ML20206R333
| ML20206R333 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 08/04/1986 |
| From: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| Shared Package | |
| ML20206R337 | List: |
| References | |
| FOIA-86-836, RTR-NUREG-1201, TASK-PII, TASK-SE SECY-86-226, NUDOCS 8609050402 | |
| Download: ML20206R333 (18) | |
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POLICY ISSUE (Information)
August 4, 1986 SECY-86-226 For: The Comissioners From: Victor Stello, Jr.
Executive Director for Operations
Subject:
STAFF ACTION PLAN FOR IMPLEMENTATION OF RECOMMENDATIONS BY THE INDEPENDENT AD H0C GROUP FOR THE DAVIS-BESSE INCIDENT (NUREG-1201)
Purpose:
To inform the Comission of the staff action plan to implement recomendations as stated in the Report of the Independent Ad Hoc Group for the Davis-Besse Incident (NUREG-1201).
Background:
The Nuclear Regulatory Comission established an Independent Ad Hoc Group in January 1986 to review both the issues subsequent to the loss of feedwater event at Davis-Besse Nuclear Power Station on June 9, 1985, and the NRC Incident Investigation Team (IIT) activities and report. The Group was asked to identify lessons to be learned from the event and IIT investigation and to make recomendations to improve NRC oversight of reactor licensees. The Group reported to the Commission on June 6, 1986.
On June 19, 1986, the Comission directed staff to review the Ad Hoc Group's report and submit to the Comission an action plan and recomendations for Comission review.
Discussion: Staff generally agrees with the recomendations of the Ad Hoc Group, but defers to the Comission any action on the -
recomendation regarding OIA involvement (Subject Area 4 Recomendation 3). In addition, staff suggests that the first recomendation in Subject Area 1 espouses a frequency and scope of effort that is impractical. That is, quarterly meetings CONTACT:
G. Holahan, ORAS 492-4410
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of Regional Administrators and Headquarters Management to review each licensee would be a large resource burden on the Agency. The current plan of less frequent meetings with priority placed on problems and problem plants is the-approach staff advocates.
In reviewing the report, staff recognized a number of activ-ties which are ongoing, which may not require any further initiatives. For those reconinendations which require new initiatives, a lead office has been designated and the action described. The Enclosure provides both the status of activities which are the subject of the reconinendations and the initiatives required to implement others.
2 Victor Stello, Jr.'
Executive Director for Operations
Enclosures:
As stated DISTRIBUTION:
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SUMMARY
TABLE OF NEW ACTION ITEMS AND LEAD OFFICES New lead Completion Recommendations
- Actions Office Date Subject Area 1
- Recommendation #1 1.1.1 Determine appropriate frequency IE 10/1/86 Management Meetings 1.1.2 Consider follow-up with licensee IE 10/1/86
- Recommendation #2 1.2.1 Consider formal system NRR 9/1/86 Project Manager Visits
- Recomendation #3 None Required Tracking System
- Recommendation #4 1.4.1 Determine need to review NRR 10/1/86 Notification of Generic Issues generic issues / specific plants Subject Area 2
- Recommendation #1 None Required Review Reliability Analyses
- Recommendation #2 None Required Performance Indicators
- Recomnendation #3 None Required Functional / Modification Inspections
- Ongoing activities relevant to each of the recommendations are discussed in the text of the Action Plan i
SUPMARY TABLE OF NEW ACTION ITEMS AND LEAD OFFICES, (CON'T.)
New lead Completion Recomendations Actions Office Date ,
i Subject Area 3
- Recommendation #1 3.1.1 Consider review of operability NRR 10/1/86 Performance-Based Requirements requirements for emergency equipment 3.1.2 NRR is lead NRR Completed
- Recomendation #2 3.2.1 Develop guidelines for meetings IE 1/1/87 Meet with Board of Directors
- Recomendation #3 None Required Optimize INP0 Programs
- Recomendation #4 None Required Integrated Living Schedules
- Recommendation #5 3.5.1 Determine after Comission IE To Be Determined Resolution of Important to Safety review and B0P Subject Area 4 .
