Text

Transcript of ACRS Regional & Insp & Enforcement Programs Subcommittee 870312 Meeting in Washington,Dc.Pp 1-136. Related Documentation Encl
	ML20212Q057
Person / Time
Issue date:	03/12/1987
From:	; Advisory Committee on Reactor Safeguards
To:	;
References
	ACRS-T-1577, NUDOCS 8703170287
	Download: ML20212Q057 (195)
	v • d • e

{{#Wiki_filter:08RS 7~-/577 c UlN11ED STATES ge NUCLEAR REGULATORY COMMISSION IN THE MATTER OF: DOCKET NO: ADVISORY COMMITTEE ON REACTOR SAFEGUARDS REGIONAL AND I&E PROGRAMS SUBCOMMITTEE Ov LOCATION: WASHINGTON, D. C. PAGES: 1 - 136 DATE: THURSDAY, MARCH 12, 1987 s k$[13OEElOE00EY -. yter@VB T0m ACRS0!! ice .0 ACE-FEDERAL REPORTERS, INC. Ofic:al Reporters 444 North Capitol Street Washington, D.C. 20001 (202) 347-3700 870312 9703170287 CRS PDR NATIONWIDE COVERAGE g9

() PUBLIC NOTICE BY THE UNITED STATES NUCLEAR REGULATORY COMMI!iSIONERS' ADVISORY-COMMITTEE ON REACTOR SAFEGUARDS THURSDAY, MARCH 12, 1987 The contents of this stenographic transcript of the proceedings of the United States Nuclear Regulatory Commission's Advisory Committee on Reactor Safeguards (ACRS), as reported herein, is an uncorrected record of the discussions recorded at the mee, ting held on the above date. No member of the ACRS Staff and no participant at. ( this meeting accepts any responsibility fo.r errors or inaccuracies of statement or data contained in this transcript. i

CR30166.0~ 1

BRT/sjg_

1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4 REGIONAL AND I&E PROGRAMS SUBCOMMITTEE 5 Nuclear Regulatory Commission Room 1046 6 1717 H Street, N.W. Washington, D. C. 8 Thursday, March 12, 1987 9-The subcommittee meeting convened at 8:30 a.m., Carlyle 10 Michelson presiding. 11 ACRS MEMBERS PRESENT: g ( 13 MR. CARLYLE MICHELSON 14 MR. GLENN A. REED 15 MR. CHARLES J. WYLIE 16 DR. FORREST J. REMICK 17 18 19 20 21 22 23 24 25 ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-66 4

30166.0 2. BRT .rx -1'~') = 1 P R,0,C,E E, D I, N G_ S 2 liR. MICHELSON: Th'e' meeting will now come to 3 order. This is a meeting of the Advisory Committee on 4-LReactor Safeguards Subcommittee on Regional'and I&E 5 Programs. 6 I'm Carl Michelson, acting Subcommittee chairman. '7 Dr. Remick ha'd to be down to Congress this 8 morning to testify. Perhaps he'll be back before the end 9 of the morning, but, at any rate I'll fill in for him as 10 best I can until -- for this particular_ meeting. Other 11 members in attendance are Glenn Reed and Charlie Wylie..We 12 are most happy to see Glenn back, I hope.he makes out all () 13 right on this and we can see more of him. 14 The purpose of this meeting is to continue 15 review of the activities under the purview of the I&E 16 headquarters office.. Paul Boehnert.is the cognizant ACRS 17 Staff member for this meeting. The rules _for participation 18 in this meeting have been been announced as a part of the 19 notice of this meeting previously published in the Federal 20 Register on February 25, 1987. 21 A transcript of the meeting is being kept and 22 will be made available as stated in the Federal Register 23 notice. It is requested that each speaker first identify 24 himself or herself and speak with sufficient clarity and 25 volume so that he or she can be readily heard. ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6

30166.0 3 ERT ( l The purposes -- as I said, the purpose is to 2 continue the meeting which we had last August? 3 MR. BOEHNERT: Yes. 4 MR. REED: August 13th, and this is the 13 -- 5 Friday. 6 MR. BOEHNERT: Tomorrow. 7 MR. MICHELSON: There must be a message there 8 somewhere. 9 The focus of today's activities are to pick up 10 those things that we did not have time to cover in the 11 meetings last August. As I recall that meeting was to be 12 followed by a meeting in November. This is a postponement ,m (_) 13 of.the meeting that we had intended to have, to meet with 14 you in November. 15 You are aware, of course, of the announced NRC 16 reorganization which will abolish I&E, and we expect to 17 hear a little more from that in the program this morning. 18 MR. REED: I would like to make a correction. 19 It was August 14th, 20 MR. MICHELSON: It was the 14th. Okay. But 21 close. 22 We also expect to hear about activities in -- 23 through other important areas, OA, technical training and 24 enforcement. Also on the agenda is the performance 25 indicator program, which the full Committee has a ) v ACE FEDERAL REPORTERS, INC. j 202-347-3700 Nationwide Coverage 800-336-6616

30166.0 4 BRT t ' (3 1 particular interest in. We are looking forward to hearing -2 more about this important work. 3 At the end of the meeting we will discuss your 4 possible support of the April full Committee meeting. 5 There has been one small change-in the schedule, 6 .as I understand. The item D., the enforcement program, 7 will be moved to coming right after the introductory 8 remarks by I&E; in other words, first on the formal 9 presentation part of the program. Other than -- I believe 10 we are ready. 11 Ed Jordan, I guess? 12 MR. JORDAN: Jim Partlow will. 'Q s7 13 MR. MICHELSON: Mr. Partlow, then, I guess will 14 take care of introducing each speaker and telling you where 15 we are at and what we are headed for. Very good then, Jim, 16 if you will, I'd appreciate it. 17 MR. PARTLOW: Good morning, I'm Jim Partlow, a 18 division director in the current office of inspection and 19 enforcement. I believe, Mr. Chairman, with that summary 20 we'll launch right into the agenda with some comments on 21 the pending reorganizat.)n. With me are Ed Jordan and 22 Brian Grimes, division directors in I&E, and Bill Beach, 23 the head of the enforcement staff. So we have here the 24 principal players for the current IE organization. 25 What I want -- the way I want to approach this O ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646 L

130166.0 -5

BRT

(

5-

~'

1

with you is to talk about the functions that have

.2 . traditionally been carried out in the office of inspection 3 and enforcement and to talk about where those functions 4 . will lie in the new organization in the middle of April. 5 When we approached this whole reorganization E6 business, down to the branch and section level, we wrote 7 down what is it that we do that contributes to the 8 regulatory program, made those up in the lists and then 9 tried to, rather methodically, ensure that those functions, 10 if they were important to keep, were kept someplace in the 11 new organization. 12 The overwhelming majority of those functions, of p) (, 13 course, are going either to NRR or to'the -- or to AEOD, 14 where Ed Jordan is the prospective office director. Those 15 functions that have to do with fuel facilities and material 16 safety are being transferred to NMSS. 17 With that, let me approach this by our major 18 functions and current divisions and talk about where some .19 of these functions are going. First, of course, 20 enforcement. Bill Beach, you can climb in at any time, 21 please. The current enforcement staff is staying 4 22 essentially intact and will move and become an office of 23 enforcement and, under Jim Lieberman, the prospective 24 office director, and will report right into the deputy EDO. 25 So that function should continue to act pretty much as it O ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646

30166.0 6 .. RT l 1 has before, although there, of course, are always plans to 2 improve it, and Bill will talk about that later. But the 3 enforcement function will be reporting in to Jim Taylor, 4 who is also the manager to whom the regional administrators 5 will report. 6 Ed Jordan's current division of emergency 7 preparedness and engineering response. The four branches 8 there are splitting into places in NRR 13 and into AEOD. 9 For example, emergency preparedness. That is moving to a 10 new NRR division of radiation protection and emergency 11 preparedness, and that's under Dr. Frank Congel in the new 12 NRR organizatio. () 13 I might note in that title, also, the division 14 of radiation protection and emergency preparedness, there 15 is now a new branch level dedicated to radiation protection. 16 It is something that was not, perhaps, well maintained as 17 an organizational unit before, but that is being returned. 18 There will be a branch of professionals, dedicated to 19 radiation protection matters. 20 The business of events analysis that -- the 21 daily work that is done by Ed's people in events analysis 22 is being maintained in a new division of operations events 23 assessment. The division of operations events assessments, 24 that will be under Ernie Rossi, who served previously in IE 25 under Ed as the chief of the events analysis branch. Yes? _) ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 800-336-6646

= ~ 30166.0 7 BRT-t 4 ^' 1 MR. BEACH:- If that organization includes 2 examining --'there is a combination there. 3 MR. MICHELSON: Where will it be located? 4 MR. BEACH: The current branch. 5 MR. PARTLOW: There is a' branch in the new NRR 6 dedicated to generic communications. The operations center, 7 under Ken Perkins, who manages the agency's incident 8 response and operations of the center is moving over and 9 will stay with Ed Jordan in AEOD. 10 Does that basically cover your current areas and 11 where you are expected to go? 12 MR. JORDAN: Training -- -h i j 13-MR. PARTLOW: I was going to get to that a 14 little bit later on. 15 MR. MICHELSON: You will keep the response 16 center? 17 MR. JORDAN: Yes, until the second building is 18 constructed. 19 MR. MICHELSON: Does this mean that you will 20 move your office to -- 21 MR. JORDAN: AEOD will move'into the Maryland 22 National Bank building when everybody else moves. 23 MR. REED: I'm trying to figure out whether this 24-is a splitting asunder of a cohesive unit or the putting 25 together of cohesive units. I'm just wondering if _ s %_J ' ACE FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 800-336-6M6

30166.0 8 ERT J t' ~ 1 something -- you know, when you reorganize, I guess the 2 purpose is to come out with either an integrated, put 3 together operation or disseminated situation. Quite 4 frankly, I wonder if some things that might be very 5 important might not be able to communicate to come up with 6 policy and philosophy in the future. I recall, at some of 7 our meetings there were presentations from a young lady, I 8 believe, concerning moving forward with respect to 9 relationships with licensees, where some of the 10 adversarialism was going to be reduced and I&E would, 11 perhaps, have policy to improve the relationships with 12 licensees. (_) 13 Where did that function go, which I thought was 14 a good function? You know, Al always felt in the I&E 15 operations that the resident inspector and senior resident 16 inspectors were really the key and heart of the situation 17 because they are right at the beating heart. I shouldn't 18 be talking about those things. 19 It always appeared to me that the resident 20 inspectors weren't really getting enough input and that 21 from them did not flow upward to the top, the building of 22 sound I&E activities. 23 In this reorganization that you are talking 24 about, have you lost this looking at your effectiveness and 25 your communications and your development with respect to n) tx,s ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646

v.

3' ! 30166.0 9 -BRT: f); 1 the licensee? Is it split asunder?- -2 MR. PARTLOW: -Well,-I1 don't.know. JWe'll see s ' 13 - 1what.happens.in the new organization. 4 In terms of communication with the Llicensee, I 5 think:probably that's one:of the-things-the reorganization 6 is about. 7 ILthink.there is heavy emphasis in this 8 reorganization in NRR on'what we-call the' project 4 9. . management side where Frank Morely will be an associate 10 director for project management and'where.the whole project 11 management is oriented towards individual. utilities by NRC I'- 12 Region. So, in other words, there's an organization and a '( ) 71 3 grou'p of LPMs, project directors that are dedicated to-the t- ~14 l'icensees-in Region 1, and a group to the licensees in, 15 Region' 2, and so'forth. 16 I think that that organization is going to be '17 .the primary-focal point for how the communication.goes with ~ 18 those utilities. 19 So, to the extent that it is now sort of focused 20 that way, I would hope that it would improve. 21 Reducing the adversarial relationship, that's l' 22 not on the organization chart anyplace. It is a matter I-l 23 that was started by IE in the ANS last fall, with an l 24 executive session that was rather successful in sitting

25 down and having candid communications with each other about

,lG- /~T 1 ACE. FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6 e

'30166.0 10 CRT ff. 1 people and how we view performance and so forth. That-has 2 not been. dropped. '3 As a matter of fact, it is a high -- item of .4 high interest with Chairman Zech and we are going' to 5 continue those kinds of workshops. We are trying to get a 6 week right now in October of.this next -- '87, to do one of 7 those, again, and to follow it by five regional workshops 8 on communicating with each other. It just happens to be a 9 function that happened to be with me at the -- in the old 10 organization and I'm keeping it in my new role in the new 11 organization. 12 If we could shift now, with Brian Grimes, in the 3' j 13 current-division of quality assurance, vendor and technical '14 training. Those functions all have a good home in the new 15 organization. 16 The-division of quality assurance goes into a 17 new division in NRR called the division of licensee 18 performance and quality evaluation. The division of 19 licensee performance and quality evaluation. That will'be 20 under Bill Russell. 21. I think that may be a pretty good marriage there 22 in bringing together the ongoing work under Bill Russell in 23 the human factors area together with this quality assurance I 24 branch from IE, together with another branch, I believe, on 25 the organization called the licensee performance evaluation () ) ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646 _~

c 30166.0 11 'BRT ,n (l-1 branch. 2 .The. vendor inspection program, under Brian, is 3 moving: to a new NRR division called the division of 4 inspection'and safeguards, and I will have that division. 5 I'll talk-about that a little bit later.on,:but it is 6 somewhat a focusing of the headquarters routine or reactive -- 7 some of the reactive inspection : work for NRR. 8 The vendor will be at branch in that new 9 inspection division. 10 The technical training center, and of course Ken 11 Raglin, the director, is here, and he'll be talking to you 12 about that a little later on. That will move over and () 13 report to'Ed Jordan in AEOD, intact. 14 The third current division, the division of 15 inspection programs, the one that I have now; one part of 16 that, of course, has been administration of the inspection 17 program and policy and so forth, fuel facilities and 18 materials. That function moves over and blends into the NMSS 19 organization. 20 Another traditional function of that division 21 has been our headquarters' direct inspection efforts.

Here, 22 of course, you are familiar with the acronyms of the PAT 23 teams, the CAT teams, SSFIs and so forth.

24 MR. JORDAN: You shouldn't say that. 25 MR. PARTLOW: Oh, I'm sorry. ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6686

30166.0:

12 LBRT-11 MR. R'EED:

A' joke. ~' 2 MR. PARTLOW: That' function will. continue in a 3 branch' called the special inspections branch. It's also an ~ 4 intent of Tom Merley here that this branch. provide'the 5 coordination and leadership for a variety of inspection 6 activities that-might take place out of headquarters. In 7 other words, ad hoc or topical inspections, as opposed to more en'uring programs like PAT and so forth. d 8 9 But now, here, when for some reason NRR believes 10 it's necessary to conduct some kind of inspection, and it 'll needs technical people from the various branches in NRR, it 12 -would be this division and this special inspection branch /'s (_j '13 that would bring that together and turn it into an 14 inspection-like activity. 15 MR. MICHELSON: Ad hoc inspection teams, also? 16 MR. PARTLOW: Yes. 17 MR. MICHELSON: The IIT, is that also in AEOD? 18 MR. PARTLOW: I was going to say reactive 19 inspections, still in AEOD under Ed Jordan is inspection of 20 the IIT. In addition, they are to develop and execute an 21 additional inspection activity that, I guess we can call it 22 diagnostic, but it would be a team that would be used -- 23 plants that we think are having operational performance 24 problems. 25 Based upon the regional inspections and all the O /\\CE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6

30166.0 13 BRT.- -t c '~' 11 information'we have-together,.we are not sure we have our ~ 2

armsLaround~what the prob 1em is.

Ed Jordan would bring 3 .togethtr special teams to go out:and do a rather expansive <4 operational assessment. 5 MR. REED: Is that a prescribed program yet? 6 MR. JORDAN: It's not-proceduralized yet, but it 7 will be. 8 MR. MICHELSON: If we want to hear about it 9 later, AEOD is the place? 10 MR.-JORDAN: Yes. 11 MR. PARTLOW: The division of inspection 12 programs.. Together-with our program support staff under p) (, 13 Jim Blaha, has been the general matter of inspection. policy 14 procedures, programs,'that kind of thing, providing the 15 1 guidance, the instruction, the policy to the field in the 16 ' interest of uniformity, completeness and so forth. How 17 much inspection, when, the budget, policy on whether to 18 increase or decrease health physics inspection. Those 19 kinds of things. 20 The main keeper of that kind of information is I 21 going to be in a new staff, not a division but in a staff 22 in NRR called program management, policy development and 23 analysis staff. The SES director has not yet been named, i 24 Jim Sniezek is really acting in that role. But there is a 25 branch there that is to be dedicated to the integration of G i ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6

1 30166.0. 14

CRT

,~ 1 our licensing-or requirements policy and our inspection 2 policy. 3 There's'another branch there that is to-be 4 dedicated to the integration of our research, working with 5 our licensing or requirements policy and with our 6 inspection policy. That work is going to be under Fred 7 Hebdon, who is currently deputy director of AEOD. 8 So, that is the place, there, with Fred Hebdon, 9 together with, I believe, Jim Blaha and Jesse Funches; it 10 is oversimplistic to say they will be the keepers of the IE 11 manual and keepers of the standard review plan, but that's 12 the place'that will keep all of that together and keep some ()~ 13 rhyme or reason to it. 14 The new policies, the new programs, the new 15 procedures for inspection or for review in the standard 16 review-plan will probably come from the other line 17 divisions that are listed there. 18 As an example, in my new division of inspection 19 and safeguards, I have the reactor security program. Just 20 using this as an example, I think I will be a rather heavy 21 inputter into Fred Hebdon on what the inspection program 22 ought to look like for security at reactors. 23 That covers the basic functions that I wanted to 24 talk about. I'd be happy to answer any questions as best l 25 we can. /\\CEJFEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6

-30166.0-15

ERT l

MR. MICHELSON:- I think you said that Fred would '2 have the. standard review plan as a part of what he keeps up-3 with? 4 MR. PARTLOW: Yes. 5 MR. MICHELSON: So, anybody that wants a change 6 or whatever -- if you want to change a: standard review plan, 7 I guess there are still some -- there's still some other 8 office that generates the change? It isn't originated now 9 with Fred, is it? 10 MR. PARTLOW: I don't know I can speak too 11 authoritatively on this, but I suspect, if Frank Congel 12 in emergency preparedness or radiation protection really p) (, 13 believes something needs to be changed in that plan, he's 14 going to be the one that's going to start -- that's going 15 to start that process and going to take Fred Hebdon about 16 60 percent of the way towards -- you'know, what it ought to 17 look like. And Fred will take it the rest of the way and 18 make sure it fits in,with the rest of the program. 19 MR. MICHELSON: The technical, though, is 20 whatever branch is directly concerned? 21 MR. PARTLOW: I suspect. 22 MR. JORDAN: I think the benefit, there, is 23 having the inspection program and the standard review plan 24 more nearly married and make them complementary to one 25 another. ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646

r ~ ~ '30166.0 '16 .CRTE ~44 U 1 MR. MICHELSON: How about the technical, plant 2 technical' specifications? There's a document -- where is .3 that responsibility? 4 'MR. PARTLOW: You'll find that under'Ernie Rossi 5 in the division of operational events assessment - am I' 6 right? Or is it Bill Russell? Just give me one second. 7 That's on page 39. Yes, under Ernie Rossi. He has events 8 assessment, generic communications and technical 9 specifications. 10 MR. MICHELSON: So, if there is to be a revision 11 or a change in the nature of technical specifications, 12 that's where the thinking will go on? . 7% - (_) 13 MR. PARTLOW: Yes. 14 MR. MICHELSON: Any other questions? If not, 15 then I.believe we can proceed. 16 MR. PARTLOW:- I would like to introduce Bill 17 Beach, the' head of~the enforcement staff at I&E. 18 MR. BEACH: Good morning, I'm going to give you 19 a very brief overview of the NRC enforcement program in the i 20 next 15 minutes. 21 (Slide.) 22 We'll start out with its functions, the policy, 23 results of the enforcement advisory committee and some 24 other significant pending issues involving material false 25 states and harassment and intimidation. LO l' ACE-FEDERAL REPORTERS, INC. I 202-347-3700 Nationwide Coverage 800-336-6M6 .. ~ _,, _... _ _ _ _ _..,.__._ _.._ ___._- __ _,._.

