ML20151H294
| ML20151H294 | |
| Person / Time | |
|---|---|
| Issue date: | 07/22/1988 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1682, NUDOCS 8808010220 | |
| Download: ML20151H294 (150) | |
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NUCLEAR REGULATORY COMMISSION a se m as = = ss = = = = = = = as = = = ss = = = = = = = = ma. = = es se m as = = = es = = = = = es = = = es es ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
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In the Matter of:
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ACRS TVA ORGANIZATIONAL ISSUES
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ON ADVANCED REACTOR DESIGNS
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July 22, 1988
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4 l i-I' UNITED STATES NUCLEAR REGULATORY COMMISSION 2
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 3
4 In the Matter of:
).
)
5 ACRS TVA ORGANIZATIONAL ISSUES
)
ON ADVANCED REACTOR DESIGNS
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6
)
7 Friday July 22, 1988 8
Room 1130 a
1717 H Street, N.W.
Washington, D.
C.
10 11 The above-entitled matter came on for hearing, 12 pursuant to notice, at 8:30 a.m.
13 ACRS MEMBERS PRESENT:
14 MR. CHARLES J. WYLIE, retired Chief Engineer, Electrical Division, 15 Duke Power Company, Charlotte, Ncrth Carolina 16 MR. CARLYLE MICHELSON, retired Principal Nuclear
}
Engineer, Tennessee Valley Authority, Knoxville, l
17 Tennessee and retired'Riector, Office for Analysis and Evaluation of Operational Data, U.
S. Nuclear 18 Regulatory Commission, Washington, D.
C.
19 DR. FORREST 3.
REMICK, Associate Vice-President for l
Research and Professor of Nuclear Engineering, The 20 Pennsylvania State University, University Park, Pennsylvania 21 MR. JAMES C. CARROLL 22 ACRS COGNIZANT STAFF MEMBER:
23 DEAN HOUSTON 24 25 Heritoge Reporting Corporation m-
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2 I
INVITED EXPERT:
2 PAUL BARTON 3
NRC STAFF PRESENTERS:
4 Edward Goodwin Mark Peranich 5
6 7
8 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 l
1 Heritage Reporting Corporation (M1) 628 eM4
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'l EEEEEEE1EEE 2
MR. WYLIE:
The meeting will now come to order.
3 This is a meeting of the Advisory Committee on 4
Reactor Safeguards Subcommittee on TVA Organization Issues.
5 I am Charlie Wylie, Subcommittee Chairman.
6 The other ACRS members in attendance are: Carlyle 7
Michelson, J. Carroll, Forrest Remick.
Paul Barton!is attend-8 :
ing as Invited Expert.
9 The puroose of this meetingis to review the generic to lessons learned from the Staff's review in regard to the re-11 start of Sequovah 2 and recent TVA oraanizational changes.
12 Dean Houston is the cognizant ACRS Staff Member for 13 this meeting.
- 4 The rules for participation in today's meeting 15 have been announced as part of the notice of this meeting 16 previously published in the Federal Register on July 5, 1988, 17 (Federal Register 25221).
18 A transcript of the meeting is being kept and will 19 he available as stated in the Federal Register Notice.
It is 20 requested that each speaker first identify himself or herself 21 and speak with sufficient clarity and volume sothat he or she i
22 can be readily heard, 4
23 We have received neither uritten comments nor re-i 24 quests for time to make oral statements from members of the 25 public.
i Heritoge Reporting Corporation j
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3 4
The meeting today is divided into two parts.
The 2
morning session will begin a review of the staff's TVA Lessont 3
Learned effort as requested of the ACRS by the Commission, t
4 by the Staff Requirement's Memorandum of March 2nd, 1988.
5 Paragraph 4 of that memroandum states: "TheLACRS 6
is requested to perform an independent review of the Staff's 7
TVA Lessons Learned effort.
The ACRS review should determine 8
if the staff's effe t was sufficient to assure that all 9
significant lessons-have been addressed.-
The ACRS should 30 report their results and make any recommendatione. to the 3
Commission and the SECY Suspense Date is 9-1-88.
12 This morning, representatives of the staff are 13 present and will make presentation regm ' ding the TVA Lessons 14 Learned effort and are available to answer questions of the 15 Subcommittee.
16 A second meeting of the Subcommittee has been-17 scheduled for August 5th, for the Subcommittee to obtain any 18 additional informction it needs and to discuss and prepare 19 a report to the ACRS : 7d to decide on what should be presente l 20 to the ACRS at the August meeting with the intent of writing 21 a letter to the Commission prior to the September date.
22 At conclusion of our morning meeting, the Sub-23 committee and our Invited Expert will discuss the plans for 24 the August 5th meeting and what'should--any additional infor-j i
25 mation that should be obtained.
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i The-afternoon session will br a review of the TVA's 2
recent reorganization of TVA management structure and cost 3
savings measures.
The concern here is to what extent does 4
these actions affect the TVA nuclear power organization and 5
what adverse affects may results from the actions, if any.
6 TVA's' Office of Nuclear Power was' exclusively J
7 reorganized several years ago and have been engaged in an 8
extensive recovery program for'several years.
The NRC' staff 9
has worked closely with TVA and followed that activity and to the ACRS has followed the TVA activity and the staff's acti-11 vity and has written several letters to the Commission regard--
12 ing the TVA management structure and restart effort and it 13 made a number of recommendations in those letters.
14 The latest letters the ACRS wrote was in February 15 and March of this year.
Some of the recent reorganizational 16 measures seem to agree with some of the ACRS recommendations, 17 however, the details of how the organization and operation 18 of the nuclear plants will be affected is not clear, there-19 fore the purpose of the af ternoon raeeting.
20 Representatives from TVA and the staff will be 21 available to make presentations and answer questions of the j
J 22 subcommittee.
j 23 The subcommittee should keep in mind what we need 24 to report to the ACbS and present, if anything, and we wil 25 discuss that at the conclusion of todays activities.
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Now, I call on members of the subcommittee, if they 2
have any comments they_would like to make before we proceed.
3 MR. MICHELSON:
I have one comment.
I 4
I notice that Fred Hebdon is here this morning, so 5
maybe he can answer on SECY 87211, there is a~1etter in the 6
SECY enclosure from Mr. Colver.
It'is a handwritten letter 7
and in my copy, it's not totally illegible, but almost totally 8
' illegible.
9 Is it possible to get a legible copy.
Certainly 30 the Commissions must have gotten a legible copy of the letter, il MR. HEBDON:
Let me check on that.
12 MR. MICHELSON:
This one here, the Xerox just didn' t P ck it up.
If necessary, I would appreciate it if it would i
13 34 be retyped or something off of a legible copy.
15 MR. HEBDON:
Certainly.
If we don't have one 16 with us right now, we'll send one to you.
17 MR. MICHELSOM:
I think it is a worthy letter,-
18 making a worthwhile contribution and I would like to be able
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19 to read it.
20 The other thing is, the last one or more pages are 21 missing because the last page ends with an incomple*,e sentence 22 which infers that there is more to follow and I checked our 23 master copy and they also have the missing page.
24 See if you can find any pages missing and then i
25 either do something special, photograph it or something so I
Heritoge Reporting Corporation i
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we can read it'because it-is a good letter but many of the
-2 Pages are just coming out illegible.
3 MR. HEBDON: We'll do that.
4 MR. WYLIE:
Any other comments?'
s (No response) 6 MR. WYLIE:
If not, let's proceed and call-on 7
Steve Richardson.
8 MR. RICHARDSON:
Charlie, Ed Goodwin, of my-staff 9
is the principal author of'the document and will make the 30 _
presentation.
11 MR. WYLIE:
All right.
12 MR. GOODWIN:
Good morning.
My name is Ed Goodwin 13 of the TVA Project's Division of Special Projects.
We have 14 been asked to provide to the Subcommittee a review.of the is preparation, general conclusions and recommendations of the 16 TVA Lessons Learned Report.
17 This report was requested by the Commission in 18 January of 1986 shortly after the various nuclear units of 19 TVA had been shut down in late
'85.
H 3
20 Their general directive was to examine the inter-21 action between the NRC and TVA in the years prior to the 22 shut down to determine what lessons could be drawn that would 23 improve the NRC's performance in future similar situations.
24 The directive was clear that the purpose of.the 25 Lessons Learned effort was not to identify problems with TVA Heritoge Reporting Corporation mannen j
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8 3
.nor to come up.with solutions to TVAs problems but rather 2
to improve the staff's performance'in future similar situa-3 tions.
I 4
It was first' envisioned that the Lessons Learned 5
Report would be issued after Sequoyah restart which was, at 6
that time, scheduled for the late fall fo 1986.
7 For a number of reasons, that.date started to slip 8
in the summer---in the Spring and Summer of 1986 and in 9
September of 1986, the Commission directed the staff to go proceed with a Lessons Learned Analysis at that-time.
11 The report was drafted by what was then the TVA-12 Project Staff which was a small coordinating committee or 13 coordinating group of raps by professionals permanently ja attached and another 10 to 15 the.t were working on various 15 aspects of the TVA restart activities.
16 We drafted that report in October of 1986 and 17 distributed it first, within-those line organizations-within 18 the NRC that had had oversight responsibility and interaction 39 with the NRC or with TVA, excuse me.
20 Based on the comments of those individuals, the re-21 Port was revised extensively, extended and was issued as a 22 Preliminary Lessons Learned Report in December of 1986--excus a 23 me, November of
'86.
The Commission was briefed in December 24 and in January, at the direction of the Commission, we sent 25 the report out to about 30 former TVA managers, former NRC Heritoge Reporting Corporation
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Managers, former NRC and TVA employess who, for one reason 2
or another, we felt had substantial personal knowledge of 3
the interaction between TVA and the NRC in those preceeding 4
years.
5 We received a~ number of comments, some quite:
6 voluminous and most quite detailed and useful that we 7
analyzed and this analysis and the comments,'along with an 8
implementation plan, were put together as another SECY 9
paper in July of 1987.
go The Commission app'.oved.that implementation plan in 11 February of 1988 and I believe at that time issued the staff 12 requirements of memorandum which requested you gentlemen.to 13 review our activities to date.
34 MR. CARROLL:
Question.
15 MR. GOODWIN:
Certainly.
16 MR. CARROLL:
In terms of former TVA and NRC 17 people that responded, the thing I have in my package is the 18 complete list of the people with asterisks next to their 19 names did not ultimately respond.
20 MR. GOODWIN:
That is correct, sir.
I.believe 21 it is Enclosure (2) to the SECY 87211.
22 My apologies for the slides.
I didn't realize they 23 were that bad until I put them up.
Based on our initial review, we determined that 24 25 the TVA situation, in retrospect, did not break upon either Heritage Reporting Corporation
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TVA or the NRC without' warning.
A review'of Inspection 2
Reports, LERs and other documentation from the early '80's 3
showed that significant problem areas had-been identified i
4 by what'was then the Inspection.and Enforcement Staff, the 5
Resident Inspectors, by certain portions of the TVA organiza-6 tion at that time.
7 Both at NRC instigation and of their own volition, 8
TVA had instituted a number of corrective action. programs 9
1.' areas like QA, treatment of employees, environmental' go qualiticetions and a number of others.
~
11 It was our general conclusion that these programs 12 were not effective at addressing major causative factors.
13 They might have corrected specific identified deficiencies, i4 they may have put new procedures and methods in place, but-the is method of doing business had not, in substance, changed.
16 The shut down, in summary, represented the culmina-17 tion of a number of efforts to change the direction TVA was 18 heading in that were, in 1985, judged to be fundamentally un-19 successful.
20 DR. REMICK:
"d, the question--
21 MR. GOCv' s,
sir.
22 DR. REMICK:
on John Ahern's response, he raised
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23 the question about what do we know about INPO observations i
24 during this time period.
Did the staff ever purcue that?
25 MR. GOODWIN:
We did pursue it, informally, and Heritage Reporting Corporation (Set) 6M4006 l
11
'l really have little to add.=
To remind you, INPO was' formed, 2
I believe, in_1984.
TVA was--
3 MR. CARROLL:
It was before '84, long before 1984.
4 MR. GOODWIN:
Started to really be active.
TVA 5
was quite active.in the training aspects of INPO, but as far 6
as we were able;to determine, they were a rather passive member 7
of INPO in other areas and that there wasn't a great deal of 8
interaction between INPO and TVA prior to 1985.
There were 9
inspections that were done either shortly before or shortly 10 after the shutdown.
My memory is the late Spring or early 11 Summer of 85 and I stand to be corrected.
12 DR, REMICK:.They must have had evaluation visits 13 prior to that time, I would think.
34 MR. GOODWIN: I am told, yes.
15 MR. RICHARDSON:
There were a number of visits to 16 the construction site.
For examplc INPO did a visit that 17 was a telethon that generated--
Ig DR. REMICK:
They must have--
19 MR. RICHARDSON:
I don't think INPO did a' corporate 20 visit of TVA but--
21 DR. REMICK:
They must have done their evaluation 22 visits in that time period, you know, of the operating plants 23 MR. CARROLL:
Do you know how many they did and 24 at what plants?
25 MR. RICHARDSON:
No, but we can get that informatio.1 Heritage Reporting Corporation (ast) Messe
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for you.
2 MR. MICHELSON:
Wasn't a part of the NRC investigati on-3 of this.whole situation to go back and see exactly.what INPO 4
.did do, if anything, during the. time period. in _ question? -
5 MR. RICHARDSON:
We'll get back--
6 MR. MICHELSON:
It certainly.would have been part 7
of any reasonable investigation of the situation.
It con-8 firmed, one way or.the other, what the participation was.-
9 I'm surprised you don't have the answer ^immediately as to_
1 10 what happened.
i
~11 MR. RICHARDSON:
We'll get back'to you on that, i
12 MR. MICHELSON:
Apparently.NRCs view of the problem 13 did nct include looking into INPOs operation in that regard, 14 MR. BARTON: One other question on that subject.
15 Do we know whether TVA made those INPO reports public?
You 16 know, they have the privilege of not making them public, if 17 they wish?
18 MR. MICHELSON:
Yes, but the utility _could make 19 them public.
20 MR. BARTON: That's what I meant.
I don't know 1
21 whether they were made public or not.
1 22 MR. MICHELSON: Probably not if they.weren't asked 23 for.
j 24 MR. CARROLL:
So what we're interested in is 25 every plant evaluation that INPO did in that time frame as Heritoge Reporting Corporation
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as well.as any corporate' evaluation. Of course,_INPOs-normal 2-practices, you do the plants every 15 months and every other 3
one,'in other words, every 30. months, you do corporate and 4
I guess I would also like to know if.TVA asked for assistance
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5 from INPO during this time frame.
Did they have assistance 6
visits in some specific area?
7 MR. RICHARDSON:
We'll have to look into that and 8
get back to you.
9 MR. MICHELSON:
I would think, Charlie, if it's to all right with you, I would be willing to wait until th'e 13 August 5th meeting so it would be a fairly complete report.
12 MR. WYLIE:
That would be fine.
13 MR. MICHELSON:
I don't think we need it today, 4
14 because we're not going to do any decision making today, but' 15 I would like to hear about it at our next meeting, in rather 16 complete detail since I think it's pertinent and has been 17 brought out on numerous occasione in the comments and-I 18 don't know the answer.
19 MR. WYLIE:
I think that's appropriate.
20 MR. RICHARDSON:
We'll. be ready on the 5th of 21 August.
22 MR. GOODWIN:
The conclusion of the Lessons. Learned 23 Review Group was that the fundamental cause of the broad 4
24 range of TVA problems was truly a lack of central and dis-25 ciplined leadership on the part of TVA, that manifested itself Heritage Reporting Corporation
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in'a breakdown of TVAs management, control of, conmmunications 2
witt its own employees.
3 We felt that this stemmed largely from an ineffec-t 4
tive TVA management in terms of true leadership and from an 5
extraordinarily fragmented organizational structure.
6 In looking at our own performance, we "concluded that 7
we had required corrective action programs which addressed g
the specific deficiencies both either we or TVA had identifiec 9
but that, in truth, that these programs were, at best, address,-
go ing symptoms and not the route cause.
t gg We concluded that for one reason or another, the 12 depth and seriousness of our concern in these areas had not 13 been transmitted effectively to TVAs Board of Directors and g4 General Manager.
15 We further concluded--
16 MR. MICHEL6vN:
Excuse me.
Why do you believe that last statement---on what basis?
17 18 MR. GOODWIN:
It was the-view of the Regional Administration, then in place which had not been a participant g,
- o the previous years, based on their feedback to TVAs Executive 21 Management and their own conclusions that TVAs Executive 22 Management did not understand the seriousness of the concern.
MR. MICHELSON:
And was it apparent that NRC had made 23 the seriousness clear?
l 24 25 MR. GOODWIN: The record is mixed on that.
It did Heritoge Reporting Corporation i=>
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=16 not-appear so from the written. record and from the memory of 2
the present board members of TVA.
The individual comments we 3
received in our preliminary report so noted.
The preliminary 4-comments that we or'the external comments that we hadfreceived 5
seemed to counter that.
4 6
MR. MICHELSON: I read the comments and they-seemed 7
to be on both sides of that view.-
The TVA people seemed to 8
be saying SRC didn't tell us and_the NRC people seemed to be 9
saying we kept telling TVA these problems.
Did I read it 10 incorrectly or--
11 MR. GOODWIN:
That is how I read it though I will 12 note that there were, I believe, 2 TVA people--
13 MR. MICHELSON:
There were. exceptions.
g4 MR. GOODWIN:
--who stated that they believed that 15 the Board of Directors was fully and currently informed of 16 the seriousness of their concerns.
It is a question of 17 judgment that we can't resolve.
18 MR. MICHELSON:
That's right.-
You've gone as far as 19 you can.
But, it seems to be a mixed bag,. depending on who 20 is doing the commenting and what level they're at.
The l
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21 Pattern seems to indicate, at the highest lcvels, they J'
22 claim they weren't told and at the lower levels people are 23 sa ing, as far as they knew they were told and some of them i
24 had direct access to the board.
25 MR. GOODWI:1:
That's how I would characterize it.
Heritoge Reporting Corporation (Set) Maest
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1 MR. BARTON:
A comment.
TVA's nuclear managers 2
-told me--TVA management was told that they~didn't understand, l
i 3
they didn't listen, they didn't understand what they were i
4 being told.
5 MR. GOODWIN: I heard that view expressed also.
?
6 DR. REMICK:
Ed, that same bullet indicates that 7
the staff did not communicate with executive management of 8
NRC.
Does that mean only the Commissions or did you find it 9
was not communicated to the EDO?
10 MR. GOODWIN: The view that was held was that r
11 the regional administration was trying to solve its own 12 problems and perhaps had not communicated effectively to the 13 EDO and to the Commission and to the Director of NRR and r
14 INE, the depth and seriousness of the problem.
i 15 DR. REMICK: Is that something that is being 16 addressed?
I still hear and I guess a month doesn't go by 17 that somebody doesn' t tell me that the regions.are--each regic n 18 is different.
There are major inconsistencies between regions 19 and regions in headquarters and I think what you just said l
20 is another example of that and is that anywhere being high-
)
d 21 lighted as a possible problem in this agency with that many 22 different arms out there doing different things and not com-
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23 municating?
24 MR. RICHARDSON: First, this recommendation and this 25 conclusion were made about things that happened principally Heritage Reporting Corporation o-
18 1
in 1983 and 1984 in a single region about a single plant.
2-There have been a number of changes made in both personnel, and 3
administrative structure, all of which address that problem.
4 Later this morning,-in implementation, NRR,'I think, 5
will discuss this in more detail the matters and their 6-effectiveness.
7 It would seem it must have happened.
The principal.
t 8
that the agencies'do now-is we have senior management meetings 9
every 6 months with EEO and principal operators meet with to all the administrators and specific problems.are discussed and 11 if there are problem plants, they are given a ' synopsis.
12 I don't think that in todays world it would be 13 quite as possible, I guess, for a region to try and be a little 34 parochial in trying to solve their own problems as far as 1
15 probling by the agency reflecting performance indicator 16 information from EOD and I think a
short answer is yes, 17 we do have programs in the agency underway today that I 18 think will address that and Mark and-Fred will talk more l
19 about that a little later.
I 20 DR. REMICK:
Okay.
Thank you.
21 MR. GOODWIN:
I would note, Dr. Remick, in terms of 22 that question of consistency, there is now a program for t
23 annual comparative assessment of regions done centrally l
24 through NRR that is designed specifically to address that 25 issue of consistency.
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1 MR. CARROLL:: To help me calibrate the comments i
1 2
that were solicited, who were the-players in this~'83
'84
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3 time frame.
Had Dirks left. as EDO at that time or was N2 i
4
.still EDO?
5 MR. GOODWIN:
Dirks was was still EDO.
The 6
. Regional Administrator was Mr. O'Reilly in Region II. At i
i 7
that time, Mr. Denton was head of NRR.
Mr. Taylor, was 8
the head of INE.
9 MR. MICHELSON: There-was no-'Special Projects at that 10 tico?
il MR. GOODWIN: No.
Special Projects was not estab-I 12 lished until 1987 In fact the formation of Special Projects 13 in part, was designed to address some of the recommendations t
14 we made about focusing of resources and a centralized location I
15 to address' broad based utility problem plants.
16 We have already discussed a number of the more i
17 important comments that were received from external sources and I would note from interal NRC. managers who were not is 1,
associated with TVA.
We also sent the preliminary report to I
20 them and their comments are interspersed here even though I
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21 don't believe you have them as individual letters.
They were 22 generally transmitted more informally by phone or by mark ups i
i 23 of the proliminary report.
J 24 MR. MICl!ELSON:
So we have them in what form?
25 MR. GOODWIN:
They are included in the commentaries Heritoge Reporting Corporation m-
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that are-in 87-211.
2-MR. MICHELSON:.
.I thought you mean you interspersed 3
them amongst your own words._ I guess you did, as.a matter of
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i fact.
It appears that way, yes.
Okay, thank you.