- Recommendation #1 None Required Procedures for IITs
- Recommendation #2 None Required Participation on IITs
- Recomendation #3 Defer to Comission 01A Investigation
- Recomendation #4 None Required Role of Counsel / Advisors
- Recommendation #5 None Required IIT Training
STAFF ACTION PLAN Subject Area 1
- 1. Recomendation Regional Administrators should meet with NRC Headquarters management to review the performance of each nuclear power plant and licensee in.their region at least quarterly, or more frequently as needed. The Group strongly endorses the current plans of the Executive Director for Operations (ED0) to implement such a program. The EDO should make prompt decisions to resolve problems and to establish appropriate schedules for completing their resolution.
Ongoing Activities The April 1986 meeting of Regional Administrators and Head-quarters management was initial step to discuss performance of all plants and to identify problem plants.
Plan to continue this effort:
Lead Office: IE Next Meeting: 10/86 New Action Comment: The review of all plants and the holding of quarterly meetings is felt to be unnecessary and would be a large resource burden on the Agency.
1.1.1 Determine appropriate frequency of meetings and identification of problem plants for discussion, based on Performance Indicator Program Results.
Lead Office: IE Completion Date: 10/1/86 1.1.2 Consider options for effective follow-up actions with licensees which are identified as poor performers. Such actions would include meeting with the licensee's Chief Executive Officer and Board of Directors. (See Subject Area 3, #2)
Lead Office: IE Completion Date: 10/1/86
- 2. Recommendation Project Managers (with appropriate technical support) should visit nuclear power plants on a periodic basis (perhaps quarterly) to comunicate directly with plant management and utility licensing officers.
2 (Subject Area 1, Can't..)
Ongoing Activities One of the goals of reorganization of NRR was to enhance familiarity of plants by the PMs through increased frequency of visits.
Discussions with plant management are included when appropriate.
Technical support is provided when issues require such, e.g., 50.59 reviews.
Lead Office: NRR New Action 1.2.1 Consider whether or not a formal system is needed to ensure frequent visits and if travel budget considerations need modifying. Visits will be coordinated with Regional management to minimize a resource burden on the Region and ensure effective coordination between Headquarters and the Region.
Lead Office: NRR Completion Date: 9/1/86 8
- 3. Recommendation The Group strongly endorses the ED0's current development and implementation of the integrated tracking and management system to assure effective manage-ment monitoring and resolution of safety and licensing issues. Such a system might have been of assistance prior to the 1985 incident at Davis-Besse.
Ongoing Activities Requirements analysis is completed and prototype of Generic Issue Management System (GIMS) has been demonstrated. Now in process of developing the tracking system of both generic issues and plant-specific licensing actions, called Safety Issue Management System (SIMS)(subsumingGIMS). The expanded system will not be fully operable until all data is in and verification by NRC if licensee ,
implementation of requirements is completed.
- 4. Recomendation f
(- The staff should decide and communicate the results of decisions to l relevant staf' and licensees promptly as to whether an issue is plant-l_ specific or gt aeric. Such decisions should be made or endorsed by the-EDO and action plans should be promulgated and executed expeditiously.
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3 (Subject Area 1, Con't.).
Ongoing Activities Comment: The new safety issues management system described above will enhance these existing mechanisms.
Mechanism is in place now to notify licensees of Generic Issues through issuance of Generic Letters and updated revisions of NUREG-0933, "Prioritization of Generic Issues".
Current practice in investigating events includes identification of generic implications and notification of licensees and/or vendors for followup (e.g., assessment of B&W design).
Lead Office: NRR New Action 1.4.1 Determine whether there is a need to review generic issues status in order to identify plants with significant safety problems which are on hold awaiting the resolution of generic issues.
Lead Office: NRR Completion Date: 10/1/86 Subject Area 2
- 1. Recommendation NRC should establish a timely and effective process to review reliability analyses requested of licensees, particularly where it is determined that such analyses will be used in regulatory. decision making.
Ongoing Activity The CRGR Charter (Rev. 2) requires that the staff provide the schedule for use of information requested of licensees in connection with proposed new generic actions.