I 30166.0~ 17 BRT ('# 1 (Slide.) 2 This slide shows you the basic purpose of the 3 enforcement program. You will note that there is nothing 4 up there that says it is punitive in nature. 5 (Slide.) 6 Enforcement begins when the heart of the program, 7 the inspectors, find something that is in noncompliance 8 with our requirements and violations. Enforcement actions 9 start usually in one of these manners. 10 (Slide.) 11 This slide basically shows you the current 12 organization of the enforcement staff. I, as the acting ,,.() 13 director, report directly to Jim Taylor, who is the 14 director of the office of inspection and enforcement, who 15 is the senior agency official responsible for the NRC's 16 enforcement program. In the new office, Mr. Taylor would 17 be the deputy EDO. As Jim said, everyone remains intact 18 with the exception of myself, and at this time I would like 19 to introduce the new director of the office of enforcement, 20 that's Jim Lieberman sitting on my right. 21 (Slide.) 22 Most of the enforcement actions taken by the 23 agency are initiated and issued by the regional offices. 24 Most violations are either severity level IV or V, which 25 are of lesser safety significance than the I, II or IIIs ( ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-33MM6

3016'6.0' 18 BRT

..p V 1 .that would' require headquarters' concurrence or signature. 2 Headquarters also issues orders, and have concurrence on 3 other significant actions like 50.54(f) letters and demands 4

for information.

5 (Slide.) 6 The next two slides show you some of the 7 statistics over the past two years of enforcement. actions.. 8 That shows~you reactors versus nonreactors. 9 (Slide the. 10 The next slide shows you civil penalties, 11 severity. level III. At this point in time, we are already 12 up to about 40, this year, which, if the current pace keeps R() 13 -up, we will double what we processed in 1986. 14 MR. MICHELSON: Which one will double? 15 MR. BEACH: The 201, the total. 16 MR. MICHELSON: Where will that doubling come 17 from? What's the major contributor to the doubling? Do 18 you double your civil penalties? 19 MR. BEACH: It's not really civil penalties. 20 The Regions are spending a lot more borderline severity 21 level IIIs and IVs. 22 We also have issues we haven't dealt with as 23 much with IV, H&I issues; we seem to be getting increases 24 in safeguards, security enforcement actions. It is not 25 really reactor operations, It's a variety of areas. ACE FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 800-336-6M6

-30166.'0 19 'BRT /~ ; 1 MR. MICHELSON: But mostly in the III, IV, and V 2 category? 3 MR. BEACH: Most are III and IV, where'the 4 Regions-believe it's a III but can be evaluated as a IV. 5 -MR. REED: What does H&I mean? 6 MR. BEACH: Harassment and intimidation. 7 M R.~ REED: You mean harassment and intimidation 8 of the inspectors or I&E personnel? 9 MR. BEACH: Yes, we'll get to this later. 10 Protected employees. 11 MR. PARTLOW: No, we don't mean harassment of 12 NRC people. Jfe mean harassment of employees -- (~'T -(_j-13 MR. BEACH: By licensees. 14 MR. PARTLOW: By supervisors of the licensee. 15 MR. REED: Of course, that's a very difficult 16 one. 17 MR. BEACH: It is. 18 MR. REED: You ask any employee if he-wants a 19 raise he'll certainly tell you yes. If you ask him whether 20 he's been harassed he'll tell you yes, there he has been or 21 not. So things are very, very difficult to pin down to 22 root cause and truth. 23 The other one is security -- are we changing 24 policy or changing something with respect to security? 25 Security, again, is another very difficult one, the balance O ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6686

30166.0: 20 ~ERT \\-/ 1. between security and emergency access for operations. 2. MR. BEACH: Yes, it is. Coincident-with that 3 there are a lot -- a significant: increase in the number of 4 security events being reported by the licensees. 5 MR. REED: My life trail shows me that if one 6 creates a military police organization,'they will go'out 7 and build their business. If one creates, even the licensee -8 creates a security organization, depending on personalities 9 and characteristics and boredom, they will go out and build 10 their business, whether it's realistic, effective, 11 appropriate or not. 12 So these increases are into a very confused - n) t, 13 .-- some very confused activities which, I think, lead to-14 turmoil and even adversarialism among the working troops. 15 And turmoil adversarialism between management and 16 employees. Thank you. 17 (Slide.) 18 MR. BEACH: The next slide shows you the 19 enforcement policy; basically the policies, procedures of 20 the enforcement program are published in the Code of 21 Federal Regulations as Appendix C to Part 2, title 10. 22 Changes to the policy are promulgated in the Federal 23 Register. 24 (Slide.) 25 In accordance with the policy, we have five O ACE FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 800-336-6M6

i 30166.0 21 BRT t 1 severity levels, I and II being the most significant, III 2 being of significant concern, and IVs and vs of less 3 significance. 4 The policy is broken into eight supplements 5 which you can see: cperations, construction, et cetera. 6 (Slide.) 7 The next t*o slides give you a. basic history of 8 the enforcement program. 9 MR. MICHOLSON: Could you go back just a moment 10 to this question of eight areas. 11 (Slide) 12 I look down there, for instance, and I expect to () 13 see a supplement dealing with the safety significance of 14 the event. Is that somehow folded into each of the other 15 supplements? 16 MR. BEACH: Under I, the five severity levels b 17 would be under reactors', with examples giving yr4 i safety 18 significance of what would'be a I, it, III, e-cetera. 19 MR. MICHELSON: It isn't always under the safety 20 viewpoint; it might be a safety level I, is it? 21 MR. BEACH: Under safety leval-I would be a 22 system, when actually called upon to work, did not function.- 23 MR. MICHELSON: Let's say it's a major 24 bresakdown in management. Of course, that has safety 25 connotations all right, out it isn't a safety system in the ( 1 ACE. FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage Nxk336t616

+, ?g. t 30166.0" 22 BRT' s.- 1,) i '~ l first order sense. J1 ': 2, ,IIR. BEACH: Right. n ni' 5 MR. MICHELSON: You are including more than-just l 'h [h'a rdware, goftware, you are including people? 1.si you y[ 4 /- t 5 ~could have~a severity level I dealing with people that did s 6 ,not deal directly_with safety?. 8 > CH 7 MR. BEACH: We have never had a severity level I / 8 dealing with a management breakdown. We generally consider S a severity level III a management breakdown. 10 MR. MICHELSON: So people never create more than i 11 a' level III; is that it? It takes hardware? [ - j 42

MR. BEACH

No. You could get to a II if it was

r. p(_j

_g( - 13 believe,d that management was so ineffective that they could I 14 not perform if called upon. 15 MR. MICHELSON: It could possibly be a II but 16 probably-never a I? 17 MR. BEACH: We have never had -- we have had -- 18 sqxtremely rare -- I believe we have had a II management _j ~ 19 Lyeak'. 1 - 20 MR. MICHELSON: But the idea of safety dl significance is folded into every one of these by the 22 severity level mechanism? 23 MR. BEACH: Yes. What I was saying is, we've 24 never had a I, but it could be -- I couldn't think of a l 25 case where we would. We have had a II. But generally a ! () 1 l l ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 800-336-6M6 j 3,U t IU ,s.

i 3 .y. 6 -30166.0 6 .23 BRT. j Sc... t. .f{!. [ # '" 1 breakdown would be in the III area. 2 MR.'MICHELSON: I think~that takes care of my 3 question. Go ahead. 4 4 MR. BEACH: The second slide here, probably'the 1 ~ 5 most important, going through.the history of the policy, q 6 ) ~ would be in 1980 when the current policy, the basic policy thatwearecurrentlyusing(fasissued' P 7

l '

tt; 8 (Slide.) 9 Minor changes were issued in 1984, and that 10 March 8,.1984 policy was the policy reviewed by the 11 Enforcement Advisory, Committee. 12 (Slide.) (_\\, l 13 The next slide speaks to the enforcement 14 Advisory Committee review. 'A review of the enforcement 'o 15 policy was first suggested by the Electric Power Resource 16 Institute in 1983. While the Commission did not accept 17 EPRI's proposal, they did decide to establish a committee 18 of outside experts to review the enforcement policy. The .c 19 purpose was to determine whether :t had achieved its 20 defined purposes and to pin. ice te Commission with 21 recommendations on any changes it believed advisable,; 22 .Several people from the industry served on the ~ 23 committee (and the Enforcement Advisory Committee for the formall established Review ofi he Enforcement Policy was 24 t i I 25 on August 31st, 1984, and spent a little over a year taking b uj r y ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-33(-6646 +. ..*g,,

30166.0 24 BRT ). ~' 1 testimony from the staff, industry.and others on-the 2 ~ effectiveness of the policy. 3' The Committee issued its report November 23, 4 1985. The conclusion was: -The policy's impact has been 5 modest in magnitude and psychological in-nature and that 6 the. intent of the policy conforms reasonably well to most 7 of'the committee's criteria. 8 We as a staff basically agreed with the 9 recommendations that the advisory committee gave and we 10 sent the specific recommendations in SECY 86-47. They were 11 also sent to the Commission.in SECY 86-234. 12 The recommendations approved by the Commission, p 1(_) 13 with the illusion of the material false statements, have 14 been incorporated into the policy for other appropriate 15 staff guidance.- 16 'Do give you a basic idea of some of the 17 recommendations, the enforcement staff should strive to 18 meet'the goal for preparing enforcement actions. 19 MR. MICHELSON: Excuse me just a minute.

Paul, 20 is the summary of recommendations we have here -- which 21 SECY.is it?

22 MR. BOEHNERT: This isn't the SECY. This is the 23 excerpt for the advisory committee. 24 MR. BEACH: There's two Commission papers. 25 MR. BOEHNERT: This was the report of the O) \\- ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6

i 30166.0 25 BRT /g ( ) N~' I advisory committee. 2 MR. MICHELSON: This.is the report of the 3 advisory committee and that resulted in'the writing of two 4 Commission papers. 5 Okay. 'I'm with you now. Just one advisory 6 committee report, I think. 7 MR. BEACH: Right. And everything has been 8 incorporated with the exception of the material false 9 statements. 10 Three, probably the three most major 11 recommendations was that licensee should receive copy of a 12 press release 24 hours before the enforcement action is () 13 issued; a change should be made in'the policy where we 14 discuss that violations should not be profitable to the 15 licensee; and mitigation of severity I violation should be 16 allowed on the same basis as severity level II and III 17 violations. One of the, if not -- probably the major 18 19 conclusion of the Committee, was the hits that we took on 20 issuing of actions in a timely manner. 21 One of the principal goals in the reorganization 22 will be to issue enforcement actions in a timely manner. 23 We had discussed ways to revise the process. 24 Jim Taylor is committed to giving the packages 4 25 out; the Regions will be committed to getting the packages (1) ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6

30166.0 26 BRT 1 out. And I think you will see a significant improvement in 2 the way the agency has been processing enforcement actions. 3 MR. REED: You said in a timely manner. -But 4 you've always got to worry about timely manner and accuracy. 5 I hope I&E is not becoming a media -- the media gets 6 flogging, produces things timely; that gets sales, but the 7 accuracy is very low. 8 I recognize -- I lived 30 years in the field 9 -- that even the reporting of an event in a timely manner, 10 what you might call a timely manner if you were familiar 11 with the situation or familiar with work, is very difficult 12 to sustain accuracy; and do a proper investigation. (m_) 13 On your part, if you are going to go for a f 14 timely manner, are you going to maintain your accuracy in 15 facts? 16 MR. BEACH: Yes, sir. 17 MR. REED: You are going to do both? 18 MR. BEACH: What I am basically talking about is 19 the situation where we have taken 12 to 13 weeks from a 20 severity level III event to issue a package. When I was a 21 resident, if we had a severity level III action the 22 corrective actions were usually resolved by the licensee 23 within four to five weeks. The enforcement package then 24 comes around seven weeks later. That's what we are -- 25 that's what's going to be alleviated. We may have a / ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336 6646

30166.0 27 BRT \\2 - 1 greater. risk because we didn't take as much time, but I 2 find I think the general view'is we believe that the 3 elimination of'the few weeks isn't going-t-o decrease our 4 accuracy. If we.are wrong at one or'two pages at the 5 proposed ~ stage, we still have the imposition stage. 6 MR. REED: Still, you say the bulk of the 7 activity will go forward in the time schedule it has,.but 8 there is some that have lagged that should have moved,out 9 faster through the headquarters or regional process? + 10 MR. BEACH: Yes. 11 MR. REED: Okay. Thank you. 12 MR. BEACH: The next slide summarizes the' /" (, }j 13 material false statement policy. 14 (Slide.) 15 The advisory committee's recommendations were 16 discussed in our SECY paper 86-36. The first 17 recommendation in this paper was that material false 18 statement citations be limited to written statements or 19 sworn statements that were made knowing the statement was 20 inaccurate or incomplete or made with careless disregard 7 21 for whether the statement was inaccurate or incomplete. 22 Second, the paper recommended the Commission 23 adopt a rule requiring all information provided the 24 Commission be complete and accurate in all material 25 respects. f~) \\/ ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6

~30166.0 28

BRT 1

,m;. ^'~ l Finally, the paper recommended the addition of a- .2 ~ catch-all reporting requirement' to replace the full .3 disclosure aspects'of:the current policy to require 4- -applicants and licensees to report to the NRC, information 'S identified by the applicant or the licensee, as having 6 ~significant implications'for'public healthiand safety. 7 (Slide.) 8-In other words, there were basically ~three areas I 9 that-would be addressed. In summary, very quickly,'the-10 statement had to impose some degree of willfulness; we 11 require that all information submitted to the Commission. be 12 factual and accurate; and third, if the licensee finds it, () 13 he should report it. 14 MR. REED: I guess what I have heard and seen in 15 written material flowing past me is that material false-16 statements are now going to dwell on willful and on written; 17 is that' correct?' oral,*off-the-cuff which might be 18 material false statements are not going to be pursued as 19 vigorously as such; is that correct? I had seen something, 20 " willful and written." It was a real bad scene and you 21 could flog the hell out of it. 22 MR. BEACH: To be a material false statement it 23 would have to involve some degree of willfulness. 24 MR. READ: Is that written or oral? 25 MR. LIEBERMAN: The true or false statement can O i ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6 ~..

--30166.0 29 -BRT '~# 1 be either written-or oral. I believe it is the' Commission's 2 intent not'to utilize true or false statements once this ~ 3 rule is.in place, except in the most egregious situation. 4 Written or sworn oral statements made with careless 5 disregard, and an oral statement where it is clearly shown 6

that the person making the statement knew the statement was 7

erroneous. 8 With this new rule that requires information to 9 be complete and accurate in all material respects, that may 10 include both written and oral statements. We won't have to 11-label it a material false statement because we'll have a 12 regulation that we'll be able to utilize to take (q - _/ 13 enforcement action. 14 If it is deliberate, a communication failure, 15 then we can say information was provided to the agency 16 deliberately. If it's just a negligent error, then we'll 17 use the appropriate adjectives. But we'll get away from 18 the term " material false statement" which causes a lot of 19 dispute, because it labels someone as someone providing us 20 information maliciously. The Commission in the VEPCO I 21 decision uses the term " material false statement" for any 22 inaccurate information, whether or not it's willful. 23 MR. MICHELSON: Something bothers me a lot. 24 There's been several policy issue papers and a proposed 25 rulemaking paper and so forth on this material false O s ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6

E 3016'.0 30 6 CRT- ,o 'l l' statement-business.- The thing lthat is confusing me 2 significantly is, unfortunately, when I see these. pieces of 3 paper, it is never labeled how the-Commission finally acted 4 on them. -I don't know, for instance -- we now have a 5 proposed rulemaking. I wouldn't call that a new rule, then, 6 I would call it-a proposed rule, because to me a new rule 7 means one that is just promulgated and is now the rule. So 8 we have to be very careful to identify whether we are 9 talking proposed rules or proposed policies or ones that 10 have been accepted by the Commission. I had that 11 difficulty in reading the package of paper that was sent to 12 me, because, unfortunately, there was never a transmittal () 13 with it' indicating how the Commission acted on it. I 14 assume it acted on all the previous ones,-but I don't know. 15 MR. LIEBERMAN: There have been many 16 deliberations over the last four years to reach the point 17 we are at now. The Commission, on March 6, sent to the 18 Federal Register a proposed ruling on true and false 19 statements. 20 MR. MICHELSON: That will be the one in which 21 they identify the fact that even an oral statement can be 22 potentially a material false statement? 23 MR. LIEBERMAN: That's correct. 24 MR. MICHELSON: But that hasn't been acted on 25 yet. But prior to that time, how has the Commission ~ ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6 l

[30166.0 31 BRT 'h, l decided, in terms of these other policy papers? You know, ~ 2 there's a policy paper of August 7th on proposed changes to 3. Lenforcement policy and so forth. Was that approved by the 4 Commission? 5 MR. LIEBERMAN:- The. current position in the 6 agency, rules of the agency, is the VEPCO decision, that a 7 true or false statement can either be willful or not 8 willful. 9 MR. MICHELSON: Can it be oral as well as 10 written? 11 MR. LIEBERMAN: Oral as well as written. 12 MR. MICHELSON: That was kind of the impression ' ( )) ~ 13 I had, but some of these intermediate policy papers were 14 trying to change that and I don't know whether they were 15 adopted or not. 16 MR. LIEBERMAN: They were adopted in the sense 17 that we have a proposed rule. As a matter of practice, the 18 Commission has -- is reserving the term " material false 19 statement" for the more willful violation. When there is a 20 communication failure because the licensee-did an 21 inadequate engineering analysis or poor QA job, such that 22 inaccurate information is provided the agency, we are 23 citing the licensee for that underlying violation. 24 (Slide.) 25 If it's only a communication error without a ~( ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Cmerage 800-336-6M6 _.. ~ __.. _ _.----~._.__... _ _. _. -, _ _. _...

m 130166.0" ~32- ?CRT .pq 'l ' violation of-some.otherl requirement'and'it is-not willful,- 2 'the Commission'in some cases has just written _a-letter -3' ratherithanzutilize material false stat'ement. 4 MR.1MICHELSON: The Commission 1actually has.not 1 5 stated-it has to be willful. It's just by their actions -6 you know, unless'it'is; willful they aren't doing anything.

7 But the Commission.has never said-it has to be willful to 8

be-a material false statement. 9 MR. LIEBERMAN: Because they have the decision, 10 the adjudicatory' decision in.VEPCO, which they can only 11 change by another adjudicatory decision or by rulemaking, 12 so they are going to have a rulemaking on the rule about ([ 13 material false statement. 14 MR. MICHELSON: In terms of the VEPCO decision, 15 does it have to be willful? 16 MR. LIEBERMAN: No. VEPCO, it does not have to 17 be willful. 18 MR. MICHELSON: In other words, right now it 19 does not have to be willful and does not have to be written 1 20 to be a material false statement. 21 MR. LIEBERMAN: That's right. t 22 MR. MICHELSON: Has the Commission -- actually 23 it is up for comment now. Of course, all the Commission 24 decided was to send it out for comment. Now it comes-back 25 from comment, then they go through deliberations to decide ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 8M336-6686

230166.0 33- -BRT - (x _ i eV 1. how to issue the rule. Okay. 2 This rulemaking gets confusing because people 3 kind of equate proposed rules to the rule _ thing. 4 MR. REED: This is one of the things,-right now 5 the' interpretation is it doesn't have to-be willful and.it 6

doesn't have to be wr'itten.- Then the normal structuring of 7

our utilities and all that. business,- the. normal presidents, 8 vice presidents, PR people, are in jeopardy. Because-9 you'll find these-people are normally the optimists, 10 boosters of their utilities and so on and so forth, and 11 they will always make statements when they don't really 12 know the sound technological aspects, they will always make ( )_ 13 statements that are optimistic. They are optimists, v 14 otherwise they wouldn't have got up there. You don't see 15 any pessimists leading companies. 16 So it's a strange situation. Quite frankly, 17 this is why I push all the time for such things as a 18 designated representative system, so the I&E folks and the 19 people in regulations have an avenue to the facts, not to 20 the optimists, the leader who is off-the-cuffing things. 21 We hear a lot nationally about off-the-cuffing things and 22 not knowing about details these days. We are structuring 23 the same kind of situatio1 if we continue to ignore an 24 avenue to the technical person. 25 MR. MICHELSON: I think the rule is saying you O Ace FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coserage 800 336-6M6

.~. ?30166201 34 BRT- [f} ' '~ l 'better not off-the-cuff things because they can be held 2 against you as' material false statements. 3 MR. REED:- How are you going to get rid of the 4 Lee Iacoccas? 5 MR. LIEBERMAN: You need a heavy dose of common 6 sense in recognizing the forum thez information is-7 communicated-in, and recognizing that oral statements are 8 inherently less reliable than written statements, and you 9 have.to look at the circumstances. 10 (Slide.) 11 The responsibility, too, of the person providing 12 that information, in deciding whether it is a puffing or

O 13 whether it is meaning to deceive.