4 5
MR. GOODWIN:
One of the--I noted in my introduc-6 tion, the purpose of the Lessons Learned effort was to[-improv e 7
the NRCs performance and therefore, the report taken as a 8
whole, appeared to be critical of and places the responsibility 9
for TVAs problems on the NRC.
At least that is a read that a
lo many people made of that report.
It was not the intent.
It was a result of the 12 focus and we received numerous comments that fundamentally
)
13 said, utility performance is a utility responsibility.
The 14 NRC cannot and ought not to hold itself responsible for poor 15 utility performance.
That, at best, we detected, did attempt i
1 16 to correct it, we probably can't prevent it.
i J
17 MR. CARROLL:
Ed, I personally share that view, but 18 I don't recall the people who made that comment, were they
)
19 all ex NRC people?
Were there any from the TVA side that 20 made that statement?
I don't recall.
21 MR. GOODWIN:
I believe one of the form TVA 1
22 directors said that, but it has been several years, but 4
23 former commissioners of every stripe made the comment.
24 That's what struck me about it was they covered the entire 25 spectrum of the commissioners I know.
Heritoge Reporting Corporation m-l
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1 MR. CARROLL:
As did Dirks.
2 DR. REMICK: I was just wondering if it isn't i
3 logical people on the NRC side to say that although, as'I 4
say, I agree with it, but I wonder if that is universally 5
felt.
6 301. GOODWIN:
Certainly it's opinion, and I would 4
7 say that's a logical conclusion about NRC staf f management.
s comments.
A commissioner when he finishes his term really 9
doesn't have a way to defend the NRC, especially since 30 several of these gentlemen were, when they were on the 11 Commission extraordinarily critical of some staff activities.
12 MR. CARROLL: But all of them, in one way or another, 13 were part of some TVA licensing.
14 MR. GOODWIN:
I think everyone who has been with l
t 15 the NRC for 20 years has been, in some way a part of TVA's 16 licensing.
17 MR. WYLIE:
You say you agree with what has been l
I 18 said.
I g9 DR. REMICK:
I agree with that statement that the l
i 20 NRC can't hold itself responsible for license of plants?
4.
21 MR. YTYLIE:
Okay.
I misunderstood you.
i j
22 MR. GOODWIN:
A number of commenters, mostly from i
23 TVA, but again afew former NRC commissioners commented, very 24 strenuously, that the NRC ought not to be about the business 25 Heritoge Reporting Corporation im m.=
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22 of telling people how'to manage, but purely judging how I
2 effective their management was.
3 That was, in general, the conclusion, perhaps ill stated, of the review group also, was that we ought to have 4
5 effective tools for measuring 1 c:eising performance.
We were 6
not trying to place ourselves in a position where we ought 7
to tell managers how to manage.
8 But we did make, in the body of some of the comments,
9 in the body of some of the recommendations, comments about to depth, strengths, size of management and management support 11 techniques which I still hold are appropriate.
12 For instance, utility management ought to have 1
tracking systems so that they can determine what they 13 14 have committed to, what they are responsible to do and that it is an appropriate exercise of our authority to insure that is 16 that have, in some manner, a system like that.
I 17 The comment that all of ou gentlemen noted about i
18 INPOs role or lack of it and our silence on the matter, was 19 a general external comment.
20 MR. CARROLL:
Was there any INPO input into the I
21 Lessons Learned?
22 MR. GOODWIN:
No, sir.
23 MR. CARROLL:
None at all?
24 MR. GOODWIN:
None at all.
It was an omission, and 1
25 not deliberate.
It was just an omission. It was turned around Heritoge Reporting Corporation (Bet) M4000
23 i
in about a month and a half, so it just wasn't done.
2 MR. CARROLL:
Not even some informal discussion?
i 3
MR. GOODWIN:
No.
4 MR. CARROLL: Okay.
5 MR. GOODWIN:
Several of the commenters on both-6 sides seconded our view that a lack of promptness and or 7
clarity in our communications with TVA could have contributed 8
to the problem._ There are recommendations addressing that.
9 There was generally favorable response to the south type of l
to evaluation, comparative ratings of utilities against objec-11 tive standards.
i 12 MR. MICHELSON:
Excuse me.
On the previous point, 13 lack of clarity in communications.
There were some discussions 14 on the part of some commenters concerning the fact that when 15 they would talk to NRC, they were not sure if they were talk-16 ing to somebody who could speak for NRC or was it someone i
17 who was just talking.
18 In otner words, the focal points of decision making f
19 that could be made to stick were not apparently clear.
l 20 Did you do anything more or think anything more t
s' 21 along those lines?
i 22 MR. GOODWIN: There have been reorganizations of 23 the major NRC functions since that attempt to centralize t
24 the decision making process.
I will noue, counterpoint, i'
i 25 that one of the observations that we made was that TVA l
Heritoge Reporting Corporation
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had a tendency to farm shop ~.
MR. MICHELSON:
Had a tendency to wh 2
3 MR. GOODWIN:
Farm shop.
If they asked one portion i
of the NRC if they could do something of if they were 4-3 required to and they got an answer they didn't like, they-6 would try asking another portion.
MR. MICHELSON:
So they just shopped around.
7 8
MR. GOODWIN:
Yes.
9 MR. MICHELSON:
In our new arrangement in the 10 NRC, where they--I forgot what they call-it, Project Managers gg now, I think.
Is he speaking for the agency on all matters 12 relating to licensing.
13 MR. GOODWIN: Yes, on all matters relating to licens-14 ing, yes.
15 MR. RICHARDSON:
Our Project Manager is the central 16 focus in headquarters for contact at NRR.
MR. MICHELSON:
And if he says something then it 17 18 can be made to stick?
MR. RICHARDSON:
It can be made to stick and I thini, g,
20 one of the things that we have been trying to do, particularly 21 since the reorganization is to insure that the Project Manager over at the licensing side and the Senior Resident Inspector, 22 and the Sector Leader in the region, for the inspection part of 23 the program, are much more closely in touch with each other 24 25 than they ever were in the past.
3 Heritoge Reporting Corporation
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MR. MICHELSON: Now in the--'-
MR. RICHARDSON:
So, it's hard-to play'this game 2
3 of trading off one side against the other because they're
- 4 talking to each other and -comparing notes much better than.they 3
ever did in the past.
MR. MICHELSON: In the time frame when this problem 6
7 was developing, who spoke for the agency when they were' dealing g
with the licensee?.
9 MR. RICHARDSON: 1 think in that time frame, there 10 was much more of a distance between NRR and the inspection pro-gram in the regional part of the inspection program and so i
12 think there probably was a much greater opportunity to do thi I
n 13 idea of shopping around in the answer because the communication 1
j y
was not nearly as strong with the NRC.
15 MR. MICHELSON: Within NRR, was it suf ficiently 16 strong then or was it just between and the field office?
17 MR. RICHARDSON: I think it was strong within NRI.
I 18 I
t'.. ink in the licensing context, the Project Manager had been-19 around a long time.
20 MR. MICHELSON:
As I recall that position has been 21 around a long time and I just wondered what's new to' day?
I 22 MR. RICHARDSON:
What's new today is the coordina-1 23 tion between the Project Manager and the Senior Resident i
)
i' 24 Inspector and the Section Leader in the Region.
That line of l
25 communication is much stronger than it has ever been.
Heritoge Reporting Corporation n a.
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p 26-1 MR. MICHELSON: Is it correct to say there's a 'little 2
less decentralization of the function than there was before?
3 MR. RICHARDSON:
I'wouldn'5 say decentralization, 4 ' there's JJst much-better communication, they just talk to each 5
other a lot more and the Project Manager'is puch more aware 6
of the issues that the Resident Inspectors are concerned about 7
and concersely.the Resident Inspectors are much,more aware.
j s
of the basis for licensing decisons and tech spec changes and 9.
so on.
10 MR. MICHELSON: I appreciate that difference.
11 Now, in case a problem comes up--
12 MR. RICHARDSON:
Yes.
13 MR. MICHELSON:
--which end decides it?
When does 14 the region decide it on their own and when does the Resident 15 Inspeccor have to--I mean, when does the Project Manager have 16 to be involved?
Is it clear how this works?
17 MR. RICHARDSON: It really depends--yes, I think
- s it's clear and it. depends on the issue.
As long as they're-19 talking to each other, if there is ever a disagreement it 20 gets elevated to the Project Manager.
1 t
21 MR. MICHELSON:
It might be they thought it was no';
22 sufficient to elevate and therefore they decided on their own 23 and it turned out to be a fairly important issue.
Do they 24 check each decision with headquarters or how do they work?
25 MR. RICHARDSON:
Well, the Pesident Inspector and Heritoge Repoding Corporation (000) Mages
- n
.1
27 i
i the people in the region are talking with the Project Manager.
2 If they raise an issue, the Project Manager has the opportunity 3
to say, no, I don't agree with you, we need to talk with upper I
4 manager.
3 MR. MICHELSON: You're satisfied' that that communica-6 tion, that improvement now, is going to prevent these things 7
falling in the cracks as, perhaps they did in the past?-
8 MR. RICHARDSON:
Yes.
i 9
MR. MICHELSON:
Thank you.
~
y)
MR. CARROLL:
As someone recently coming from 33 industry, I can attest to the fact that what you're describing l
12 seems to be a major change that will, in general, is working.
l 13 I think sometimes the people, the Project Manager 14 is bored sitting in his office in Washington and wants to get 15 involved in things happening in power plants that he really i
16 isn't too qualified to do, but,in general, I think I have l
17 observed a real improvement there, f
is MR. RICHARDSON:
We'll keep working on it.
I'
]
MR. GOODWIN:
Another multiple comment was that the O
SALP type inspections and performance indicators were a useful 21 tool to measure both management's performance at utilities and 22 through'it safety and should be improved still further and 23 used heavily.
24 One recommendation that was made received a lot of 25 negative press, which was that we noted that a lot of the long l
l Heritoge Reporting Corporation o=>
28 term regulatory programs TVA had undertaken such as Environ-2 mental Qualification,' Appendix R, though looking at the pro-r 3
gram plan, they ought to have worked rather well, they were f
adequately staffed, adequate resources should have worked, 4
they were dying on the vine, and as a consequence of that, 3
4.
6 we made a recommendation that there be periodic progress in-i spections and reviews of these major programs that take 8
several years to implement by a utility.
4 9
There was a strong response that applying that to a 4
10 100 plants is exactly the sort of inspection that's done, 11 whether it's needed or not, that tends to take resources f
12 away from focusing on the real problem.
It was a bad recommen-
[
i
)
13 dation.
i 14 MR. CARROLL:
I would comment that the resources 15 that you're talking about are not only the NRC's, but the i
16 utilities.
l
]
17 MR. MICHELSON:
You're going to make a recommenda-l 1
18 tion in lieu of that sometime today or tell us about it?
In i
i 19 other words, what do you do--if you don't use that approach j
3 20 to see to it that they are implementing these long term i
1 1
21 programs, what approach would you suggest?
l 22 MR. GOODWIN; We use completion reviews.
l 23 MR. MICHELSON: Pardon.
24 MR. GOODWIN:
Completion reviews.
l 23 MR. MICHELSON:
Yes, but the completion _isn't for 1
i Heritogo Reporting Corporation (9N) 6864Au4
29 I
severhl. years.
2 MR. GOODWIN:
That's correct, sir.
3 MR.'MICHELSON:
You going to wait several years to 4
4 find out they're not working?
j MR. GOODWIN:
You have to address'it as prt of 6
the resident normal inspection process and this sort of thing I
7 is also something that if you are effectively monitoring 8
utility management, is the' utility's responsibility.
They i
9 out to be aware of their progress in it.
There isn't a free i
p) lunch.
II If the NRC wants a 100 percent a'ssurance that it's l
t 12 happening at every plant, the resources required to do it j
i I
j 13 are enormous.
pi MR. MICHELSON:
No.
I think that though some t
15 reasonable spot checking would be in order by more than just I
J 16 a resident inspector who is, perhaps, too close to see it.
17 MR. GOODWIN:
We could list find an ef fective
[
18 procedural method of doing so.
I'll defer to Mr. Hebdon in 19 his implementation planning, but--
a I
I 20 MR. MICHELSON:
It leaves me a little uncomfortable 1
l I
21 on the one hand to recognize that a lot of utilities have J
22 been delaying what they promised to do and you're not even 23 aware they're oslaying it and on the other hand, inspecting i
24 a 100 percent is obviously not a very feasible alternative,-
l 25 but there must be something in between that would answer the i
Heritoge Reporting Corporation
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1 30 question without just ignoring it.
1 MR. HEBDON:
Well one of the things.we have done 2
3 is we have now a system called, "The Safety Issues Management 4
System," where we are trying to keep track of these issues,
~
3 particularly some-the longer terms issues'to make sure 6
they don't get delayed forever and I think that was really 7
a problem several years ago and we now have people that are 8
assigned to each of these various issues and.their responsi-9 bility is to watch the plants and make sure that these things 10 do, in fact, get done in a timely manner and when inspection 11 is required at the end, we do have--we write temporary instruc-12 tions ta go out and do the inspections.
13 MR. MICHELSON: What do you mean now by people 14 assigned to watch?
What do they do when they watch?
15 MR. HEBDON:
They do not actually moniter what's 16 going'on as it is being implemented, what they monitor is 17 that the programs are, in fact,.being completed and so, for 18 example, if they had an issue, one of the print outs-that.they 19 get from this peer system is a list of which plants-have com-20 pleted the implementation of a particular requirement.
21 MR. MICHELSON:
1sn't that rather late in the 22 game though if it's a 4 - 5 year out requirement?
23 MR, HEDDON:
If it is, it is sometimes late in the 24 game but at least we are making sure that these get'done in a 25 timely manner and if an inspection is required at the end, we Heritoge Reporting Corporation
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31 1
do conduct that inspection.
2 MR. MICITLSON :
I'm sure you do.
Are the utilities 3
required to give us updates on a periodic basis?
In other 4
words, at least the utility ought to be committing as to wherc 5_
they think they're are, even if it turns out not.o be correct 6
at least it's better than waiting 5 years for them to tell 7
you, oh, we aren't going to be done_with that for another 3 8
years.
9 MR. HEBDON:
We do monitor when they are going to 10 be done.
11 MR. MICHELSON:
Oh, I'm sure you'do.
12 MR. HEBDON:
Bct we don't really--except in some 13 isolated cases, but in general, we don't try to spend too 14 much time monitoring the implementation as it goes along.
15 MR. MICHELSON:
Would it be an unreasonable im-16 position for a utility, once a year, to tell you the percent 17 of progress made'on a particular, commitment?-
18 MR. HEBDON:
I think you do tb.at formally.
19 You're talking about a lot of items.
There are a lot of 20 items, there are a lot of issues that are going on.
21 MR. MICHELSON: And so instead, we're just guessing 22 as to what the status is and when we have an accident, then 23 we go in and find out, oh gee, we thought that was in and it's 24 not, it's going to be another three years off.
It's too late 25 to find out then.
Heritage Reporting Corporation
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32 MR. HEBDON:
No.
The Project Managers are respon-2 sible for keeping up this print out I--
3 MR. MICIIELSON:
But that's useless, that's just 4
the end date they're keeping up with.
5 MR. HEBDON:
But if that end date starts to slip--
6 MR. MICHELSON: But it won't slip until.the day it's 7
due and then the utility says I'm not done.
That's the first 8
time you might knov. The utility isn't required to, apparently 9
report to you until the due date.
30 MR HEBDON: But the project managers do keep up with 11 those dates and if those dates are slipping, their contact-12 with the licensee, they should be aware that those dates 13 are slipping.
14 MR. MICHELSON:
When do the dates start slipping?
15 MR. HEBDON:
When the licensee perceives that he
_6 isn't quing to make it.
17 MR. MICHELSON:
And the licensee isn't required 18 to tell you this until the due date.
As I gather, there are 19 no intermediate reports.
20 MR. HEBDON:
Carl, there is an intermediate check 21 that the NRC has that, as to SALP evaluation procedure, it 22 has been re-written under the licensing sub-heading, there j
l 23 is a requirement to examine, in general, the performance on 24 regulatory requirements.
I don't know if it will get'them 25 all, but it is addressed within the SALP context.
Heritoge Reporting Corporation c=i i
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. MR. MICHELSON:
I just wondered how they know what 2
the progress is on regulatory?
Does the inspector ask to go 3
in and check on each of these items from the report?
There l
4 has got to be some way, before you wait--some of these are 5
way out, 4,
5, 6 year items.
There has got to be some way 6
to--
7 MR. HEBDON: The Project Manager doesLkeep in' touch 8
with the licensee and does find out the status of these issues..
9 Now, they don' t go in and do a 50 percent comple-10 tion inspection, but they do keep in touch with the licensee 11 and if the licensee--if the date is slipping on a particular 12 item, I would expect that the Project Manager would find that 13 out from the licensee and would incorporate it into the SIMS 14 System and then as we review the issues for a plant or review 15 the status of a particular issue, that should come to light 16 and if a plant shows up that they're not going to have some-17 thing done until 1991 or 1992 orfl993, then management in NRC i
18 has to make a decision as to whether they consider that tc be 19 acceptable, j
20 MR. MICHELSON:
I sense though, we're into the same 21 box as you were in the early '80's because you're not really 22 checking up on this.
Not even requiring the utility to commi".
23 on a yearly basis as to what their schedule is, which I think 24 would not be an unreasonable requirement.
25 The utility, once a year, ought to audit its own Heritage Reporting Corporation
[
(982) 6 4 4000
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requirements to see where it's at and-therefore, just~ copying 2
those down on a piece of paper isn't that big a chore.. Now,
~
3 if they don't know~and-they got to go out and find out, maybe 4
once a year they ought to find out where they're'at.
5 I think we ought t'o entertain some kind'of a 6
reasonable means of making sure the utility itself is aware 7
of ite problems.
8 MR. HEBDON:
Well the Project Manager does that.
9 It's not done in a formal report under oath and affirmation, to but it is done by the contact of the Project Man'ager'with the 11 licensee's organization.
12 MR. MICHELSON: Okay.
13 MR. CARROLL:
The deficiency in that is that in i
14 some organizations is that the Project Manager is talking to 15 licensing guys, not the doers, but again, if he is a competent 16 guy and if the licensing guy in the utility is on the ball, 17 they can get the information.
18 MR. HEBDON:
And he is also talking to the Resident 19 Inspector.
It's more than just the licensing individual.
20 MR. CARROLL:
Yes, but a lot of these issues t
21 are happening away from the plant site.
22 MR. HEBDON:
Yes, that's true.
23 MR. CARROLL: The Resident Inspector really doesn't 24 know what the Design Engineers are doing on some particular 25 fire protection issue or some EQ issue or whatever.-
Heritage Reporting Corporation (302) 6M dese
1
- )
35 MR. MICHELSON:
I think the bottom line on this 1
2 is that SIMS is a good system for tracking;what you're told.
MR. HEBDON:
Yes.
3 I
MR. MICHELSON:
The question is, is the goodness 4
of the information being given to you to'put into SIFW!S and 5
6 how often is it updated.
MR. HEBDON:
That is an issue and within the re-7 8
sources that we have available, we're trying to-make sure we have the best date we can, but there are literally 9
thousands of issues in SIMS and to do a lot more, when you 10 start multiplying even fairly small levels'of effort' times jg thousands of issues, the total resources, is to be enlarged 12 13 quite rapidly and it's just a matter of what we can afford.
MR. MICHELSON: Well,'maybe we're not tracking the g4 15 right things in SIMS to begin with.
You know, if you're 16 putting all the trivial items in SIMS, then it probably be-comes a useless means of tracking.
If the big ones are in 17 18 there, the important ones are in there,'they're worthy of being tracked carefully and update'd, at least once a year.
39 Maybe you need to look at SIMS to see'if you're 20 21 filling it full of noise.
MR. GOODWIN:
The last of the general comments, 22 l
23 the one that we have discussed in detail already, was how cur 24 rently and thoroughlyinformed was the TVA Board.
I have no 25 more to add on that.
Heritage Reporting Corporation
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36 1
Among the specific lessons that we felt the NRC.
2 ought to have learned from the TVA situation was that we need 3
to develope and implement a program that, requires, that 4
focuses the NRC on the identification of poor performing 5
licensees and for focusing agency' wide resources and attentior 6
on_ poor performing licensees.
7 And that when such a utility is identified that 8
our concerns ought to be pro aptly and ef fectively and strongl3 9
brought to the attention of the' utility executive management.
10 As a consequence of'that lesson, we made three major 11 recommendations: a system to identify and monitor--identify, 12 address and monitor such utilities, better' tools to identify 1
13 the poor performers and improvements in our internal manage-14 ment structure that would allow effective focusing of resourec s 15 on such utilities.
)
16 MR. BARTON:
On this item, it looks to me like you 17 have always had these three items, at least you have had a 18 system that basically was supposed to do that.
19 So, what is going to be different?
20 MR. GOODWIN:
Well, the first thing is that the j
21 SALP System--remember that the traditional definition for the 22 SALP III is minimally acceptable performance and the range 23 to get a 3 goes from just barely bel'ow above average and there 24 was not, at that time, a strong focus on identifying among, say 25 the lowest third of tne. utilities, those that were really in-Heritage Reporting Corporation
< = >.
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37 I
bad shape.
That has changed since this was written in 198'6.
2 There was a:resistence in the late '70's and early
~
3-
'80's to writing lists of. poor performers.
That has changed.
4 DR. REMICK:
Are the performance indicators beginnir g.
5 to play a role yet in helping the~NRC identify Ihe poor per-6 formers?
7 MR. GOODWIN:
Yes.
They are particularly useful, 8
it appears now, in the area of operations of SCRAM frequen-9 cies, frequencies of ESF actuation, a lot of easily quanti-10 fiable data, go - no go type data that either is or is not 11 true factually, it just is, seems to correlate very well with 12 performance.
It's being used to monitor performance and it's 13 quite effective in identifying early plants that trending 14 towards problems, especially new plants as they start or 15 a plant that starts after a prolonged shut down, this kind of 16 quantified data is used to get us in.early.and effectively 17 and it seems to be working.