Existing program office procedures for control of plant-specific i backfits require that the staff consider the schedule for use l of information requested of licensees in connection with licensing actions imposed.
Continue efforts to prioritize the order in which plant-specific licensing actions are completed using cost / benefit analyses and l .
risk and reliability methods where applicable (in response to Commission Planning Guidance item A-14).
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4 (Subject Area 2, Con't.)
Development of the concept and implementation plan for more fully integrated evaluations of nuclear plant systems, balancing safety benefits of specific regulatory actions and potential impacts on interacting systems, has been initiated.
This plan will include guidance for the review and incorporation of reliability analysis.
Lead Office: NRR Final Implementation Plan: 2/87
- 2. Recommendation NRC should evaluate the use of qualitative management and reliability disciplines as a means of increasing confidence in the day-to-day performance of nuclear power plant licensees.
Ongoing Activities Such disciplines are considered in the now-developing Performance Indicator Program.
Lead Office: IE Recomend a minimum set of Performance Indicators: 10/86 The Operational Safety Reliability Research Program has use'd failure modes and effects analysis to develop a new technique of reliability-centered surveillance as a means to improve effectiveness of identifying potential blind spots in surveillance testing.
RES has developed an approach to the problem of regulatory implementation of reliability programs. The thrust of the approach is to put the burden of safety more on the licensees, and would require adoption of a performance-based regulatory policy.
l Lead Office: RES Draft paper for coment: 7/86
- 3. Recommendation IE should give priority to the conduct and promotion of safety system functional inspections and cutage system modification inspections.
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5 (Subject Area 3, Con't.)
Ongoing Activities The innovative inspection approaches (Safety System Functional Inspections, SSFI, and Safety System Outage Modification Inspections, SSOMI) are at the latter stages of development.
Pilot inspections have been conducted by Headquarters and Regional staff; methods have been provided to the Regions for comment. These approaches will be assimilated into the Regional inspection programs as they are refined and resources permit. The five-year plan calls for sufficient resources for full integration by the end of FY 88.
4 Lead Office: IE Full Integration: End of FY 88 Subject Area 3
- 1. -Recommendation The NRC should shift emphasis away from detailed, prescriptive requirements toward performance-based requirements. A systematic, continuing review of NRC's regulatory requirements embodying the full scope of regulatory oversight is needed to ensure th:t these requirements are coherent, consistent, and act to improve pl6nt safety.- Responsibility for this l function should be assigned to a specific office.
l l Ongoing Activities t
l This is current NRC policy, as articulated in PPG 1986 (NUREG-0585).
[ Training and maintenance programs are approached this way.
L The Technical Specification Improvement Group is focused on eliminating unnecessary requirements from Tech. Specs. A policy paper is being developed to define the scope and purpose of Technical Specifications.
l Lead Office: NRR Policy paper to be l
t forwarded to Commission: 8/86 Development of the concept and implementation plan for more fully integrated evaluations of nuclear plant systems, balancing safety benefits of specific regulatory actions and potential impacts on -
interacting systems, has been initiated.
l Lead Office: NRR Final Implementation Plan: 2/87 l
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The ELR (Effectiveness of Regulatory Requirements in Limiting Risk) program is a program to examine risk-limitation effectiveness of regulations.
Lead Office: RES Paper on status and future efforts of the program to go to Comission: 8/86 The PETS (Procedures for Evaluating Technical Specifications) program is designed to develop tools for evaluating the risk reduction effectiveness of existing and proposed new Technical Specification requirements. Final technical guides and software for analysis and review of allowed outage times, surveillance test intervals, and action statement risk will be completed by 9/87. In addition, criteria for proposing modifications and acceptability of submittals will be completed.
Lead Office: RES Completion Date: 9/87 Following EDO approval, an interoffice working group will be formed to report on the feasibility of an approach to performance-based regulation developed under the Operational Safety Reliability Research Program.
Lead Office: RES Report Due: 9/87 New Action 3.1.1 Consider the need to review operability requirements and compensatory measures during outage of equipment relied on in emergency procedures.
