIED UPON INDUSTRY'S PROGRAM FOR
-IMPLEMENTATION OF A RESOLUTION.
HOWEVER, WE MONITOR AND AUDIT INDUSTRY ACTIVITIES AND ADJUST OUR REVIEW AND LIMITED INSPECTION 4
RESOURCES WHEN WARRANTED.
IN ADDITION, IN THOSE CASES WHERE INDUSTRY SELF-IMPROVEMENT INITIATIVES APPEAR TO ADEQUATELY ADDRESS NRC'S PERCEPTION OF AN IDENTIFIED GENERIC SAFETY ISSUE,.THE COMMISSION GENERALLY DESIRES TO RECOGNIZE AND ENCOURAGE SUCH INITIATIVES BY REFRAINING FROM THE PROMULGATION OF ADDITIONAL FEDERAL REGULATIONS.
THIS POLICY IS,-OF COURSE,-CONTINGENT UPON NRC'S ONGOING DETERMINATION THAT INDUSTRY IS, IN FACT, ADDRESSING
.AND SATISFACTORILY RESOLVING SAFETY ISSUES WITHOUT THE HEED FOR FURTHER REGULATIONS.
f
I QUESTION 8.
(B)
WHAT IS THE COMMISSION'S POSITION WITH PESPECT TO RECEIVING INPO REBORTS AND-PLACING THEM IN.THE PUBLIC DOCUMENT ROOM?
WHAT IS THE RATIONALE FOR THIS POSITION?
ANSWER'.
THE NRC AND INPO HAVE ENTERED INTO A MEMORANDUM OF AGREEMENT
-(M0A) IN ORDER TO HELP ENSURE THAT' THs GOALS OF BOTH ORGANIZATIONS ARE ACHIEVED IN THE MOST EFFICIENT AND EFFECTIVE MANNER WITHOUT DIMINISHING OR INTERFERING WITH EITHER PARTIES' RESPONSIBILITIES OR AUTHORITIES.
APPENDICES TO THE M0A ARE USED TO COORDINATE SELECTED NRC AND INP0 ACTIVITIES.
AS NEW AREAS OF MUTUAL INTEREST HAVE EMERGED, APPENDICES HAVE BEEN ADDED TO THE M0A.
THUS, THE NRC'S POLICY ON THE RECEIPT, USE, AND PUBLIC RELEASE OF INPO DOCUMENTS AND PRODUCTS HAS DEVELOPED OVER THE COURSE OF SEVERAL YEARS.
THE GENERAL POLICY REGARDING RECEIPT AND HANDLING OF INPO DOCUMENTS IS DESCRIBED BELOW.
INPO ASSIGNS ITS DOCUMENTS TO ONE OF THREE CLASSIFICATION CATEGORI'ES: GENERAL DISTRIBUTION, LIMITED DISTRIBUTION, OR RESTRICTED DISTRIBUTION.
DOCUMENTS WITH A GENERAL DISTRIBUTION CLASSIFICATION ARE NONTECHNICAL AND ARE GENERALLY AVAILABLE TO I
QUESTION 8(B).
-(CONTINUED) THE PUBLIC.
FOR EXAMPLE, INP0 DOCUMENTS PROVIDED AT INP0
~
BRIEFINGS OF THE COMMISSION ARE GENERAL DISTRIBUTION DOCUMENTS AND ARE PLACED IN THE PUBLIC DOCUMENT ROOM (PDR).
MOST TYPES OF INPO-GENERATED TECHNICAL, GENERIC DOCUMENTS (NOT PERTAINING TO A SPECIFIC UTILITY) ARE CLASSIFIED BY INPO AS LIMITED DISTRIBUTION.
THESE DOCUMENTS ARE DEVELOPED FOR AND PROVIDED TO INPO MEMBERS AND PARTICIPANTS PRIMARILY.FOR THEIR
. INTERNAL USE.
COPIES OF THESE DOCUMENTS ARE USUALLY PROVIDED TO
.THE NRC; HOWEVER, INP0 CONSIDERS THESE DOCUMENTS AS CONTAINING PRdPRIETARY INFORMATION, THE NRC ACCORDS THESE DOCUMENTS PROPRIETARY TRE,ATMENT AND DOES NOT NORMALLY PLACE SUCH DOCUMENTS IN THE PDR.