River Bend is-an example.. There 18 was a Region II plant--a Region III plant that just escaped 19 me now, that had strong aggressive in early NRC participation 20 when its number of SCRAMS and containment isolations were 21 just obviously climbing above the norm for a plant in the 22 same condition.
23 MR. MICHELSON:
What's not quite so clear, I don't 24 celieve though, is whether or not the lack of good performanco 25 is due to the management or other factors or combinations Heritage Reporting Corporation q
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38 1
and performance indicators-are of limited value there.because 2
they don't really pin point whether it's maintenance or 3
whether it's operational or whether it's management philosophy 1 '
4 of just what it is.
5 It clearly indicates that there is a problem, but~
6 you got to.go way beyond that.
7 MR. GOODWIN:
Clearly they are not a means to 8
identifying the mode of solution.
I would rather identify 9
them as being the same as alarm indicators on a-control 10 panel.
They tell you you have a problem, they. don't tell li you what the problem is.
12 MR. MICIIELSON :
We're trying to squeeze more out of 13 perforn ance indicators than perhaps they can -yield.
For 14 instance, trying to determine--a performance indicator for 15 maintenance is not an easy thing _to come up with and we're 16 over using them.
It's good for SALP in general, but not in 17 particular to pin point the problems.
18 SALP, in fact, is a way you take a performance 19 indicator that says there is something wrong and kind of sort 20 through it and come up with where the new problems might be, 21 that's the SALP process, I think.
j 22 MR. GOODWIN: The second lesson--
23 MR. CARROLL: Back to performance indicators for a 24 moment.
25 MR. GOODWIN: Yes, sir.
Heritage Reporting Corporation
<m -
l 39 MR. CARROLL:
Does the NRC have access to the-2 individuel plant's performance indicators that INPO is keep-3 ing?
I
.R.
GOODWIN:
I would prefer'to defer that question M
4 5
to NRR's implementation planning.
I just don't know the 6
answer to that.
7 MR. CARROLL:
All right.
8 MR. GOODWIN:
The second major lesson that we felt 9
could be drawn from this is that the NRC needed better skills to in assessing overall licensee management performance. identify-ing indicators that management and organizational deficiencies 12 exist.
13 What I just said before was we are using performancc 14 indicators that are easily quantifiable to determine whether 15 4 management is effective or not effective is.much.less 16 cbjective.
It's difficult to even find the measures of 17 effective management.
18 We concluded at TVA that there was, within the NRC 19 a body of opinion that said, hey, it's being, badly-managed, 20 but it was very difficult to go beyond, I feel it in my 21 bones, I know it because of experience, that they have a 22 management problem.
It was difficult to support objectively i
23 that subjective conclusion.
24 MR. MICHELSON:
Well, there is a body of-management 1
25 science information, there are people skilled in the managemerit Heritage Reporting Corporation omsnau
40 g
sciences and-maybe science is a little stretch, but that's 2
the way they call it anyway.
It's a reasonably understood field.
I studied it a little bit back inithe early
'60's, 3
it.was well understood'then the kind of bodies of information 4
that go into it.
5 But, what I don't see in the NRC is any particular 6
7 focal point for that kind of thinking and it's not someting 8
that you pick up'on th'e' side necessarily, you have to be 9
well versed in management sciences'as well as understanding to the process that you're dealing with.
I don't see that in 11 the NRC.
I don't see any steps to even correct--to try and 12 correct the human factors area now, so we built a little 13 human factors credibility, but I don't see us building any 14 management science credibility.
- 8. 5 MR. GOODWIN: We concluded that 3' areas could be 16 properly addressed.
First, the identification of a specific 17 person within the NRC who was held accountable for'the 18 monitoring of management-performance and responding to 19 deficiencies in it.
The second---
20 MR. CARROLL: Excuse me.
Who is that person?
21 MR..GOODWIN: In general, the Regional Administra-22 tor, a person of senior enough scope to be able to deal with 23 senior utility management and close.enough to the problem 24 to identify deficiencies there.
25 MR. BARTON:
Is this basically saying in this item Heritage Reporting Corporation (303) 636-400s
~41 I
that in the past, the responsibility within NRC was to 2
fragmented?
3 MR. GOODWIN:
Yes.
I MR. BARTON:
That no one was really held completely 4
3 responsible?
6 MR. GOODWIN:
Yes, sir.
7 MR. CARROLL:
One of the comments in this package 8
was that the TVA Board didn't really want to talk to the 9
Region II Administrator, protocol wise, he was well below then 10 and, if the NRC had something to say to the TVA Board, the 11 Commissioners ought to come'and talk to them.
12 Do you think that's a unique problem?
Do you think 13 today that most utility CEOs know who the Regional Administra-i4 tor is and what his responsibilities are?
15 MR. GOODWIN:
'It is my impression that most of the 16 utility CEOs realize that the Regional Administrator's 17 opinion of their management' performance can have very 18 significant effects on them and are generally willing to talk with them.
39 20 MR. MICHELSON:
The Regional Administrator didn't 21 exist during, at least a portion of this time which we're 22 talking about.
23 MR. CARROLL:
Yes, he did.
MR. MICHEL.<:.
Not in'the position he now has, no.
24 25 lie was way down in the ranks of I&E.
He was not at the high Heritage Reporting Corporation
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42 1
end of_the Commission.
2 MR. CARROLL':
His position kept being elevated.
3 MR. MICHELSON:
Yeah, he was just like a Branch i
4 Chief.
He had an office, but he was the equivalent to.a 5
Branch Chief.
6 MR. GOODWIN: He was a little higher than that.
7
'MR. MICHELSON:
Well, a little higher.
8 MR. RICHARDSON:
That situation is changing.
9 MR. MICHELSON:
I understand that, but we're 10 talking about how did we get into our problem and the 11 rectification, I think, -was giving the Regional Administrator 12 a migh higher visibility than he had at that time.
13 MR. BARTON:
Another thing, in working with the 14 staff versus the Regional Administrator, the staff, in those 15 days, didn't want to relinquish their authority.
They seemed 16 to want to hold on to it.rather than let the Regional Adminis-17 trators speak.
18 MR. MICHELSON: Well,'they had the responsibilities, 19 so they also held the authority.
20 MR. GOODWIN:
We felt that the guidelines for 21 regulatory response to deficiencies in management were not 22 merely as well defined as the guidelines in the areas of 23 response to defined safety violations.
You knew exactly what 24 to do if somebody operated without the requisite minimum 25 equipment.
It was clear what happened on a second offense, Heritoge Reporting Corporoflon (MI) N
43 1
that this same clarity' of regulatory response did not exist
~
2 in the management area and third, we felt, as Mr. Michelson 3
said, that there was not,.within the NRC, adequate standards 4
for assessment of' management performance.
5 MR. MICHELSON: Are we taking'any steps yet to correct' 6
that?
7 MR. GOODWIN: Yes, sir, but again, I prefer to g
defer to the implemters.
I am in the happy position that 9
where all I have to say is something needs to be done, go exactly what is to be done is left up to somebody else.
MR. MICHELSON: Who is taking the lead in developing gg 12 management standards?
13 MR. PERANICH:
Well briefly, OE had the responsibi-j4 lity, Mark Peranich is the name.
OE had the responsibility 15 to review the enforcement sanctions associated in this area 16 and they have amended Part II of 10 CFR 50 and have just 37 recently forwarded that amendment to.the Commission for their 18 review.
MR. GOODWIN:
The third area that we identified 39 20 where we felt we learned something that needed to be changed 21 was that the NRCs inspections tended to focus on specific 22 violations rather than on, is the program that led to this 23 violaiton generally effective.
24 In the best managed of programs, there will be 25 things left undone that constitute violations.
It was diffi-Heritage Reporting Corporation
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44 I
cult, in the documentation we' reviewed, to identify whether 2
this specific violation was indicative of a problem with the
~
3 program or was it an isolated example.
4 We felt that inspection reports or the violation 5
notices should discuss the generic significance or cumulative 6
significance of violations.
A minor violation,'probably in 7
most cases, is not problem.
A series of minor ones is 8
indicative of serious problems and is a serious violation.
9 We felt that inspection reports should not just to be negative, and report the deficiency, but attempt to assess 11 the overall effectiveness of the program favorably if.that 12 was the conclusion and we felt that--
13 MR. CARROLL:
Do you feel that message has gone-out 14 to the regions?
15 MR. GOODWIN:
I can only speak for the inspection 16 reports that I read which are mostly associated with TVA, 17 but, yes, they tend to speak more, is this program working, 18 are these violations indicative of something serious?
19 MR. HEBDON:
We have revised the guidance, it's 20 Manual Chapter 610 that defines how an inspection report is 21 supposed to be written and it's much more the types of things 22 that we're talking about here.
It takes time to get that 23 word out to everybody and, of course, some people are more 24 willing to embarace it than others, but I think we're making 25 programs.
We are working much more to get into this less of Heritoge Reporting Corporation
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45 a compliance orientation, writing' speeding t'ickets type of thing, and more into a program--effectiveness program of 2
efficiency type of orientation with the inspectors and, zus 3
i 4
you can imagine, some inspectors are more interested in that 5
approach than others and it's taking' time to educate people, 6
MR. MICHELSON:
The problem that I have is we seem 7
to be depending more and more on the resident inspectors to 8
look for certain kinds of things and make certain kinds of 9
observations and, I think, perhaps that's where it would be 10 '
most effective, but my concern is, are we tending to overload 11 his time and also his capabilities. Resident Inspectors aren't 12 all created equal.
Some have expertise in one area and some 13 in another area, never asking them to look at such things as 14 management effectives perhaps and, if we are, is he really 15 qualified to judge management effectiveness or what criteria 16 does he use or how are you going to indoctrinate them 17 adequately so that he can make good observations.
18 MR. PERANICH:
We are revising--we'll discuss this l
19 when we get to some of the actual reports, but we have under 20 way a revision of the inspection program for operating re-21 actors and under this inspection program, we have new concepts 22 with respect to how we implement the program and some of these 23 new concepts haven't been introduced that address your ques-24 tions.
25 MR. MICllELSON:
Are you going to re-train the Heritege Reporting Corporation (Set) masse
46 1
inspectors for these new areas?
2 MR. PERANICH:
No.
We're reducing the amount of the 3
inspection'that residents serve in a speciality area,: is what.
4 we refer to as our Core Inspection Program, in which it is 5
required to be done at each plant.
6 We're including inspection modules ~that are required 7
to be done in each plant by specialists so that we can get the 8
proper expertise out at the site to insure the early identifi-9 Cation of the problems.
10 We we're taking away from the residents some of the 11 speciality areas that he was trained to do, but he.wasn't 12 necessarily an expert in it.
13 MR. MICHELSON: Is management going to be one of-14 those areas you will send expertise in?
He's in a better 15 position to judge it because it's the sort of thing you have 16 to integrate over time J
17 MR. PERANICH:
We're developing a series of proce-18 dures which, when they are combined, give us a look at 19 management.
One of these turns out to be the self assessrc.ent 20 that we do--licensing self assessment.
We have a specific 21 procedure that SALP looks at, all aspects of how licensing 22 self assessment fits SALP with respect to events, with respect 23 to correcti ve action, with respect to their findings and our 24 findings.
25 There will be a--you know, an end product based on Heritage Reporting Corporation von sm
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that inspection which when combined with the other findings 2
'that the regions have, we also are adding a new procedure witt.
3 respect to periodically, probably mid term, to evaluate all 4
the findings and determine the impact of thosel findings on 5
the effectiveness of the. licensing' programs with specific 6
focus on quality assurance programs.
7 MR. MICHELSON:
The procedures are fine, but I hope 8
you're doing something to bring the inspector himself into 9
this new way of operating.
In other words, traditional 10 training and' indoctrination so he can start thinking a new 11 way because even in the past, he hasn't be'n used to thinking e
12 in these ways necessarily.
13 MR. PERANICH:
Well, we have course on'inspecti0n 14 and performance with all the Regiona. Inspectors and that has 15 been a one week course which focuses on performance and how 16 you evaluate management performance.
17 MR. MICHELSON: Is that the Chatanooga course?
18 MR. PERhNICH:
Well, yes.
It's going to be--it has 19 been held here at Headquarters and in the regions, but the 20 course now has been recognized as being effective'and is 21 being incorporated in the Chatanooga Program.
22 But, I think when you look at management, you have 23 to recognize that any one inspection, unless it's an intensive 24 4 week team inspection which can give you a quick picture of 25 all the activities of the plant, that your assessment o' Heritage Reporting Corporation
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48 l
1 management depends on the aggregate total or the results of l
2 NRC activities, not only inspection activities, but licensing 3
activities and this is the result and purpose of SALP, i
4 primarily, and that's where we hope to get an assessment of 5
management when it appears in the SALP report, that-it is 6
sufficient within in the abili,ty within NRC such that 7
appropriate NRC management would be able to focus on.whether 8
or not we need to take action.
Of course it's discussed at 9
the Senior Management Meeting in detail.
10 MR. MICIIELSON:
Important input to SALP though is the 1
Resident Inspector's views that he developes over a period 12 of time observing, in general, how the operation is going 13 and if you're reasonably well trained, you can see by just 14 watching day to day operations what is really happening and 15 it would nice if the Resident Inspector were kind of tuned
~
16 a little bit as to what to watch for--kinds of things to watch 17 for.
18 MR. HEBDON:
Well, I think that's a big change 19 in the inspection program'and the inspection philosophy 20 within the last year or two certainly is this idea'to be 21 much more performance oriented and must less compliance.and 22 Paper oriented, trying to look at, does the program work, j
l 23 is it effective, rather than looking at whether'this particu-24 lar thing has the right number of signatures on it and then 25 when you do start seeing cases where performance is degrading Heritoge Reporting Corporation (303) H44006
49 1
then you start questioning whether or not the management is 2
effective in the context of whether or not they recognize that 3
the performance is degrading and whether or not they are 4
taking effective. action to. correct the problems.
5 MR. MICHELSON:
Not to belabor, but I would like 6
to hear what you're doing to bring-the inspector into this 7
new regime of operation, not just more procedures for him 8
to read and carry out or whatever.
~
9 You have got to do something to the individual to go give him some additional feeling for the problem which he 11 Perhaps doesn't have from his past work at all.
12 MR..HEBDON:
There has been a considerable amount 13 of senior management attention to trying to get across to the 14 residents and to the region based inspectors and to-the peopl e 15 in NRR who are starting to do inspections'now, this idea that i
16 we're performance and safety criented, we're not compliance 17 oriented any more.
j 18 For example, we have a Fundamentals of Inspection.
19 Course now that is being taught to all the' people in NRR 20 who are starting to do inspections for them.
The opening 21 session of that is about a two hour presentation that is give n 22 by the Deputy Director of NRR and he teaches each one of 23 these sessions personally and-the emphasis, the point he 24 keeps coming back to over and over in that presentation is 25 this idea that safety end performance rather than compliance Heritoge Reporting Corporation mm.
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and it takes time.
Different people, at varying degrees, 2
going to embrace this concept, but I think it's a process that.
3 just needs continual reinforcing and I think that.is-happen-ing and we're starting to'see results in that area and people 4
5 are becoming less compliance oriented and more safety perfor-6 mance oriented.
7 MR. BARTON:
Does the training of these resident 8
inspectors include emphasizing the importance of informal 9
discussions with the Station Manager rather than wait until to he finds a clear violation to talk about.and correct problems 11 before they really develope?
12 MR. HEEDON:
Very much so.
Again the program 13 we're trying to shift much more toward being performance 14 oriented and so if a Resident Inspector sees a problem that 15 he feels--just because there's not a violation associated 16 with it, that's the' type of thing he should be bringing to 17 the attention of the appropriate people withing the licensees 18 organization and if he doesn't feel that he's getting a adequate 19 response, it's the type of thing that he should then elevate 20 through his own management to bring the appropriate level up 21 to the Regional Administrator, if necessary, to make sure that 22 these things are getting taken care of.
23 That's exactly the kind of point we have been 24 stressing with the inspectors.
Just because you can't hang 25 a violation on it doesn't mean that it's important and does Heritoge Reporting Corporation
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51 not mean that you should simply bury it in the report or 2
ignore it.
It's the type:of thing that you should make 3
sure it~gets taken care of.
I 4
MR. PERANICH:
The resident has a lot of discus-5 sions with plant staff.
In fact, the majority _of his'obser-6 -
vations,.which he looks at,-doesn't necessarily have a 7
compliance matter, he still discusses those with the plant g
staff and expresses his views 'and gives the plant staff!the 9
benefit of his observations. That's all part of the training.
10 We have resident counterpart meetings.
That's part-of.our 33 program.
These types of things are discussed and they're 12 encouraged to maintain a liaison with plant personnel and 13 communications on anything they feel is a safety issue regard-1 I
14 less of whether there is a specific _ regulation or Reg Guide 15 which they're committed to.
That's the focus.
16 MR. CARROLL:
One hele in that, of-course, is that i
17 some fraction of the activities are going on away from the 18 plant site.
g9 MR. PERANICH:
Correct.
20 MR. CARROLL:
And plant management, although they 21 can find out what's going on downtown or whatever, if it's 22 some activity that they're going to learn about eventually, 23 you're sort of putting a burden on them to be up to date on 24 it at all times so they can tell the Resident Inspector about 25 it.
Heritoge Reporting Corporation -
mm
52 I guess what I am leading to is, has there been any 2
thought that Resident Inspectors ought to broaden their scope 3
a little bit, at least with those utilities that have general 4
office organizat ons, that they ought to go visit them once 5
in awhile and s a what's going on?
6 MR. PERANICH:
The answer is, yes.
We're debating 7
about whether we can afford to do that right now and the 8
revision of the Resident Inspection SECY 71-707 which would 9
give,him an opportunity to pursue a design issue within the 10 corporate office, but currently the process is that we 11 identify the issue as a result of the operation at'the plant 12 and may involve the corporate office design organization.
13 He has the facilities.or resources at the' region l
14 that he is supposed to initiaye action to do that.
What we're 15 trying to do is get the resident involved, to some extent, l
16 in that activity, so it has had that benefit of knowing what
\\
1-7 corporate office is and what's going on.
18 We haven't made a decision yet, resource wise, 19 whether we can afford the luxury or not.
20 MR. CARROLL:
I have see many cases--
21 MR. PRTANICH:
The answer is yes, but we haven't 22 decided yet.
23 MR. CARROLL:
--where the resident gets all pumped 24 up about an issue, you know, and he goes to the Plant Manager 25 and the Plant Manager says, well, you know, be patient, I'm Heritage Reporting Corporation tmi m
53 1
not working on this.
If you want a status report, I guess I 2
can get it for you, but, you know, another organization is 3
handling it, but this cort of swims around--
4 MR. RICHARDSON:
That varies by utilities.
5 At Sequoyah, for example, at TVA, there's a major on' site 6
engineering organization.
The resident doesn't have to go to 7
Knoxville or some place to get something resolved, whereas 8
at some smaller utilities that don't have big engineering 9
staffs, maybe they're doing something to the contrary, so go we are trying to work it out and broaden the scope of the residents and their purview where it is pract'ical and'still gj 12 have the on site exposure and coverage of plant operations.
13 MR. CARROLL:
Okay.
14 MR. GOODWIN:
Okay, so the last area was that we 15
'nobd,in general, team inspections which.were multi disci-16 plined, tene.ed to be much more effective at assessing pro-17 gram ef.ctiveness and we encouraged their use for this 18 among other reasons.
39 The fourth area that we addressed was in assuring 20 quality of construction.
We concuded that there was no way--
21 in the construction of plants, there was no way around relying 22 on the utility and the utilities quality assurance organiza-23 tion to assure that a plant was being constructed well, that 24 just the sheer amount of resources made any signficant NRC 25 independent verification of the quality of construction an.
Heritage Reporting Corporation
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54 g
impossibility.
2 We therefore fel,t that those inspection resources 3
that we used on construction had to be focused on modes of
(
assuring the' validity of the utilities OA checks, the 4
5 validity rather'than'the paperwork adequacy of'it and we 6
made a number of recommendations, all of which werefpointed 7
towards, in one way or another, using the'NRC's limited 3
- resources more effectively to assure this validity.
9 I don't think I'll go through those.
They tend to go be fairly specific to plants under construction.
gg MR. MICHELSON:
Major modifications, do you treat 12 them like plants under construction from this argument view-13 point or is that going to be a different argument later?
14 MR. GOODWIN:
In theory, you treat them like plants 15 under construction, from this point of view.
16 MR. MICHELSON:
What you're saying then is that 17 in case of major modifications, you're just going to try and i
18 focus on the validity of the program as controlling mode g,
modifications, not on the nature of the work being done?
20 MR. GOODWIN:
I did not say that we were going to.
21 I said that the Lessons Learned conclusion was that.because 22 of constraints of resources, we have little choice but--
23 MR. MICHELSON:
I stand corrected.
But that is your inbant though for major modifications, thac you would not 24 25 attempt to go in and do more than examine the program that Heritage Reporting Corporation
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55-1 is. controlling?
2 MR. GOODWIN:
No, no, please, that isn't-what I 3
meant.
4 MR. MICHELSON:.
Not in.the paper-program, the 5
implementation.
6 MR. GOODWIN:
Yes.
7 MR. RICHARDSON:
The NRC has developed a major 8
inspection program called SSOMI, Safety System Outage Modifi-9 cation Inspection where we send in a team very similar to 30 the Construction Assessment Team, the CAT Team inspections it that are done at construction sites where.we actually take 12 samples of hardware implementation, radiograph readings, 13 independent verification of outage--modification and outage 14 type activities, right.
15 MR. MICHELSON:
So you're going to go in and do a 16 Periormance sampling with a team and base your judgment on j
i 17 that*
i 18 MR. RICHARDSON:
It's a team for outage activities, 19 at selected sites, not every site and we would--
20 MR. MICHELSON:
I just wanted to make sure it was 21 going to be different than construction?
Your construction 22 plan is not the same--
23 MR. GOODWIN:
No.