Lead Office: NRR Completion Date: 10/1/86 3.1.2 NRR is designated to coordinate agency-wide effort.
- 2. Recomendation NRR management and Regional Administrators should meet with the licensee's Board of Directors when a plant's deteriorating performance warrants. The purpose of such meetings would be to discuss the adequacy of the licensee's activities to protect the health and safety of the public. It would also provide the Board with an opportunity to express its views on the effectiveness of the current regulatory process.
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.(Subject Area 3, Con't.)
Ongoing Activities The identification of programs to effectuate licensee improvements is part of the SALP and Performance Indicator Programs, which include the involvement of senior NRC management with licensee management.
Lead Office: IE New Action 3.2.1 Develop criteria and guidelines to determine when a Chief Executive Officer and subsequently the Board of Directors should be informed by the NRC of the problems.
Lead Office: IE Completion Date: 1/1/87
- 3. Recommendation NRC should take advantage of INP0's programs to assess licensee's maintenance management programs to the extent reasonable and practical.
Ongoing Activities Currently being done as Phase II of the Maintenance and Surveillance Program; reviewing INP0 maintenance guidelines as well as considering training and accreditation with INP0.
Lead Office: NRR Interim report on the status of maintenance in the industry: 7/87
- 4. Recommendation The staff should improve its followup on licensee corrective actions.
Licensee " integrated living schedules" should be encouraged.
Ongoing Activities The Safety Issue Management System (SIMS) is an effort by the NRC to expedite followup on licensee corrective actions .for generic and plant-specific issues. (See discussion under Subject Area 1, Recommendation #3)
. ^
8 (Subject Area 3, Con't.)
x Integrated Living Schedules as formally structured have been encouraged, but volunteers have been few. Rather, less formal de facto living schedules have been evolving'as a result of frequent Project Manager / licensee interface to resolve ongoing regulatory issues. The staff is curtwntly preparing a policy statement on Integrated Schedules using input from the industry.
Lead Office: NRR Policy paper to go to Comission: 10/85
- 5. Recommendation Resolution of the "important to safety" issue, and its application to -
balance of plant (BOP) items in existing, as well as future plants, -
deserves high priority. (The Group understands that I&E has responsibility [
for resolution of at least part of this problem.)
Ongoing Activities Position paper currently before Comission requesting approval of Important-to-Safety definitions and of a proposed standard which should apply to such equipment prior to initiating rulemaking.
Staff is examining coverage of BOP in current inspection program for potential need to expand inspection coverage.
Lead Office: IE New Action 3.5.1 Actions on ITS rulemaking to be determined after Comission review of paper on Important-to-Safety definitions. Staff is examining B0P issues. Report to go to the Comission on NRC efforts related to B0P, October 1986.
Lead Offices: IE/NRR Completion Date: To be determined Subject Area 4
- 1. Recomendation Expedite the development of detailed procedures for the formation, training, operation, and reporting requirements of future IITs. These procedures should clearly define the (a) scope of the investigation and its schedule; (b) mode of operation for the team; (c) legal constraints and rights of licensees.and employees, including NRC employees; (d) quaran-tining of equipment, with clearly defined roles for the licensee and the
__ _ . . ]
9 (Subject Area 4, Con't.)
Region; and (e) completion of the assignment. These procedures should be developed and coordinated with the nuclear power industry and Agency personnel should meet with them to explain the role of IITs and how they will function.
Ongoing Activities Detailed procedures for the formation, training, operation and reporting requirements for future Incident Investigation Teams (IITs) are addressed in Draft IIT procedures. Industry, utility, and NRC staff review and comments will be coordinated before finalizing.
Lead Office: AE00 Final Procedures: 12/86 Detailed administrative procedures for implementing IITs are in place and are part of the training curriculum for the IIT training course which started in July, 1986.
Lead Office: AE0D
- 2. Recommendation Participation on IITs of members from INPO, EPRI, vendors, other utilities, and Federal and State agencies with applicable technical expertise, when appropriate, should be encouraged.
Ongoing Activities Participation by non-NRC organizations in future IIT investigations is a goal for the Incident Investigation Program.