TECHNICAL DOCUMENTS THAT CONTAIN PLANT-SPECIFIC INFORMATION ARE CLASSIFIED BY INPO AS RESTRICTED' DISTRIBUTION.
THESE DOCUMENTS ARE NOT NORMALLY PROVIDED T0.THE NRC BY INP0; HOWEVER, INPO MAKES THESE REPORTS AVAILABLE TO THE NRC FOR REVIEW AND READING AT THEIR OFFICES IN ATLANTA, GEORGIA.
IN ADDITION, PLANT-SPECIFIC INP0: REPORTS ARE AVAILABLE.FOR NRC REVIEW AT LICENSEES' FACILITIES.
1 I
i
O QUESTION 8(B).
(CONTINUED) UNDER THE INP0/NRC MEMORANDUM OF AGREEMENT, TECHNICAL INFORMATION IS EXCHANGED BETWEEN THE TWO ORGANIZATIONS.
INPO TECHNICAL
'INFORMATION AND DOCUMENTS ARE PROVIDED TO THE NRC FOR THE AGENCY'S INTERNAL PURPOSES ONLY.
THEREFORE, INPO-GENERdTED DOCUMENTS WITH LIMITED OR RESTRICTED DISTRIBUTION WILL NOT NORMALLY BE PLACED IN THE PDR UNLESS SUCH INFORMATION IS USED AS THE BASIS FOR A SPECIFIC REGULATORY DECISION AND IT IS DETERMINED BY THE NRC THAT IT IS IN THE PUBLIC INTEREST TO RELEASE THE INFORMATION..THE NRC INTERPRETS THE PHRASE " SPECIFIC REGULATORY DECISION" TO INCLUDE BOTH DECISIONS WHICH RESULT IN SPECIFIC REGULATORY ACTION BEING TAKEN SUCH AS THE ISSUANCE OF CONSTRUCTION PERMITS, OPERATING LICENSES, AMENDMENTS, BULLETINS, ORDERS, OR INFORMATION NOTICES; AND DECISIONS WHERE A DOCUMENTED ANALYSIS CONCLUDES THAT NO ACTION IS NECESSARY (E.G., A GENERIC-
~
STUDY INDICATES THAT THERE IS NO SAFETY CONCERN REQUIRING REGULATORY ACTION).
IN SUCH CASES, THE INFORMATION WILL BE
' RELEASED IF THE INFORMATION FORMS A BASIS FOR THE REGULATORY DECISION IN A DOCUMENTED NRC STUDY ADDRESSING THE SAFETY CONCERN AND THE APPROPRIATE OFFICE DIRECTOR DETERMINES THAT THE PUBLIC'S RIGHT TO KNOW THAT BASIS OUTWEIGHS THE NEED FOR PROTECTION OF THE INFORMATION.
L i
QUESTION 8(B),
(CONTINUED) UNLESS A COMPELLING SAFETY REASON DICTATES OTHERWISE, INP0 IS NOTIFIED IN ADVANCE OF THE NRC DECISION TO MAKE THE INFORMATION PUBLIC, THUS ALLOWING INPO AN OPPORTUNITY TO EXERCISE THEIR LEGAL RIGHTS REGARDING SUCH DISCLOSURE,
-WHEN DOCUMENTS PROVIDED TO THE NRC BECOME THE SUBJECT OF A FREEDOM OF~lNFORMATION ACT (F0IA) REQUEST, THEY ARE PROCESSED IN ACCORDANCE WITH 5 U.S.C. 5552 AND PART 9 0F OUR REGULATIONS.
THE DOCUMENTS OR PORTIONS OF DOCUMENTS THAT CAN BE RELEASED UNDER THE F0IA REQUEST ARE PLACED IN THE PDR, THE AGENCY IS CURRENTLY INVOLVED IN LITIGATION C01;ERNING PORTIONS OF CERTAIN INPO DOCUMENTS FOR WHICH A CLAIM OF PROPRIETARY DATA WAS MADE.
SEE CRITICAL MASS ENERGY PROJECT
- v. NRC, CIv, ACT, NO, 84-1943 (D.D.C.),
THE AGENCY'S POSITION IN COURT IS THAT THESE DOCUMENTS CONTAIN CONFIDENTIAL, COMMERCIAL INFORMATION, THE' RELEASE OF WHICH WOULD IMPAIR THE GOVERNMENT'S ABILITY TO HAVE ACCESS TO SIMILAR MATERIAL IN THE FUTURE,
QUESTION 9.