Out construction plan is the same 24 What we were trying to focus on was rather than try to inspect 25 generally a percentage of everything that was going on, Heritage Reporting Corporation
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56 3
. basically our resources are one-fiftieth to one-one hundroth 2
of the utilities QA resources which in turn are about one 3
Percent of the construction resources, that if you attempted 4
to monitor uniformly, across the board, it could not be done 5
effectively and that therefore, the affected means of 6
checking validity were. things like.SSOMI where we were 7
monitoring third party inspections.
We were strong on this 8
because, f rom the NRCs point of view, it is free resources that 9
are independent and to validate their work, to try to find to effective and new ways of validating without having a 11 statistically signficant sample so'that you could say it 12 was statistically valid.
13 If I could sample 10 percent of all the QA work 14 that was done or 10 percent of the film work, I could stand 15 here and say, I have a statistically significant sample and 16 I can conclude that the construction work in progress is 17 being done well.
18 We do not have enough resourses to do statistically 19 valid analysis and therefore uniform sampling is not an effec 20 tive way of assuring validity and we were--
21 MR. MICHELSON:
What are you going to do?
You've 22 told me all about what you're not going'to do to assure the 23 Proper inspection?
24 MR. GOODWIN:
The recommendations we made were 23 third party inspections, readiness review type inspections, Heritoge Reporting Corporation
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team inspections like SSOMI, monitoring areas where where 2
utilities noted tnat they wre departing from accepted 3
industry standards.
We felt that industry standards reflect, i
4-in general, the collective wisdom gained over years.
When 5
utility strikes out on its own and is using something differerit 6
from them,the probability of doing something wrong. increases 7
dramatically.
8 We felt that as built inspections rather~than 9
process inspections--in past years, many of our inspections 10 were process inspections. We inspected along with the utility 11 OA people.
We felt that the resources could be more effec-12 tively used by verification of as built quality, of a system, 13 going in when the system'is complete and then checking the 14 electrical, the mechanical, the structural altogether rather 15 than as each installation inspection took placs, doing a 16 little of that ourselves.
17 MR. MICHELSON:
In the past the agency has been 18 accused of waiting too late to tell the licensee that things 19 were wrong.
Of course that kind of'looking at the end produc t 20 is waiting until very late in the game to find out if you're 21 happy with the game that went on.
22 MR. GOODWIN:
Yes, sir.
23 MR. MICHELSON:
And that's the danger in doing it 24 that way and I thought the thrust in the future was that we'r a 25 going to get ahead of thet things and so on and so on end Heritoge Reporting Corporation
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58 1
that doesn't seem to be consistent.
PERANICH: I think it all depends on the thrust 2
3 of the industry.
If they go ahead and come in with future 4
plants based on essentially a completed design, then the whole 5
Process. changes.
The complexion--the inspection program 6
can focus directly on that installation that thy're indeed 7
supposed to comply with the design that is completed, but 8
during the current method of licensee construction process, 9
we allow him to make many changes as he goes along, to the 10 construction process and changes even after the structural is aspects of the project are completed do affect the mechanical 12 or electrical.
This is all within acceptable limits, the way 13 it's set up and it's very difficult, even when CAT inspections.,
14 as you're #amiliar with, which I was involved in, we found 15 that to go in much earlier than the year and a half before, 16 this would be his licensing, was not productive from the 17 standpoint of determining whether they are complying with 18 their design--their SAR design commitment.
19 We tried to go in earlier, it just was nc' prnduc-20 tive because of the allowances with respect to final comple-21 tion of the project as it's turned over to the operating i
22 organizations within the plant.
23 The CAT inspections were usually done about a year 24 before plans for operating licenses and it all ties into whether
- s work is typically assigned really.
Heritage Reporting Corporation (Set) 654000
-59 r,
3 MR. MICllELSON:
-I was just trying to answer the 2
questions that have been raised and many other comments
-3 elsewhere that'you know about.
Why did the agency wait so l
4 long in the case of TVA before they had problems-and'I can see
'~
5 the same message coming from the, if you let-somebody-build 6
something and then waited'until the end of the game to look 7
at the finished product and say,-why did'you wait so long to
~
8 tell us this was not being done right.
9 I'm not saying there's a good answer on how you do 10 it and, of course, the end product performance is the best gg way to do judge, but it's kind of untimely'if it's wrong.
33 MR. RICHARDSON:
In some areas where we go in early, 13 on DQ, for example, we try and go in for inspection with they 14 are about 30 percent complete ar t based on that, we end up 15 going back and doing a follow-up inspection when they're 16 essentially complete, ready to sign off on their certifica-17 tion letters.
That methodology works in some cases.
18 Fire protection, we go in when they're sufficiently 19 along the way to be able to tell them they're on the right 20 track or not, but we don't wait--we have had limited success 21 both ways.
22 MR. PERANICH: I don't want to give you a miscon-23 ception of the inspection. program, in the construction 24 process, there's an elaborate inspection program of inspecting 25 for each activity, not with respect to the as of question,.but Heriloge Reporting Corporation
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60 3
many plannings are identified during the construction process 2
for each activity.
They're identified and they're required 3
to address those.
But, with respect to the final aspects, 4
it's very difficult to ascertain whether or not those are 3
achieved until actually the plant is ready #or turn over to-6 operations and that is a very difficult thing to do be-7 cause you have so many outstanding issues that are still 8
being dealt with by the construction and numerous of these 9
are turned over to the operations plant to follow up as i
go they are getting ready for testing activities.
11 MR. GOODWIN:
The next area that the Lessons Learned 12 Group addressed was not only we had discussed earlier that 13 resources of the NRC ought to be focused on problem performero,
14 that the good plant clearly needs less regulation and less 15 oversight than a plant that is having problems.
16 But withir that, at a problem utility, the resources 17 should be focused as the areas problem.
When we were doing 18 this, we pulled the time reports for our inspectors for TVA 39 and one thing that struck me was what a large percentage of 20 the inspectors time and of our engineers back at headquarters 21 went into areas where there was no indication of problems, 22 because the various guidance documents that were in existence 23 at that time required that this be inspected or this be re-24 viewed and that there really wasn't a great deal of discre-25 tionary resource available to address proolem areas, so we Heritoge Reporting Corporation msm
61 1
made a couple of recommendations to address that.
One to just 2
affirmatively increase, again NRC manager's-ability to focus 3
his own resources on area perceived problems rather that check
(
4 off this box and this box, that we did inspect this, we did.
review that and the second was that a lot of NRC resources 6
were going into inspections and reviews that had been.requirec 7
generically, perhaps by regulation or perhaps all plants will.
8 have this inspected.
So that it intended very-specifically 9
to reduce the resources that were available to go to the 10 problem area.
11 The next area was corrective action.
TVA had, 12 for example, had instituted large programs to address certair t 13 specific areas.
Reviewing those programs even in the light d4 of hindsight, I had no reason to doubt that they ought to have 15 worked.
I would not have changed them in significant ways, 16 even now, it looks like they should have worked. In most 17 cases they were not effective.
18 And, we started working at how we could insure their 1
19 corrective actions really worked because we had spent a lot of 20 time telling the rest of the NRC, hey, you ought to be working 21 at problem performers and making sure they're doing something 22 But how do you make sure what they're doing is working?
And 23 clearly, there was, especially in hardware corrective action 24 programs, a tendency at that time to take the program plant.
25 The utility sent you his corrective action program.
You read r
Heritoge Reporting Corporation
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62 it and it looks good and you say, _therefore the problem is resolved.
The problem wasn't resolved, the tools to resolve 2
3 the problem had been put in place and there was not a great deal of emphasis in' going back and seeing how well these 4
5 corrective action programs worked in practice and in the ' field, 6
There was an obvious problem about resources doing 7
that and we felt, an effective way to. assure these corrective g
action programs worked was by-third party inspectors inspec-9 tions done at the utility's behest, with their independent results available to us.
10 gg We felt, at that time, that it was difficult 12 to take enforcement action when a corrective action program 13 didn't work, absent new violations that there appeared to g
be this problem ir. the way some of the enforcement guidance was written.
15 16 And, the last thing is that we felt that perhaps the NRC had been too involved in the nuts and bolts of 17 18 formulating some of these corrective action programs for TVA
~
and that TVA's sense of individual responsibility for isow wel l 19 20 these programs worked had been reduced because of it, that I
21 there could have been a tendency to say, we did what the NRC told us.
If it doesn't work, it's the NPCs fault.
We felt 22 that had to be dealt with.
23 i
MR. CARROLL: What would you say now was really the j
24 25 root cause, from a TVA perspective?
These corrective action Heritage Reporting Corporation j
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63 I
programs that looked fine one paper weren't working. Nobody 2
cared, nobody had a
proprietorship in them.
3 MR. GOODWIN: There was, in general, no single 4
individual or group who had a proprietary interest in this 5
plants got t run right rather that because authority 6
responsibility, and therefore, even the ability to get 7
praise for having done it well was so fragmented that~the 8
best that the person could do was say, well, I can show that l
9 I did my part of this, I got mine completed.
But, we 10 couldn't see that there was an individual who held himself 11 responsible or was held responsible for it working rather j
12 than being completed.
13 The last area we addressed was: How do you measure-14 how well a licensee is performing?
And, we felt that--we 15 were discussing problem performers and based on our review 16 of the TVA history, we felt that a sign that they weren't 17 performing that well, that we had missed, was in the area 18 of long term requirements.
We talked aboit environmental 19 qualifications, fire protection.
20 Maintenance and surveillance tend to behave the 21 same way.
They are a continuing responsibility.
There is 22 no end.
It's like a housewife's work, it's never done and 23 because it's never done, the ability to keep doing it is 24 indicative of good management.
25 And, we felt that there were some specific tools Heritoge Reporting Corporation
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64 or recommendations that could be made.to assure both that 2
the day to day grunt work of operating. safely got done well 3
and that we could identify ~when it wasn't being done well.
4 We felt that one of.the most important' tools 5
was to give-licensee management the kind of sophisticated' 6
tracking system they needed to make sure their routine safety 7
related work got done evry month, according to schedule, that a
they needed these kinds of schedules.
9 We felt -that we ought to be, in ourselves, ' emphasiz-30 ing this sort of getting out the payroll type of safety work 11 more strongly that we had been.
12 We felt that the NRC ought to conduct itself such 13 that if a utili.ty, trying to do things expeditiously, that 34 they aren't held up unduly by our lack of promptness in 15 reviewing their submittals and responding to their mail.
16 We felt that another area where we could identify 17 problems in this area was what we discussed earlier, progress 18 reviews of major regulatory problems.
That got discussed I
19 extensively. It is very resource intensive.
20 And the last part was when a utility said, we 21 finished with this, get down there pretty rapidly and find ou t, l
22 did they do it right.
23 MR. MICHELSON:
Before you leave this, and apparently
)
24 you are, one of the things that was brought out by a couple 25 of the commenters in which some my own' observations was a Heritoge Reporiing Corporation m *=.
65 1
very valid comment and that is, there was a problem'in the 2
early '80's with TVA when they decided to go on an economy 3
kick, a rather serious one, in fact,in which the resources i
4 with which to do these various things were being severely 5
restricted at a' time when many new requirements were,being 6
added, so how is the agency going to--to what extent.is the 7
agency going to review, on a periodic or continuing basis 8
assuring itself that the resources are available1with which-9 to--they believed the utility could. carry out its licensing 10 requirements.
11 I see nothing in here that is re~ source oriented.
12 You're going to look up management and so forth, maybe 13 indirectly that is looking in resources, but could you commen<.
14 on--and the reason I raise it because we're seeing the early 15
'80 all over again in TVA today.
They're on a new economy l
16 kick.
Very serious restriction on the people available 17 and so on and so on.
18 How is NRC now viewing this new resource allocation 19 in view of its obligation to assure public health and safety?
20 I don't see it on any of the listings here.
21 MR. HEBDON:
I think our review of the licensee's 22 performance and more than just TVA, is getting to be more 23 and more performance oriented and if we see the performance 24 degrading, then the question that we look for is why is it 25 degrading?
Is it, in effect, management, is it a lack of Heritoge Reporting Corporation
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resources, some combination of the above?
But to be able to 2
go in and conduct an inspection and say-you need "x" number of 3
People in your Engineering Support Group, I just don't think 4
that would ever be practical.
5 MR. MICHELSON:
I don't think these are suggesting 6
that, of course, but rather you are taking a little higner 7
view of it though.
Certainly you are in a position to ask-g the agency to explain,.tn reasonable detail, why it thinks 9
it can still carry out its commitments.with 30 percent, 40 go perce't fewer people and'certainly it's not a little 33 increment, it's a big increment and you certainly are in a 12 position to judge.
13 Now, are you going to try and get a head start on 14 these problems or are you going to wait 3 years?
It will 15 take 3 years to see whether or not it falls on its face.
16 MR. RICHARDSON:
You said these were not commitments 17 My division staff had advance warning that some of the budget 18 cuts were coming and we immediately' started looking at the 19 commitment list and discussing it with Mr. Otto and tur.
20 Gridley and they were successful in going back and getting 21 some of those budget cuts restored in the nuclear areas 22 that would make it--
23 MR. MICHELSON:
Th Jeason that prompted me, I 24 didn't quite hear the message under Item VII, that you're 25 also concerned about resources available with which the Heritoge Reporting Corporation m ue==
67 3
utility could reasonably carry out its commitments.
If they-2 aren't there for your-viewing, they either must be shown 3
to be there by the utility or you take corrective; action.
4
-You wouldn't let a utility start up a plant if it didn't have 5
an adequate operating crew, for instance.
That's always-6-
within your domain-to look at.
I think it's within~your 7
right to look at their resources available to carry out 8
promises that they make to you from time to time, and I:
9 think that ought to be a line item, because I think.that's to a line item in this whole management question, are they making 11 Promises they obviously can't carry out.
12 MR. WYLIE:
So basically, you're looking at the 13 commitments and examining those to see whether or not they're l4 going to meet them as a measure as to whether or not they got 15 the resources to do it.
16 Is that being done, not just special projects group 17 but also across the Commission?
18 MR. PERANICH:
Well, if there's any reductions _in 19 resources which the regional offices feel would impact on 20 the licensees ability to meet it's commitment, those usually 21 are addressed by the Regional Offices and the headquarters 22 as part of the overall licensing inspecting program.
23 There have been, in fact, there is a situation 24 right now, I won't mention the plant,.that we are considering 25 looking into a concern on our part whether a licensees Heritoge Reporting Corporation (392) 626 4000
-68 reduction in resources will affect his ability-to meet his 2
commitment. But it does happen. I just wanted to let you know 3
that it does happen.
4 MR. WYLIE:
But that is-a uniform message to the' 5
regions to do'that?
6 MR. PERANICH:
Well, yes.
7 MR. WYLIE:
Some of the problems that occurred in 8
the past, I won't mention them, as you well know, was because 9
they didn't meet commitments.
10 MR. HEBDON:
I think that's certainl; a sensitivity gg on the part of the Regional Management, when there are major 12 changes in resources and sometimes major changes in indivi-13 duals, it tends to raise the level of management's sensitivity 14 that there's been a major change, we're going to need to watcr 15 the situation carefully to make sure that the situation doesn' t
16 degrade.
17 MR. CARROLL:
A few years ago, the big buzz words 18 were, "integrated living schedule," that was going to be the 39 solution to this problem.
My understanding is that that has 20 sort of fallen by the wayside.
Is that correct.
2]
MR. RICHARDSON :
That's my understanding.
22 MR. PERANICH:
This is one of the lessons learned 23 action items.
The integrated schedule policy was issued for 24 public comments.
The staff is reviewing the public comments 2s and there have been some very brief discussions with the staff Heritoge Reporting Corporation ownw.=
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responsible.
It doesn't'look too favorable, but they're 2
looking for another method for accomplishing the same thing.
3 So, I am not in a position to discuss that in detail, but 4
I guess your observations, your understanding is probably 5
fairly. correct.
6 MR. CARROLL:
On the other hand though, I guess I 7
have had the view that a utility that is really running 8
things properly has something like that.in house and probably 9
would be willing to share it with the NRC, at least to some 10 degree.
I mean, that's how you manage things.
You decide what 11 you have to do, you get the money so you have the resources 12 to do it with, prioritize it and--
13 MR. RICHARDSON:
I think you have a problem with 14 the living shcedules.
The good performers already have 15 done and were doing them in their own ways and the bad 16 performers really didn't have the mechanisms for getting 17 one, so it really didn't solve anything in such cases.
Ig MR. MICHELSON:
Maybe it's a good performance indi-J 19 Cator.
)
20 MR. RICHARDSON:
It could very well be.
l 21 MR. MICHELSON:
You know, you get right down to it, 22 and you start looking around at the poor performers, you 23 find they don't lack these various fundamental management 24 tools, for whatever reason they lack them and maybe you ought 28 to search around and see whether they got the tools before yoa Heritoge Reporting Corporation
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judge the management capabilities.- It might be a better indi-2 cator than a few of the others would try to use.
3 MR. WYLIE:
Any other comments?
4 (No response)
MR. WYLIE: If not, let's move on then.
6 Wait a minute, we got a break at this point'.
7 Let's take a 15 minute break at this time and 8
we'll be back at 10':30.
9 (Whereupon at 10:15 a.m., the subcommittee 10 took a short recess to reconvene at 10:30 a.m.)-
Il 12 13 14 15 16 17 18 19 1
20 21 22 i
23 i
24
)
25 Heritoge Reporting Corporation (8H) M
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71 iR.'fWYLIE:
We'll resume the meeting.
I 1
2 MR. PERANICH:
My name is Mark Peranich.
Fred Heb-i 3'
don, who is the chief of our branch, which includes Licensing
(
4 Inspection and Research activities, as far as integrating 5
them within the NRC, have come down to give you an overview 6
of the actions, actually the status of the actions, that were 7
outlined for the TVA lessons learned.
8 We were given relatively brief notice that you 9
wanted the overview so we did prepare a brief overview of to the actions and their status, and you have received the slide 11 that I planned to--
12 Before I get to the first slide, I guess it's pro-13 per to look at the paper and the Commission paper indicated 14 that we had twenty-seven final recommendations,-nineteen of is which required some action.
Eight of which were either in-16 corporated with others or didn't require action.
So we'll 17 cover these.
18 It's fair to say that we in the earlier discussions 19 with that and Steve Richardson that we did cover the status 20 of some of these actions where we did, we'll briefly cover 21 that and go by it.
l 22 The paper and the slide here, just to give a recap, 23 we provided the paper, at least it was dated August 20th 1987 24 to the Commission and we received the Commission's response 25 on March 2nd 1988, where they asked the staff to proceed with Heritoge Reporting Corporation ema n.
72 I
the actions with certain information that they passed on, 2
and the summation of the comments that we received were to 3
reconsider disposition of 7-4.
The Commission believed that 4
the action that we had planned should provide a little more 5
reasonable goals completing licensing actions should be-esta-6 blished by the staff.
The prior action referred to using 7
current procedures for completing that action.
8 The Commission wanted to be advised on disposition 9
of 7-4 and 7-6 and you'll be receiving a memorandum which 10 we issued, an internal document, which we issued to provide 11 that response.
12 They wanted the Commission to be provided with a 13 quarterly progress report and we are doing that through the 14 PRIMR Program.
15 The slide that you'll be seeing captures the es-16 sence of what we're referring to the Commission on the status 17 in the PRIMR Program.
18 They asked for OIA to verifying completion of staff 19 actions which OIA is doing.
They are remaining aware of what 20 we are doing.
They haven't come in yet to actually complete 21 their activity.
They asked ACRS for this independent review 22 which you are now doing.
They asked for Lesson 1 to reflect 23 the Commission's semi-annual review of operator licensee, 24 and that refers to the senior management meeting which is 25 done on a semi-annual basis of the Commission's input to that Heritoge Reporting Corporation
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is factored in and will be factored in the final procedure.
2 With respect to Lesson 3, the action indicated 3
should not be limited to NRR and this was a discusssion, they 4
used the team inspection, and that's been taken care of. The 5
-use of team inspections reemphasis for.use of team inspections 6
will include both NRR and the Region.
7 Recourses to implement the actions should be re-8 flected in the Five-Year Plan.
Our administrative office is 9
addressing that and as you can see from the paper that we~in-10 dicated in the Commission paper that the impact on resources 11 would be minimal.
12 Staff response to two OIA findings to the Commission 13 which the Commision wanted our response, you'll be receiving 14 copies of internal memorandum which provided the staff the 15 two OIA findings.
I don't plant to go into detail on those.
16 If you have questions we can address them at a. subsequent 17 meeting or if you have some general questions, we can discuss 18 them now I guess.
19 MR. MICHELSON:
On the question of resources, before 20 you get to that, it really isn't clear to me now that--I J
21 think you have added as a result of writing this SECY some l
22 significant new areas of effort.
On the other hand, you are 23 deleting some perhaps some significant areas of ef fort.
And 24 so I guess you are saying on the balance that we did every-25 thing the SECY says and that you would not require any Heritage Reporting Corporation (set) 636 seat
a 74
-1 additional or any significant impact on resources.
Is that 2
what you are saying?
3 MR. PERANICH:
In part, yes.
Another part of it 4
was that the staff all along had been trying to address some 5
of the issues that were occurring at nuclear power plants, 6
not only TVA, and some of the actions that are indicated 7
already were going on.
The NRC senior management meeting is 8
an example of that.
There was a need to assure that input 9
was received from all appropriate offices and was properly 10 considered, and now we're formalizing that process.
As far 11 as the SALP program goes, as you know, the SALP program was 12 ongoing.
However, it was subject to revision to focus more 13 on areas that we now feel need to be looked at.
So there was 14 an impact on doing the formalizing or revisions of these pro-15 grams, including the inspection program that we're going to 16 talk about for reactors, but this is part of the normal pro-i 17 cess within the NRC and this was moving along.
So a lot of 18 these things were addressed through what we had initiated 19 and then some further refinement to incorporate further the 20 actions that were required by the TVA Lessons Learned.