And I think on. track 14 record in the area of taking action for oral statements,.I 15 think -- I can think of maybe three cases in the last 10 16 years where we have had enforcement actions for oral 17 statements. This is not the case of someone saying:

Boy, 18 if I make the slightest misstatement I'm in trouble.

We 19 just haven't done that. 20 MR. REED: I don't think you would have a good -- 21 quite frankly, just to place this in focus -- I don't think 22 you'd have good energetic leadership of utilities if we had 23 pessimists and strictly factual people at the very top. 24 But in your dealing you are bound to interface with these 25 people who make off-the-cuff remarks. That's the way you O ACE FEDERAL REPORTERS, INC, 202-347-3700 Nationwide Cmerage 800-336-6646

-30166.0 35 BRT

(O!

' ' = > 1. are structuring yourselves, because you don't rely that

2 heavily on the resident inspectors, I think.- And you are 3

communicating with the top management. And those people -- 4 I don't know if they'll get the message if they.should: 5 downplay, say I take the Fifth on everything that happens. 6 Ask them a, question, no response -- that's not their nature. 7 Thank you. '8 MR. BEACH: The other issue that is around is 9 harassment, intimidation and discrimination. These issues 10 were discussed.in SECY 86-235, and this slide summarizes 11 the major recommendations that were approved by the 12 Commission. Briefly, employees should be considered as f( ) 13 engaged in protected activities if they are raising 14 potential safety concerns to their management. They do not 15 need to raise these concerns with the NRC in order to be 16 protected from fear of reprisals by management. 17 Secondly, the NRC should normally wait to deal 18 with all investigations and other proceedings before 19 proceeding on its own. 20 Third, licensees should be held responsible in 21 enforcement actions for the discriminatory actions of its 22 contractors; and we are currently adding additional 23 examples to the enforcement policy, demonstrating various 24 severity levels for these types of violations. 25 MR. REED: A number of years ago, probably eight, ACE FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Cmerage 831-33M646

$N y ci 130166.0 36 BRT' D 1 .nine years ago, there was a regulation that came out with -- 2 parallel with the setting up of the resident inspector ~ .3-program, whereby any employee in any~ plant could go by the 4 back door -- and the resident inspectors had a back door 5 -- to.the resident inspector and say something was wrong 6 or they were being harassed or something. I've forgotten 7 -the number. 8 I thought that certainly gave any-employee an 9 opportunity to make reports without being flogged. 10 What has gone wrong? Why is this coming to the i 11 forefront? Are these people, perhaps, terminated? Perhaps 12 the job is over.and they don't want to accept the job is . () 13 over, the construction is finished, they don't want to 14 accept the construction.is' finished? so, in order to get i 15 notoriety or something they go around and stir up something? i 16 I thought we had a system to take care of 17 employee intimidation, harassment or anything that they 18 thought was wrong. 19 MR. BEACH: This specifically addresses -- there 20 were events at operating plants, where possibly an 21 individual alleges that his supervisor told him to fill out i 22 a form and the information was erroneous, and DOL does an i 23 investigation and substantiates the claim, and also he was 24 told that if he didn't fill it out in this manner, he would 4 25 be fired. ACE FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coserage MU-336-6646 =

V 30166.0 37 ERT 1 DOL substantiates that. We believe that it is 2 significant that these people can't take concerns to their 3 management and get resolution; and that's why we have 4 promulgated this policy for significant enforcement action. 5 It's to ensure that communications systems within the 6 licensee's organization are open. 7 MR. REED: I guess what I would like to happen, 8 whether an employee cease something wrong or has some 9 criticism, yes, he would touch base with his supervisors 10 first, and if he got no action then he'd go to the back 11 door to the resident inspector under the regulation. 12 MR. BEACH: We would hope that when he went to t's l _) 13 his supervisor the situation would be resolved. 14 MR. REED: And the supervisor should well know 15 if the man is right, he has to do something about it. He 16 should well know that. Any supervisor worth being a 17 supervisor should know that, because he knows the avenue of 18 follow-up is there. I don't see why it doesn't work. 19 I guess there are cases where it hasn't worked 20 and they are genuine. There's no intrigue here, no false 21 gains. It's genuine. 22 MR. MICHELSON: Go ahead. 23 MR. BEACH: Finally, in closing, this is a brief 24 slide on why we believe the enforcement program has been 25 effective. n f 1 V ACE FEDERAL REPORTERS, INC, 202-347-3700 Nationwide Coserage 800-336-6646

30166.0 38 BRT 5 ' ~ ' ' 1 (Slide.) 2 Along with this, as a result of Davis Besse and 3 some other problems, we have tried to use other tools 4 besides just civil penalty action and orders. We have 5 tried to implement 50.54(f) letters, that ask for 6 information, and other things that probably can accomplish 7 the same thing as a civil penalty or court order. 8 MR. MICHELSON: Question. The SECY paper that 9 was issued on the rulemaking, I guess it resulted in the 10 rule going on for public comment, and when is the public 11 comment due back? 12 MR. LIEBERMAN: April 10th. in () 13 MR. MICHELSON: After it comes back, what is 14 thought to be the schedule, in terms of sending this to the 15 Commission for final decision? 16 MR. LIEBERMAN: We don't have a schedule but, 17 depending on the number of comments, I think we are really 18 going to try and expedite that process to get this rule -- 19 MR. MICHELSON: Do you have a thought in mind 20 when this might be? The reason I'm asking is it may be l 21 that this Subcommittee will wish to look at the rule before 22 it is issued, if we have any comments to make. I was 23 wondering, schedule-wise -- when to expect them? 24 MR. LIEBERMAN: I would expect sometime in 30 to 25 60 dayss. That may be optimistic. O V ace FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Cmerage 8m-33MM6

c: i 30166.0' 39 BRT (N - 1 MR. MICHELSON: So really we should get at it no 2 llater'than the middle of June. When will it go to the 3 Commission,'was my question? ~4 MR. LIEBERMAN: Right. 5 MR. MICHELSON: If we review it with you by the 6 middle of June we probably still will be all right; is that 7 so? 8 MR. LIEBERMAN: Probably. I know the Commission 9 really wants to get this rulemaking process completed. 10 MR. MICHELSON: I have a large number of-11 questions on the rule, but this is no place or time to go 12 through them. I'm sure once the public comments are in ( )) 13 some of these may go away or maybe more will be generated, 14 I don't know. But I think you would want to answer them 15 before it goes to the Commission. So I just wanted to give 16 our Subcommittee chairman an indication of what you thought 17 had to be our schedule, so anything up to the middle of 18 June, I guess, sounds like reasonable timing for our 19 purposes. Is that okay? 20 MR. LIEBERMAN: The comments are in April 10th. 21 They dribble in, as I say, the end of April, mid-April -- I 22 would think the end of May would probably be really the 23 earliest that we will be able to get it to the Commission. 24 It is going to take the Commission -- 25 MR. MICHELSON: A month or more. O ace FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Cmerage 800-336-fM6

z~ 30166.0 40 TRT .p 1 MR. LIEBERMAN: A month or more to act, so June 2 _might not'be unreasonable. 3 MR. MICHELSON: That sounds like a reasonable 4 time for us to have it for their benefit. 5 Any questions on the presentation? If not, then 6 let's go ahead and proceed. 7 MR. PARTLOW: Next is Brian Grimes on the 8 quality assurance function. 9 MR. GRIMES: Before we go over the quality 10 assurance branch functions, let me make a few overview 11 remarks on the division of quality assurance, vendor and 12 technical training. center programs. ( 13 At the last meeting in August we made a 14 presentation on the vendor program branch. Today we are 15 going to cover the other two thirds of the division, the 16 quality assurance branch and the technical training center 17 in Chattanooga, Tennessee. 18 The NRC's OA responsibilities were consolidated 19 in the Office of Inspection and Enforcement in early 1983 20 in response to major quality construction and design 21 problems in the nuclear industry, such as Marble 11111 and 22 Zimmer, which had resulted in significant public and 23 Congressional concern. 24 At this same time, legislation was passed by 25 Congress requiring the NRC to report to Congress on the O ACE-FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coverage 80th336-6M6

-30166.0 41 BRT O' ' ' I causes of quality problems in the nuclear industry. This 2 study, known as the Ford Amendment Study, was submitted to 3 Congress as an NRC Staff report, NUREG-1055, in April of 4 1984. It was entitled " Quality and the Assurance of 5 Quality-in the Nuclear Industry." 6 The recommended initiatives of the report were 7 later endorsed by the Commission with certain exceptions, 8 in December of 1985. The main conclusion of the Ford 9 Amendment Study was that the root cause of quality problems 10 in the nuclear. industry in the construction and design area, 11 and the difference between well and poorly constructed 12 facilities, was the ability and performance of licensee n(,) 13 management. 14 The experience, and senior management attention 15 to detail, were found to be critical factors in successes 16 as well as failures. 17 A word on the effect of the reorganization on 18 the OA area: The consolidation of licensing and inspection 19 functions, which occurred in early 1983 will be maintained 20 in the reactor area when it's transferred to its new 21 location in NRR. It has, in a sense, been a successful 22 pilot of inspection and licensing functions along with the 23 emergency preparedness function in I&E where this joint 24 administration functions. 25 MR. MICHELSON: Could you refresh my memory O Ace FEDERAL REPORTERS, INC. 202 347 37(o Nationwide Coverage H00-3346M6

r 30166.0 42 CRT q. 1 quickly about OA and where it is moving to in NRR? 2 MR. GRIMES: It's moving to a division under 3 Bill Russell for performance evaluation. It will be 4 maintained as a quality assurance' function. 5 MR. MICHELSON: So the work that.is now under. 6 way will essentially move intact to that new location? 7 MR. GRIMES: In the reactor area, with two 8 exceptions. One is that the standards area will return to 9 the office of research where it was before 1983, and the 10 quality assurance aspects of the waste repository in 11 monitoring retrievable storage will go to the NMSS. For 12 the last three years we have been working in that area. () 13 I would now like to introduce Hub Miller, my 14 deputy and for the last six months acting chief of the 15 quality assurance branch, who will describe the Staff 16 initiatives in the quality assurance area, particularly as 17 a result of the Ford Amendment Study and the integration of 18 these initiatives into the overall NRC programs. 19 MR. MILLER: With me today is Frank Hawkins, the 20 chief of the quality assurance policy section within the 21 quality assurance branch. He's sitting to my right. 22 As Brian said, the Ford study provided the 23 underpinnings for the quality assurance program plan that 24 the quality assurance branch has had the lead within the 25 agency for-implementing. i ACE. FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coverage Mn336-6646

30166.0 43 - C RT 1 Also, as Brian said, the Ford study and the plan 2 that implemented its recommendations, addresses many things 3 beyond the traditional QA kinds of issues. In the chart 4 that you have, the first chart. summarizes what some of 5 those Ford study findings were. Management being chief 1 6. among -- poor management being chief among the problems, or q 7 root causes of the quality breakdowns that occur, that were 2 8 studied in the Ford study. It sparked a number of 9 initiatives that go beyond what the quality assurance 10 branch itself is responsible for. 11 What we are doing, at the current time, is 12 revising the quality assurance program plan. And what we () 13 are doing in this revision is focusing the scope of the 14 plan on the things that the quality assurance branch, in 15 the new organization, will be directly responsible for and j 16 that is on the proving -- the inspection -- licensee i 17 quality assurance organizations, recognizing that the types i 18 of initiatives that were undertaken following the Ford 19 study have been -- that dealt with the things that go 20 beyond the traditional OA type of concerns, that is, go to 21 management, to go overall licensee performance in achieving P 22 quality -- that those programs are, in fact, or have in 23 fact been incorporated into other programs within the 24 agency. 25 Look at the next chart, I'll give you an example. J Ace. FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coverage 8(x)-336-6M6

30166.0 44 ERT 1 MR. MICilELSON: Before you get into that, let me 2 tell you something that bothers me. It's kind of 3 subjective and fuzzy, I guess. We keep seeing examples of 4 organizations which have OA programs, longstanding, 5 apparently well written, look great, and the NRC inspects 6 these programs, and yet after a period of years we suddenly 7 come to the realization that things aren't well, in fact 8 haven't been well for years. Ilow -- why does this happen? 9 You know, TVA with Watts Bar, OA problems; I think Zimmer 10 was very much a OA problem. I don't know about Comanche 11 Peak yet. I don't know the details, but I kind of suspect 12 it is OA problems. But all of these must have had approved O) (_ 13 OA plans long ago. 14 What happens? The paper looks good and the 15 inspectors inspect the wrong things or something? And 16 finally come to the realization because things aren't well, 17 because it's happening, and then everything comes to a 18 screeching halt? 19 MR. MILLER: I think I can address that. That 20 was the very point that was made by the staff in the report 21 to Congress. 22 MR. MICilELSON: What's the number on that? 23 MR. MILLER: This is NUREG-1055. I hadn't 24 planned to go into any detail on this. I know you have 25 been briefed on this in the past, the ACRS has been briefed O N. Acc FEDERAL ReponTuns, INC. 202 347 3700 Nationwide Cmcrage 800-33MM6

30166.0 45 ERT e 1 on this several times in the past. 2 MR. MICHELSON: We have heard about.QA for years. 3 MR. REED: That's two years old? 4 MR. MILLER: This is the document shown in the 5 first chart that was issued in May of '84. It was the 6 basis upon which the Staff issued the quality assurance 7 program plan in February of '85. It was that very point, I 8 think, that was brought out in this report on lessons 9 learned at Zimmer and Marble Hill. I can talk about what 10 some of the specific -- 11 MR. MICHELSON: But, does it take a long time to 12 realize that another utility is in trouble? I guess you O(,) 13 are going to tell us about indicators, on how much we can 14 indicate a little further ahead of time that they are in 15 trouble, but it seems that we always end up, years later, 16 finally realizing we really do have -- they have lost 17 control. I don't understand why that should be. 18 MR. REED: I remember that report well. I 19 remember disagreeing with it very much because it just 20 addressed the designated representative thing and then 21 throw it away as unimportant and not useful. In fact, I 22 had a number of discussions, I think, with members of the 23 Staff. I didn't like the work. 24 You just made a comment that management is at 25 fault for 0A breakdown. I would like to say that maybe O Acn FliDI!RAL RIIPORTliRS, INC. 202 347 370) Nationwide Cmerage

x)-))MM6

30166.0 46 ' CRT Q,,.- 1 partly at fault is regulatory structure. I think in the 2 regulatory we have to know the management, know the 3 situation, know the scene, and make our structuring, in 4 this reorganization, make our structuring to effectively 5 carry out the mission. 6 We have an example that's very current right'now 7 in these Cooper diesels which are throwing connecting rods. 8 Somewhere along the line the inspection, what used to be 9 traditional-inspection in the manufacturing facilities, in 10 which I used to have to take my little manufactured parts 11 up and get them stamped and approved that they are done 12 right -- somewhere along the line in this Cooper operation () 13 the inspection department -- maybe now called the quality 14 department, more focusing on paper than on micrometers and 15 so on and so forth -- the inspection department allowed 16 them to pass, and instead of stamping them scrap they let 17 them pass and they were plated, probably leading to 18 hydrogen embrittlement in the rods, and they were put into 19 service. 20 To me we must focus on why do things like this l 21 happen, the things that you are bringing up, Carl, why do i i 22 things like this happen? And is there something wrong, is 23 management at fault? Or is it our structuring and our 24 emphasis to make sure that these kind of scrap pieces don't 25 get out into the diesel engine? O ace. FEDERAL REPORTERS, INC. 202 347 1700 Nationwide Coserage Mn33MM6

30166.0' 47. BRT -1 Quite frankly, I keep saying the answer is the 2 designated representative system. And I think'it's in the 3 FAA, in the aircraft industry, so that this doesn't happen. 4 But we keep hearing in our operations, we keep rejecting it. 5 End of-speech. 6 MR. MILLER: Well, a number of points have been 7 made. Let me'see if I can respond to them. Most of them 8 are points that~I will be addressing in this talk. 9 First, your question, Mr. Michelson, yes. I 10 think when you sit here in 1987~and you look at this 11 document, which was issued in '84, which drew conclusions 12 like the one you drew, and in fact the Staff recently () 13 requested the Commission form a " lessons learned" on the 14 TVA situation. And if you read that report, which I think 15 is something you have access to, it draws almost the same 16 conclusions again. 17 I think the feeling is that many of the kinds of 18 problems that occurred at TVA had their roots in activities 19 that occurred prior to the time that the Ford study was 20 issued, and hopefully we are learning. I think if a year 21 or two from now we have another situation which is the 22 exact same situation as the TVA, current TVA problems, then 23 I think you'd have to say we failed to learn. 24 Let me go on. i i 25 MR. MICHELSON: The thing that bothered me a O Ace FnonRAL REPORTERS, INC. 02 347 3700 Nationwide Coverage m)-336 6M6

q

30166.0 48

.BRT (D 1 little bit, that report went on just about the time you 2 were beginning to understand that TVA had a problem. 3 Apparently, the'1 earning process is just awfully slow on 4 the part of the utility and on the part of the agency. I 5 . was just wondering, is there any way of somehow speeding up 6 the agency's ability to detect these things sooner instead 7 of later? 8 MR. GRIMES: I think we'll be going over several 9 months on that -- 10 MR. MICHELSON: I was just trying to share my 11 concern with somebody else. 12 MR. GRIMES: We share the concern. () 13 MR. MICHELSON: I was wondering just 14 something has to be done to speed up the process by which 15 we find these things out, instead of waiting, having to 16 wait so long to realize that a company is in dire straits. l 17 MR. MILLER: With the kinds of questions you i 18 asked, it might be useful to just spend a moment on the P l 19. four bullets on the first page to summarize what some of 20 the basic findings of the study were, basically are: line l 21 management was primarily responsible for achieving quality. 22 That is to say you cannot inspect into -- inspect quality i 23 into product. It must be put in the product in the first 24 instance. I 25 Here I would agree with you, Dr. Reed, that it O(_) ACE. FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coserage 800-3364M6

30166.0 49 BRT O 1 is not just line management, of course. You have to havu 2 good structure and you must have gooa, competent QC, good 3 checks. At the conclusion, the conclusion of the Ford 4 study was in many instances the key to quality control, 5 quality assurance type of cher:ks chat were made, in fact, i [ 6 were highly paper-oriented and did not test sufficiently 7 the technical attributec and the hardware being installed 8 in these plants, the technical aspects of design in 9 sufficient detail to. find the problem and he).p line 10 achieve the quality. 11 A third point somewhat goes to your concern, 12 Dr. Reed, about getting at the technica'l facts and getting () 13 beyond, kind of the optimistic ganeralization that might be 14 put forward. It was a conclusion about the adequacy, 15 techniques and the resources thit were available through 16 NRC to do inspections. 17 As I'll get to in a moment - 18 MR. REED: Please don't call ne Dr. Reed, 19 because I'm not a doctor in any sonse of the word. You taay 20 call me Mechanic Reed, Operator Feed, or anything like that. 21 (Laughter.) 22 MR. MILLER: The fourtn point was that there 23 were -- a lot of the indicators of major quality breakdowns 24 were there, but neither the licensee, in < case 9 where the I 25 problems occurred, nor the NRC worr. adeq3gt91y synthesizing Act!.Flim!RAl. RiiNRTliRS, INC.

