ML20195F164
| ML20195F164 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/05/1986 |
| From: | Ferraro N DATA DESIGN LABORATORIES |
| To: | Russell W Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8606090404 | |
| Download: ML20195F164 (2) | |
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(714) 987 2911 P.O. Bo x,11 D ATA-D ESIG N Laboratories f
7925 CENTER AVENUE CUC AMONGA, CALIFORNI A 91730 5 June 1986 U. S. Nuclear Regulatory Commission Washington, D.C.
20555 Attention:
Mr. W. Russell, Director Division of Human Factors Technology, NRR
Dear Bill:
Thank you very much for the opportunity to meet with you and discuss the various aspects of the Nuclear Utilities Training Programs.
As you recall, we both agreed that Chernobyl will certainly increase the pressures on the Utilities to provide airtight designs, operating procedures, analysis and feedback in order to assure that a Chernobyl does not occur in the United States.
Certainly, such an occurrence would devastate the great progress made in the development of nuclear utilities, and certainly raise the question of the effectiveness of all the current oversight processes.
As I stated to you, the scope of liabilities and national implications involved in each and every one of those nuclear utilities is far beyond that of other corporation and type of work in the United States, with the possible exception of chemicals production.
I personally believe that, if not a directed independent audit on an annual basis of such utilities, an independent self audit would be the prudent thing to do by the individual utilities' senior executives. The price of mistakes is too high to expect the 15-month INPO reviews and every four years re-accreditation process to provide a realistic assessment of day-to-day practices.
The accreditation and re-accreditation process is an essential safeguard; but they act as specific point in time milestones that must be met.
Independent surprise operational process reviews might better identify, for management, everyday issues whf ch may be masked during known and expected inspections.
Certainly, the fiducicry responsibilities to shareholders that are protected by the annual audits of the major accounting houses pale against the responsibilities to, not only shareholders, but citizens, community members, and tax,ayers of our country, inherent in the proper operations of our nation's nuclear utilities.
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g Page 2 I thought your points regarding better analysis of root causes for problems that are reported to NRC should be a crucial element of an overall assessment program that provides for not only the review and analysis of the effective-ness of procedures, programs and practices, but of a feedback system to assure that established processes, procedures and practices are continuously updated as a part of an ongoing refinement process.
We are looking forward to commencing work on the Three Mile Island follow-up audit in the near future.
We are confident that the quality of our performance will permit us to provide such services to the industry as a whole.
Again, thank you for your courtesies and time.
Very truly yours, DATA-DES GN LABO TORIES gll, NOW DM Niel P. Ferraro, USN (Ret.)
Vice President NPF/ew