21 MR. MICHELSON:
Well, clearly you must have been 22 also making some significant reductions in efforts in certain i
23 areas because you've identified some new programs that I i
24 think cannot be done without a significant effort.
25 MR. HEBDON:
I think the point that Mark is making Heritoge Reporting Corporation
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is that we'had already started this program of trying to 2
shift the emphasis in inspection program and I think the com-3 ments that came out of the TVA Lessons-Learned were very 4
consistent with the direction we were trying to take.
This 5
idea of performance and overall safety instead of emphasis 6
on compliance.
And so a lot of these efforts and a lot of 7
the things that are being done are things that we had recog-8 nized needed to be done and the TVA Lessons Learned reinforced 9
some of the concerns that were identified particularly when 10 the reorganization took place and the inspection program
~
11 became the responsibility of NRR and the people who were 12 there now to manage NRR.
13 MR. PERANICH :
Then it's a matter of priorities.
14 MR. MICHELSON:
You are saying those were already 15 in the Five-Year Plan?
Resources were already allocated--
16 MR. HEBDON:
The total resources for the inspection 17 program would not be changed by this.
18 MR. MICHELSON:
Because they were already pre-19 planned.
These things had already been factored into your 20 Five-Year Plan?
21 MR. HEBDON:
That's correct.
22 MR. MICHELSON:
And therefore whether or not you'd t
23 ever written the SECY would make no difference, yor were going 24 to do them anyway.
25 MR. PERANICH:
Well, I won't say that exactly.
Heritoge Reporting Corporation mm.
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MR. MICHELSON:
Well, that's the only way you-end 2
up with no inspection--
3 MR. PERANICH:
No, ARM is now looking at this paper 4
and what we are doing and talking to us about whether we need 5
new resources and so far we haven't seen where the Five-Year 6
Plan doesn't provide adequate resources to do this.
7 MR. MICHELSON:
That was my understanding.
8 MR..PERANICH:- But they are looking at it.
They 9
are not ignoring it.
They are taking another look at it.
10 MR. MICHELSON:
I think I appreciate now that in-11 deed it does take additional resources, but they had already 12 been pre-planned, not a part of this SECY effort.
Is that 13 correct?
14 MR. HEBDON:
Well, I don't want to imply that 15 there's going to be more resources in the inspection program 16 as a result of this effort.
The net resources available for 17 the inspection program will be the same, and it will not 18 change.
19 MR. MICHELSON:
Now you are getting around to what 20 I said originally which you didn't seem to be agreeing with 21 and that is that you must be reducing some things in order to 22 be adding some things because I see--if I believe what you 23 tell me, you are going to add some significant new efforts, j
24 and so I have to believe you are dropping some significant 25 efforts to balance the resources.
Heritage Reporting Corporation i
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MR. HEBDON:
Well, one of the things we'll talk 2
about is the new inspection program.
3-MR. MICHELSON:
Okay.
4 MR. HEBDON:
And, yes, there is a reduction in the 5
amount of inspection that's done, particularly at the better 6
performance.
One.of the things that we're trying to do with 7
the new inspection-program is to give the Regional adminis-8 trators much more flexibility to allocate the resources to 9
where the problems are.
And we're trying to give them-some 10 additional tools to do that with.
And so that's very con-11 sistent with the comments that came in the TVA Lessons 12 Learned.
13 MR. MICHELSON:
Yes, but you've been doing that 14 already.
15 MR. PERANICH:
What we're really doing is refining 16 it.
I think Ed made some comment to the fact that the prior 17 program, as you are aware, was the minimum of basic and j
18 supplementary program for Inspection of Nuclear Power Act.
19 Is the goal to be to try to do the minimum and the basic 20 where you can for all reactors and the supplementary program 21 would focus on those licensees that needed more inspection 22 effort.
23 The goal tended to allow the regions to estimate
'l 24 these things again on a six-month basis and some of these 25 inspections were being accomplished as Ed indicated even Heritage Reporting Corporation t=%.m
4-78 1
though there wasn't any findings or a need for these in-2 spections with respect to the basic program.
3 The revision or restructuring this program now 4
will specifically identify what core inspection program 5
modules must be done including a mandatory team inspection 6
at all facilities, and it will essentially take the other 7
inspection procedures and make them available through re-8 gional initiatives and reactive inspections, and the Re-9 gional administrator will be held responsible for allocating 10 the resources where they need to be allocated based on pro-11 blems at plants.
He'll be given approximately. half of the 12 past resources to do this.
And the program that's designed 13 has a master inspection plan and it's going to be structured 14 such that when he does allocate resources he's going to 15 identify two--well, identify in the master inspection plan 16 the basis for allocating those resources, those additional 17 resources, for that use as a regional initiative.
There has 18 to be a reason for doing it, i
19 Now, it's going to be a little more difficult in 20 scheduling.
But we feel it's going to be much more effec-21 tive as a resource utilization, so to this extent we hope 22 to gain resources out of the current total package that we 23 originally had.
The resources totally are going to be about a
24 the same from last year to this year.
But we hope it will be 25 a more effective use of the resources to address the TVA Heritoge Reporting Corporotion (set) 6 masse
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79 Lessons Learned problem with respect to allocating resources--
MR. MICHELSON:
Are you going to reduce these--for 2
the good performer you are going to perhaps inspect even 3
less in that plan than the original Five-Year Plan?
4 MR. PERANICH:
Yes.
5 MR. MICHELSON:
In order to pick up some resources 6
7 -
or just to focus--
MR. PERANICH:
Well, I won't say the--we've decided 8
that even the good performers may need a little more with respect to the experts that we have in regions to look at to them.
We _ relied too much on the residents in the other 3,
Programs for the top performers to d: most of the inspection.
12 We're changing that to bring back the experts to the site 13 to support Regional activities.
g But other than that, there's going to be a reduc-15 tion from what was normally done at every plant, unen you 16 compare the core inspection program to the minimum and the 37 basic.
18 MR. HEBDON:
Even within subject areas we'll be y,
i 1 oking more at where the problems are, so if you've got a 20 P ant that's an average plant in most areas but is very good l
21 in another area--let's say, they are pretty much average 22 across the board, but they have a very good HP program.
We 23 might cut back at that particular plant in the tiP program.
g MR. MICHELSON:
But there'll still be certain 25 Heritage Reporting Corporation im -
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minimum-effort that you are going to try to--
2 MR. HEBDON:
Yes, there is a core inspection pro-3 gram that's a minimum set of modules that we've done at 4
overy plant and the feeling is that most other plants--or 5
most plants will have had at least some other level of in-6 spection.
There will be very few plants that will have only 7
the core inspection program.
But what those other modules 8
are that will be done in most of the plants will vary from 9
plant to plant, both with respect to how many and which:ones.
10 MR. MICHELSON:
The whole idea is trying to make 11 sure that the good performers remain as good.
12 MR. HEBDON:
Yes.
There is some minimum level to 13 the core inspection program that will be done at every plant.
14.
And as I said, there will be very few plants that will have 15 only the core inspection.
Most plants will have at least 16 some additional level.
17 But the idea that we're trying to move to is 18 basically a tailor-made inspection program for every plant.
19 Tailored to their specific strengths and weaknesses.
- Now, l
20 as you can imagine, that's a pretty serious management pro-21 blem to get that to work.
And to make sure that the resources 22 come out right and that's going to be I think the most diffi-j 23 cult part of it, and that's the area that we're trying to
{
24 deal with now.
Because we want to start this about the 1st 25 of October.
And the regions are now starting to gear up to Heritage Reporting Corporation (Set) 6M40e9
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figuring out how to do this because for big regions, for ex-2 ample,you are talking twenty-five or thirty tailor-made in-3 spection programs.
4 MR. MICHELSON:
The unfortunate thing is that even 5
the best performer has a finite probability of experiencing 6
a serious accident and once experienced, then you are going 7
to be asked how come you weren't doing this and weren't doing 8
that and so on and so on.
9 MR. HEBDON:
That's true.
10 MR. MICHELSON:
You've got to have at least a 11 minimum program to show that you had--that'it wasn't incre-12 dible.
13 MR. HEBDON:
Yes.
And there is that.
And we've 14 been careful to make sure that that covers all the different 15 functional areas as well.
16 MR. MICHELSON:
Okay.
i 17 MR. PERANICH:
I think we'll get into some of this 18 as we go through the Lessons Learned.
I think--I just want 19 to point out that when we got the SRM we didn't incorporate l
20 those comments into the Lessons Learned.
The actions that 21 were originally planned distributed that to the NRR and other 22 offices within the NRC so that they were all--we made sure 23 that they were aware of them and gave them proper attention i
24 and indicated to them whether or not the planned action as 25 indicated in our correspondence had changed based on that Heritoge Reporting Corporation
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for them to consider it in their actions and that was done.
2 So with that, we'll proceed to cover the TVA Lessons Learned.
3 I think we can gain some time from the standpoint 4
that I can explain the structure of this.
Of course, the main category up at top is the TVA' Lessons Learned and the 6
sub-items I refer to them as Lessons.
They are recommenda-7 tions that Ed had just talked, and they have been abbreviated 8
'of course, and underneath that we talk about the status.
9 The first item indicates what the status is and to the narrative that follows is the' action that was planned.
11 So when we say it's ongoing, that's the action that was 12 still planned and is ongoing.
13 We have other things added in the individual les-14 sons like the Commission requested us to incorporate their 15 actions.
16 So the responsible organization is identified here l
17 and the status gives you the action plan and the status, and 18 then any other things that might add to that are provided to 19 you.
20 MR. MICHELSON:
What's this semi-annual review 21 plants--what are you--
22 MR. PERANICH:
The Commission in the SRM that 23 they provided to us asked us to consider their semi-annual 24 review of plants as input to the senior management--
25 MR. MICHELSON:
You mean the Commissioners do a Heritoge Reporting Corporation i= %
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semi-annual review?
2 MR. PERANICH:
That's how I interpret it.
3 MR. MICHELSON:
Is that correct?
4 MR. HEBDON:
There's a meeting with the Commission s
after the senior management meeting where the regional ad-6 ministrators and the Director of NRR discuss with the Com-7 mission the conclusions from the senior management.
8 MR. MICHELSON:
That I can understand.
This state-i 9
ment I don't understand.
Apparently you are--is this the 3
4 30 particular plants that were identified in that meeting as 11 being problem plants?
Is that what was meant by that bullet?
12 MR. PERANICH:
Not necessarily the way I read it.
13 It's any input they may have which may be--
ja MR. MICHELSON:
If you left the word "plants" off 2
is I'd have no problem with the statement.
16 MR. PERANICH:
- Okay, i
17 MR. MICHELSON:
You are inferring to me that you 18 are identifying certain plants semi-annually, gg MR. HEBDON:
There are specific plants that are 20 discussed with the Commission semi-annually.
21 MR. MICHELSON:
And the Commission feeds back to 22 you their instructions concerning those plants?
23 MR. HEBDON:
There is a discussion and if they add 1
24 any comments during the meeting, certainly those comments 25 would be incorporated in the actions taken.
It's a very l
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senior level meeting.
It's regional and then it's:very--
2 MR. MICHELSON:
Has one of those ever taken place?
f 3
MR. HEBDON:
Yes.
There was one just in the last 4
week or so.
5 MR. MICHELSON:
Is there a staff requirements docu-
]
6 ment issued as a result of that meeting?
a 7
MR. HEBDON:
I don't recall if.there is a specific 1
8 staff requirvments document but certainly there is a dis-9 cussion and the discussion is.at a very high level.
I mean 10 this is Regional Administrators and the Director of NRR.
11 MR. MICHELSON:
I'm sure that's the case.
I 12 MR. HEBDON:
If the Commission provides guidance, 13 they are certainly sensitive to what they are told.
q 14 MR. PERANICH:
And essentially whatever input the 15 Commission provides that's intended to be considered in deal-16 ing with the plants.
17 MR. MICHELSON:
I would think this is a public 18 document.
I would think that you could tell me then shortly 19 what plants are currently on the Commission's list of problem 20 plants.
The Commissioner's list, I should say.
If that's 21 indeed what was meant by that bullet.
22 MR. PERANICH:
I'm not aware that that list has yet i
23 been made available to the staff.
I haven't seen it.
24 MR. MICHELSON:
But it will be a public document 25 when it is made avaliable.
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MR. HEBDON:
I'd have to look into-that and get 2
back to you.
I i
3 MR. PERANICH:
Well, I think we discussed the 4
senior management meetings and they are ongoing.
The last 5
one was held just the end of June.
The next one is scheduled 6
for December.
We plan talking to the NRR division responsi-7 ble for that.
They plan to have the formal procedures in 8
effect by the December meeting that's going to occur.
9 MR. CARROLL:
The June meeting was the first and to only meeting of this nature?
11 MR. PERANICH:
No, no.
It was the fourth senior 12 management meeting.
13 MR. PERANICH:
With respect to the next item, I 14 think we've covered a lot of these also.
As far as the sta-15 tus of the issues in the individual lesson, the SAI.P program 16 was completed.
The revision of Manual Chapter 0516 approved 17 by EDO on 4/6/88 and went to the printers and is being is-18 sued.
19 That chapter changes the categories from thirteen 20 I believe to eight.
And puts more focus on safety assess-21 ments and verification of activities in addition to some of 22 the others, so I don't plan to go into the details of that 23 but there is a change in the focus of a number of categories.
4 24 Some, like fire protection, are incorporated into other 25 categories.
The focus more such that fire protection wasn't Heritoge Reporting Corporatie me
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made a separate category ano that happened to a couple of the 2
others also.
QA is combined with safety.
3 MR. CARROLL:
I don't know about the rest of the 4
members but I'd like to see that.
5-MR. PERANICH:
We can provide a copy of what was 6
issued to the Commission or if it's printed and issued to 7
the Regional Office we'll give you final NRC copy of 0516 8
if it's out.
9 MR. MICHELSON:
I'd like to go back to Item 1 for 10 just a moment.
You said that it would be in place in'Decem-11 ber of
'88.
And then I looked at--what are you talking about?
12 What's in place?
13 MR. PERANICH:
Formal procedures for assuring that inputs in senior management meeting provided by all offices.
15 For instance, AOD--
16 MR. MICHELSON:
Well, jurt the procedures that 17 will be in place, is that what you are saying?
Not the sys-18 tem?
19 MR. PERANICH:
We ll--
1 20 MR. MICHELSON:
See, the first part of the bullet 21 you can't read up there.
It says, "A system to periodically 22 identify monitor and address poor performunce."
l 23 MR. PERANICH:
The system will be the program pro-24 cedure associated with the senior management meeting which 25 provides--the program will assure that each office within the
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NRC provides appropriate input.
For instance, AOD is re-2 sponsible--
3 MR. MICHELSON:
Let me just tell you.
I'm reading 4
what you've got_there.
I know I've heard your words.
You 5
don't seem to want to answer my question.
6 MR. PERANICH:
Maybe I should--
7 MR. MICHELSON:
Let me ask the question first.
8 MR. PERANICH:
Go ahead.
9 MR. MICHELSON:
There will be a system to perio-10 dically identify.
Does'that mean by December of '88 I can 11 go to your system and I can tell you which ones are the poor 12 performers you are working on?
Is that what that means?
l 13 MR. MERANICH:
No.
14 MR. MICHELSON:.That's what identify mea : to me.
15 MR. PERANICH:
That means there will be a' program 16 in effect consisting of procedural instructions which will 17 provide a means for each NRC office to provide input tc the 18 senior management meeting which then will ident!'y as a re-19 sult of that meeting and the subsequent meeting 'with the i
20 Commissioners which are the problem plants.
That's the 21 system.
22 MR. MICHELSON:
Okay.
That's the syctem.
And-it 23 is a paper process that you go through.
There won't be a 24 printout or something of the major poor performers, the 25 monitoring schedule, and so forth?
And what you are doing Heritage Reporting Corporation
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2 MR. PERANICH:
No.
3 MR. MICHELSON:
It won't be that sort of. system I
4 which SIMS might be preferred in some respects to me, but it 5
doesn't identify poor performers.
6 MR. PERANICH:
No, the--
7 MR. MICHELSON:
So really it's a paper. system that 8
you are talking about only, not the actual identification 9
per se.
10 MR. HEBDON:
There have been meetings to identify ja problem plants.
What is being done now is formalize that 12 with formal procedures.
It's been somewhat ad hoc in the 13 past, and now that's being formalized in formal procedures 14 and that's what will be issued in December.
15 MR. MICHELSON:
Okay.
16 MR. HEBDON:
We've already had two or three of 17 these semi-annual meetings although they've been somewhat 18 ad hoc in the past.
19 MR. MICHELSON:
The system will be in place.
20 MR. HEBDON:
It will be more institutionalized.
21 MR. MICHELSON:
Yeah, okay.
22 MR. PERANICH:
And each of fice such as AEOD that has 23 responsibility for performance indicators will provide their 24 input with respect to that to that process.
25 MR. MICHELSON:
The thing that bothers me a little fultoge Reporting Corporation
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bit, Fred, is how does the agency know who the poor performers 2
are?
By agency, I mean not the A OD and not 'the Regional Ad-3 ministrator, but how do the people doing the work know what i
4 the performance of that particular utility is?
Is this a 5
list that they can get to look at and think about or is it 6
word of mouth?
7 MR. HEBDON:
Well, keep in mind that meeting is 8
attended by a Director of NRR and by the Regional Administra-9 tor for the problem plants, and the people who are involved 10 with the plants that are going to be discussed are generally 11 aware of that ahead of time.
And they generally attend the 12 meeting or listen to the part of~the meeting that-pertains 13 to their plant.
And so particularly with the new audio' visual 14 system that we have in the White Flint building.
There's a 15 lot of people that see that. conversation between t.tose senior 16 people and the Commission.
17 MR. MICHELSON:
It's transmitted throughout.the 18 building.
19 MR. HEBDON:
It's transmitted throughout the build-20 ing and it's available in a number of different places on the 21 TV monitors and if a particular individual has an association 22 with a particular plant, they would sit in on the conversa-23 tion associated with their plant.
24 MR. MICHELSON:
See, what-bothers ms--
25 MR. HEBDON:
So it does get very wide dissemination.
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MR. MICHELSON:
We just heard a little earlier, you 2
are going to focus on poor performers.
I was trying to 3
figure out how does the guy who is going to do the focusing 4
now know that a decision was made, this is the poor performer 5
to focus on?
This' will be chitchat and that meeting will be 6
a lot of generalized discussion but not--
7 MR. HEBDON:
This discussion is a fairly small 8
number.of the poorest performers.
The approach with the 9
inepection program is to have a whole spectrum all the way 10 from whst's perceived to be the best plants down to the 11 poorest performers.
And eo that's really somewhat different 12 than the managtment meeting.
That's more of an ongoing pro-13 cess that's done in the regions and in NRR.
14 MR. MICHELSON:
So within the Region at least, if 15 I asked the Regional Administrator,-he could supply me a list 16 of these priority plants, some kind of order.
17 MR. HEBDON:
He should be.able to provide you a-18 master inspection plan for every plant in his region with a 19 rationale of why the resources are being-put where they are 20 being put.
That's where we're trying to head with this.
23 Both with respect to a particular plant and with respect to 22 the resources down to the level, for. example, HP.
He has a-23 certain amount of HP resources.
You should be able, we should 24 be able to go in and look at how he's spreading the HP re-25 sources across the various plants in the region.
And be'ahle Heritc3e Reporting Corporation (set) u&4hae
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to find that there's a rational decision-making process that's 2
used, and that hopefully the plants that are perceived to be.
~
3 the.best in that area are getting~the least resources all the 1
way down through the spectrum to the plants that are.per-4 5
ceived to have the most problems are getting the most re-6 sources.
7 MR. MICHELSON:
I think that takes care of it.
8 Thank you.
9 MR. PERANICH:
Okay.
The performance indicator go program has been completed through by the Commission as 11 fully implemented and I'think you are aware of the documents 12 issued on that.
13 The Trends and Pattern Analysis whien is still g4 being looked at by both AEOD and NRR is still ongoing.
We 15 say SIMS is ongoing.
We have issued the basic NRC procedures 16 on SIMS.
NRR has issued their basic procedures.
There are 17 still some refinements to the procedures which we're working 18 on so we've classified SIMS as ongoing.
19 I guess I-3 is the status of the Lesson allocated 20 NRC review and inspection reports is based on performance.
21 And I think we discussed--I guess I've got a problem with 22 how I. sort these slides out.
23 MR. MICHELSON:
While you are sorting that out, 24 you made a statement about Performance Indicator Program that 25 is in place.
Where is the documentation that put it in place?
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It isn't that MC 2515.
2 MR. PERANICH:
No, the Commission. paper that was 3
discussed with the Commission where the Commission reviewed
- 4 the Performance Indicator Program.and accepted it and that 5
was administered by AEOD and. occurred awhile back.
6 MR. MICHELSON:
Is that what you mean now by the 7
Performance Indicator Program is in place?
8 MR. PERANICH:
No, I'm talking about the book' 9
that's issued with respect to the results of the program for 10 each plant distributed and that I see.
I am not directly it involved in that.
If you want more details you are going to 12 have to talk to the AEOD.
13 MR. HEBDON:
AEOD publishes a book of performance 14 indicators.
15 MR. MICHELSON:
Yes, I've seen that.
16 MR. HEBDON:
That's the-program.
17 MR. MICHELSON:
But that's not a program--I mean 18 I thought there was something more formal than that.
39 MR. PERANICH: In fact, it was discussed with'the Com-20 mission in a SECY paper--I think I have a copy of the paper 21 in my other--
22 MR. MICHELSON:
I have a copy of the paper.
23 MR. PERANICH:
Okay.
With respect to f'ocusing on 24 Performers and allocating resources, I think--we say that's 25 completed and we discussed that at length and we're revising Heritage Reporting Corporation m sna.,
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1 the program now to address regional comments and provide 2
further guidance with respect to'how they are supposed to 3
focus discretionary-resources on' problem plants.
4 The next lesson is Response to Licensee Performance, 5
and we'have individual lessons there.