02.ma7m samnwide unewre smaw uw,

I' k

,10166.0 50

' Bkl O' 1 these seemingly separate problems into an overall picture 2 of performance, trending that performance so that we could 3 detect early that there was a sign of problem, as opposed 4 to 1 s ta. - 3 c j 5 ~ MR. REED: I like what you are saying, and I 6 like thits one word here in the list, "line manager." I 7 like that.. And I like the words, getting back to OC, the '3 heart of quality when I was in manufacturing facilities 9 years ago, in the inspection department is the line 1 10 supervisor, you might say, who passes the part, passes on 11 the work, so on and so forth P 12 This reminds me of the fact -- I'm trying to () 13 remember the name of the doctor that was speaking for r [ 14 quality a couple of years ago and spoke for that report -- K E 15 he, in the last year or two, said he was going to come out 16 wit a bulletin to the licensees telling them that they 17 didn't necessarily have to take all their good OC people, 18 wh'o knew what was quality, and tear them away from that 19 activity of approving quality and put in place a OA stamped E 20 on their chest, clerical person following a bunch of paper. 21 That bulletin never did come out, but it was 22 promised to me in two meetings. Do you know where it is, 23 or now, with the reorganization maybe it's lost forever. N 24 MR. GRIMCS: We worked for some time on an n u 25 information notice rather than a bulletin which would E ACE FEDERAL REPORTERS, INC. 202-347 370) Nationwide Coserage 80)-336 3 46

130166.0 51 .BRT 'l )' 1 indicate our current policy that OC organizations do not S d 2 have to report to the OA organization but may report, and 3-they do in many instances, report to line management. My 4 memory isn't current, but I think we finally decided that 5 the word had got around in other ways and that perhaps it 6 was a little bit of a misuse. of an information notice and. 7 wasn't reporting'on operational'information. So we decided 8 not to issue it. But the position we have made clear in 9 talks to industry and in other ways,.that point has'not 10 been lost. 11 MR. REED:',Well, I'm disappointed ~you didn't.put J 12 out an information notice because, just like I think ()~ 13 newspapers should put out information notices Shen they do ~ 14 things inaccurately, I think that we asia technical 15 regulatory organization ought to always-clean our closet. (ll 16-MR. MICHELSON: I;think it's dangerous to assume a 17 that everybody gets the word. Maybe you asked around and 18 maybe those you asked had gotten the word, but that doesn't (l: 19 really mean that the entire industry understands it, g-20 MR. MILLER: We can go back and pulse that again. j, J si i H 21 I think working through various professional organizations, 7 ? 22 the NOA, ASME -- my sense is that the word has gotten at 23 around on that. We can go back and do a check. Lr j 24 In you go to the next page, maybe that covers 25 the specific initiatives that were undertaken and were i h ACE-FEDERAL REPOATERS, INC. 202-347-3700 Nationwide Coserage 800-336-6M6

30166.0 52 ERT I ) 1 described in the, for the most part, in the QA program plan 2 to deal with the kinds of problems that I've just discussed. 3 There are kind of two categories of things, as I 4 mentioned. The first category of things are a number of 5 initiatives that go beyond what the quality assurance 6 branch is directly responsible for at the current time, and 7 I won't go into these in much detail at all. To a great 0 extent they have been covered in a previous presentation. 9 Ed Jordan will talk about performance indicators, about the 10 performance indicator program. The quality assurance plan 11 identified an initiative in work on performance indicators 12 several years ago. When the new chairman came, assumed his. I) 13 position and identified performance indicators as an 14 important initiative, that was assigned to Ed Jordan and 15 that is, of course, a major program within the industry; 16 and the work that the QA branch had been doing under the 17 program plan has been integrated into or has been folded 18 into Ed's work. 19 The part that I want to focus on is the second 20 category of things, and that is what the Staff of the QA 21 organization is attempting to do to reorient or to continue 22 the process, I should say, of reorienting quality assurance, 23 quality verification organization reviews and checks f rom 24 being highly processed and paper-oriented to subject to 25 technical reviews. p V ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 800-336-6646 1

~

30166.0 53 ERT-1 The next chart --

2 MR. MICHELSON: By substantive technical reviews, 3 though, what do you-mean? 4 MR.' MILLER: I mean, instead of having an audit 5 which goes in and merely checks to see that they are back 6 to procedure there, that, indeed, as the procedure calls 7 for, there was a signature saying that the calculation, 8 which is a design activity, that the calculation was, 9 indeed, checked. In other words, just. checks the 10 appearances of things as they are evidenced in paper, to 11 actually picking up some calculations, supplementing the 12 audit with bona fide technical experts to actually check A' ( ). 13 some of the calculations and assumptions, the kinds of 14 technical decision-making that goes on in the -- in a 15 calculation. 16 MR. MICHELSON: This would be on an audit basis 17 with a particular system or component in mind, and just go 18 through the whole process? 19 MR. MILLER: Right. What we learned -- what we J 20 in effect instituted as a practice within NRC's own 21 inspection practices several years ago, even before-this 22 was published, was that it was a better idea to go 23 vertically, take a vertical slice of a system or a comp or 24 a portion of plant activities, and dig down very deeply 25 than it is to take a superficial look at the upper tier O ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646

30166.0~ 54 BRT g 'f 1 operation. 2 MR. MICHELSON: This is the SSFI idea? 3 MR. MILLER: The CAT idea, the IDI idea. 4 Basically what you do is test'one area very deeply and then 5 if you find problems you ask the question: Well, now, what 6 does this mean if other activities may be likewise affected? 7 MR. MICHELSON: Of course you need, certainly, 8 both. But spend less time checking the signatures and more -9 time looking at individual cases. 10 MR. MILLER: Precisely. It's a question of what 11 is the right balance. It has'been our judgment in the past, 12 there hasn't been a balance, the proper balance. There has p()- 13 been too much paper and not enough actually testing the 14 substance of'the technical work. 15 Along that line, we recently issued a guidance 16 document to our inspection force, regional inspection force 17 that is, that has as its primary responsibility evaluating 18 quality assurance programs at reactors. This temporary 19 instruction, so-called, directs that the inspector take an 20 approach where we start with a known problem at a plant, an 21 area of weakness at a plant.as that is determined or 22 discovered through our other technical inspections, the 23 inspections done by the NRC or things that are identified 24 by the licensees themselves through an event or as 25 evidenced by an event, and asking the question: What was ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646

e30166.0 55 .BRT ' A' ) ~ \\ 1 -- what has been the contribution of the quality 2 . verification organization, the quality assurance 3 organizations in that area, in the affected area? We could 4 take maintenance, for example. 5 If, through the inspections of our maintenance 6 ~i~nspectors or the specialists within the inspection force, .7 we discover that plant A has a problem in that area, then 8 it is our intent to go and ask what has the QA organization 9 -- even done any audits in this area? If they have done 10 audits, what kind of audits were they? 11 It gets around a problem that you will always '12 have with.an audit organization, which is that: Look, I'm I) 13 only doing audits and I can't catch everything. It focuses 14 on actual -- on the bottom line, which is licensee 15 performance, and asks the question: Is the quality 16- _ assurance organization, are the quality verifiers 17 meaningfully contributing to it? And I think it would be 18 difficult to do this TI on a single event. Rather, what we 19 would do is look for an area where there has been a 20 repetition of problems, and I think, by this technique, we 21 have the best way of testing the actual effectiveness of a 22 QA organization helping line avoid problems. 23 MR. GRIMES: And we hope by this pressure or 24 this direction to influence the staffing and the management 25 of the quality assurance organization and the way they are 0, ~ ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6

'30166.0 56 BRT 1 used by-line management as the eyes and ears operation, as 2 was originally intended, rather than just punching a 3 required ticket, as is often the case. 4 MR. MILLER: One of the specific things that we 5 will be asking in this is what are the qualifications of 6 people doing these audits and doing these checks, to 7 determine if they are, in fact, capable of finding a safety 8 problem if they fell over it. And, as Brian said, also to 9 determine what support is given to quality assurance 10 organizations by line management. 11 The Ford study, I think, determined -- one of 12 the. things it observed was that a number of utilities set I ,) 13 up quality assurance organizations because they were 14 required to by regulation, not because they had conviction 15 that the organization could help them avoid problems and, 16 as a result -- the result is an obvious one. If the line 17 management is not really relying upon and counting upon the 18 quality assurance organization to give them help in 19 detecting problems, that organization is not going to 20 perform very well. And so this, one of the important 21 features of this is to try to test what kinds of support 22 and reliance is placed on this program by the line 23 management. 24 MR. REED: If the agency wasn't in such a people 25 -- numbers of people, I should say, oriented focus, these p. %./ ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-fM6

c l-L 30166.0 57 [ ~

BRT,

' ('# 1 . things would work themselves out. You know, when.I was in 2 manufacturing, 40-some years ago, the man who was the

3 inspector, who really -- or men who were inspectors, 4

. determined quality, had probably served in the. departments' 5 machining for 30 years. They were the senior people, the 6 most craft-oriented and best people. They became the 7 inspectors, or the quality assurance personnel, if you want 8 to call them t, hat, or quality control personnel. You are 9 ~right. 10 All of a sudden we acquired a thing called 11' quality assurance and the utilities went around and rushed -12 into place these organizations and separated these . () 13 organizations, but there was no attention to those being 14 the best craftsmen. And there weren't -- if you were going 15 to play the numbers game and have -- well, I can tell the; 16 agency I have 20 of these people or 40 of these people or .17 200 in some cases, you didn't have those people, those 18 skilled people, the old-timers who really knew and deserved 19 to be the inspectors. You didn't have them. So.we got a 20 numbers game which conflicts with achieving real quality 21 control. 22 Quite frankly, I'd rather see 10 people handling f 23 the quality of a nuclear plant, but they would be the most 24 skilled and oldest people and they would be in, again I l 25 hate to say this, the designated reps in the plant. Then l 1[]) l I i l ACE FEDERAL REPORTERS, INC. l 202-347 3700 Nationwide Coverage 800-336-6M6

'30166.0. 58 BRT I 1 1 'you would get quality in the plant. 2 If you set up the same in the manufacturing 3 _ enterprises, Westinghouse and General Electric, you'd get 4 quality there. But we are in the numbers game, the bigger 5 the balloon the better it is, but it busts. 6 MR. MILLER: I think I_ agree with you. You are 7 talking _about the quality control -- quality inspectors. I 8 think1we had less experience -- a problem with -- they are 9 typically the people who, just by the job they do, have tc 10 know the job they are involved in. A lot of the problems-11 came from the fact that the quality assurance organizations 12 who were checking, had been peopled by people who did not 'n ! (,) 13 have strong technical backgrounds, and that's what we are 14 trying to influence. I guess the last, I don't want to 15 take up too much time, so let me just quickly go to the 16 other one initiative. 17 MR. MICHELSON: One brief question. On this 18 inspection module or' instruction, is that intended, now, 19 that the resident inspector do this? 20 MR. GRIMES: Not at this point. We are still in 21 the pilot stage. But this is to be done, now, out of the 22 regional office. 23 MR. MICHELSON: It would be a group coming out 24 of the regional office? 25 MR. GRIMES: Yes. ace FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646

l..-

30166.0-59 BRT ,m: 1 MR.-MILLER: Wo would expect this'be done in 2 - many fashions. It may be someth'ing done in a. team fashion, 3; lit may be.something_done_by-itself with the' people _from the 4 regional office.- There's a lot of different ways to do it, -5

but I don't think it would be'something that the resident-6

~ would be held accountable for doing. 7_ -MR. GRIMES: Although the same logic can be 8 ~ applied tur the resident when he looks at areas-in which he 9 is-familiar with, the surveillance area. 10 MR. HAWKINS: I think we want to. incorporate the 11 philosophy and temporary instruction into everyone who does-12 instruction, into their thinking. That's down the road. . t,p). 13 That's something we are shooting for. Right now it's just 14 for regional-based team inspections. 15 MR. MICHELSON: Just this judgmental factor, for 16 instance, deciding whether or not the person who did the 17 review was qualified to do it. That's very judgmental. 18 MR. GRIMES: The best way to test that is -- 19 MR. MICHELSON: The resident inspector is not 20 necessarily in a good position to know that. 21 MR. GRIMES: That's right. 222 MR. MICHELSON: I have trouble with the idea 23 also, from the viewpoint of, you have to ask, not alone, 24 was he qualified, but was he given the time to do it? He 25 may have been required to sign these off with a cursory ) t^~/ ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6

30166.0 60 .BRT 7, \\ i 1 examination. He may have been required to sign off without 2-time to do a good examination. Some of these utilities'get 3 in a bind for time and they sign them en masse. 4 MR. GRIMES: Also, it's not has he a-degree, how 5 many years, how much experience, as much as if we took out 6 a technical expert ourselves and looked at the same thing 7 that individual did, and assumed he had adequate time to 8 look at it, and we find something he did not, we are in 9 direct evidence -- 10 MR. MICHELSON: Your look at one area or one 11 component might pick up on the fact that although he was a 12 qualified reviewer he didn't spend much time doing it and ji j 13 therefore didn't pick up on the problems. That would have 14 implications for how many other things that he reviewed in 15 too cursory a manner. 16 MR. MILLER: The other thing that this temporary 17 inspection is intended to do, or this philosophy is going 4 18 to do, is deal with that very problem you talked about 19 earlier where we have all these programs out there approved 20 by the NRC and that meet the letter of every one of the 21 quality assurance standards of the ASME, NQA and so on, and 22 yet somehow don't work. And, so, this is really a test of 23 effectiveness, as opposed to just looking at paper to s 24 determine the health of a program. 25 MR. MICHELSON: I didn't hear any plan of AV ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646

[ t' l-3016 6. 0 61 BRT /,, l: ~ .1 implementation on this. p-2 'MR. MILLER: Right. We'have conducted several ~ 3 partial -- we made several attempts to implement this 4 already this year. I say partial, I mean partial because 5 we are very late in the inspection program ~for some. 6 -Diablo Canyon and Crystal River, I believe, we: attempted to 7 begin the process for incorporating this. We had plans for 8 how many other' inspections to issue? 9 MR. HAWKINS: We are going to do one at each 10 Region, minimal. 11 MR. GRIMES: This will be a cooperative regional 12 headquarters effort. Lee will be.the Region but we will ( 13 provide the personnel -- 14 MR. MICHELSON: Apparently this is th'e answer to 15 my concern about why does it take so long to find out 16 somebody is in trouble? This is one of the ways you are 17 going to use, searching to see if there's a troubled area.- 18 Are'you going to pick, then,.who you think might 19 be in trouble to do the inspection on? 20 MR. MILLER: I think the idea is to pick, not a 21 plant that has overall problems, but a plant that the 22 regional inspection force believes is weak in just an area, 23 very much so. The payoff has to be where you think there 24 is a problem, as opposed to going where you are not -- 25 where we don't have any evidence of a problem. J ACE. FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646 i

-30166.0 62 ERT 1 The other thing I would like to mention briefly 2 is the readiness review program that has been undertaken on 3 a pilot basis at Georgia Power's Vogtle facility. The 4 quality assurance branch within the office has had the lead 5 on the programmatic point of view in that case. We are to 6 be issuing a report to the-Commission, in fact this month, 7 on the results of that pilot program. There's a meeting 8 this afternoon on the granting of a full power license for 9 Vogtle. The program is essentially complete. I think you 10 have been briefed before on the concept of readiness review. 11 I won't go into the details, but the basic ingredients are 12 these: that you break this large program of construction n() 13 down into discrete parts and you set up a system whereby 14-the utility, first, in a structured way, bringing in senior 15 management, far before the point where you get to the end 16 and you say you are ready to receive the operating license, 17 far before that point, in process you have senior 18 management involvement where they test, area by area, 19 whether the licensing commitments have been met or not. It 20 is done in a structured way so that there is a reasonably 21 good documentation of the basis for making those 22 conclusions. 23 We found that in this program the objectives of 24 the program, of adding stability to the licensing process, 25 identifying problems early as opposed to waiting until the V ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646

cr 30166'.0 63~ 'BRT \\'~/ l very end, has been -- was achieved; that the resolution of 2 dif ferences of interpretation on regulatory requirements 3 was achieved to the extent to which it could be done. In 4 the Georgia Power case -- and I should-point out that in 5 this case the readiness review was initiated when the plant 6 was fairly well along in construction, so this wasn't a 7 complete test of the readiness review as a concept that 8 might apply to a future plant or from beginning.to end. In 9 general, I think.the feeling of the Staff and the 10 inspection force was that, by Georgia Power going through 'll this process, we marching along with them, that there was 12 --an additional assurance added to, and confidence, that that (_) 13' plant'was constructed properly and that Georgia Power is 14 ready to operate. 15 MR. MICHELSON: QA was not a part of the 16 readiness review process, were you? 17 MR. MILLER: Well, it involved -- 18 MR. GRIMES: It really originated with the 19 person who, at that time, was head of the QA organization, 20 Mr. Rice. I 21 MR. MICHELSON: QA wasn't the thrust, was it? 22 MR. MILLER: QA, in a large sense, yes. What 23 the utility did, and I've lost some of the details, but 24 they set up an organization separate from the line 25 organization and staffed it with technically savvy people i (~T V /kCEJFEDERAL REPORTERS, INC. 1-202-347-3700 Nationwide Coverage 800-336-6646 k

.30166.0 64 BRT I to do an audit,' essentially, of the program in all areas, '2 not just.in construction, but also.in' design. 3 MR. MICHELSON: Okay. 4 MR. MILLER: So you had a very strong QA -- S MR. MICHELSON: It was certainly an element in 6 the process although it wasn't, as I understand it, it 7 wasn't the thrust of it. 8 MR. GRIMES: It wasn't restricted-to the 9 tra'ditional OA organization. 10 MR. MILLER: This in a sense was an add-on 11 program for the utility. They made estimates of $30 to 112 $40 million, I believe, but they had said in a letter to j). (_ 13 the Commission that they believed it was a very worthwhile 14 thing that paid for itself, from their point of view. 15 MR. MICHELSON: Let me ask you another question 16 relative to the quality control. Perhaps this is answered 17. by the readiness program. 18 I see things happen in LERs, and I wonder, gee, 19 how did that ever get through the preoperational test 20 program? Why didn't they pick that up? Why didn't they 21 find that they had the wiring wrong and so forth? It 22 should have been picked up in testing. 23 I'm sure you ask the same kind of questions. Do -24 you go back into the preoperational test program and 25 examine the capacity control exercised during'that period .O l' ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6 4 6

130166.0 65 BRT ( ) 1 of-construction? Because that's a very critical time in 2 which to find where'your problems are and get them properly 3-corrected. And if it is done with poor control-of'the 4 quality of. work, it has to wait until you have an operating-5 event to find out. 6 Clearly, many of these events had to have been 7 picked up or should have been picked up, I should say, 8 during preoperational work, and they just weren't. And 9 -nobody can explain why it was wired backwards. Why didn't 10 they find it out when they tested it? 11 So, do you go back and focus on preoperational 12 testing as an area to look at how well they control quality ) 13 of the work? 14 MR. PARTLOW: I don't think these readiness 15 reviews went that deep. When that happens, it is probably 16 more a matter of the quality of the test as opposed to the 17 quality of the work. 18 MR. MICHELSON: Right. Yes. It was just a poor 19 test. They didn't do it right. 20 MR. PARTLOW: It goes all the way'back to the 21 quality of designing the test. 22 MR. MICHELSON: Isn't that part of OA? As I 1 23 recall it says in there it includes testing and so forth. 24 Do you ever go back and investigate the quality control 25 exercise during testing? O ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6