NRC will solicit participation as part of the industry review and comments of the draft IIT procedures. When and if anyone indicates an interest in participating, the necessary agreement will be negotiated.
l Lead Office: AEOD Connent: Although outside participation may be appropriate, the process should not jeopardize the independence of the NRC's decision making for corrective actions, and industry partici-pation should not compromise the independence or the perceived independence of the IIT from the affected utility and vendor.
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.(Subject Area 4, Con't.)
- 3. Recommendation
'The Commission should assign NRC's Office of Inspector and Auditor (OIA) to investigate pre-event interaction between the NRC staff and the
. licensee as it may be relevant to the root cause of the event.
Comment: One of the objectives of the-Incident Investigation Program is that the investigation of significant operational events would be conducted by a single team having no significant .
prior involvement with the facility. The draft NRC Manual Chapter NRC-0513, defines a principal objective of the Incident Investigation Program as "to improve regulatory '
_ oversight of licensee activities by uncovering facts that could show whether the regulatory process prior to the event contributed directly to the cause or course of the event."
The issue of who should conduct this evaluation was considered
, during the development of the Manual Chapter. In addressing i this issue, a number of alternate approaches were considered.
For example, consideration was organization (specifically OIA)given .
to relying However, OIAon hasanother indicated that it does not have the resources to accomplish an invest-igation on a time frame consistent the IIT investigation.
Given the available IIT resources and schedule limitation, the IIT leader may recomend to the EDO areas requiring further investigation or followup by other organizations (e.g., 0IA or 01).
[ Although staff believes that the IIT is capable, based on its l knowledge of the operational event, of identifying and eval-l uating relevant areas of the regulatory process, the staff
! defers to the Commission on this recomendation.
4.- Recommendation
(
The NRC manual chapter and otNi appropriate procedures should specify guidelines concerning the role o counsel or other advisors for personnel interviewed by an IIT.
Ongoing Activities This has been incorporated into IIT procedures.
The IIT training course curriculum covers these issues.
Lead Office: AE00 l
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37 (Subject Area 4', Con't.)
- 5. Recommendation The IIT incident investigation training program should be accelerated and consideration given to extending some of this training to Augmented Inspection Team candidates and other I&E staff members.
Ongoing Activities
- - This is addressed in the IIT procedures.
- The first IIT training course was held July 7-18, 1986.
IIT members may be used on AITs. The IIT roster t.as been provided to NRC Program Office Directors and Regional Administrators for possible use in selecting AIT members.
Lead Office: AE0D Next IIT training course: 1987
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C13-7es-2264 December 3, 1986 CD-LIS-86-1217 Project 1816 Director FREEDOM OF INFORMAnon ACT REOUESY Division of Rules and Records Fo.TA 236 W$higo D.C. 20555 M'i-~8b
Dear Sir:
This is a Freedom of Information Act request for the following documents to be placed in the Public Document Room:
- 1. SECY 86-226 dated August 4, 1986 " Staff Action plan for implementation of recommendations by the independant ad-hoc group for Davis-Besse.
If clarification is needed, please call me at (813) 796-2264. Thank you for your assistance.
Sincerel ,
Mike Jo nson Licensing Engineer Licensing Information Service MJ/hz A Ha!!iburton Company
A NUS .
CORPORATION
$Ei2EwT [a".k"8a5c E EN"foso C13-796 2264 December 3, 1986 CD-LIS-86-1217 Project 1816 FREEDOM OF INFORMATION ACT RE v s on of Rules and Records U.S. N.R.C.
Fo.TA -hUEST6-23(o Washington, D.C. 20555 (M4 g /g, g,g
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Dear Sir:
This is a Freedom of Information Act request for the following documents to be placed in the Public Document Room:
- 1. SECY 86-226 dated August 4, 1986 " Staff Action plan for implementation of reconnendations by the independant ad-hoc group for Davis-Besse.
If clarification is needed, please call me at (813) 796-2264. Thank you for your assistance.
Sincerel ,
Mike Jo nson Licensing Engineer Licensing Information Service MJ/hz h A Haniburton Company
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