The first lesson re-6 lated to reemphasizing accountability for instituting regula-7 tory action related to management.
And that was assigned to 8
EDO as responsible.
He did implement and he indicated to.the 9
staff that he will continue to emphasize the need to do this to and primarily this is done with higher level management at 11 the various meetings that he has, either in the region or 12 with s,nior management.
13 With respect to the recommendation or Lesson II, 14 that has been the most significant of those that OOE was 15 responsible for.
Establish a set of escalating responses, 16 deficiencies and licensee management pr ormance..
AEOD has 17 amended Part 2 of 10 CFR 50, enforcement policy, and that i
18 policy has been submitted to the Commission for their re-19 view now.
And it does place further emphasis with respect 20 to evaluating management performance.
21 Lesson III.
Evaluate adequacy, NRC standards.
22 This is ongoing further-studies consistent with future de-23 velopment of performance indicator and SALP.
There were two-24 aspects of that recommendation.
One said use SALP and the.
25 other one said improve it.
We feel the improving part of the Heritogo Reporting Corporation an,. m
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performance indicators and SALP problem is something that's 2
still ongoing and we want'to see how this new program works 3
and, of course, it's a continuing thing.
. e're going to keep W
4 looking at'it.
5 MR.'MICHELSON:
Well, when I -talk to people about 6
. performance indicators they keep emphasizing to me to make 7
sure now it's only one of many inputs to a judgement.
And 8
in many cases only a small input.
9 What are we doing in terms of--if we're going to 10 judge licensing management performance, are we developing 11 some kind of ideas or something as a means of how you go
-12 about judging management?
Other than these performance 13 indicators, which is one input to their judgement perhaps.
14 But I don't think anybody pretends it's the major input to it.
15 MR. PERANICH:
No, I think the assessment of manage-16 ment right now is being done primarily through the SALP pro-17 cess and that's primarily an integration of the performance 18 as seen through the inspection reports, the performance indi-19 cators, the operational events, the whole spectrum of what we 20 see occurring at a plant over a period of twelve to eighteen 21 months.
And one of the products of that is then to integrate 22 that assessment in the context of the performance.
Is this 23 plant working well or isn't it working well?
And then if it 24 is not working well, then the question becomes, well, is 25 there a problem with the management of the plant and that's q
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I the reason it's not working well?
2 MR. MICHELSON:
Well, when we get to that stage, 3
how do we decide there is or is not a problem?
Is it still 4
the performance numbers that we're.using in our judgement or--
5 MR. PERANICH:
It's a' subjective assessment based 6
on the SALP process.
It comes out of the SALP where you have 7
fairly senior managers from NRR and from NMSS and from the 8
Region to try to look at the overall performance of the plant 9
for the period of time that's being assessed by SALP.
And to trying to take all of the things that they say and integrate 11 that up and then make a decision about the effectiveness of 12 the management of the particular plant.
13 MR. MICHELSON:
The reason I'm inquiring a little 14 bit--you know, depending on who's asking the questions or 15 what their particular interest is, there is a group of people 16 who ask the management kinds of questions, the real ones, and 17 they ask about the competence of the NRC'to judge management and 18 so forth.
Why do we think that we are competent to judge 19 the management?
And this is brought out in some of the com-20 ments even and what is our response to our capability to judge 21 other than to performance numbers--
22 MR. PERANICh:
Well, it's not performance numbers.
l 23 We judge management by judging performance.
If a plant is j
24 SALP Category 3 is a lot of areas and doesn't seem to be' 25 getting any better, then you need t take a pretty hard.look Heritage Reporting Corporation j
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If the plant'is SALP Cate-2-
gory I.in most areas, AP'sfan occasional II and even when you 3
see a II you find the plant'doing something to try_to bring 4
that up.
5 MR. MICHELSON:
When we Cec de to look closer, as 6
you say, to the~ management, then what do we do?
Do we use 7:
our own in-house competence to do this or do we get external 8
help to look into the management or, you know, do we consider 9
ourselves adequately qualified to examine these questions 1of go -
management competence versus performance?-
think we feel that we are competent l' gg MR. PERANICH:
I 12 in assessing management performance in the ccntext of assess 13 ing the performance of a facility.
If.we look at a-facility 14 and we integrate what we've seen over a period of' time and 15 we decide that things are not going well, then I think we 16 are then capable of deciding whether that is a function of 17 the management of the facility.
18 MR. MICHELSON:
So our argument is we're looking 39 at the performance aspects and. judging management on the 20 basis of performance?
i 21 MR. PERANICH:
That's correct.
As opposed to look-22 ing at the management structure and'saying that this particu-23 lar structure is right and this particular structure is wrong.
24 MR. MICHELSON:
Correct me if I'm wrong but I've 25 gotten the feeling on a couple of occasions the NRC has gone Heritoge Reporting Corporation Den Assases
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in and fingered, shall we say, particular people as being 2
the problem and those people then have been replaced.
Is 3
that true or is that just folklore?
Now, if we go in and 4
finger particular people, on what basis do we do that in 5
terms of understanding there's a lot more than just--if there 6
is poorLperformance, sure, we-can identify that, butEhow do 7
identify individuals as being the problem?
Where is our com-8 petence to make that judgement?
9 MR. HEBDON:
The particular~ individuals who've been 10 involved in it, of course we've acted.
If they were directly 11 related to violations of regulatioas.
12 MR. MICHELSON:
They were the prompter of the 13 violation--so we really didn't say they were incompetent.
14 We just said that they, shall we say, did an unlawful act.
15 Okay.
Thank you.
16 MR. PERANICH:
The next lesson, we have the sub-17 lessons 1, 2 and 3.
I think we've discussed to some extent 18 some of them but let me recap. 'The first one relates to us.
19 revising guidance in our notice of violations transmittal 20 letters.
Actually we made a Chapter 0610 specifically to 21 require a summary of all the issues, safety issues, and indi-2.
cated that these matters should be discussed in the trans-23 mittal letter to the licensee so the focus of the issues gets i
24 the attention of the executive receiving the letter.
25 We are working with Enforcement who has also been Heritage Reporting Corporation
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modifying their input to the transmittal letters-to come up 2
with final guidance to the regions for transmittal letters.
3 In practice, this, as you can see, or-if you look at the 4
reports, this is being done.
We just haven't formalized the 5
issuance of the final guidance.
6 With respect to 2, Root Cause discussions.- The new 7
NRC inspection manual, Chapter 0610 addresses root cause. dis-8 cussions in inspection reports.
And asks the inspector-to 9
document any information related to it and, of course, our H) normal practice is to ask licensee in reponse to notice of 11 violations or deviations, for him to identify the root cause 12 corrective action and tha*, s evaluated through a procedure 13 that's currently in thc Corrective Action Program-and that 14 Procedure is currertly being modifie/. to provide for follow 15 up inspections specific to wnat we refer to as the more 16 significant findings which bear on the effectiveness of the 17 QA program, so there will be some further sampling in-the 18 core inspection program of the adequacy of the corrective 19 action as it bears on the effectiveness of the program.
20 MR. MICHELSON:
If I were to go and read Chapter.
21 610--I didn't realize such a chapter had been written--what 22 would I expect to find relative to root cause which apparent-23 ly was the subject of the chapter?
24 MR. PARANICH:
The subject of the chapter is:how to 25 write an inspection report.
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l MR. MICHELS'ON:
That's what I was. afraid it'was.
2 It really isn't how to go about trying to-do the thinking it 3
takes to identify true root causes.
That's the--how does the 4
inspector-know what you are even talking about when you are-5 talking about' root causes?
6 MR. PERANICH:
That's usually handled through the 7
various training courses that we give.
8 MR. MICHELSON:
Well, it's not in the manual chapter 9
There's no guidance in there on--
10 MR. PERANICH:
On how to identify root cause?
11 MR. MICHELSON:
Yeah.
.1 12 MR. PERANICH:
No, not specifically.
13 MR. MICHELSON:
What you mean even by root cause.-
14 That means many things to many people.'
15 MR. PERANICH:
To answer your question, no.
That's 16 not in 610.
That's hand written.
17 MR. MICHELSON:
That's having thought you've got 18 a root cause, here's how you would write it up?
19 MR. HEBDON:
Well, it's not quite that simple.
20 The point of 610, which changed the emphasis, and make it 21 clear that the emphasis in the inspection report should not 22 be simply what violations did you find.
The emphasis in the inspection report should be are the licensee programs ef-23 24 fective?
If you did find problems, what was the root cause 25 of the problem?
Why did that problem exist?
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MR. MICHELSON:
Did you define root cause in the 2
manual chapter then or give them some guidance on what you 3
mean by root cause?
I 4
MR. HEBDON:
It's really more a function of-their 5
training.
6 MR. MICHELSON:
I would think it's sufficiently an 7
important subject that you would cover it with something he 8
can read as well as listen to.
9 MR. HEBDON:
I think in the text.it's defined in 10 general terms as being the actual cause of the--
11 MR. MICHELSON:
I don't want to get into the sense 12 of root cause because that gets pretty deep all by itself.
13 I'd just like to know where to read about it so I know what 14 it is the inspectors is the root cause.
Because I see 15 root cause reports from inspectors that I really don't be-16 lieve they understand what is meant by root cause.
And I 17 wonder what kind of training are they getting?
It's an im-18 portant subject and everybody focusing on it, somewhere or 19 other the agency ought to have a discussion on root cause 20 that every inspector can read so he knows~what you are talking 21 about in the manual chapter.
And the best plece to do it is 22 to put it in the manual chapter.
But I doubt that they did 23 that.
'l 24 MR. PERANICH:
Well, with respect to II, we did H
25 finish the manual chapter and, of course, we're ongoing for i
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the report of transmittal as what you've discussed.
2 Lesson III, use the team inspections.
The current 3
program that has restructured-the program into the core and a
4 specialized teams, mandatory team inspection.
Those place 5
further emphasis on team inspections both for headquarters 6
ano the regional offices..And.the Commission recommendation 7
that we include the regions and not limit the teams to NRR 8
has been implemented in that program revision.
9 MR. MICHELSON:
When you have a team inspection 10 do you ever bring consultants in or is that normal or ex-11 ceptional?
12 MR. PERANICH:
Yes.
No, it's very common to bring 13 in consultants.
14 MR. MICHELSON:
Now, in the case that you are con-15 cerned about really looking closely at management practices 16 and so forth, do you bring a management consultant for that 17 purpose?
18 MR. HEBDON:
No, I don't know of cases where we 19 use management consultants.
20 MR. MICHELSON:
I would kind of wonder at this 21 stage of the game, does the NRC think there are no such 22 things as management experts or is it they think they can 23 do it internally, that they understand management sutficiently 24 well, or just what is our position on why we don't ask--we 25 ask other kind of specialists in I think.for other kinds of Heritoge Reporting Corporation
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problems.
2 MR..HEBDON:
Well, we try.to look at management's t
3 performance, and if we see that the performance is effective 4
I don't think we try to get into judging whether or-not the 5
management of an organization is this or that.
Is it de-6 centralized or is it centralized?
If it's matrix versus 7
management by objectives or whatever.
You try to look at the 8
performance and decide whether or not the system works.
9 MR. MICHELSON:
I realize--I was one step further 10 down the road I thought.
The team--it's decided to send a 11 team in when you think you have a problem or a potential 12 Problem.
You form a team.
And you've already done your 13 performance indicating look in all that.
You've decided 14 there's a problem.
Now you send a team in.
And my question 15 is what kind of people are on the team?
And if it is a 16 management-related problem, and there are no manager-related 37 experts on the team, then I wonder why.
18 MR. CARROLL:
Well, aren't you saying that'you 19 don' t go tilat far in general?
20 MR. HEBDON:
The teams usually have a fairly i
21 specific focus.
The management deficiency type of thing 22 would.be something that would come out of the assessment of 23 the result of the team.
24 MR. CARROLL:
I suspect one other thing you might 25 do is you might strongly suggest to the licensee he might Heritoge Reporting Corporation
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want to get INPO to come in and look at.his management and 2
how it's functioning.
3 MR. PERANICH:
We did during the CAT inspections t
4 have-on occasion where we did have an individual on was on 5
the staff who used to be a vice president of a couple of 6
utilities that we did use to assess the management of the 7
plant with respect to construction based on the types of 8
things we're finding at CAT.
9 Our experience was that'you really need an indivi-10 dual who fully understands plant operations and responsibili-11 ties of plant managers at a plant to talk at the right peer 12 level with these people with the issues that were involved.
13 It's something that is not easy to do.
You can talk to 14 management based on performance.
That you can do and we-have 15 skilled people to do that within the NRC.
To get into the 16 actual responsibilities of a manager and how he executes 17 those responsibilities,.during the CAT inspections we felt-18 you needed a person who actually had experience in doing that 19 in order to be able to discuss these things at the peer level.
20 You are getting into a very subjective area.
And 21 you just need that experience.
22 Now, we don't necessarily do that all the time.
23 It's obvious.
We feel that assessing management based on 24 Performance has and is an effective method.
25 Our next area is Assured Quality Construction.
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is'the one that relates to construction and,-of course, most 2
of the construction is over'with and-we sort of skipped.over 3
this.
We did-have some lessons.
The readiness-review, yer.,
4 we agreed to continue that for the Vogtle, the one plant that 5
we have left where that is being going on.
6
.With respect to specialized inspection techniques, 7
we incorporated that recommendation III-3.
With respect to 8
licensee review--our response to that is that's accomplished 9
through the Standard Review Plan and the licensing reviews 10 that are accomplished as a result of the Standard Review 11 Plan.
12 And just for your information, the staff, when we 13 have a new safety issue coming out of SIMS or Research, the 14 process calls for us to update the Standard Review Plan and 15 tech specs as may be required to address any new issues that 16 need to be subject to review for future plants.
So.the 17 Standard Review Plan, even though there aren't any new appli-18 cations, is getting updated at some frequency.
19 With respect to IV-4, this has been continuing.
We 20 initiated this with the construction program in
'84.
It's 21 been a continuing process where we're focusing more on the 22 actual activities than on the programmatic aspects of proce-23 dures or records.
And the current revision of the 2515 24 Reactor Operations Inspection places more emphasis and pro-25 vides a further shift towards performance looking at Heritage Reporting Corporation
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activities.
2 Of course, we havecto understand that when we go
.1 3
out there to look at an activity, we try to capture activi-t 4
. ties underway. Where we can't capture an adequate sample of 5
that, we d'o have to look at current documents of activities, 6
but we no longer look at the documents related to the format.
7 or structure of a document.
We're looking for substance 8
with respect to what was accomplished and what may have not 9
been accomplished with respect to-the safety of that system 10 or component.
11 With respect to V, the Enforcement Office has in-12 dicated to me that they have completed the initial training 13 to address that Lesson V and it will be a continuing program.
14 We have one more, Lesson VI, and this one was dis-15 positioned by incorporating it into'I-3 and III-2.
And 16 that's discussed in the Commission's paper earlier.
Re-17 flected in the Commission's paper.
18 Allocation of Resources.-
I think both of these were discussed and how we planned to do this with respect to 19 20 utilizing the revision to 2515 to provide for more effective 21 allocation of resources.
In particular for problem plants.
22 And with respect to Generic-Required Inspections 23 and Reviews, we do have the Specialized Team Inspections which focus in some case on Generic-Required Inspections.
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and the SIMS Program, and we use temporary instruction which 2
you are p:obably familiar with'to issue a requirement for 3
verification of the specific safety issue on a one-time basis i
.before it's incorporated as a matter of sampling through the 4
5 Inspection Program.
So temporary instructions are utilized 6
for that purpose.
7 We have VI, the lessons measuring the effectiveness 8
of Licensee Corrective Action.
The first lesson of that is 9
to emphasize periodic inspection to licensee corrective 10 action.
Our status is continually ongoing.
And specifically 11 we have the new core instruction program procedures.
We 12 have one that's going to focus on licensee self assessments 13 that he does himself with his various safety review committees 14 or his other committees that look at audit findings and cor-15 rective actions.
Look at INPO.
It will look at the INPO 16 results.
It will look to see what the licensee is doing.
17 We'll do it within the guidelines of our agreement with INPO, 18 of course, unless it's a matter of immediate safety signifi-19 cance, we don't plan to take any significant action'on our 20 own, but it will be an indicator of whether the licensee is 21 doing a proper assessment and follow up on INPO type findings.
j 22 So we will be reviewing it from that standpoint.
)
23 We have a--
24 MR. CARROLL:
Why are they reluctant to mention 25 INPO?
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I MR. PERANICH' Well, because there's~more--when 2
you do licensee self assessment, he has about four or five 3
committees.
He has third-party groups.
This is all part of 4
this.
There's more than just INPO that this procedure will 5
be looking at.
6 MR. MICHELSON:
Wait.a minute.
What more than INPO "7
will it look at?
8 MR. PERANICH:
Well, we'll be looking at whether 9
the licensee has initiated--if he has a problem and he has.a H) lot of SALP 3 categories, or he has one major one and it 11 covers a broad area of the plant, we'll be looking at'whether 12 he has initiated any third-party activities on his'own.
13 MR. MICHELSON:
On his own.
14 MR. PERANICH:
Yeah.
So we'll be seeing--you'know, 15 that's one indicator of how he's_ managing his plant.
In 16 some cases he doesn' t have the resources to' pursue - the prc' ' am 17 so that procedure will provide for looking at these types of 18 things.
19 MR. MICHELSON:
Thank you.
20 MR. PERANICH:
We have another procedure besides 21 the routine one which I discussed earlier that will look at 22 corrective action, root cause and the effectiveness of the 23 QA program related to the area of the identified NLV or 24 deviation.
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more the regions' look.
You might call it a SALP from a QA 2
perspective that would probably. occur as a mid SALP that will 3
require the regions to look at all the findings, look at the t
'4 events, and to organize-those into such a fashion to see 5
whether they are indicators of ineffectiveness in the effec-6 tiveness of the QA program.
7 The regions indeed have been really doing this in 8
practice but we're going to formalize it such that it pro-9 vides a better focus on whether the QA program is effective 10 or isn't effective.
And that procedure will'be part of the 11 core inspection program.
12 If the net result of that evaluation by the region 13 turns out to be negative with respect to particular areas, 14 they'll be obligater'. by that procedure to do a regional 15 initiative follow-up inspection to pursue why that program 16 that they believe is ineffective is ineffective.
17 We have Lesson VII, measuring licensee regulatory 18 performance.
The first individual lesson encourages licen-19 sees to develop manitgement tracking systems.
And we discussed 20 the integrated schedule policy statement that was sent out 21 for public comment earlier and there's no further information 22 I can add to that at this *.ime.
23 The next one in judging the licensee management 24 performance.
We discussed that completely.
The primary 25 measure for doing that is the SALP process and it's an-Heritoge Reporting _ Corporation o.o = =
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accumulation of ali the input that we received.from all of-2 fices within the NRC including licensing and the regional 3
offices, AEOD, and the Enforcement Office.
And the net t'
4 result of that is a management assessment of that plant.
5 With respect to VII-3, develop a schedule for' prompt 6
review of new generic requirements.
We consider that to be 7
ongoing.
NRR is working to ensure program developing new 8
requirements.
To sov.e extent that's covered in a communica-9 tion you are going to get from NRR to the EDO which was 10 transmitted to the Commission on what they are doing to ad-11 dress the licensee amendments.
12 Lesson 4, consider requiring initial technical 13 review and submittal within thirty days and, that's response 14 instead of raise, within ninety days.
The staff just com-15 pleted.
The Commission in the original action indicated that 16 regional goals should be established for completing the li-17 censee actions and the Commission should be advised of the 18 resolution.
It provided you with a copy of ourfresponse to 19 that for you to look at.
I don't know if you have it in 20 front of you now, but the staff in essence indicated that the 21 existing system would be utilized.
There would be additional 22 provisions taken to make sure that'the majority of the amend-o 23 ments which the project managers were dealing with would be 24 issued and addressed in approximately two months.
And there 25 would be additional procedures developed to clarify'the Heritage Reporting Corporation
($$t) 6M-4006
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methodolcgy for completing that activity.
2 So there were'some further improvements from what 3
we intended originally in our original action in attempting 4
to address the commission's request-to-provide more than we 5
originally intended.
6 I haven't heard whether or not the Commission has 7
responded to our staff in that regard or not.
8 MR. CARROLL:
That is'a very frustrating situation.
9 I know a lot of licensees don't really feel that project n) managers really move these things through very effectively.
11 I wonder whether a better solution would be to set some 12 specific time goals and require the project manager to get 13 an exception and have a good reason for it.
14 MR. PERANICH:
It's been discussed extensive by 15 the project people and there ere all sorts of things that 16 bear on that with respect to priorities and I think the 17 approach they are using considering the limited resources 18 is to assure that they identify which are the most safety 19 significant urgent are appropriate.
I can't speak for them 20 but as I understand the discussions.are those which are lcr.s 21 safety significant or bear on the plant operations do got i
22 delayed, but they are delayed for reasons for acting on i
23 more safety significant ones that are submitted.
24 MR. CARROLL:
.Yes, but if the project manager--if 25 the onus was on him to explain to his management why he Heritoge Reporting Corporation
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111 1
couldn't get it out within some reasonable time periods, it 2
would be a management tool.
Management would say, hey, we 3
seem to have a very common problem here.
I~
4 MR. PERANICH:
NRR is working on trying to esta-5 blish a better scheduling.
It's just in the infancy right 6
now and being developed.
I really can't discuss it in detail 7
but they are looking at how to manage all the actions within 8
the NRC a little better than they are doing now.
9 MR. CARROLL:
Okay.
10 MR. PERANICH:
This next one which is the wrap up 11 is--the first one is combined with VI-1, as far as the lesson 12 goes.
And the Lesson VI--
13 MR. MICHELSON:
Wait a minute.
Now, when you say 14 you combined it, what does that mean?
Ycu are still going to 15 do it?
But just put it in there?
16 MR. PERANICH:
Yeah.
It was felt that the VI-1 17 would be able to address that.
18 MR. MICHELSON:
I'm sure it could.