30166.0-66- .BRT- \\',/ 1 MR. PARTLOW: I hesitate to again say SSFI, but 2 that is one of --- that system functionality -- .3 MR. MICHELSON:- But that's, again, way after the 4 fact. It doesn't really. focus on why -- was there a 5 quality breakdown? 6 MR. MILLER: I think you do do that. I can give 7 you some examples at TVA right now. I know they are in the 8 TVA case,Lwhere there have been some things found to go 9 back to something that happened in the initial design. 10 _There are two aspects that you look at. One is, it's too 11 late to worry about why it happened at that point, to 12 incriminate anybody at the time. But you have to know () 13 where else it may be a problem so you can look. technically 14 to determine that,.so that is being done. And then you 15 have to look to see did we pick up all the lessons learned 16 from that_in structuring the current OA/QC programs. l-17 MR. MICHELSON: ' My question was what kind of 18 program do you have for inspecting -- examining the quality l 19 control exercise during preoperation and testing? I don't 20 want to get an answer now, but it might be one we might 21 want to hear about some day, just as a case in point, 22 because I wonder how these things get through the 23 preoperational test and all the way into operation before 24 they find out the leads were in backwards. This shouldn't 25 happen unless somebody went into the cabinet later and /^T l \\_) [ ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 800-336-6M6

'301'66.0' 67 BRT Y) - 1 jiggled them around again. But a numbe'r of these things 2 just: shouldn't - I don't know how they escaped testing.- -3 It's simply unclear. 4 Have you ever gone in or what, program do you .5 have that even looks at preoperational testing from the 6 viewpoint'of quality control?' 7 MR. HAWKINS: There's a series of modules-on'the 8 2513 program. 9 1M R. PARTLOW: We do our own observation of testing. .It becomes the three phase -- we review the test-10 11-plans for selected cases, we observe the actual testing in 12 some cases, and then in other cases we review the test (, 13 results. 14 MR. MICHELSON: Later-on, when something happens '15 that clearly should have been picked up in that process,' 16-does the agency go back to ask itself why did it get by us; 17 and secondly, why did it get by the utility as-well? 18 MR. PARTLOW: No, in all honesty we don't ask 19 ourselves that question. 20 MR. MICHELSON: Really once in a while it might 21 be helpful to see why the process doesn't work, because I 22 really believe that most of the operating problems could be ( 23 found if you had a really good preoperational test program, l 24 but we, apparently, don't have a good enough one; and I l 25 therefore we should be wondering how to improve that. And ACE FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 800-336-6646

30166.0 68 IRT L g I we do that by saying well, gee, we watch but maybe we 2 aren't watching it well enough. And.the utilities have -3 controls, but maybe they are not good enough. 4 MR. PARTLOW: If the committee has yet, I don't-5 know if you:do, draft agency strategic plan, there's a 6 section in there that's rather heavy on this subject called 7 the transition from construction to operations. It speaks - 8 very much to this area. 9 MR. MICHELSON: That's when it occurs. I was 10 just wondering what thoughts you'had ever given to looking 11 at LERs from the viewpoint of which ones indicate that 12 sometting went wrong during testing, and going back on an ..() 13 audit basis or a few-case basis and chase it back, once, to 14 see why our programs don't work. You know? Because I know 15 .that the NRC watches most of the pre-op tests, in fact. 16 MR. GRIMES: Let us consider that as one '17 possible input to our TI inspections. 18 MR. MICHELSON: Well, think about it, anyhow. 19 It has often puzzled me. I'm sure it's puzzled you also 20 when you see things that happen and say, gee, it had to 21 have been that way at the time of testing and yet we didn't 22 find it. What's wrong with our program? 23 Okay. Thank you. 24 MR. GRIMES: I think that completes the OA 25 branch. .i ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646

30166.0 69 BRT l I 1 MR. MICHELSON: We are running a'little.behind, 2 but I find it most interesting; but I want to ask the 3 members-what.are your travel plans, so we don't screw up 4 -the departure times? -5 MR. WYLIE: I'm open. 6 MR. MICHELSON: What time is your departure? 7 MR. REED: My departure has-to be, so I can make 8 my handicaps, a 2:50 plane out of National. 9 (Discussion off the record.) 10 (Recess.) 11 MR. MICHELSON: Let's proceed. 12 MR. GRIMES: Let me remark the technical l ) 13 training center has been part of I&E since the '70s, it was 14-to Chattanooga partly as a low-cost area to conduct 15 training for all the regional offices, and partly to take 16 advantage of the simulators which, at that time, were 17 ' located at the Sequoyah site. 18 MR. REED: Aren't they still there? 19 MR. GRIMES: The Sequoyah is, the Bellefonte 20 has -- been to the Bellefonte site -- we have taken some 21 initiatives because of that. Over the last two years we 22 have significantly upgraded the physical plant at the TTC, 23 -by the addition of a boiling water reactor control room 24 simulator which was formerly destined for the Black Fox 25 plant, which was canceled, and two scale engineering models , ~. Ace FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646

c30166.0 '70 'ERT x '( i-1 from canceled TVA plants, Hartsville, a boiling' water-2 reactor,'and Yellow Creek, a bus engineering. 3 MR. MICHELSON: You'mean the plastic model? 4 MR. GRIMES: The large room full of engineering 5 detail. 6 We are also in the final stages of negotiations 7 for a pressurized water reactor control room simulator 8 .which we hope will be installed and operational this summer. 9 MR. MICHELSON: Is that from a plant that 10 canceled also? 11 MR. GRIMES: It's a SNUPPS simulator now located 12 at the Zion facility owned by Westinghouse. ,9 (_j 13 I will juct note in the new organization this 14 will continue to report to a technical organization which 15 we believe is very important, technical management overview 16 of the content and thrust of the training programs for the 17 technical people in the agency. That will be under Ed 18 Jordan and AEOD, so I'll turn it over to Ken Raglin now to 19 go over some descriptive remarks on our Commission and 20 facilities. 21 MR. RAGLIN: I am Ken Raglin, director of the 22 technical training center. I would like to talk about four 23 general areas: just general information about the 24 technical training center, some words about the TTC 25 curriculum, the type of students that we serve, and finally, O ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6

30166.0-71- .BRT n a i. 1 theLuse of training aids within the TTC curriculum. 2 The mission of the technical training center is 3 historically -- 4 MR. MICHELSON: Before you leave the curriculum, 5 .I1 guess you are not going to say much about it,'could you 6 send me a copy of the current offerings? 7 MR. RAGLIN: I am going to say more about the 8 curriculum. 9 MR. MICHELSON: I would like to get a copy.of 10 the current offerings. I haven't looked at one in years. i 11 I have. attended a couple of the courses in the distant'past 12 and found it to be a very impressive operation. I havec rh t,) - 13 nothing but good to say about what's. happening down'there. 14 I would-like to see what's changed. 15 MR. RAGLIN: The mission of the training center .16. has' historically been to develop and implement a program 17 for training reactor inspectors, primarily a program 18 focused on reactor tachnology. 19 The training center staff has provided initial 20 and refresher-type training required for inspectors; again, 21 focused toward reactor technology primarily. I guess I 22 would say that what we are doing is providing the 23 inspectors with a number of tools that they can use on the 24 job, and it's part of an overall inspector qualification 1 25 program, of which the TTC represents just one element. ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6 .~

30166.0 72 BRT u,, ( 3-1 -MR. REED: ~ The-inspectors have already been 2 hired and they are sent for-training. I was going to ask -3 the question, whether _ you are accepting warm bodies-through - 4 the door or whether you have some criteria for acceptance, 5 'but since they are already hired you are in the chain of 6 events. You apply nothing to initial requirements and 7 qualifications? 8 MR. RAGLIN: All of.the people coming through 9 our. courses are NRC employees or other government officials 10 with the same type of need to know, and foreign 11 counterparts..The students coming are already on board NRC 12 Staff. (~)s 13 We have' reached our maximum class sizes in a g_ 14 number of the classes and we are almost always fully booked. 15 We allocate slots to the different Regions or user offices 16 and they send the new people through the pipeline. 17 MR. REED: This would be a nice place to conduct 18 some research. It probably would never be approved by 19 anybody as being properly conducted. But if you were to 20 give natural ability tests to these people, just the first 21 day orientation, give these natural ability tests, look at 22 the grades, file them away and then let them go through the 23 system and finally be graduated, it would be interesting to 24 see the meaning of natural ability versus level of activity 25 and training that you are trying to give. i l ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646

i 30166.0~ 73 .BRT .(' l'" 1 MR. RAGLIN: I would have to say in regard.to 2 that,-in the past,_ students th'at we would typically see had 3 more experience than the students we typically see now, 4 more operational experience in power reactors. So it's 5-probably more important now than it was a few years ago 6 .because we are starting at a lower level. 7 The line organization of the training center has 8 been addressed before. 9 (Slide.) 10 We have historically been IE, and going to.AEOD. 11 The training center is physically located in Chattanooga, 12 Tennessee. Nice facilities for training. We have several f 13 classrooms, designated areas for engineering models and 14 other training aids, as well as the office complex for the 15 technical training center staff. 16 The budget of the training center consists of a 17 staff of 23 full-time equivalents and a fiscal budget 18 roughly on the order of $2.5 million annually. Of the FTEs 19 on the staff, 20 of those positions are technical. The TTC 20 staff represents a blend of people with degrees and a great 21 deal of operational experience. Approximately -- the 22 average experience of the TTC technical staff is 23 approximately 16 years in the nuclear field, and on the 24 staff a total of 12 former senior reactor operator licenses 25 or senior reactor operator certifications, which is ACE FEDERAL REeonTens, INC. 202-347 3700 Nationwide Coverage 800-336-6646

4 130166.0-74 BRT. 'U 1 relativelyLa.large congregation of those types of people 2 within the-NRC. 3 An initiative that has taken place within the 4 training center, within the last year, has been_the 5 implementation of an instructor qualification program, a '6-formal program for qualification. This is a structure not 7 unlike that of the inspector qualification program. It 8 includes signature cards, practical factors that must be 9 accomplished and culminates with an oral qualification '10 board. So we feel that we are emphasizing the importance. ~11-of the instructor qualifications. 12 The fiscal budget of the training center is (')N 13 roughly $2.5 million, which can roughly be split out as q, 14 S1.5 million associated with reactor simulator training. 15 We provide the training in the four major U.S. 16 Reactor vendors, General Electric, Westinghouse, Combustion 17 Engineering, and Babcock & Wilcox. That does represent a 18 considerable part of our budget. 19 MR. GRIMES: The way that is conducted is to 20 lease simulator time, except for the one that we have on 21 lease / purchase basis right now at the facility, and to 22 provide our own instructors. 23 NRC instructors, the money and budget is for the 24 equipment on which we train. 25 MR. RAGLIN: Also in that $2.5 million is + i /\\CE-FEDERAL REPORTERd. INC. 202-347-3700 Nationwide Coserage 800-336-6646

q 30166.0 75 CRT-l' 'approximately a. half a million devoted to what we call 2 other specialized technical training, areas that are 3 typically nonreactor areas that require contracted training 4 frequently. That's a considerable part of the budget. And 5 the remainder is associated with the administration of the. 6 TTC building lease costs and otner administrative items. 7 (Slide.) 8 The curriculum of the technical training center 9 is determined based on the needs of the agency. There is 10 an-annual need survey that is conducted by the Technical 11 Training Center. Historically, the emph& sis has been 12 towards reactor inspectors and the mainline part of the () 13 training program has been further focused on resident 14 . inspectors. We do recognize a number of other needs, 15 however. 16 The solution to the technical training needs, 17 however, is to develop a spectrum of courses. That 18 spectrum of courses includes what we call generic courses. t 19 Some examples of that type of course would be reactor 20 concepts, fundamentals of inspection, power plant 21 engineering, which is a course that was given for the first i 22 time last year, designed to bridge the gap between the 23 theory people get in engineering degrees in college and the 24 applications they are going to see in the power plants. j 25 Another example would be motor-operated valve training. f i ( i-Ace FEDERAL REPORTERS, INC. 202-347-3700 Natianwide Coverage 800-336-6M6 I

~ "30166.0 76 BRT' L'f ~ 1 MR. MICHELSON: Just as an example, how long:a 2' training course-is-it? 3 MR. RAGLIN: Three~or four days. We'just had 4 one in the last month. There's another:one scheduled real 5' soon; .6 MR.'MICHELSON: Along the same line, do you 7 offer anything in fire protection? 8-MR.,RAGLIN: Not presently. 9. MR. MICHELSON:'.You don't have any kind of 10 training program? ~11 MR. RAGLIN: No. 12 MR. MICHELSON:' Just as an aside, how do our

()j 13 inspectors become proficient in understanding the types of 14 Lfire protection devices, importance, safety significance, 15 vulnerability to actuation and'all this. sort of thing?

16 They just pick that up as they go? 17 MR.' GRIMES: We should also mention 68 -- 18 MR. JORDAN: We, the regional office, hire fire b 19 protection-type experts in addition to the NRR Staff, and 20 then the inspection modules related -- ) 21 MR. MICHELSON: Of course, if you can find the i 22 right expert. I have not found too many that not only l: - 12 3 un'de rs ta nd fire protection very well, but also understand 24 the nuclear power plants very well. I can find fire 25 protection experts very well who understand fires l t /\\CEJFEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646

p 4 30166.0 3 77 BRT I significantly but don't undecstand the significance of one, 2 in a nuclear power plant. s 3 MR. JORDAN: We couple them with nuclear ' systems, 4 so -- 5 MR. MICHELSON: But -- hopefully together, but 6 there is no formality of training inspectors in this area. 7 MR. - RAGLIN: One of our reac. tor Cechnology 8 courses, the advanced technology cQ6rse, we'do provide some } 9 coverage of fire protection; within the cource panuals 10 there is a chapter on fire protection systems. Altogether 11 that's -- we are talking.abcut a module in the classroom 12 that might last two to three houra. We just briefly touch I) 13 on fire protection systems. 14 MR. MICHELSON: Would it be an imposition if you 15 would send me g copy of that portion of the manual that n 16 deals with fire prutection? I would just like to see it. 17 That's the only exposure within the training 18 school that you have? 19 MR. GBIMES: Also general agency training, if 20 there are specialized training courses for fire people, not .? 21 necessa"rily nuclear fire protection systems, but if there ~ 22 was a general commercial course available there is the 23 ability to send an individual to that commercial course. 24 That is taken advantage of, too. 25 MR. MICHELSON: In lieu of do'ing'it yourself you ,9L.) Acu. FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 800-336-6646

&{ ' x w 30166.0 78 . CRT ' 3 ,3 i^^ 1 just go out to the commercial contractor who provides that 2 service. W*. 3 MR. JORDAN: I think I'would add for the fire i 4 protection experts we've hired in the Region, they get 5 integrated eventually and go through the TTC reactor 6 systems. ] 7 MR. MICHELSON: There are very few courses that ] 8 a nonnuclear person might be'able to take. ~ 9 MR. GRIMES: We do have one week courses which - 10 are slanted more toward the engineering, more general /m ll inspectors in-the Regions, than this complete technology 12 series, which is really aimed towards the resident ( i 13 inspector. 14 There are different degrees of difficulty of 15 courses that can be taken. Certainly fire protection 16 inspector might well take one week BWR technology, and one 17 week PWR technology. 18 MR. MICHELSON: He might try at least. (- ' 19 MR. RAGLIN: Those are very difficult and P 20 intense courses. 21 MR. MICHELSON: I took those a long time ago. I 22 would say a person, unless he has a little understanding of 23 nuclear power to-begin with, would get lost about somewhere 24 through the first hour of the first day. 25 MR. GRIMES: Ken should mention these are very i ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646

Y b i) 30166.0 79 ERT 1 intensive courses, and the testing we do at the end, also, 2 determines -- whether people know the subject. 3 MR. MICHELSON: That's why I was particularly 4 interested in what you might offer on fire protection. 5 When you do offer something, in my experience it is good. 6 MR. RAGLIN: Okay. tr 7 (Slide.) 8 The second broad category is reactor technology 9 courses. That includes coverage of the boiling water i 10 reactor design, the pressurized water reactor design, and l 11 some coverage of the high temperature gas reactor design. 12 I'll expand a little bit on the boiling water and (; 13 pressurized water reactor courses momentarily. 14 A third broad category would be reactor 15 engineering support courses. They used to be called 15 construction courses. We are talking here about subjects 17 such as welding technology, instrumentation, codes 18 technology, electrical instrumentation and codes technology, 19 and nondestructive examination. Those would be some examples of that category. 20 21 Another category is safeguards courses, which 22 would involve such things as nuclear materials courses and 23 courses associated with intrusion detection systems, for 24 example. 25 The other broad category up there is the physics /\\ i ) '/ ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6 s

p 30166.0 80 CRT: ym,. i 1 courses, which would include courses such as BWR or PWR rad 2 waste systems; safety aspects of industrial'radiolography, 3 transportation of radioactive material, radiation 4 contamination and protection courses. Just to give a few 5 examples. 6 MR. GRIMES: I guess we should say, except for 7 the technology courses, there's a fairly high content ~of 8 contracted-out for courses. In the safeguards area we 9 don't staff the Chattanooga center with safeguards experts. 10 We, rather, have a solicitation for bids on the safeguards 11 course which meets our objectives. 12 MR. MICHELSON: They come in and offer that at /~$ () 13 the school? 14 MR. GRIMES: Or at some other location; a 15 particularly things that require lab facilities.- NDE, for ^ 16 example, may be done at a laboratory in anottor location. 17 MR. RAGLIN: The typical loading on the training 18 center has been about 1600 student-weeks annually. That 19 includes everything that our staff formally presents and 20 everything that is done through contracts that are c 21 controlled through the TTC; DOE agreements or anything that 22 we are associated with. We do cycle in a number of people 23 on an annual basis. 24 The major thrust, historically, has been the 25 reactor technology training. That's where most of the TTC . (~; ' (./ ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 800-336-6M6

. rm - ) ?' V ) r l U _81-j p 130166.0 f' BRT: U /~Ti 1 Staff effort-is directed. LWe provide coverage of the four f s g ( 2 major.U.S. Reactor vendors: General l Electric, Westinghouse, l .i 1 3 ' Combustion' Engineering and Babcock & Wilcox. We provide l i I. 4 _both. classroom training and reactor simulator training for { 3 i l' 5 all of-those vendor technologies. l: I 6 Within the reactor technology curriculum there t 7 .are: essentially two types of courses,-those which are i 8 associated with a course series and those which are 4 i 9 stand-alone courses. 10 The major pipeline for the resident inspectors l-11-and other operational reactor type inspectors involves a i I 12 series of three courses at the training center, or wherever l ) 13 the reactor simulator might be. 14. The first of these is a systems level-technology. i 15-course; second is an advanced technology course; and the 16 third is a reactor simulator course. Within the systems 17 level course, the points we are trying to deliver there are t. 18 the functions of the major systems at the power plant, i 19 major components, potential problems, and system interfaces. i I. 20 We typically provide coverage of reactor core .{ 21 characteristics, primary and auxiliary systems or secondary 22 systems, in case of PWRs, process instrumentation and 23 control systems; containment systems; neutron monitoring I t 24 systems; information and display systems; reactivity 25 control systems; rad waste management systems; and O f Ace FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coserage 800-336-6646

W-30166.0 82 ERT g - [ ~ 1 emergency core cooling systems. 2 The second course,-the advanced technology f 3 course, is designed to integrate the system knowledge that 4 was picked up in the first course. We have major 5 subgroupings within that course associated with transient 6 analysis, technical specifications, operational events and 7 technical issues. 8 Within our transient analysis study, in the 9 advanced technology course, we cover how the different 10 systems interact with one another. If you put a 11 perturbation on the system at one place, what are the 12 effects other. places within the overall reactor system? ,r3 (_) 13 Our coverage of technical specifications 14 involves acquainting the inspectors with the general 15 content of typical plant technical specifications. 16 Our focus is to provide an understanding of the 17 bases of the technical specifications and emphasis on 18 safety limits, limiting conditions for operatior, limiting 19 safety system settings. i 20 The operational events portion of the advanced 21 course involves log summaries and other write-ups of other -- 22 actually reactor events that have happened over the last 23 several years. We analyze the events with the class, talk 24 about what went right, what went wrong, what could have 25 been done better, some of the lessons learned, some of the 'G t.) ACE FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coverage 800-336-6M6