TVA COMMISSIONER ASSELSTINE HAS STATED THAT THE REGULATORY BREAKDOWN AT TVA IS "THE SINGLE GREATEST FAILURE OF THE NRC REQULATORY PROGRAM SINCE THE THREE MILE ISLAND ACCIDENT."
WHAT IS EACH COMMISSIONER'S VIEW AS TO THE SEVERITY OF THE SITUATIONS, THE NEED FOR CHANGES IN NRC PRACTICES AND PROCEDURES TO ASSURE THAT SITUATIONS OF THIS TYPE DO NOT RECUR?
ANSWER UNQUESTIONABLY, THE PERVASIVE AND SEVERE BREAKDOWN OF MANAGEMENT CONTROL AND OVERSIGHT AT TVA IS SERIOUS AND, GIVEN THE SIZE OF THE TVA NUCLEAR PROGRAM, IS UNPRECEDENTED IN ITS SCOPE AND ECONOMIC RAMIFICATIONS.
HOWEVER, ONE CANNOT CONCLUDE THAT A LICENSEE'S FAILINGS, NO MATTER HOW SEVERE, MUST REPRESENT A REGULATORY BREAKDOWN.
THE COMMISSION IS NOW ENGAGED IN DETERMINING HOW MUCH OF TVA'S-PRESENT PROBLEMS COULD HAVE BEEN AVERTED BY NRC ACTION.
IN ORDER TO ANSWER THIS QUESTION OBJECTIVELY, OUR OFFICE OF l
INSPECTOR AND AUDITOR AND THE TVA SENIOR MANAGEMENT TEAM STAFF ARE EVALUATING VARIOUS ASPECTS OF OUR INTERACTIONS WITH TVA TO l
DETERMINE WHAT ACTIONS WE MIGHT TAKE TO REDUCE THE PROBABILITY OF ANOTHER SIMILAR SITUATION OCCURRING IN THE FUTURE.
- ALSO, r
THE NRC ACTIONS REGARDING TVA ARE UNDER INVESTIGATION BY THE SUBCOMMITTEE ON OVERSIGHT AND INVESTIGATIONS.
WHEN THESE ACTIONS ARE COMPLETED, WE WILL PROVIDE TO THE CONGRESS OUR CONCLUSIONS AND OUR. PLANS FOR THE FUTURE.
me.
Chairman Palladino and Commissioners Roberts, Bernthal, and Zech's Response to Udall Question 9 - TVA Question:
Commissioner Asselstine has stated that the regulatory breakdown at TVA is the " single greatest failure of the NRC regulatory program since TMI".
What is each Commissioner's view as to the severity of the situation, the need for changes in NRC practices and procedures to assure that situations of this type do not recur?
Answer:
Chairman Palladino and Connissioners Roberts, Bernthal, and Zech do not concur in Commissioner Asselstine's assessment.
The responsibility of the Nuclear Regulatory Commission is to regulate commercial nuclear power activities in order to protect the public health and safety.
It is the responsibility of the utility, in this case, TVA, to construct, maintain, operate, and manage the facilities in such a manner as to protect the public health and safety.
NRC establishes rules and standarcs, carefully monitors licensed activities, and takes enforcement steps if appropriate.
In this sense, we do not currently believe that the TVA situation represents a severe regulatory breakdown.
In fact, TVA made the decision to shut down their plants owing in large part to the regulatory concerns that had been expressed by the NRC.
In the case of Sequoyah, it was equipment qualification; for Browns Ferry, it was a verbal request from the Regional Administrator to TVA to justify continued operation of the facility.
Nevertheless, we do believe that there are lessons to be learned from the TVA situation that can be used to improve the performance of the NRC.
Indeed, TVA has had the benefit of considerable NRC attention over the past few years.
The number of inspections, enforcement and management
_a-----
. conferences, civil penalties, confirmatory action letters, and Systematic Assessment of Licensee Performance (SALP) report ratings confirm this observation. A special regulatory improvement program was required to be implemented at Browns Ferry and a NRC senior management oversight team was established to monitor Browns Ferry operations.
Since similar actions by other utilities had been successful in resolving like problems, it was believed that these actions would be successful at Browns Ferry. Manage-ment changes and new programs take time to implement and take effect.