Is your inten-19 tion then to propo.e pariodic monitoring of the implementa-20 tion status?
21 MR. PERANICH:
Yeah, through the SIMS Program.
22 MR. MICHELSON:
Well, the SIMS Program, I think we 23 discussed earlier doesn't necessarily do that.
Remember I 24 asked how do you know--when a utility gives a particular 25 in point.
"I'm going to have it done four years from now."
i Heritoge Reporting Corporation (308) H6 4000 -
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Well, to what extent does the staff periodically're-review
~
2-that to be sure that they are indeed done.four years from f
3 now?
4 MR. PERANICH:
The staff and--these are current 5
things that are starting to be implemented and we're initiat-6 ing it for those safety issues where we're issuing a bulletin 7
and we're factoring it into generic letters that the. licensee 8
will be able to--is going to be required by that communication 9
to inform ~us when he has completed the action.
10 MR. MICHELSON:
Right.
And we discussed this and II I'm not going to discuss it again.
Four years from now is 12 too late to find out he hasn't done it.
To what extent do 13 we know within a year that he's not going to be done in four 14 years?
And that's what I thought by this--this VII-5 says 15 that this is a formal periodic review to monitor implementa-16 tion.
That meant to me that periodically we're going to check 17 to see how the implementation is going.
And you said, yes, 18 we are going to do that but we're going to call it VI-l and 19 I said, fine--
20 MR. PERANICH:
The SIMS report will give you 21 a status of which of these have been implemented.
22 MR. MICHELSON:
The SIMS report is not a periodic 23 review of the status.
It just is a listing of when the 24 utility says it's going to be done.
And if a utility changes 25 its mind, you change SIMS.
If he don't change his mind, you Heritage Reporting Corporation (man.
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don't check.
2 MR. RICHARDSON:
I think the real issue is is the 3
SIMS data periodically audited and updated and we don't have l
4 that now, but I-think we can provide that during the August 5
meeting.
We can give you a brief--I believe'that the project 6
manager does have requirements to go back and discuss withthe 7
utility the SIMS data and make sure--
8 MR. PERANICH:
There is a lead project manager for 9
every multiple action.
He is responsible for monitoring--
lip MR. RICHARDSON:
We'll talk more about this.' We 11 don't have the right--
12 MR. MICHELSON:
SIMS is for data collec cion.
It's 13 not the process.
And if you tell me that you are indeed going 14 to establish a process of updating SIMS every six mo_.
s, for 15 instance, you can tell me what that process consists of and 16 that will be great.
17 MR. RICHARDSON:
In the specific case of TVA, they.
18
'in response to our 5054F letter in September of 1985, they 19 had developed a tracking system.
There was no central'and i
20 OSP has an inspection procedure, a regular audit of the --
21 tracking system to make sure that they are meeting the commit-22 ment.
Now, how this goes over agency wide, we'll have to 23 (inaudible).
24 MR. MICHELSON:
That would be great.
It's just 25 that we have run into cases in the past where you became Heritoge Reporting Corporation
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surprised long after you should have known.
And it's because 2
the utility didn't tell you and you didn't make any effort 3-to find out.
4 MR. PERANICH:
With respect to VII-6.. Acknowledge 5
receipt of report completed-requirement within thirty days.
6 That was addressed in the 4/13 memo which you have a ' copy of.
l 7
And that indicated that tha staff would try co do:a better 8
job in particular with respect to those handled by the pro-9 ject manager in trying to get a response back in two months.
10 I think that covers--I think we diccussed this 11 to some extent during the~ earlier presentation.
It covsrs 12 the status and I understood that that's all you wanted'at 13 this time.
If you need more detailed information pertaining 14 to specifics of OEED did with respect to Part 2 policy, with 15 respect to AEOD performance indicators and what they are do-16 ing, 3'n'll have to ask the specific office to ccme in and 1
17 give you the specific details.
18 Our responsibility with respect to this is to co-19 ordinate the close out of these actions and provide a status 20 report.
21 Unless you have any other questions I thank you 22 very much.
23 MR. WYLIE:
Isy other questions?
24 Thank you very much 25 I guess what we ought to consider at this time is Heritage Reporting Corporation (MS) W-4000
,n.
115 our plans for further action in whatever information we.need.
1 2
Maybe what we ought to talk about is what we've identified 3-as additional information for our' August 5th meeting.
I 4
I've got a note regarding the availability-and use 5
of the INPO reports.
And that's historically with respect 6
to what went on at TVA.
7 And what about this last item we talked about on 8
the use and utilization of the SIMS report update and so 9
forth?
10 i
MR. MICHELSON:
They are going to give us an update on exactly what they are doing I guess and how they are assur-12 ing that the dates are monitored effectively before you reach 13 the end date.
14 MR. WYLIE:
Okay.
15 MR. MICHELSON:
And in August they'll tell us 16 better how they are going to do that.
17 MR. WYLIE:
All right.
18 MR. RICHARDSON:
We'13 give you specific information 19 on the SIMS at the TVA plant.
20 MR. MICHELSON: Would the staff have any--after going 21 back and reflecting on it, do you think you would have any 27 additional thoughts to tell us about the really how do we 23 get at thic root cause question and how does--since we're 24 now admitting that we're supposed to be looking at root 25 causes and we even put them in a manual chapter, what does the Heritoge Reporting Corporation m me
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program or how do we effectively get the information to the 2
people writing toot cause reports as to what we mean and 3
things to consider and whatever?
Is-it strictly an educa-i 4
tional process and by osmosis they acquired, or is there 5
written material that they look at or is there an intent 6
upon part of the staff to write guidance on root cause or 7
just what?
Because it's a very interesting, important sub-8 ject and I'm not surprised-that you don't have much written 9
yet but I think it's worthy of some real careful thought.
I 10 imagine the ACRS would like to provide you comments on root
- 1 causes since they seem to have a number of views in the 12 committee on this subject as well.
But I don't know if you 13 intended--you didn't make any commitment to come back and 14 tell us anything more.
15 MR. RICHARDSON: During the August meeting we can 16 give you a current--
17 MR. MICHELSON:
A short discussion of--
1 18 MR. RICHARDSON:
A short discussion of manual i
i 19 chapter 610 and inspector training and--
20 MR. MICHELSON:
- Yeah, Maybe we can get a copy of 21 610 if you will so--I know I won't find what I'm looking f >r 22 because you've told me it's not there, but I'd just like to 23 see what the official guidance is.
24 VOICE:
I might point out something about usage.
23 I am aware that the term "root cause" has a very specific Heritoge Reporting Corporotion mm
117 1
meaning within the context of more or other failure evalua-w 2
tion tracking systems.
When I used.the term, I was not talk-3 ing about that sort of formalized, you know, and quantitative-t 4
root cause analysis.
When I used the term in the Lessons 5
Learned Report, I was looking more at--just don't tell,me how 6
many violations.
Don't just tell me what they were..
Tell me 1
7 in general why they were, because management wasn't paying 8
attention to-this area and I meant it in a more informal 9
sense.
10 MR. MICHELSON:
Which is perfectly all right if 11 the person preparing the root cause report understands that's 12 what you want.
And I'm wondering how do you convey that 13 understanding to them?
l4 MR. PERANICH:
We're hoping--this is difficult.
15 You can pursue a root cause of an individual deficiency in 16 welding, for instance, or in electrical of cable.
And 17 you can identify what the root cause of that deficiency wac.
18 But you are never sure on any individual inspection o.: any 19 individual action whether that's really the. basic reason for 20 that happening until you step back and take a picture of 21 everything that's happening to see if there's other indicators 22 that say that maybe it might be management involved in that It might be the program which we thought was all right 23 area.
24 really isn't all riyht.
It might be a lack of proper super-25 vision in a specific area.
It's very dift ult to really Heritoge Reporting Corpcration
<= m
118 identify true root cause in some cases because~it takes 2
iurther evaluation.
Apparent' root cause isn't too hard to 3
identify.
True root cause is a little more difficuls.
I 4
MR. MICHELSON:
I fully agree.
And what I'm saying 5
is what does the author of a root cause report think he is 6
doing?
What'does he-think he's supposed to be doing".
How 7
deep, how far back is he supposed to be'looking?
And this is 8
the guidance which the writer has to have.
Because I look at 9
it and then I can tell you whether or not an inspector is go qualified, for instance, to even write a root cause report lj because this perspective of the total happenings is limi':ed 12 to what's going on basically on site.
And that may no'. be 13 the root cause at all.
But I don't expect him to know root y
causes that are beyond his normal purview.
15 so I just wonder what kind of guidance to we give 16 them and there's nothing wrong with writing root cause aports 17 that don't even get all the way-back to the true root cause, Maybe somebody else han to think about it after they pick up 18 39 whatever this report is.
But some kind of guidance is needed because some people tr. ink the root cause is that somebody 20 21 pulled the plug out of the wall.
And that may or may not be 22 the root cause of the particular incident.
And, you know, 23 you've got to give them some kind of guidance.
I would like 24 to read it because I would like to get the guidance myself 25 on how to write root causes.
Heritage Reporting Corporation (308) 696'4008
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MR. PER.' NICH i Well, the licensees in all' cases 2
are required to respond to what they believe the root cause 3
of the problem was.
t 4
MR. MICHELSON:
And you'll find the licensee 5
doesn't understand the term necessarily.either because'we have 6
not provided guidance and so he uses his own interpretation.
7 The easy way out is what caused the event.
Okay.
8 The shaft broke.
That's the-root cause.
But that's not 9
generally the root cause.
But it can be.
It just depends 10 on how you write your guidance.
Il MR. CARROLL:
I do believe the-utilities are getting 12 more sophisticated in this You mentioned Mort.
The other 13 one that I was very negative about initially but I think has 14 some merit is this HPES thing that INPO is touting, that a 15 number of utilities are practicing.
If you want some guidanta 16 on how to look at root cause, that might be a place to look 17 alsO.
18 MR. MICHELSON:
You might even ask INPO what's 19 their view on this approach to root cause.
How ua you write 20 root causes.
21 MR. CARROLL:
HPES is the official answer I'm 22 sure of that.
23 MR. MICHELSON:
I've read LERs which indicate to 24 me that the utility in some cases indeed is doing some very' 25 deep thinking.
In other cases it's clear they are doing what I t A
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I'd call very superficial thinking.
The easy way out kind of 2
LER.
So you get the full spectrum out :here.
And, of course, 3
we're looking for the poor performers._ This may be a per-4 formance indicator for all I know.
5 MR. WYLIE:
Well, in that rege.rd it would seem to 6
me we may want to hear more about the process that the 7
Commission goes through in identifying the problem plant' list.
8 And could somebody walk us through that at the August meeting?
9 MR. CARROLL:
Somebody hTnded us a July 18th insight 10 NRC that identifies who the problem plants are.
11 MR. MICHELSON:
I see.
That's interesting.
12 Yeah, I think that process ought to be looked at.
13 MR. WYLIE:
A good suggestion, as to how they go 14 about determining this.
15 MR. MICHELSON:
Yeah.
le MR. CARROLL:
It might be good to give an example 17 of how they went about particular plants.
18 MR. MICHELSON:
Well, maybe the one here described 19 is a good one.
I don't know.
20 MR. WYLIE:
Yeah, I think that would be helpful.
21 MR. BARTON:
For example, how do they reach that 22 conclusion on that particular plant?
It might be a good way i
23 to get a feeling for it.
l 24 MR. CARROLL:
Well,-I do see something encouraging 25 here.
Something got taken off the list.
Heritoge Reporting Corporation (set) H6-dete
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MR. WYLIE: _Maybe that would he worth exploring.
2 How you get off the list.
3 MR. MICHELSON: _ Yeah, both sides, 4
MR. WYLIE:
Well, you've described to some degree 5
today how you went about detecting _the early-on deficiencies, 6
programmatic deficiencies or change'in philosophy, particu-7 larly, of course, with TVA, you mentioned, you know, resource.
8 allocations and commitments which you detected, and there's 9
been some response on part of TVA in that regard.
10 From a programmatic standpoint, it.might ce well 11 if somebody could tell us what was being done generically 12 across NRC in that regard, 13 The thing that bothers you is, at least it bothers 14 me, is if you wait for performance indicators and you measure 15 by performance, you are waiting a long time to find out where 16 the problem is.
17 MR. MICHELSON:
We're supposed to be getting a i
18 jump on these problems.
1 19 MR. WYLIE:
Yeah.
20 MR. MICHELSON:
You don't get a jump if you want 21 for performance to tell you there's a problem.
It may take 22 three'cn: four years for performance to tell you.
1 23 MR. WYLIE:
I'm sure.
You know, it's obvious j
24 performance is a sure way of doing it.
~
~
25 MR. MICHELSON:
Yeah.
H.eritoge Reporting Corporation i
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MR. PERANICH :'
Let me say that'the' basic ingredient-2 of core inspection program--the purpose of it is to provide 3
for the early identification problems.
Which then can focus
-4 more resources at the discretion of the regional office with 5
the hopes--with a little more flexibility that the focus on 6
these problems we'll then find out in further detail where the 7
real problem is.
8 I think the direction the program is going in will s
9 do more to achieve this.
And the results will be reflected 10 in the SALP process that's underway in the futura.
11 MR. WYLIB:
Well, for example, if the licensee de-12 cides that he's going to alter his schedules and delay 13 things, say, for example, a safety analysis, in the safety 14 analysis area.
If he delays those, would you pick that up is by that process?
16 MR. PERANICH:
No, the licensing arm of the NRC 17 would be picking that type of thing up--
18 MR. WYLIE:
Are they directed to do'that?
19 MR. PERANICH:
I really can't speak for that--
20 MR. WYLIE:
That's the kind of thing I'm talking 21 about.
The more subtle things that pertain to safety issues s
22 that may be delayed because of resource reallocations.
23 MR. GOODWIN:
The NRC does monitor from the other 24 end.
In the recent reorganization last year a portion of 25 what used to be the Office of State Programs that monitored Heritage Reporting Corporation (399) M4000
123 1
financial condition of utilities was transferred to NRR.,
2 Its purpose being to identify those_ utilities whose financial 3
condition could lead them to significant cutbacks in re-i 4
sources available for safety.-
I am aware of several condi-5 tions where through various means a utility was identified 6
being in-financial straits where cutback,in resources avail-7 able to safety could have been a problem.
In those cases 8
NRR and the region specifically focused on what the conse-9 quences of the macro budget problems the utility had were 10 on resources.
11 So we are looking at that area from that point of 12 view.
13 MR. CARROLL:
That's really only one possible 14 reason though.
I mean, you know, you can have all the good 15 people walk out the door.
That's another reason things 16 wouldn't get done.
17 A utility could be in fine financial shape but 18 management could decide, well, we ought to be spending more 19 money on this and taking it away from the nuclear program 20 in some midguided fashion.
So it's more involved than just
)
21 financial health.
22 MR. MICHELSON:
Another comment.
We're focusing 23 heavily I think on performance oriented judgement of manage-24 ment of the utility or licensee.
If we're going to focus on 25 it, of course one of the things we've said we would use would Heritage Reporting Corporation
<mem
,124 l
I be the so-called-performance indicators.
I'm wondering, 2
Charlie, at the next meeting if we could devote some greater 3
length of time to the discussion of the performance indica-4 tors as they relate to management performance versus other 5
kinds of performance.
6 I listened for some time to performance indicators i
7 as they relate to judging maintenance in a workshop recently 8
and talked about it for three days.
It's not a simple pro-9 blem.
It's very difficult to-know what these numbers really 10 mean in terms of maintenance performance.
I think the same 11 discussion could also last three days in which you discussed 12 whether or not you even know good performance indicators for 13 management.
14 But I'd like to hear at least the rationale that 15 says which of these indicators are you using to judge manage-16 ment, because not all of'them are suitable for that purpose 17 I suspect.
But I haven't heard any discussion unless other 18 members have on how performance indicators--what performance 19 indicators you use to indicate good management as opposed to 20 good operations or good maintenance of good whatever.
21 Probably good maintenance might also be. management related 22 but if we could just get some idea of how you use performance 23 indicators, which ones and how in the process of inputting i
i 24 to a judgement on the management competence, which I think l
25 is one of the elements.
That's what we're focusing on here Heritoge Reporting Corporation m u.=
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125 I
is management competence.-
2.
And then also perhaps, obviously most of-it is i
3 going to be a subjective input.
Performance indicators are i
4 just one of many indicator inputs.;So maybe you could tell 5
us a little bit about the other kinds of things that really 6
basically-enter into a judgement of management competence, 7
which performance indicators are a part of it, what are some 8
of the other thoughts.
9 I haven't seen sny reports of any sort to read on to this subject.
So I think it's word of' mouth and I'd.like to 11 at least see--
12 MR. RICHARDSON:
A lot of that will come out when 13 we talk about the process that senior management goes through 14 in their deliberations to get a plant either on or off--
15 MR. MICHELSON:
Yeah, and then how their perfor-16 mance indicators relate to their ability to make those de-17 liberations effectively.
Because I've seen how management i
18 works a little bit.
And it's a very complex procest und 19 trying to reduce it to oversimplified terms to make the judge-i 20 ment sometimes may be totally invalid.
21 And I'd just like to see.
We really are touting 22 the performance indicators as the answer.
23 MR. GOODWIN:
I don't think they're saying that, 24 Carl--
25 MR. MICHELSON:
No, no.
No, wait a minute.
i Heritage Reporting Corporation mma
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126 i
MR. GOODWIN:
They are also saying~SALP is.an~im-2' portant--
3 MR. MICHELSON:
No, no.
In terms'of the'quantita-4 tive inputs, I think your performance indicator'is the only' 5
. quantitative input you've got.
And then you feed that into 6
the self process.where you put in these other judgement 7
factors.
Is there something else in betw.een?-
8 MR. GOODWIN:
I believe the Commission directed--
9 said that performance indicators are not to be used as a 10 judgement upon--an indicator upon areas to explore.
And that 11 the SALP guidance specifically excludes the direct use of 12 performance indicators as a mode to getting a grade.
13 MR. MICHELSON:
Oh, I'm sure it does.
14 MR. GOODWIN:
I just wanted to make that clear.
15 MR. MICHELSON:
It's used as part of the input to 16 deciding what if anything to say about a particular problem 17 area whether there are decisions made to increase inspection 18 or whatever.
That's all SALP really does basically is decide--
19 to identify an area for greater concentration.
And so these 20 indicators are I think being used as an important influence.
21 And so I think we need to hear about it.
Or at least I think 22 we do.
23 MR. WYLIE:
Yes.
24 MR. BARTON:
Well, this memo that was handed out.
25 They've got some way of figuring it out.
When the statement Heritoge Reporting Corporation (act) 636 8008
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says the root cause of performance problems is the division 2
between plant. staff and teaching between the site engineering 3
group.
How do they go about determining this?
~
4 MR. WYLIE:
That's a good question.
5 MR. MICHELSON:
If we're going to use it as a solu-6 tion, we need to understand what the staff has in mind.
7 MR. WYLIE:
Okay.
Are there other areas that we 8
should take up at our August 5th meeting?
9 MR. MICHELSON:
There may be by the time we think to about it awhile.
11 MR. WYLIE:
Okay.
Well, I think we've pretty 12 well concluded our morning session, so let's adjourn.until 13 1:00.
14 (Whereupon, there was a recess for lunch at 11:57 15 a.m.)
16 17 i
1 18 19 20 21 22
]
23 24 25 Heritoge Reporting Corporotion (908) H4 4000
1 CERTIFICATE 2
3 This is to certify that the attached proceedings before the 4
United States Nuclear Regulatory Commission in the matter of:
5 Name: ACRS'TVA Organizational Issues on Advanced Reactor Designs 6
7 Docket Number:
8 Place:
Washington, D.
C.
9 Date:
July 22, 1988 10 were held as herein appears, and that this is the original 11 transcript thereof for the file of the United States Nuclear 12 Regulatory Commission taken stenographically by me and, 13 thereafter reduced to typewriting by me or under the direction 14 of the court reporting company, and that the transcript is a 15 true and accurate record of the foregoin -proceedings.
16
/S/
uin YSfM p-IRWIN L.
COE BERki Q
~~
^
17 (Signature typed):
c 18 Official Reporter 19 Heritage Reporting Corporation 20 21 22 23 24 25 Heritage Reporting Corporation (202) 626-4888
't SECY 87-211 - FillAL REPORT ON TVA' LESSONS LEARNED o
PAPER TO COMMISSION - AUGUST 20, 198/
o COMMISSION REVIEW RESPONSE (SRM) - MARCH 2, 1988-o RECONSIDER DISPOSITION OF-Vil-4 o
REASONBLE GOALS FOR COMPLETION OF LICENSEE ACTIONS SHOULD-BE ESTABLISHED o
ADVISE THE COMMISSION ON DISPOSITION OF Vll-4 AND Vll-6 o
PROVIDE COMMISIS0N WITH CUARTERLY PROGRESS REPORT (PRIMR) o OlA TO VERIFY' COMPLETION OF STAFF ACTIONS o
ACRS TO PERFORM INDEPENDENT REVIEW 0F STAFF TVA LESSONS LEARNED EFFORT o
LESSON 1-1 TO REFLECT COMMISSION'S SEMIANNUAL REVIEW 0F OPERATIONS LICEhSEE o
LESSON 111-3, ACTION SHOULD NOT BE LIMITED TO NRR o
RESOURCES T0 IMPLEMENT ACTIONS SHOULD BE REFLECTED IN FIVE YEAR PLAN o
STAFF RESPONSE TO TWO OlA FINDINGS TO Tile COMMISSION o
COMMISSION SRM RECOMMENDATIONS FORWARDED TO NRC 0FFICES FOR CONSIDERATION IN COMPLETil!G ACTION - MARCli 30, 1988 o
COMPLETION OF TVA LESSONS LEARNED ACTIONS - ONG0ING l
0 i
I-IDENTIFICATION OF P00R LICENSEE PERFORMANCE I-I LESSON:
SYSTEM TO PERIODICALLY IDENTIFY, M0filTOR AND ADPRESS POOR PERFORMERS, (NRR)
STATUS:
ONG0ING:
SENIOR MANAGEMENT MEETING WILL CONTINUE TO ADDRESS REGIONS AND PGM, 0FFICES ARE DEVELOPING PROCEDURES, INCORPORATE THE COMMISSION'S SEMI-At!NUAL REVIEW PLANTS.