30166.0 83 LBRT / g-(# 1 outcomes of those events that have happened. h 2 Finally, the technical issues represents an area 3 that we can slide material-in and out of the advanced 4 technology course based on what the important technical 5 issues are with the agency at the time.- 1. 6 In the past we have provided coverage of BWR 7 Mark I containment modifications,.feedwater sparger 8 modifications, that type of material. Today that material 9 typically includes discussions about anticipated transients 10 without scram. 11 MR. MICHELSON: How about other accidents? 12 Accidents beyond the design basis? Do you get that ( )) 13 philosophical at the training school? 14 MR. RAGLIN: We haven't but that's something 1 15 that could be done and it would be -- it would fit in with 16 the idea of the technical issues. 17 MR. MICHELSON: Thus far you haven't attempted, i 18 though, to instruct the students in considerations of 19 severe accidents? 20 MR. RAGLIN: Recently we have introduced 21 training in the owners' groups emergency procedure 22 guidelines. We provide that training in the classroom, in 23 the advanced course if there is an advanced course for the 24 technology. 25 MR. MICHELSON: Is there actually a training ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 800-336-6M6 . _, - - - - - -, -, _.. =

..y..___.. [ L i I r.. - h 30166.0- '84-t E f , ERT j. > a l 'l module now on emergency procedures and guidelines? Or is [ ' it just;something you talk about as_a part of another- [ 2 4 t [ 3 course? (- L f 4 MR. RAGLIN:- We talk about it withinLthe [ 5 advanced technology course and then.we hit it again in the 6 simulator course where we are able-to use the safety parameter display system or emergency system response j [ 7 8 _ system as appropriate. j 9 MR. MICHELSON: Okay. Thank you. i 10 MR. RAGLIN: Then the third course in the series- -11 is the reactor simulator course. In that course, we L 12 provide'the inspectors some hands-on training at the l j t r~s i -( ) 13 controls. We are not trying to make operators out of the i 14 inspectors. That's not what their job is. t 15 What we are trying to give them is an l 16 appreciation for what is involved in starting up and l t 17 shutting down the major systems and the plant; relative 1 l 18 difficulties in performing different systems operations, l 4 l l-19 and we cover a number of transients in the simulator course, i l Il 20 transients and events. Some of them we expect the students i 21 to take some action on. Some of them we are just trying to ] f 22 make a point and we just want them to observe while we 23 point out some of the things that happen. 24 That pretty well hits the course series courses. i l 25 MR. MICHELSON: As a matter of clarification, i i i /\\CEJFEDERAL REPORTERS, lNC, 202-347-3700 Nationwide Coverage 800-336-6M6 i

30166.0 85 ERT-1 you indicated earlier that within the building you have now 2 the Hartsville model? 3 MR. RAGLIN: Yes. 4 MR. MICHELSON: I thought you had said one other? 5 MR. GRIMES: Yellow Creek. 6 MR. MICHELSON: You must have taken over a few 7 more floors of the building, then? 8 MR. GRIMES: No, but we filled up all the lounge 9 spaces. 10 MR. RAGLIN: We used to have a larger student 11 lounge than we presently do. 12 MR. MICHELSON: That model of Hartsville alone /,() 13 is three quarters of the size of this whole area here. 14 MR. RAGLIN: It would probably fill up from this 15 table to the wall easily. We didn't get the entire 16 Hartsville engineering model. We selected portions. We 17 got the containment, auxiliary buildings, different 18 sections, and the turbine building. And some sections of 19 the rad waste building. 20 MR. MICHELSON: I see. Too bad you didn't get 21 it all. 22 MR. RAGLIN: We didn't have room for it all. 23 MR. MICHELSON: I was wondering where you put it 24 all. That's the explanation. You may do with it what you 25 could. What did they do with the rest, junk it? 0; \\.s ACE FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coserage 804336-tM6

30166.0-86 'BRT m ( ) 1 MR. RAGLIN: Probably still at the warehouse ~at 2 the Hartsville site. 3 MR. GRIMES: As a matter of fact, we had it-on a 4 $100 a year lease from TVA, so it's theoretically being 5 maintained still. 6 MR. WYLIE: What's the scale? .7 MR. RAGLIN: Quarter inch to the foot. The 8 Combustion Engineering model'is, I believe, 3/8 of an inch. 9 It's a little larger. 10 Our curriculum 17cludes a number of stand-alone 11 courses. Brian had mentioned these earlier..They are not 12 directed toward the resident inspectors, perhaps directed .c 13 towards some of the other inspectors or other NRC Technical 14 Staff. 15 One-week classroom only courses, and also 16 discrete one-week simulator courses. 17 We also offer a combination classroom simulator 18 courses -- course for technical managers in each of the 19 reactor technologies. 20 MR. GRIMES: I might remark if any ACRS members 21 were interested in taking the technical managers course, 22 Commissioner Carbon did so within the last few months and 23 it is at an appropriate level to discuss the differences 24 between different types of a particular technology and what 25 the key considerations are from a manager's standpoint U(~~ l ACE-FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coserage 800-33M646

30166.0 87 1CRT h ?~'?' I combined with giving you a feel for what the simulator 2 control room operation is like through the use of the 3 simulator.- 4 MR. MICHELSON: What's that, three-day? 5 MR. RAGLIN: Yes. Three days. 6 The other major area outside of reactor 7 technology is basically everything that's left. That's 8 what we call specialized technical training. 9 Our experience has been that the further we 10 diverge from the reactor technology, the more difficult:it 11 is to provide the training _because the needs of the 12 individual inspectors are very specialized. Consequently, () 13 the approach in the past and in the future will probably be 14 through the use of contracts where we are able to go out 15 and get experts in that particular field. 16 MR. MICHELSON: In the case of fire protection 17 you say you use the outside contractors, underwriters or 18 whoever is running the special class. Are those L 19 coordinated in the agency through you, then, or are they 20 done directly? 21 MR. GRIMES: No. That's through the Office of 22 General Employee Training and Personnel. That's a separate, 23 individually initiated thing that does not come through the 1 24 training center. 25 MR. RAGLIN: A lot of other very specialized O ACE-FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coserage 800-336 4 46

30166.0 88 BRT ,3 ~~ 1 areas do come through the training center, where we are 2 coordinating contracts. 3 The use of contracts has been essentially out of 4 necessity. The training center staff doesn't have the 5 expertise in these specialized areas. The emphasis of the 6 staff down there has been directed toward the reactor 7 technology curriculum, consequently the contracting process 8 has been the chosen method. 9 Some examples of these contracts are the, oh, 10 new contracts on welding technology and codes, instrument 11 technology and codes, electrical safety aspects of 12 industrial radiography and several more that are coming on n() 13 down the line. 14 This area will require future TTC emphasis 15 because there are a great number of very specialized 16 inspectors within the agency, whose training needs are just 17 as valid as those within the reactor areas. 18 (Slide.) 19 There's a slide up there now that shows the type 20 of students that typically come through our courses. It 21 has included over the years resident inspectors, 22 Region-based project directors, engineering support 23 inspectors, operations center or duty officers, operator 24 license examiners, technical managers, other NRC Technical 25 Staff, and personnel from foreign countries. p L.) ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 80F336-6M6

r 1 30166.0 89 'CRT A( #. 1 1 What I'm talking about here is NRC foreign ~ 2 counterparts that come through our Office of International 3' Programs and sometimes go through the courses in 4 Chattanooga. 5 Also, over the last 12 years, the foreign 6 countries listed have requested reactor technology courses 7 in the host country and our Staff has provided those 8 courses. It looks like a total of 12 courses over 12 years:- 9 Brazil, Republic of Korea, Mexico and Taiwan, having 10 requested and received more than one of those courses. 11 (Slide.) 12 The final area I would like to mention is the () 13 use of training aids within the TTC curricula. 14 First on the list, there is the reactor 15 simulators. Within the last two years, as mentioned 16 earlier by Brian, we have succeeded in getting a boiling 17 water reactor simulator physically located in the same 18 building as the trairing center. We are in the final 19 stages of completing an agreement which will allow 20 relocation of a Westinghouse PWR designed SNUPPS simulator, 21 also within the same building in Chattanooga. 22 The advantages are tremendous to the agency by 23 having these simulators available to us down there. We 24 have been able to achieve the acquisition of these 25 simulators within the existing budget that we otherwise p/ x_ ACE FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 800-336-6M6

130166.0 90 .BRT ('#b 1 would have spent on BWR simulator-training or Westinghouse 2 PWR simul'ator training, the amount of time that is now 3 available to us is two to four times as much as before and 4 we are able to train on day shift. 5 I don't know whether any of you have ever worked 6 night shift before, it's very difficult. And it's even 7 more difficult to receive training on night shift and 8 that's what we-have been faced with for a number of years 9 and we are finding ways around that now. 10 Another major area of training aids is the 11 reactor plant models. The BWR model is the Hartsville 12 model from the canceled TVA flartsville project,.BWR VI () 13 design. One that we recently got is the PWR engineering 14 model with the Combustion Engineering Systems 80 design. 15 That's f rom when TVA canceled the Yellow Creek project. 16 And, then, a smaller table top nuclear steam supply system 17 model that we have received even more recently, which shows 18 the nuclear steam supply system for the Babcock & Wilcox 19 design. We were able to obtain that model from Consumers 20 Power in the canceled !!idland project. 21 These models represent a means for the training 22 center to come as close as possible to having students go 23 out to a real plant and trace the systems. They are 24 detailed enough so that the students can find the major 25 valves. They can find the pumps. They can find the system O ace FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coserage 800A36-6M6

30166.0-91 ERT 1 interconnections where one system physically taps into 2 another. 3 We feel it has been a real advantage to the 4 effectiveness of the technology training down there. 5 Another area deals with hardware training aids. 6 As part of the BWR simulator contract, we were able to have 7 included a number of nuclear components configured as 8 training aids. These include a BWR dummy fuel assembly, 9 cut away so that the internals can be viewed; a BWR control 10 rod drive mechanism, which was cut down the middle and then 11 cut into sections so that the internals of a control rod 12 drive mechanism can easily be viewed; a BWR jet pump ,o ) 13 assembly, BWR hydraulic control unit; and, recently, a s 14 pressurized water reactor dummy fuel assembly for the 15 Westinghouse design. That was a training aid that we were 16 able to obtain from the canceled Marble Hill project. 17 MR. MICHELSON: To what extent do you use the 18 TVA training facility valve laboratory or whatever you -- 19 training laboratory that they have? Is that used for your 20 three-day course? 21 MR. RAGLIN: Yes. That's where the motor 22 operated valve training was conducted out there at the TVA 23 facility through a modification of the NRC/TVA interagency 24 agreement. 25 MR. MICHELSON: Okay. Thank you. /~N ) (_ ACE FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coserage M433MM6

n 30166.0 92

BRT-I 1

MR. RAGLIN: Other hardware, we are seeking out, 2 involves surplus material, first of all, from canceled TVA 3~ projects.- We are in the final stages, I would say, toward 4 procurement of a number of hardware items from these TVA 5 projects, different types of valves, some pumps, other 6 hardware that students will be able to see at the training 7 center when they come through the courses. 8 MR. MICHELSON: By now, you must have more space 9 than you used to have. 10 MR. RAGLIN: At backs of the classrooms. Move 11 the desks closer -- 12 MR. MICHELSON: Are you checking the. floor () 13 loadings, too? 14 MR. GRIMES: The control room simulators are in 15 different floors. 16 MR. MICHELSON: Those must be in the basement. 17 MR. RAGLIN: The BWR is two floors up, the PWR i 18 is in the first floor. 19 MR. GRIMES: The PWR has hollow panels and the 20 BWR does not. 21 MR. MICHELSON: So it's in the same building you 22 were in before? 23 MR. RAGLIN: Yes. Ever since we were in 24 Chattanooga. 25 Finally, with respect to training aids, the TTC l I /\\CE FEDERAL REPORTERS, INC, 02-347-3700 Nationwide Coverage 2 0-336-6646 i

30166.0 93 BRT ^ - ' 1 .is exploring the use of high technology training aids ~2 within the curriculum, and by that I mean the use of 3 quality videotapes commercially produced, video disk 4 systems that two or three companies now produce that have 5 on the video disk maybe 40,000 slides of a particular 6 nuclear-plant and you can take a tour through the plant via 7 the video disk. We are looking at projection TV equipment 8 for putting these displays within the classrooms, up on the 9 backboards. 10 MR MICHELSON: There have been scme pretty good 11 PC level computer programs developed that are essentially 12 simulators on a PC scale. Do you use any of that sort.of () 13 thing? 14 MR. RAGLIN: We don't presently use any of that. 15 That is another area that we are also exploring, the 16 potential use of computer based or computer managed 17 instruction in some areas. One of the areas that we are 18 looking at specifically is the power plant engineering 19 training, trying to go from the theoretical to the 20 practical applications; explaining some of the theory. 21 MR. MIC11ELSON: Some of these ECCS models were 22 reduced down to computer-based programs that did a real 23 nico job. They would plot the charts as the accident was 24 going on and did a lot of things on a small scale which is 25 nice for a small group training as opposed to sitting on a O ACE. FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coserage 8533MM6 i

30166.0 94 BRT ) ~ l large simulator. It did things big simulators don't do, 2 like plotting the course of the accident, that sort of 3 thing. Which, I guess your simulators include, now, the 4 SPDS program -- 5 MR. GRIMES: Yes. Specifically SPDS. 6 MR. MICHELSON: So you are getting some of this 7 specifically on the SPDS simulator. 8 MR. RAGLIN: The GE equivalent of SPDS's 9 emergency response simulation system, which is installed. 10 The Westinghouse simulator, that hopefully will be 11 relocated to the training center, will have a safety 12 parameter display system. At some point in the future, we (G_) 13 would probably look toward providing some means of having 14 those same displays in the classrooms, without having to 15 take students -- 16 MR. MICHELSON: In the case of your boiling 17 water simulator which is already operational, I presume you 18 are using it routinely -- 19 MR. RAGLIN: Yes. 20 MR. MICHELSON: Is it tied up overy day? 21 MR. RAGLIN: We have day shift for the whole 22 year. That doesn't mean we are conducting a course because 23 we don't have the staff size to do that. It is available 24 for our staff to go up and practice presentations, practice 25 scenarios, run through different evolutions to see what the (v) Ace FEDERAL RunonTuns, INC. 202 347 3700 Nationwide Cmcrage Nx)-3364M6

30166.0 95 BRT 1 effect is. 2 MR. MICHELSON: In the process -- is it tied up 3 in the evenings also? 4 MR. RAGLIN: No. By the contract we are 5 authorized 2000 hours per year until the end of the 6 contract. 7 MR. MICHELSON: It's in your building. Does 8 that mean you just don't use it? 9 MR. GRIMES: It is on a lease / purchase from GE, 10 and GE has given us during the four-year lease time before 11 we own it, we have essentially the day shift. 12 MR. MICHELSON: You can't play with it after n() 13 hours, you are saying? 14 MR. RAGLIN: We can if we schedule the time, it 15 depends on how we spend the 2000 hours which is more than 16 we need. 17 MR. GRIMES: We are not up to the maximum -- 18 MR. MICHELSON: After looking at some of the 19 operating procedures for boiling water reactors, it would 20 be nice, on an ad hoc basis, to go on the simulator to see 21 how some of these exercises work from our viewpoint. 22 MR. GRIMES: We would be happy to schedule any 23 use like that. 24 MR. MICilELSON: Normally, it's hard to go to a 25 utility because they have a different objective. O ACE. FEDERAL REPORTERS, INC. 202-347 37(x) Nationwide Cmerage 8(Xb3E(M6

[30166.0 96

BRT-

'('" 1 MR. GRIMES: There is time available for that 2 sort of. thing. 3 MR. MICHELSON: It would be possible'to go on an 4 evening shift and run some of these exercises. 5 MR. GRIMES: Or a day shift when we don't have a 6 class scheduled. 7 MR. MICHELSON: So you'd just like a test plan 8 and then you'd see how you could fit it in? 9 MR. RAGLIN: And we could fit it in. 10 MR. MICHELSON: That's nice to know. That's 11 only on the boiler right now? 12 MR. GRIMES: This summer I hope it will also be .() 13 true on the pressurizer. 14 MR. MICHELSON: Will it be in and running by 15 this summer? 16 MR. RAGLIN: July. Operational in July. 17 MR. MICHELSON: We will keep that in mind. That 18 would be essentially a SNUPPS-type? 19 MR. RAGLIN: Physically the SNUPPS 1 machine t 20 upgraded to the SNUPPS 2 facilities with an SPDS. 1 21 MR. MICHELSON: It's particularly the SPDS I l 22 wanted to watch from the viewpoint of what are the 23 operators really seeing as this thing evolves? You'd have 24 all the exercises and so forth on it by then? Or just 25 physically in place? O ace FEDERAL. REPORTERS, INC. 202-347-3700 Nationwide Coserage MX) 336-fM6

30166.0 -

97 CRT 17m S-1 MR. GRIMES: We should be trained and 2 operational for classroom instruction at t' hat point. I'm 3 sure there's going to be an evolution as time goes on -- 4 MR. MICHELSON: One thing I would like to see is 5 some special scenario that we mi -- in looking through t 6 the procedures, if we think that there's a possible 7 deficiency in the procedure, one way to do it is to just 8 give it to a group of students who don't even know what's 9 coming off yet and feed that particular sequence into the 10 program and see how they respond. It's a fairly decent 11 test of how a utility might respond in the real world. 12 MR. RAGLIN: That's possible until you reach the l( ) 13 limits of the models for the simulator. 14 MR. MICHELSON: Right. In all cases, that's the 15 limit. But a lot of these are just a matter of putting the 16 right sequence, order in, to see how a student responds 17 which might be a nice exercise. We are running out of 18 exercises because, by now, we probably know what all the 19 standard exercises are. 20 MR. GRIMES: Our instructors are pretty 21 inventive. 22 MR. MICHELSON: I think you have completed. Are 23 there any questions? 24 Now, as to timing. I think you come -- the 25 performance indicators are all we have left. O Ace FEDERAL REPORTERS, INC. 202-347 37(X) Nationwide Coserage 8(X)-336-6646

y 30166.0-98 ~BRT. rN \\ I 1 MR. JORDAN: Yes. 2 MR. MICHELSON: It's fine Inr us if.you would 3 like to excuse everybody else from the Staff so they can 4 get going. We'll get on with the performance indicator 5 section. 6 Before the Staff leaves, though, there-is the 7 question of the full Committee meeting. We may want-8 somebody to come in on these other topics, depending on how 9 the Subcommittee feels whether we are done, but they don't 10 need to be here for that discussion. 11 Thank you very much. I appreciate it. It was 12 very, very helpful. r'( 13 MR. JORDAN: On the performance indicators, this 14 is Ravi Singh from my staff. He has been instrumental as a 15 staffer for developing performance indicators. He's going 16 to be assisting me by slides and responding to questions 17 with detail that I may not have. 18 The performance indicators are teally responding 19 to one of the questions that you asked about what's the 20 agency doing to try to recognize problems earlier. 21 (Slide.) 22 We did feel the concern to recognize the 23 probability to both timely and with a greater degree of 24 certainty identify either poor or declining licensee 25 pe r fo rmance. The agency had had experience in using I ace. FEDERAL REPORTERS, INC. i - 202 347 3700 Nationwide Coverage 800-3364446 k'

30166.0 99 BRT- -(3 1 performance indicators in a number of earlier tasks. Some 2 of the experience was not really good and I'll. illuminate 3 the. bad experience first and then work from there. 4 In about 1975-76 time frame, and I think Glenn 5 Reed will probably recall some of the things that happened 6 with Z scores, the agency explored counting licensee 7 information and collecting enforcement data and collecting 8 certain parametric type information about plants and 9 applying some statistical modeling to come out with a Z 10 score that, in effect, ranked the 50 or so plants that were 11 operating in that particular time in an order 1 through 50. 12 That publication then caused problems within the t'.() 13 NRC and with industry. It was regrettable. And we are not 14 going to do that again. This process is not intended to 15 rank plants at all. It's intended to try to get another 16 dimension of understanding that is only a tool, not, in 17 fact, a decision process. 18 The Commission directed the Staff last year 19 about this same time, almost a year ago, to provide a 20 development of performance indicators. We were given three 21 tasks: to provide the status of the use of performance 22 indicators, to provide the status of the development of 23 indicators, and then to provide a plan and implementation 24 program. 25 We did respond with all, but the actual plan, /~ (_T) ace-FEDERAL REPORTERS, INC. 202-347-370) Nationwide Coverage 80)-336HA6