It takes time to determine if the changes were effective.
As a result, significantdejayscanoccurbetweentheidentificationandeffective resolution of a problem.
The NRC was monitoring this process and was clearly devoting more than average resources to the TVA situation.
In our minds, the question is whether the NRC could have been more timely or more aggressive in analyzing the TVA performance trends, or whether the NRC could have been more demanding in directing TVA corrective actions.
Information gathered by the current O! and OIA investigations will help the Commission answer these questions, but we believe the NRC has already taken and can probably take even more actions to reduce the likelihood of a similar occurrence. Valuable lessons are oeing learned; there is always room for improvement not only by TVA, but also by NRC.
Actions the NRC has already taken include new safety system functional inspections and pilot outage inspections. We are looking at better ways to apply inspection resources by using SALP categories and, as you are
- - - - ~ -
.__.__._.__m
- i l
aware, by putting at least two resident inspectors at every site. All these actions should help the agency identify problems at plants in a more timely manner..
In summary, it is important to recognize that NRC regulates while TVA constructs, maintains, operates, and manages the facilities.
The NRC strives to learn from all its regulatory experiences. Within our regula-tory role, we believe we are devoting the resources necessary to help TVA solve its problems. Wewillcontinuetolookforwaystoimproyeour l
regulatory actions as more information becomes available.
l i
l l
Commissioner Zech adds that he has recently asked the Commission to consider tasking the staff to better use specific performance indicators that the agency can track and analyze in one centralized location in order
'for the NRC to be able to better recognize increasing and declining performance trends.
Some of these indicators might be unplanned scrams, Engineered Safeguard Feature (ESF) actuations, number of Licensee Event Reports (LERs), number of personnel errors and SALP report categories.
Although the Commission majority did not support this approach, he is I
continuing to attempt to focus his attention on performance indicators.
l l
(Commissioner Asselstine supported Commissioner Zech's proposal.)
r 6
f
o Question 9 Commissioner Asselstine adds the following:
This Agency was aware of significant quality assurance problems within TVA as early as 1975.
(See the attached memorandum fron re to the E00 dated January 21,1986.)
I believe we arrived at the current state of affairs largely because this Agency har historically been reluctant to face up to ranagement issues.
The NPC Authorization Act for fiscal years 1982/83 (P.L.97-415) directed the NRC to conduct a study of quality and quality assurance (OA) in the design and construction of nuclear power plants and to develop improvenents te NRC's and the industry's programs for achieving and assuring quality in design and construction.
In April 1984, the staff completed its report
" Improving Quality and the Assurance of Quality in the Design and Construc-tion of Nuclear Power Plants, NUREG-1055." The staff reported thet the key to achieving erd assuring quality lies with utility management.
The report highlights the fact that one of the greatest contributnrs to the risk associated with nuclear plants in the human component which plays a part in design, construction, operation and maintenance of ruclear facilities.
And, how the human element affects nuclear plants, whether for good or for ill, depends largely upon the quality of utility meregement.
The Commis-sion seems to take this idea one step too far.
In a recent letter we informed the Congress of the Commission's final actions related to P.L.
l l
L
2 97-415.
In that letter, a copy of which is attached, the Commission I
states:
"To put its decisions into suitable context, the Comission wishes to make clear licensees, not the NRC, are primarily responsible for achieving and assuring quality.
Substantial improvements in quality in the nuclear industry must ccce from the industry itself; they cannot be ' inspected in' or
' regulated in' by the flFC."
ISee letter from Chairman Palladino to the Honorable Thomas p. O'f:eill, Jr., dated December 12,1985.)
As indicated in my separate views on that letter, I believe the Comission has substantial responsibility fcr assuring quality.
The NRC must estab-lish and enforce minimum standards to ersure quality in the design, con-struction, operation and maintenar.ce of nuclear power plants. The Comission cannot abdicate this respensibility and merely rely on the industry to regulate itself.
In the case of TVA, as in the past, we are reviewing their proposals and programs. Where we find programs to be acceptable, we so inforn them.
That is missing a major lesson that should have been evident years ago --
TVA may develop good programs but, historically, TVA does not adeouately implement them.
A change in the head of operations and a set of new programs and calculations will not by themselves adequately resolve the past failinps at TVA.
The Comission must become much more aggressive in working with and in requiring TVA to improve its perfnrrance.