ML20205D654
| ML20205D654 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse, Grand Gulf, 05000000 |
| Issue date: | 01/29/1986 |
| From: | Helmetes C, Heltemes C NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD) |
| To: | Rehm T NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20205D576 | List: |
| References | |
| FOIA-86-126, FOIA-86-127, FOIA-86-131, FOIA-86-166, FOIA-86-201, FOIA-86-209, FOIA-86-263, FOIA-86-80, FOIA-86-82, RTR-NUREG-0090, RTR-NUREG-90 NUDOCS 8608180128 | |
| Download: ML20205D654 (2) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION o
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WASHINGTON, D. C. 20555 January 29, 1956 j,
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NOTE T0:
T. A. Rehm Assistant for Operations, EDO l
FROM:
C. J. Heltemes, Jr., Director Office for Analysis and Evaluation of Operational Data In response to Mr. Stello's question, the Commission policy statement on l
abnormal occurrence reporting includes major deficiencies in management controls as reportable events.
(In this regard, see Item 3, second paragraph on page 27 and Item 11 on page 28 in Appendix A - Abnormal Occurrence Criteria.)
l There have been a number of events reported under this criterion (see the l
attached guidance to staff) on the application of the A0 criteria and examples.
l Recent events reported as A0s using deficiencies in management controls as the I
basis are:
l 85-6 Significant Deficiencies in Reactor Operator. Training and Material False Statements (Grand Gulf) 85-7 Loss of Main and Auxiliary Feedwater Systems (Davis-Besse)
These were approved by the Comission.
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$.QTnf jJ. & '. %
temes, Jr., Director fi e f>.
Analysis and Evaluation J Da, ational Data
Attachment:
As stated I
81 8 860725 j
h GARDE 86-80 PDR
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'o 4.2.1.11 Example A-11:
" Serious deficiency in management or procedural con-(
trols in major areas."
A0s Reported 76-15, 77-4, 77-7, AS78-2, 79-7, AS79-1, 80-5, 80-8, 80-9, 82-3, 83-2, 83-7, 83-8, 83-9.
Discussion Administrative controls relating to organization and management, procedures, recordkeeping, review and audit, and information reporting are viewed by the NRC to form one of the levels of the defense-in-depth for the protection of the public health and safety.
The following is generally assessed in determining whether events involving management or procedural control deficiencies should be reported as A0s.
(1) The safety significance of the deficiencies.
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(2) The prevalence and the degree of management or procedural contrni deficien-cies involved (were the problems in one area or several major areas of licensed activity; were the deficiencies repetitive in nature; were the deficiencies primarily management or procedural. control problems; etc.).
C-(3) The degree of importance placed on the events by the NRC (usually evidenced e,i by significant licensing or escalated enforcement action).
(4) The licensee's response.
(5) The resolution of differences between the NRC and the licensee.
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The intent is to report instances where one or more deficiencies in management performance or procedural controls have been judged to be a major safety con-cern (see Glossary).
Sometimes, the circumstances may involve a history of inadequate performance in several areas such as plant operations, health physics, quality assurance, or compliance with NRC requirements. A history of serious items of noncompliance, or of one or more events with serious actual or poten-tial safety consequences, provides the bases for the judgment. The determina-tion is also usually supported by (1) an escalated NRC action such as, issuance of an order or other elevated enforcement action, (2) an outside agency is brought in to assess the licensee's management or procedural structure, or (3) a licensee response including significant personnel or organizational changes, or priority program revisions such as major rewrite of procedures or change in company policy.
k 32 December 14, 1984
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