30166.0 100 BRT (D 1 that'is,'a. set of performance indicators, in:May of last 2 year. In so doing, we established an interoffice task 3 group'to try to gain all the experience we had in the 4 agency to cause the agency to work-in a coherent fashion. 5-I want-to'put one other caveate on before we jumpito the 6 charter. 7 Earlier in the discussion today, you indicated 8 that.ACRS didn't get feedback on proposed Commission i 9 actions. I did, then, provide you a copy of the Commission 10 action on performance indicators. That's the December 30th 11 letter. There the Commission advised the Staff and warned 12 the Staff about the possible misuses of performance O (,j 13 indicators. 14 MR. MICHELSON: Let me ask you on a Commission 15 paper, policy issue, whatever it might be -- you prepare a 16 paper, it goes forward to the Commission, they review it 17 and they give you back, I guess, some comments or things 1 18 that they think about it. 19 Do you issue a new paper, then? 20 MR. JORDAN: No. 21 MR. MICHELSON: You implement the comments. The I 22 problem I have is picking up Commission papers as 23 individual documents, is that I'm not ever quite sure that 24 you end up doing exactly what they say or whether the 25 Commission modified it. So I think an essential piece of O ace FEDERAL REPORTERS, INC. 202 347-37(X) Nationwide Cmerage 8(N)-33MM6

30166.0 101 BRT O 1 every document I get ought to be the final implementing 2 document that says: The Commission agrees, or here is 3 where they want changes made or whatever. Because 4 apparently they.are never reflected back into the SECY, 5 there's no revised SECY put out. 6 MR. JORDAN: It's a memorandum like this which 7 would be the tool for the Staff to work from. Or they 8 wanted caveats -- that's right. 9 I did want to focus for a moment on the caveats. 10 It is important that the Commission understood and alerted 11 the Staff regarding the limitations on performance 12 indicators. I'll read you number 1. () 13 "EDO should ensure that all elements of the 14 staff are aware that performance indicators are not used to 15 rank plants nor should they be displayed in such a way as 16 to imply ' problem facility' status for a given plant." So 17 the performance indicators are a judge of select data and 18 provided for management use rather than an end to 19 themselves. 20 The second item was " performance indicators 21 should only be used as one ingredient among many for 22 regulatory decision-making." The Commission also brought 23 to the Staff's attention, once again, the INPO letter of 24 November 15, regarding the limitations on performance. A I-25 modification to the Commission paper was that the i Ace FEDERAL RneonTens, INC. 202 347 3700 Nationwide Cmerage 800-336-6M6

] -30166.0 102 BRT n ^~').' 1 enforcement action index that was proposed by the staff ( 2 shall be' removed from the list. And it has been. 3 In addition, in the further development on ~ 4 . performance indicators, the list should not be extended 5 'beyond 10.without. coming back to the Commission. _And, in-6 fact, in the Commission paper, we had proposed continuing 7 development.of further indicators, so we are still 8 continuing with those developments. 9 Enough of that introduction. 10 I would like to jump to'-- 11 MR. REED: Still on this -- I agree with 12 Commissioner Roberts, he says that he believes the formal () 13 performance indicator plan will lend itself to liberal j 14 emphasis in the decision-making process on performance i 15 indicators in an inevitable attempt to rank plants. I'm 16 not so afraid of ranking plants, but I'm afraid of 17 performance indicators and the fact that the public service l 18 commissions are out there tooting horns about their own -19 performance indicators and this and that and the other; and 20 I very much agree with the statement that was made by 21 Dennis Wilkinson, and I'll attempt to paraphrase it. 22 He says something likes Good performance, good 23 maintenance and good operation will lead to high -- to 24 capacity factors. But focusing on capacity factor as 25 performance indicator will not necessarily lead to good ACE. FEDERAL REPORTERS, INC. 202 347 3700 Nationw;de Coverage 800-336-6M6 11

30166.0 103 .' C RT 1_ performance, good maintenance, good operation. I believe 2 those are essential experiences. And I think they are 3 very, very important words. ll This is a very important thing when you start on 5 performance indicators. I am afraid 'it's simplistic to 6 some and there are many of those public service commission 7 and other people who will grab upon these things,_not 8 understand the thing and its context, not understanding the 9 context of the site of the plant and the design 10 vulnerabilities and all the things that have happened, and 11 you are off to the races. 12 I hope you can live by these things you put down ( ). 13 here, items 1 through 5. I worry about it. I always worry 14 about the use of capacity factor, I think it's wrong. If 2 15 you want to use availability factor fine, but never use 16 capacity factor. 17 MR. JORDAN: We did in fact adopt availability 18 rather than capacity factor. 19 The charter that the task group was given, and 20 this was a charter that they evolved, first of all that the i 21 SALP process is the cornerstone of efforts to evaluate 22 licensee performance. The SALP process didn't provide 23 adequate trending, and so the performance indicators are 24 necessary in order to detect a change between the SALP 25 ovaluations and provide a more objective input. The SALP O ace FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 800-33MM6

'30166.0 104 BRT \\ ) 1 is, in a large sense, subjective, as being individual's 2 solution, based on the information it collects. 3 The third item is structured decision-making in 4 response to declining performance is necessary, and 5 separate from performance indicators. Performance 6 indicators are only a tool in the structured 7 decision-making. And I'll talk more about the 8 decisien-making process. 9 Finally, there are some programs within the 10 agency that will continue to develop indicators in a given 11 program area. The example is the maintenance program area 12 that NRR has been involved in. There is a need to continue (n s_,1 13 to find better ways of measuring, evaluating maintenance, 14 and where those better methods are found then such a 15 maintenance indicator would be adopted by this overall 16 process. 17 (Slide.) 18 The development process that we went through 19 consisted of, first of all, and not on the list is 20 reviewing all the past and ongoing work in performance 21 indicators from the NRC's standpoint, and also from the 22 industry and foreign experience. So that we are working 23 from the best of what we could find that has already been 24 done. 25 Then, from that we selected a set of performance O tj ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 8(X)-33MM6

, 3.,, c., { I 30166.0 105

CRT

/ _ (s, / 1 indicators'for a trial program from that set and from 2, . brainstorming sessions. 'We selected a set of p1. ants for a 3' trial program, went through a data collection, coordination ,s 4 with industry, a validation of the indicators; wo selected 5 what we call was a minimum set, has now been tEr.r.[.1: the, 6 optimum set, or optimal set, and'then develapd a ethod 'f o ,m 7 - analysis irr monitoi-ing the simulation, and prov)deo-the y s s 8 recommendations of the Commission were adopte4.[then, on ~h 9 December 30, 1986. ~ 10 (Slide.) 1-

r a 11 MR. MICHECSON: 'Have any reports been issued on

'j 12 this? O 13 Ma aoao^~ we i ees. e ieteri report =5e 14 October which was for the first two quartersL05.1986. Then 15-we have subsequently. issued a draft eport for Staff use l ~ i 16 only at this point at the end of Febl:uary for the last two z 17 quarters of 1986. We expect to losue those reports ,Nq L 18 quarterly thereafterr two months lag, the close of that i 19 previous quarter. You;have not yet gotten those. You will. 'N 20 It has not yet gone public, so-I couldn't discuss the 21 report in this open meeting at this time. 22 MR. MICHELSON: But you could the October report. 23 MR. JORDAN: Yes, I could -- no, I'n sorry. 24 MR. SINGH: It isn't public,yet. 25 1 MR. JORDAN: Bhcause of some predecisional parts, I ~ ACE FEDERAL REPORTERS, INC. 20$347-3700 Nationwide Coverage 8m3h MA6 i

v. .f .? I 30166.0 106 ~ BRT p ~ 1 it was not public yet. With respect to certain problem 2 _ plants, that was used as input.for Commission deliberations 3 about those plants. 4 MR. MICHELSON: We'd have to have a closed e, 5 meeting, then, to discuss it? 6 !!R. JORDAN: Yes. 7 The task group came up with what we-thought were j'd 8 ideal attributes of performance indicators. These were 9 jdeais. We certainly couldn't meet them for all the r 10 p'erformance indicators, and for some -- not any of them, as 31 a matter of fact. But in selecting them we wanted to work x 12 from the best basis we could find. O (_j 13 Obviously, first and foremost is we would like 14 the performance indicators to be related to safety and 15 regulatory conformance; that the data should be available 19 to the NRC readily and timely. That is, we would not have i 17 ,to enact regulations or change the way people do business 18 to begin collecting this kind of data. 19 We would want the data not to be susceptible to 20 manipulation. 21 The data should be comparable between utilities. 1 22 That's not for the purpose of ranking plants but for the f 23 pyrpose of looking at a particular indicator against 24 sindustry mean. 25 They should represent a worthy goal for /\\CE. FEDERAL REPORTERS, INC. f 202-347 3700 Nationwide Coverage 800-336-6M6 L a =.

E" 30166.0 107 11RT 1 utilities. Certainly if we were causing the utility to 2 respond to some pressure and the pressure were to reduce -) g[ 3 manual scrams, that would be a bad signal to give to the 4 utility and the operators. We want to carefully avoid that. 5 We would, of course, want them to be independent 6 of one another. We would like to reflect a range of 7 performance, and that one is difficult because, in many 8 cases the indicators are ones at zeros, which don't give 9 really a range of performance unless you integrate over a 10 longer period of time. 11 We would like the indicators to be leading and 12 predictive of future performance. That, also, is hard. 7'() 13 And we were looking for a set of performance 14 indicators that would correlate with SALP in the 15 operational area. 16 (Slide.) 17 Why don't we just skip that slide and go 18 directly to what becomes my favorite. 19 (Slide.) 20 The ACRS may have seen this slide in different 21 forms. The object here was to try to come up with some 22 basis for connecting to plant safety. This came 23 principally from the office of research, that plant safety 24 could be expressed in terms of the frequency of arrival of 25 transients, the availability of safety systems and some o jL) i ACE FEDERAL REPORTERS, INC. 202-347-3703 Nationwide Coverage 80)-336-6M6

.30'166.0 108-CRT~ 7 / 1 other stuff. 2 The "other stuff" is the inherent design 3 features and low potential for cognitive errors. Those 4 .available at'this point to identify performance indicators 5 ,that will relate very directly to those -- we are still 6 working. 7 Under low frequency of transients, we grouped 8 the trial program performance indicators that most nearly 9 relate to that; things such as scrams. A scram is a 10 transient and so, if the'overall number of scrams at the 11 plant'is reduced, then there is a lower frequency of 12 transients associated with that plant. .So we are looking () 13 ~ for things that give a measure that is proportional to this 14 particular parameter. 15 Availability of safety systems, that can be 16 . broken.down into trainable availability and potential for 17 common cause failures; 18 The trainable availability, the indicator that 19 we liked from the trial was the, essentially, LCO action 20 statements; that one turned out to be very difficult to 21 correct. It's not a part of the agency's record, and so we 22-ended up adopting safety system failure, forced outage 23 rates, as being supportive of that particular feature. 24 MR. MICHELSON: Let's say, for instance, though, 25 you really did want to use the LCO action statement as an ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6 ..~

r 30166.0 109 BRT .I ) 1 indicator. What's involved to get the data? 2 MR. JORDAN: For the trial program we selected 3 the data by causing the residents to go to the licensee and 4 go back through records, which was a laborious, 5 time-consuming and pretty difficult -- 6 MR. MICHELSON: I was thinking for more future 7 use. It's not a very difficult parameter to get reported. 8 MR. JORDAN: We would justify a regulation 9 change to justify such data to be reported if we found it 10 to be of sufficient benefit. So there would have to be a 11 cost / benefit type review. 12 MR. MICHELSON: Right now you would just like to 7, i,_) 13 know would it be worthwhile to collect, and so you would 14 have to do it by hand, backfit and collection, until you 15 get an idea of how useful it is. 16 MR. JORDAN: The task group -- 17 MR. MICHELSON: Why aren't you going back and 18 looking at LCOs? 19 MR. JORDAN: We are but we are not adopting it 20 as one of the indicators for prompt implementation. 21 MR. MICHELSON: And the reason was because you 22 found it not sufficiently good? 23 MR. JORDAN: In the trial program the data was 24 so poor that we couldn't come to a conclusion based on the 25 data. /~'T %. J ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 800-336-6646

30166.0 110 BRT y,. ( ) 1 MR. MICHELSON: It's hard to give it a fair 2 shake either way? 3 MR. JORDAN: It really was. Inherently and 4 logically, one believes it is inherently a good indicator, 5 but the trial did not provide us the basis. 6 Ron, you had something you wanted to mention? 7 MR. HERNAN: Ron Hernan, for the Staff. I did 8 want to point out if we did decide to use LCOs for example, 9 and collect new information that we don't now, that 4 : 10 justification would have to.be made to OMB, who would look i 11 at it. 12 l MR. MICHELSON: But this is not a particularly ) 13 difficult or expensive item for a utility to report. 14 MR. HERNAN: Yes. But the process is there. We 15 have the burden of proving that it is beneficial. 16 MR. MICHELSON: There's a process already 17 established and this would just be an item added to the 18 process, and you have to show that it's cost justifiable. 19 MR. HERNAN: It's not quite that simple. 20 MR. JORDAN: It is that simple. It's a 21 regulatory change, we would change 50-73 and a part of that 22 regulatory change is a cost / benefit analysis. And there is, 23 in enact, for OMB a record collection budget. It would not 24 be hard. 25 MR. MICHELSON: I guess you weren't able to Ov ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646

'I0l66.0 111 BRT 1 establish its usefulness with the procession you went 2 through. 3 MR. JORDAN: Not sufficiently to enact a 4-regulation at this time. -5 MR. MICHELSON: Okay. 6 MR. JORDAN: The low potential for common cause 7 failures, we had several interesting trial indicators that 8 we continued; cause codes were among them. This is 9_ applying personnel error, equipment failure, various cause 10 codes across collected data to try to get a picture of 11 common cause failures. That one is probably more doable 12 with the existing' data but it takes additional work on our /~)x. 13 part. So we are unable to adopt it directly. But we found (_ 14 .a need for further work. 15 MR. MICHELSON: And ESF actuations weren't 16. adopted. What was the reason? -Oh, I'm sorry -- yes. No 17 . asterisk.by it. You didn't adopt it as an indicator, I 18 guess,_because you found not a good correlation? 19 MR. JORDAN: Right. We felt that safety system 20 actuation was a stronger and better indicator as opposed to 21 ESF actuation. 22 Tech specs have caused ESF actuation -- the 23 differences between tech specs have caused EFS actuation 24 not to be very comparable. There are some trivial failures 25 that are identified under that one. ACE. FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646

I 30166.0 112 BRT s 1 MR. MICHELSON: Safety system I assume. 2 encompasses ESF as well? 3 MR. JORDAN: Not necessarily, no. We have not 4 included, for instance, control room ventilation actuation, 5 which-is labeled as an ESF actuation in the safety system 6 actuation. 7 MR. SINGH: The safety system actuation includes 8 only the ECCS and emergency SEPOLL -- 9 MR._MICHELSON: There's a lot of things left out-10 of it, then. 11 MR. JORDAN: Why don't we turn the page and go 12 to the definitions for the selected set of performance -{ws,)_ 13 indicators. 14 (Slide.) 15 One of the important things that we came to in 16 this process was not causing confusion or perturbation with 17 industry in terms of having slightly different indicators 18 than industry was already using. 19 So we converged on the industry definition where 20 there was or.e that was close to our need. For instance, 21 for scrams we used automatic scrams while critical. It is 22 identical to the INPO unplanned automatic scrams while 23 critical. So, their numerical values and ours should be 24 the same. And it gives us, then, an opportunity to compare 25 data later on to verify the accuracy of the data that we've O V ace FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646

30166.'O 113 ~BRT-1. collected from -- and now I~should talk about,how we 2 collect the data. 3' The data for all of these indicators is derived ~ -4 from.the licensee event reports, from Staff evaluations of 5 reports, and from the operational data that is.reporte'd to 6 the NRC by'the utilities. 7 So all of this data-is collected in that fashion. 8 INPO receives reports from utilities on their specific 9 indicators. The utility compiles the information or 10 provides it periodically to INPO. 11 MR.-MICHELSON: You are aware of course of the 12 INPO indicators. () 13 M R.~ JORDAN: Yes. 14 MR. MICHELSON: -Even though that's apparently '15 not, shall we say, public information, you were able to 16 know what they did? 17 MR. JORDAN: Yes. We of course communicate with 18 them, obtained their definitions, discussed at some length -- 19 MR..MICHELSON: Did they also supply you the 20 current values of these indicators? j, 21 MR. JORDAN: We are not receiving from them 22 plant data. We have exchanged data in terms of -- for the 23 indicators that we have in common. We have provided INPO 24 with our data so that where we have differences it can be 25 identified, and then we can find why the differences. i ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646

30166.0 114 BRT / 1 MR. MICHELSON: They won't tell you what their ~ ~ ' 2 values are but they will tell you if yours are in the right 3 ballpark or something? 4 MR. JORDAN: At this time we are not receiving 5 their data and we haven't asked to receive it yet. 6 MR. MICHELSON: But you tell them what you get 7 and they tell you whether they think you are off base or 8 not? 9 MR. JORDAN: Right. So we are looking for 10 errors at this particular point. And we are exploring with 11 them, an exchange of data. 12 I should also mention for the scrams, because of ,. -(j 13 interest in what it might tell us, we have also collected 14 but don't use it as an indicator, the number of automatic 15 scrams above 15 percent normalized per 1000 critical hours. 16 Those automatic scrams below 15 percent. 17 So far that data has not been of sufficient 18 benefit for us to perhaps even collect it further. 19 MR. MICHELSON: How about the manual scram data? 20 MR. JORDAN: The manual scram data will come to 21 us in another way, through related forced outages or 22 through significant events, if it is a complex event. 23 MR. MICHELSON: Those manual scrams may be, of 24 course, overt ones if they wanted to scram, or they may 25 have accidentally scrammed. g L ACE. FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646

30166.0 115' BRT ,,~ t N' 1 MR. JORDAN: The manual scrams are punched out. 2 MR. MICHELSON: They are what? 3 MR. JORDAN: The operator punched it out because ~ 4 he felt they were approaching a scram point. He had a 5- . concern. 6 MR. MICHELSON: Or maybe the instrument mechanic 7 cautioned it. 8 MR. JORDAN: That would then be an automatic 9 scram. 10 MR. MICHELSON: That's considered automatic, 11 even though it was manual cause -- it.was an automatic 12 response. (f 13 MR. JORDAN: It was a part of-the -- 14 MR. MICHELSON: The only other part is where he 15 pushes a button and then that's what you called manual. 16 MR. SINGH: Intentionally scramming the reactor. 17 MR. MICHELSON: Most of them, actually, are 18 really then automatic scrams. 19 MR. JORDAN: Yes. Safety system actuation we 20 have talked about. We use the identical definition as INPO 21 for that set. 22 Significant events. That one is worth talking 23 about a bit because it turns out the ACRS has been involved 24 in this and didn't know it, perhaps. 25 In the NRC's review of events, the process we go O ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6 m..