TO BE IN PLACE BY DECEMBER 1988, 1-2 LESSON:
CONTitlVE TO DEVELOP SALP PERFORMANCE INDICATORS, SIMS TRENDS AND PATTERNS ANALYSIS, (NRR/AEOD)
STATUS:
DATA SYSTEMS BEING UPDATED OR DEVELOPED, EVALUATION OF DETERIORATING PLAtlTS WILL BE PREPARED FOR SENIOR MANAGEMENT BASED ON DATA SYSTEMS AVAILABLE, REGIONAL ACTION TO BE DETERMINED AT SENIOR MANAGEMENT
- MEETINGS, o
SALP:
COMPLETED, REVIS10tl 0F MC-0516 APPROVED BY EDO ON I4/6/88, i
o PERFORMANCE INDICATORS:
COMPLETED, APPROVED BY COMMISSION AND FULLY IMPLEMENTED, o
TRENDS AND PATTERNS ANALYSIS:
- ONGOING, 0
SIMS:
- ONGOING, 1
=
I-3 LESSON:
ALLOCATE NRC REVIEW AND INSPECTION RESOURCES BASED ON LICENSEE PERFORMANCE, REASSESS RESOURCES SEMIANNUALLY.
(llRR/ REGIONS)
STATUS:
COMPLETED, REVISION TO MC-2515 ISSUED FOR INTERIM IMPLEMENTATION 5/9/88, CURRENT PROGRAM DOES.
PROVIDE THE INSPECTION OFFICE OPPORTUNITY TO REALLOCATE RESOURCES AS'NEEDED TO FOCUS ON PCOR PERFORMANCES,
. PEG 10NS/NRR WILL CONTINUE T0 MONITOR WHICH PLANTS-NEED MORE RESOURCES, C
e J
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11-RESPONSE TO P00R LICENSEE PERFORMANCE 11-1 LESSON:
REEMPHASIZE ACCOUNTABILITY FOR-INSTITUTING REGULATORY ACTION RELATED TO LICENSEE MANAGEMENT-COMPETENCE, (ED0)
STATUS:
COMPLETED, EDO WILL CONTINUE TO EMPHASIZE, 11-2 LESSON:
ESTABLISH SET OF ESCALATING RESPONSES TO DEFICIENCIES IN LICENSEE MANAGEMENT PERFORMANCE, (0E)
STATUS:
COMPLETED, OE TO STUDY NEED FOR MORE PRESCRIPTIVE PROCEDURES, AMENDED 10 CFR PART 2 ENFORCEMENT POLICY HAS BEEN FORWARDED TO THE COMMISSION, 11-3 LESSON:
REEVALUATE ADE0VACY OF THE NRC STANDARDS FOR ASSESSING LICENSEE MANAGEMENT PERFORMANCE, (NRR/AE0D)
STATUS:
- ONGOING, FURTHER STUDY REQUIRED CONSISTENT KITH FUTURE DEVELOPMENT OF PERFORMANCE INDICATOR AND IMPROVED SALP,
TVA LESSONS LEARNED
-TVA #
111-EVALUATION OF LICENSEE PROGRAMMATIC DEFICIENCIES 111-1 LESSON:
NOV LETTERS SHOULD INCLUDE GENERIC OR CUMULATIVE SIGNIFICANCE AND PROGRAMMATIC DEFICIENCIES, (OE/NRR)
STATUS:
ONG0ING:
OE AND NRR TO REVISE GUIDANCE ON NOV TRANSMITTAL LETTERS, IS DEING DONE, FINAL PROGRAM GUIDANCE TO BE ISSUED IN FY88, 111-2 LESSON:
DEVELOP GUIDANCE ON INCLUDING ROOT CAUSE DISCUSSIONS IN NRC REVIEW AND lilSPECTION DOCUMENTS.
(OE/NRR)
STATUS:
TO BE IMPLEMENTED:
DRAFT GUIDANCE IN FY-87, IMPLEMEt!T IN FY-88, COMPLETED:
NRC INSPECTION MANUAL CHAPTER 0610 ISSUED 12/4/87.
ONG0ING:
ACTION FOR PROGRAM GUIDANCE ON REPORT I
TRANSMITTAL LETTERS WILL BE COMPLETED DUR.
A FUTURE (FY88) REVISION OF IMC-0400 AND NRC IMC-0610, 111-3 LESS0ft:
INCREASE USE OF TEAM INSPECTIONS, (NRR)
STATUS:
COMPLETED:
IMPLEMENT IN FY88, INCREASED USE OF TEAM INSPECTIONS IS AN INTEGRAL PART OF THE NEW INSPECTION PROGRAM, IMC 2515 REVISION DATED 5/9/88.
COMMISSION RECOMMENDATION THAT ACTION INCLUDE REGIONS AND NRR INCORPORATED.
IV-ASSURE CUALITY OF CONSTRUCTION IV-1 LESSON:
CONTINUE PARTICIPATION IN THE V0GTLE AND PILOT READINESS REVIEW PROGRAMS, (NRR)
STATUS:
ONGOING:
MOST CP UNITS ARE IN LATE STAGE OF CONSTRUCTION, CONTINUE WITH-0NG0ING READINESS REVIEW
- PROGRAMS, IV-2 LESSON:
DEVELOP RECENTLY INITIATED SPECIAL INSPECTION TECHNIQUES, (NRR)
STATUS:
DELETE:
SAME AS 111-3.
IV-3 LESSON:
DURING LICENSE REVIEW PROCESS EXAMzNE COMMITMENTS THAT DEVIATE FROM INDUSTRY STANDARDS, (NRR)
STATUS:
COMPLETED - 10 CFR 50,34(G) (STANDARD REVIEW PLAN)
TV-4 LESSON:
EMPHASIZE DIRECT VERIFICATION OF AS-BUILT GUALITY RATHER THAN PROCEDURAL VERIFICATION IN INSPECTIONS, (NRR)
STATUS:
ONGOING:
INSPECTION PROGRAM FOR OPERATING' REACTORS BEING CLARIFIED IV-5 LESSON:
USE ENFORCEMENT SANCTIONS IN ENFORCEMENT, POLICY TO RESPOND T0 INADE0VAtlES IN CONSTRUCTION MANAGEMENT AND CUALITY ASSURANCE, (DE)
STATUS:
COMPLETED *:
OE WILL TRAIN HEAD 0VARTERS AND
- REGIONS, CONTINUING PROGRAM,
J
~
TVA LESSONS LEARNED t
t-IVA #
IV-6 LESSON:
INCREASE EMPilASIS ON REVIEW 0F ROOT CAUSE AND CORRECTIVE ACTION SECTIONS OF LICENSEE RESPONSES TO INSPECTION FINDINGS AND NOVS, (NRR/0E)
S STATUS:
COMPLETED BY INCORPORATION lN 1-3 AND 111-2, I
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f V-ALLOCATION 0F RESOURCES V-1 LESSON:
ESTABLISH POLICIES TO GIVE GREATER FLEXIBILITY-TO ALLOCATE RESOURCES TO ADDRESS PLANT SPECIFIC PROBLEMS.
(NRR)
STATUS:
COMPLETED.
IMC 2515 PROGRAfi REVISION.
V-2 LESSON:
CONSIDER GENERICALLY REQUIRED INSPECTIONS AND REVIEWS.
(NRR)
STATUS:
COMPLETED:
NRR TO COMPLETE ONG0ING REVIEW OF INSPECTION PROGRAM.
t t
I
TVA LESSONS LEARNED i
TVA #
VI-MEASURING EFFECTIVENESS OF LICENSEE CORRECTIVE ACTIONS VI-1 LESSON:
EMPHASIZE PERIODIC INSPECTIONS OF LICENSEE CORRECTIVE ACTION PROGRAF 1 RESULTS OVER AN EXTENDED PERIOD AFTER IMPLEMENTATION, (NRR/ REGIONS)
STATUS:
ONG0ING:
REGIONS AND PROGRAM 0FFICES TO CONTINUE TO ASSESS PROGRAMS THROUGH LICENSEE PERFORMANCE, SALP AND QUALITY ASSURANCE PROGRAM EVALUATIONS.
o NEW CORE INSPECTION PROGRAM PROCEDURES o
LICENSEE SELF ASSESSMENTS o
REGION REVIEW 0F LICENSEE QUALITY ASSURANCE PROGRAM EFFECTIVENESS t
Vl-2 LESSON:
LICENSEE TO PROVIDE INDEPENDENT THIRD PARTY AUDITS OF INSPECTION RESULTS IF OVERLY RESOURCE INTENSIVE FOR NRC, (NRR/ REGIONS)
STATUS:
DELETED:
INCLUDED IN VI-1, VI-3 LESSON:
USE INCREASED SANCTIONS IN ENFORCEMENT POLICY WHEN CORRECTIVE ACTION PROGRAMS ARE NOT EFFECTIVE IN ADDRESSING UNDERLYING PROBLEMS, (0E)
STATUS:
COMPLETED:
OE TO TRAIN HEADCUARTERS AND REGIONS ON ENFORCEMENT, INITIAL TRAINING COMPLETED, CONTINUING PROGRAM, VI fi LESSON:
REVIEW NRC ROLE IN REVIEW OF TVA CORRECTIVE
- ACTIONS, STATUS:
DELETED:
INCLUDED IN 11-2,
TVA LESSONS LEARNED I
TVA #
Vll-MEASURING LICENSEE REGULATORY PERFORMANCE VII-1 LESS0fi:
ENC 0URAGE LICENSEES TO DEVELOP MANAGEMEf!T TRACKING SYSTEMS.
STATUS:
ONG0ING.
IllTEGRATED SCHEDULE POLICY STATEMENT SENT FOR PUBLIC COMMENT.
C0PMEtiTS RFr_IVED AND BEING REVIEWED.
Vll-2 LESSON:
IN JUDGING LICENSEE MANAGEMENT PERFORMANCE EMPHASIZE LICENSEES ABILITY TO COMPLETE LONG-TERM REGULATORY RE0VIREMENTS.
(NRR)
STATUS:
COMPLETED:
REVISE SALP PROGRAM IN FY-88.
VII-3 LESSON:
DEVELOP SCHEDULE FOR PROMPT REVIEW OF NEW CENERIC REQUIREMENTS.
(NRR)
STATUS:
ONG0ING:
NRR WORKING TO ENSURE PROGRAM IS PART OF DEVELOPMENT OF NEW REQUIREMENTS.
Vll-4 LESSON:
CONSIDER REQUIRING INill AL TECHNICAL REVIEll 0F SUBMITTAL WITHIN 30 DAYS AND RiiSt WITHIN 90 DAYS, (NRR)
- U ""
STATUS:
COMPLETED:
NRC TO HANDLE LICENSEE SUBMITTALS IN ACCORDANCE WITH ESTABLISHERD PROCEDURES DISCUSSED j
ED0'S 4/13/88 MEMO TO COMMISSION.
l COMMISSION RECOMMENDATION:
REASONABLE G0ALS FOR COMPLET10f! 0F LICENSEE ACTIONS SHOULD BE ESTABLISHED j
WITH COMMISSION ADVISED OF FINAL RESOLUTION /lMPACT ON NRC B4DGET.
(DONE)
Vll-5 LESSON:
SCHEDULE FORMAL PERIODIC REVIEWS TO MONITOR IMPLEMLNTATION OF LONG TERM REQUIREMENTS.
(NRR)
STATUS:
DEFER:
COMBINED WITH VI-1.
VII-6 LESSON:
ACKNOWLEDGE RECEIPT OF REPORT OF COMPLETED REQUIREMENT WITHIN 30 DAYS, (NRR)
STATUS:
COMPLETED:
PM TO TRACK, SIMS WILL BE USED TO TRACK AS DISCUSSED IN ED0'S 4/13/88 MEM0 TO COMMISSION.
COMMISSION REC 0KMENDAT10N:
LICENSEE REPORTS OF COMPLETION OF NRC REQUIREMENTS DESERVE PR0f',PT AND TIMELY RESPONSE, COMMISSION SHOULD BE ADVISED OF FINAL DISPATCH AND IMPACT ON NRC BUDGET.
(DONE) i i
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I TVA 1.ESSONS LEARNED JULY 22, 1988 i
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-LESSONS LEARNED CHRONOLOGY k 04-08/85-TVA SHUTDOWNS 01/86 COMMISSION DIRECTIVE TO UNDERTAKE LESSONS-LEARNED REVIEW AFTER SEQUOYAH RESTART 04/86 TVA MAKES FIRST OF SERIES OF SLIPS IN SEQUOYAH RESTART-SCHEDULE 09/86 COMMISSION REQUESTS PRELIMINARY Lr,SSON-LEARflED REPORT BY NOVEMBER 10/86 REPORT DRAFTED BY TVA PROJECT STAFF WITH INPUT FROM THOSE DIRECTLY INVOLVED IN TVA OVERSIGHT 11/86 DRAFT CIRCULATED TO ALL SENIOR MANAGERS IN NRR, IE, AE0D, AND ALL FIVE REGIONS FOR COMMENT AND INPUT 11/86 PRELIMINARY LESSONS. LEAR!iED REPORT DELIVERED TO COMMISS10rt 12/86 BRIEFING OF COMMISSION 1/87 PRELIMINARY REPORT CIRCULATED TO For"dR NRC MANAGERS AND COMMISSIONERS AND TO PRESENT AtlD FORMER TVA MANAGERS FOR COMMENT AND RECOMMENDATIONS 3/87 COMMENTS ANALYZED AND REVISED RECOMMENDATIONS TRANSMITTED TO NRR FOR IMPLEMENTATION 7/87 IMPLEMENTATION PLAN TRANSMITTED TO COMMISSION 2/88 COMMISSION APPROVES IMPLEMENTATION Pl.AN
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GENERAL CONCLUSIONS OF PRELIMINARY LESSONS-LEARNED REVIEW A,
OBSf?VATIONS
!7ENTiFIED SIGNIFICANT PROE'.EM AREAL IN THE a
L, ' Y '980'S TV
.STITUTED VARIOUS CORRECTIVE ACTION PROGRAMS Po.0 GRAMS WERE NOT EFFECTIVE AND TVA PERFORMANCE CONTINUED TO DETERIORATE SHUTDOWNS REPRESENTED CULMINATION OF A SERIES OF PROBLEMS B.
ROOT CAUSES LACK OF LEADERSHIP BY TVA MANAGEMENT BREAKDOWN IN TVA MANAGEMENT'S CONTROL OF AND COMMUNICATION WITH EMPLOYEES STEMMED FROM INEFFECTIVE TVA MANAGEMENT AND FRAGMENTED ORGANIZATIONAL STRUCTURE C.
NRC'S ROLE CORRECTIVE ACTION PROGRAMS ADDRESSED SPECIFIC AREAS OF DEFICIENCY-SYMPTOMS AND NOT ROOT CAUSES DEPTH OF NRC CONCERN NOI EFCECTIVELY COMMUNICATED TO EXECUTIVE MANAGEMENT cF TVA OR NRC UNTil EARLY 1985 NRC's AC11se ROLE IN DEVELOPING SPECIFIC CORRECTIVE ACTION PROGRAMS LED TO EXCESSIVE TVA RELIANCE ON NRC AND A LACK OF TVA COMMITMENT TO EFFECTIVELY SULVING THEIR PROBLEMS NRC MAY HAVE PARTIALLY RECOGNIZED THE FUNDAMENTAL TVA MANAGEMENT PROBLEM BUT NEVER DEALT WITH IT DIRECTLY AND FORCEFULLY UNTil EARLY 1985 i
MAJOR COMMENTS ON PRELIMINARY REPORT NRC FUNDAMENTALLY CANNOT PREVENT AND SHOULD NOT HOLD ITSELF RESPONSIBLE FOR LICENSEE SHORTCOMINGS NRC SHOULD MONITOR LICENSEE MANAGEMENT PERFORMANCE NOT DICTATE METHODS INP0 ROLE OR LACK OF ONE IN IDENTIFYING TVA PROBLEMS NOT DISCUSSED IN REPORT LACK 0F PROMPTNESS AND CLARITY OF COMMUNICATION BETWEEN TVA AND NRC WAS AN UNIDENTIFIED CONTRIBUTOR TO SITUATION SALP TYPE PROGRAMS AND PERFORMANCE INDICATORS WITH IMPROVEMENTS IN QUANTIFICATION AND CONSISTENCY WOULD HAVE BEEN USEFUL RECOMMENDATION FOR PERIODIC PROGRESS REVIEWS AND INSPECTIONS OF REGULATORY PROGRAMS (E.G., EO AND APPENDIX R} WAS CRITIClZED AS EXPENSIVE AND INFLEX1BLE SEVERAL INDIVIDUALS (TVA AND NRC) DISAGREED WITH REPORT FINDING THAT TVA BOARD WAS NOT APPRAISED OF DEFICIENCIES IN TVA PERFORMANCE) RATHER THEY FELT THE BOARD KNEW AND FAILED TO RESPOND DECISIVELY AND EFFECTIVELY
r TVA LESSONS LEARNED LESSON 1:
NRC-NEEDS BETTE7 METHODS OF IDEllT1FYING AND FOCUSING ATTEElf0N ON POOR PERFORMERS RECOMMENDATIONS:
1-1 FORMAL NRC SYSTE'M TO IDEl4TIFY AND ADDRESS POOR
' LICENSEE PERFORMANCE I-2 BETTER NRC TOOLS FOR IDENTIFICATION I-3 MORE FOCUSED ALLOCATION OF NRC RESOURCES ON POOR PERFORMERS
(
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i LESSON 11 NRC.NEEDS.MORE CAPABILITY IN ASSESSING LICENSEE
)
MANAGEMENT PERFORMANCE RECOMMENDATIONS:
11-1 FORMAL IDENTIFICATION OF NRC MANAGER,WHO OVERSEES LICENSEE PERFORMANCE 11-2 DEVELOP FORMAL' SCHEME OF REGULATORY RESPONSE TO LICENSEE MAN?,GEMENT DEFICIENCIES 1
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LESSON 11.1 NRC INSPECTION REPORTS SHOULD ASSESS j
PROGRAMMATIC SIGNIFICANCE OF DEFICIENCIES RECOMMENDATIONS:
111-1 NOTICE OF VIOLATIONS SHOULD INCLUDE ASSESSMENT OF' PROGRAMMATIC AND CUMULATIVE SIGNIFICANCE 111-2 INSPECTION REPORTS SHOULD ASSESS PROGRAM EFFECTIVENESS, NOT JUST IDENTIFY DEFICIENCIES 111-3 USE MORE TEAM / SPECIALTY INSPECTIONS TO M0illTOR PROGRAMMATIC EFFECTIVENESS
LESSON IV NRC SHOULD IMPROVE TECHNIQUES FOR MONITORING LICEf1SEE DESIGN, CONSTRUCT 10f4 AND INTERNAL INSPECTION PROGRAMS RECOMMENDATIONS:
IV-1 MORE THIRD PARTY INSPECTIONS IV-2 If4 NOVA!!VE NRC INSPECTION TECHf1100ES, I.E.,
VERTICAL SLICE AND READINESS INSPECTIONS IV-3 MONITOR LICENSEE C014FORMANCE TO STANDARD INDUSTRY PRACTICES AND STANDARDS IV-4 MORE NRC VERIFICATION OF AS-BUILT QUALITY RATHER THAN OF CONSTRUCT 10t1 PROCESS IV-5 STRONGER ENFORCEMEf1T ACTION FOR CONSTRUCTION VIOLATIONS IV-6 BETTER LICENSEE ROOT-CAUSE ANALYSIS AND CORRECTIVE ACTION PROGRAMS
t LESSON V MORE AND BETTER FOCUSED RESOURCES Of4 POOR PERFORMERS AND PROBLEM AREAS RECOMMENDATIONS:
V-1 MORE FLEXIBILITY FOR NRC MANAGERS TO ALLOCATE RESOURCES V-2 ' REDUCE GENERICALLY REQUIRED INSPECTIONS Af4D REVIEWS
LESSON VI INCREASE'NRC FOLLOWUP TO ASSURE CORRECTIVE ACTION PROGRAMS REALLY ARE WORKING RECOMMENDATIONS:
VI-1 MORE NRC FOLLOWUP lilSPECTIONS VI-2 USE THIRD PARTY ll4SPECTORS FOR ONGOING Mol41TORING VI-3 FORMAL PROGRAM OF El4FORCEt4ENT ACTIONS FOR INEFFECTIVE CORRECTIVE ACTION VI-4 FORMALIZE METHODS OF NRC PAfTICIPATION IN DEVELOPMENT OF LICENSEE CORRECTIVE ACTION PROGRAMS 5
LESSON Vil POOR PERFORMANCE IN MAJOR REGULATORY PROGRAMS LIKE EQ & FIRE PROTECTION AND IN MAINTENAtlCE
& SUP'/EILLANCE ARE BOTH AN INDICATOR AND A CONSLQUENCE OF POOR LICENSEE MANAGEMENT.
NRC SHOULD MONITOR THESE AREAS CLOSELY RECOMMENDATIONS:
Vll-1 REQUIRE FORMAL LICENSEE REGULATORY TRACKING SYSTEMS Vll-2 ASSESS REGULATORY PROGRAM PERFORMAtlCE IN SALPS Vll-3 PROMPT NRC REVIEW AND INSPECT 10tl TO LICENSEE REGULATORY PROGRAM PLANS Vll-4 PROMPT NRC RESPONSE TO LICEt1SEE SUBMITTALS Vll-5 NRC PROGRESS REVIEWS AtlD INSPECTIONS OF REGULATORY PROGRAMS Vll-6 PROMPT NRC INSPECTIONS OF COMPLETION OF REGULATORY PROGRAMS l
O f
_._