30166.0 116 BRT ( ) 1 through, there's the daily call between the offices on all 2 of the units, and a discussion of those that are most 3 interesting. Then there's a weekly meeting between the 4 offices on the set of events that are of greatest interest 5 here in the past week, and a discussion with management. 6 Then there's a further sifting of those events on a 7 bi-monthly basis, for meetings with ACRS. That process is 8 evolved and become formalized, has been of great advantage, 9 certainly, to the Staff. So we have now provided 10 definitions of "significant events" as a particular 11 threshold and used that process for identifying, of the 12 reported events, which of those fit this classification. ) 13 I have to say, first of all, that the term 14 "significant event" is a bad term. We are going to have to 15 fix it, and we haven't yet come up with the right set of 16 words, because INPO has significant events and Staff uses 17 significant events in varying ways, so we need a unique 18 descriptor. 19 MR. MICHELSON: But INPO does result in 20 significant event identification, and you are going through, 21 essentially a screening process here. 22 MR. JORDAN: And getting a different result. We 23 do not use the same definition -- 24 MR. MICHELSON: At what point do you decide 25 whether or not it's significant? j% LA ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Cmerage 800-336-6M6

.l .30166.0 117 BRT 1 7 ') '~' 1 MR. JORDAN: In time? In most cases the day 2 after the event. 3 MR. MICHELSON: You decide then to put the label H 4 on. You may decide to take it off, again, may you not? 5 MR. JORDAN: Yes. 6 MR. MICHELSON: But mostly it's early on, and if 7 it isn't removed it's this set of numbers? 8 MR. JORDAN: Exactly. So the threshold is set, 9 and based on the data, I think we have about 300 a year. 10 MR. SINGH: About 300 a year. 11 MR. MICHELSON: AEOD, when they screen events, 12 their purpose is to also decide which ones are significant ,\\

(,)

13 but that's a different set of-significant events. 14 MR. JORDAN: We expect to integrate that. 15 MR. MICHELSON: So it will be just one set? For-16 MR. JORDAN: That kind of definition it will be 17. just one set conclusion, the agency. 18 MR. SINGH: Yes. 19 MR. MICHELSON: On day one you'll see an event 20 that doesn't look all that great, but on day 50, AEOD will 21 integrate that event with 20 others and collectively they 22 are significant, and go back and label the individual ones 23 significant then, too? 24 MR. JORDAN: These are for a given facility and 25 I believe those case studies would not result -- OLI ACE-FEDERAL REPORTERS, INC, 202-347-3700 Nationwide Coverage 800-336-6646

30166.0, 118 L BRT: IT t/ ' 1 MR. MICHELSON: I wouldn't think you'd go back 2 there. This is on the basis of the event per.se as to how 3 significant it was. 4 MR.~ JORDAN:- Risk for that particular plant. 5 MR. MICHELSON: It's.true, significant might not-6 be recognized until it was integrated with several other 7 such events, and then you don't go back and reidentify this? 8 MR. JORDAN: We don't at present. But there 9 will be more opportunity for that, I think, in the future. 10 MR. MICHELSON: Or that might be yet another 11 measure. 12 MR. JORDAN: Yes. It may be.

- s J-13 MR. MICHELSON:

i just wanted to understand the 14 process. -Thank you. 15 MR. JORDAN: Safety system failures. These are 16 cases in which the safety function is not available. We 17 have listed cut about 24 systems and subsystems that are 18 monitored for that particular indicator. 19 MR. MICHELSON: Of course you have to identify 20 the word " failure" here, or define it. 21 'MR. JORDAN: Right. 22 MR. MICHELSON: The fact that they found you 23 lost a piece of paper on it doesn't mean it has failed. 24 Although in some cases it has been declared failure -- 25 failed, from the tech spec viewpoint, because you don't .n ) ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6

30166.0 119 "BRT 73: 6* I have the paper on it. 2 MR. JORDAN: We intend for this to be that the 3 equipment would not have functioned within -- in an event. 4 MR. MICHELSON: This is direct functionality. 5 MR. JORDAN: It shouldn't be a paper side. 6 MR. SINGH: Loss of function. 7 MR. JORDAN: Forced outage rate, this is the 8 identical outage rate as used by INPO, based on the Grey 9 book data. 10 The last is our closest tie to maintenance. The 11 maintenance' indicators that NRR had developed, consisting 12 of a number of groups of data, some of which are now ( )) 13 included in these other indicators, so when we stripped 14 those out the strongest measure we had was this 15 equipment-forced outages per 15,000 critical hours. We 16 simply normalized it for better comparison purposes within 17 itself. So it is the inverse of the mean time between 18 forced outages due to equipment failures and does not, in 19 fact, correspond to the forced outage rate. There's some 20 overlap but they don't correspond. We are not content with 21 that as the maintenance indicator, but it's the best 22 indicator we can come up with in this time frame. 23 (Slide.) 24 We have had extensive coordination with industry. 25 We met with AIF, INPO and utility representatives in June C\\ V ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 800-336-6M6

30166.0 120 BRT 1 and found it very helpful. We met with INPO along the way 2 separately; the ANS executive seminar, Jim mentioned, that 3 was held here in Washington in September, we mentioned our ] 4 performance indicators in our planning in that session and 5 we had a subsequent meeting with the utility 6 representatives. 7 Out of this we got two things that I think were 8 very strong and direct feedback. One was that industry 9 didn't like a proposed enforcement index as a performance 10 indicator, with a view that there could be some adverse 11 feedback from that mechanism and it was untimely. The 12 Staff recommended to the Commission that we maintain, in 13 any case, because it was a very strong correlator with the 14 SALP results. But, based on that industry feedback the 15 Commission had, in their own view, decided we should not. 16 So that's not included. So I link that with industry 17 feedback. 18 The other was maintenance backlog. The Staff 19 liked maintenance backlog as being a good indicator of 20 maintenance. The industry comments, however, convinced the 21 Staff that that one was subject to manipulation and might 22 not represent a worthy goal, in the sense that a utility 23 might be inclined to change their bookkeeping system on 24 backlog. By doing a trial program, we found wide-ranging 25 differences in the way utilities maintained maintenance 7_ ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 800-336-6646

30166.0 121 BRT- \\'~) 1 backlog data. Some included-the kitchen sink and some only 2 included,the main pump. 3 MR. REED: I think that's a wise decision. In 4 my view some plants, ones that I was involved in, anybody -- 5 anybody can write a maintenance request. And that gets 6 into a process and you can wind up with a large number of 7 maintenance requests, like fix my pencil sharpener. 8 MR. JORDAN: We'd like to encourage that. 9 MR. REED: -You would like to encourage that, 10 that anybody can write it and then it goes through the 11 system. 12 MR. JORDAN: In trending the information, we saw )) 13 some reverse trends. In'this process we collected two 14 years worth of plant data and trended and looked at it for 15 the trial set of plants. For instance, the maintenance 16 backlog you could see in some cases a trend where the 17 backlog was increasing, but other indicators, in our own 18 judgment, indicated that particular plant was improving. 19 It was because that particular plant had adopted a more 20 aggressive attitude in fixing equipment that was in trouble, 21 and they had changed their process. So on an individual 22 plant it may be interesting to trend it as long as their 23 system remains constant. Across the board, it is not one 24 that we would adopt. 25 I would like to jump to the sample report. ACE FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coverage 800-336-6M6 .-~

30166.0' 122 i -BRT- -l /m a k_) d 1 (Slide.) 2 -The task' group had a great deal of difficulty '3 ' coming up with some means of communicating the information 4 4. in a'way that was understandable and most beneficial. j 5 Tabular data for 105 plants is overwhelming, when you lay 6 six parameters and a couple of years worth of data out. 7 So we do have, in fact, a data summary table which provides 8: that. That's simply so one could get' to the-raw data and, 9 try to understand why some data looks like it docc. t-10 That industry summary table has a listing of-the 11 latest SALP scores for information. It has the four 12 . quarter average for that particular indicator and then the n(_) 13 latest quarter or quarters, and I'll talk why quarters. .14 And that big table was virtually useless unless you studied 15 it in great detail. l 16 We then came up with some presentations to try 17 to -slow a plant profile, and the way we ended up was to L 18 trend the latest quarter against the previous four-quarter 19 average and state it as a standard deviation from that 20 previous mean. 21 Similarly -- and I'll show you a chart in just a 22 moment -- similarly, then, we also compare each of those 23 performance indicators, four-quarter means with the 24 industry, four-quarter means for that same time frame. 25 Okay? We call these finger charts. ! O %-) ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6 L

30166.0 123 BRT i 1 (Slide.) 2 Please ignore the sixth item on there. It's not 3 an indicator. We simply used the same slides for several 4 presentation. Equipment-forced outages is not an indicator. 5 We used the same chart for other purposes. 6 To the right is improved and to the left is 7 declined. It gives a simple visual impact message for that 8 particular plant. We have three indicators -- I'm sorry, 9 Lwo indicaLors that have declined, and don't let the scrams 10 mislead you. Only the top scram signal is the performance 11 indicator. So, forced outage rate for that particular 12 plant has increased substantially during this particular () 13 quarter compared to the previous four quarters, and the 14 equipment-forced outage rate has increased substantially. 15 That's not of itself a serious problem. Those may be 16 explained by a couple of plant trips and some extended 17 outage as a result of equipment failure. It may not be a 18 big problem. 19 However, if you look at the bottom segment you 20 find that that particular plant, in fact, is substantially 21 below the industry mean and has been during the previous 22 four quarters. So we are comparing, with that bottom chart, 23 four quarters of data for that particular plant against the 24 industry mean for each of those indicators, and find that 25 that particular plant seems to be consistently below the i n.; ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coterage 800-336-4 46

? ~ L30166.'0: 124 BRTL Om 1 mean. So you find that it is below average, so to speak,. 2 and has shown'a decline'in a couple of indicators. 3 It would be a basis-for the' regional office ~4 -looking,more closely at thatLparticular plant and its 5 . operations. Certainly it's not the basis for anybody 6 taking any action without selecting more information, and I 7 think that's the thing I'd want to emphasize. These' data 8 are'only a tool. It only leads you to consider further, t-9 and on a more frequent-basis than the-SALP process, whether L 10 a plant-is getting into a problem. 11 .The SALP process is on an 18-month cycle and it 12 is formalized and a great deal is gone through with all the

()

13 offices. If, for instance, a plant comes out on the low 14 end of the scale in the SALP-process, and you were -- you l 15 are watch'ing the performance of that particular plant, the 16 performance indicators'become a useful tool since, if you 17 are already on the low end of the scale and you find the 18 plant performance in these indicators is trending downward, 19 let's say two quarters consecutively, from poor, you really i 20 do have a basis to worry more about that plant. l 21 So, on a semiannual basis, there are management 22 meetings held; the first one was held in October of this 23 past year with the executive director, Vic Stello, the [ 24 office directors of each of the program offices, and the 25 regional office directors, at which they come in with a o i ACE FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coverage 800-336-6M6

30166.0 125 BRT' (- 5 1 concern about a set of plants and then base their concern 2 on the Region's review of the. performance indicators and 3 the headquarter's review of performance indicators; review 4 of the enforcement history; review of their subjective view 5 of licensing performance. 6 And so a group of six, eight or 10 plants are 7 discussed in: great detail, away from Washington or away 8 from the' trials of the offices, to decide whether'other 9 action should be taken with respect to those plants. 10' Whe th'e r, in fact, a plant that'was previously felt to be a -11 problem appears to be improving or whether a plant that was 12 marginal-has now become a problem, and there ought to be, ( ) 13 for instance, a letter to the chief executive officer or a '14 meeting with the utility at the top management level from 15 headquarters or whatever action is deemed appropriate. 16 But the judgment by senior NRC managers is based 17 on the best collection of information; and, so, once again 18-I would say the indicators are only a tool and a means 19 towards formalization of a decision process rather than an 20 ends in themselves. 21 MR. MICHELSON: In picking your examples, plant 22 A, how far back in time does your study go? 23 MR. JORDAN: Two years. Why don't you put up l 24 the scram. 25' MR. SINGH: The details. l ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646

L L 30166.0 126 BRT ' (,,( ^ 1 (Slide.) 2 MR. MICHELSON: Another question. These 3 indicators are fine. Perhaps they are good indicators.. 4 For instance, in the indication of TVA, maybe these 5 indicators wouldn't have looked so bad for Sequoyah for two 6 years of operation because the problems they were getting 7 into were not related necessarily to scram or safety system 8 actuation, but to breakdown in the control of configuration 9' and things of that sort, which are not reflected 10 necessarily in the indicators at all. 11 MR. JORDAN: If it's configuration control that 12 result in equipment failures -- () I 13 MR. MICHELSON: It may or may not. It may be 14 that it results, what may happen is that you are finding 15 that they are not controlling or saving their records or 16 whatever. That doesn't reflect necessarily in these 17 indicators. At least from the short te rm. 18 MR. JORDAN: It doesn't. If you recall the 19 logic chart that we had, we were unable to come up with 20 indicators that would relate directly back to design. And 21 some of the TVA problems are relating back to -- 22 MR. MICHELSON: Modification control, things of 23 that sort which are going on more or less constantly on an 24 operating plant. 25 MR. JORDAN: I believe that modification of O V ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 800-336-6M6

30166.0 127 BRT 1 1 control would end up ultimately as an operating problem, a 2 safety system actuation. It's not. 3 MR. MICHELSON: Maybe it would, maybe it 4 wouldn't. Let's say the problem is-you are not keeping 5 your records on the welding as you are going, things of 6 that sort. That wouldn't show up here. It wouldn't show 7 up until somebody checked in and found out that there 8 aren't any inspection records. No inspections were ever 9 ll performed. And that would be a serious problem. 10 MR. JORDAN: Right. I have to say that goes 11 back to design and construction. This will not go back in 12 time and reexamine pre-ops or design or construction. (,) 13 MR. MICHELSON: Would this process, do you think, 14 pick up the Sequoyah problem? Or TVA's general problem? 15 MR. JORDAN: Yes. We did look back at plants 16 that we felt were problem plants based on SALP and based on 17 subsequent events and got a very high -- 18 MR. MICHELSON: SALP picked up on some of these 19 other areas, like how are you doing? SARP will pick up, 20 it's a type of on-spot checking that the records weren't 21 being kept up on verification or something of that sort. 22 But these performance indicators won't pick that up unless 23 it reflects into operations. 24 MR. JORDAN: Let me answer though, in respect to 25 TVA, in the trial program the data did reflect ,m N ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 800-336-6M6

y 30166.0 128 CRT* ) 1 operationally as well. 2 MR. MICHELSON: As well. But the main thing is 3 there is a danger, don't focus on these indicators -- 4 MR. JORDAN: They won't solve the world. 5 Exactly. 6 MR. MICHELSON: There are still other things you 7 have to look at that are a little more intangible. 8 MR. JORDAN: A lot. We provide backup data to 9 the management of each plant. 10 (Slide.) 11 For instance, a display of this sort where one 12 can look at total number of scrams, real data rather than ,.-(_j 13 deviations, as a function of time and compare it with the 14 industry average and also look at the operating history. 15 The dotted line that jags up and down is the operating 16 history of that particular plant over that time frame.

And, 17 in many cases one can explain a spurious finger based on 18 looking at the data in more detail.

19 In other cases, as I indicated, if a plant is on 20 a particular get well program and has increased its 21 maintenance or increased certain activities which lead to a 22 poor indicator for a time, that's also explainable, and 23 that's another reason for not taking the indicators in 24 blind. One looks at what the plant has been doing 25 operationally and what the plant has been doing in terms of ACE FEDERAL REPnMTERS, INC. 202-347-3700 !ctionwide Coverage 80t)-336-6646

30166'.'0. 129 BRT g ^~')- 1 its own get well programs. ( 2 (Slide.) 3 In terms of milestones, we have gone through all 4 of those milestones. We are now operational. We have 5 issued the first quarter report in draft to the Staff. We 6 do expect to send it to the BDR and licensees, and make 7 periodic communication of that information. We have held 8 seminars in all of the regional offices with utilities. 9 The last one was yesterday in Region V, so the utilities p 10 have a clear understanding of what we are about; why we are 11 doing it, how we are doing it, and in fact the opportunity 12 to provide feedback on an every-utility basis, regarding ( 13 concerns they may have or questions they may have about how 14 we are using this data. Those have been very beneficial 15 and I have to say the industry has, I think, taken a very 16 responsible attitude with regards to how performance 17 indicators are used and the fact that the Staff does, I 18 think, have the right -- caveat the right concerns about 19 inappropriate use of performance indicators. 20 We will continue to publish on a quarterly basis 21 and, in December of 1987, we owe the Commission a 22 evaluation of the first year's experience with the 23 indicators, a presentation on any results of research and 24 development of further indicators, and our plans for i 25 further work in the area. OV 4 ACE-FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coserage 800-336-6646

~30166.0 130 CRT 1 MR. MICHELSON: What was the date on that? e 2 MR. JORDAN: December of '87. 3 MR. MICHELSON: That's sort of a status _ report 4 on the whole business? -5 MR. JORDAN: Yes. 6 Rabi, what did I miss? 7 MR. SINGH: It's done. 8 MR. REED: Your report, quarterly report, is 9 ll supposed to be available to the Public Service Commission 10 of'the State of New York;'right? 11 MR. JORDAN: Yes. 12 MR. REED: I understand what-you are doing. I n (_) 13 think.what you are doing is appropriate. I like it. But 14 I'm wondering, do you think the Public Service Commission 15 will understand what you are doing or were they just seize 16 upon what obviously is ranking --' your lower chart here is 17 a ranking if you interpret it. 18 MR. JORDAN: It could be, in terms of being 19 above or below some median point. 20 MR. REED: It goes beyond SALP. And if, 21 simplisticly to take that, not understanding the real world 22 of work and design and problems, I wonder how it would come 23 out? 24 MR. JORDAN: We would be willing to provide 25 comments or suggestions. m ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 80(F336-6M6

30166.0 131 BRT /m. ( ) ~ l MR. REED: How would you head them off at the '2 pass? Would you provide the briefing before they make 3 judgments? 4 MR. JORDAN: At this point we don't have a plan 5 to communicate directly with them. I do have to say that I 6 met with a public utilities group of representatives in 7 Phoenix earlier this year, and it was a group that were 8 reviewing the possible uses. I did not get a sense that haing clnar indicators. 9 they were abnut to encircle thpan an 10 But we have not had other direct communications. 11 MR. REED: This was a number of states? 12 MR. JORDAN: Yes. i_"%;) 13 MR. MICHELSON: You indicated that these earlier 14 reports weren't yet publicly available. What is the policy 15 on making your indicator reports publicly available? 16 MR. JORDAN: The policy that we are adopting is 17 that we will make them publicly'available on a routine 18 basis after the Staff has had a chance to review it and 19 identify errors or glitches. 20 MR. MICHELSON: But on a routine basis you mean l 21 on an every quarter? l 22 MR. JORDAN: So we plan to get them out within 23 two months of the end of a given quarter, and then we'd l 24 expect to allow three or four weeks for Staff review of the l 25 data, and then go public. l /\\CEJFEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6 h

-30166.0 132 BRT '/ 1 MR. MICHELSON: What you are saying is they will 2 come out quarterly,.they will just be delayed for the time 3 required by Staff review, so once into steady state 4 operation, every quarter a report will come out. 5 MR. JORDAN: That's right. It will be one 6 quarter offset, essentially. 7 MR. MICHELSON: It may be offset by.as much of a 8 quarter. That's probably good enough. 9 MR. WYLIE: Were exposures considered? 10 MR. JORDAN: Yes. And, in fact the Commission 11 requested that we provide exposure data. There is a 12 problem in having a trend. As you know, the data is based ( )' 13 on outages, particular plant conditions. There are cleaner 14 plants and dirty plants based on fuel problems that they've 15 had along the way. And in some cases practices. But it is 16 not very trendable. 17 We are providing that as data in this report. 18 What we are not providing is a performance indicator that 19 we compare with averages. 20 MR. REED: I really think that exposure is an 21 inappropriate one because it is so related to something 22 over which the licensee has no control. It is design. 23 For instance, I would expect BWR exposures, over 24 the long term, would always be higher than PWRs. 25 MR. JORDAN: Generally they are. p s ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646

/ ^

-30166.0

\\ ,133 'BRT j. f i l. MR.-REED: So it's very design-related. A ' ~~ 2 couple of those are very'desjgn-related, but I didn't count. a 3 I said I guess that will --lwhere is that page -- item 1, 4 automatic scrams can be very d'esign-related. 5 MR. JORDAN: Yes.- s 6 MR. REED: For instapce, I would expect B&W reactor would just come 'p_highInormally in that, unless 7 u 8 they suppress them somehow. And'ltem 3, significant events, he very design-related.- 4 can y 10 I think what you are looking fo'r is plant is 11 performance indicators; not so much -- you' said 12 construction is o'ut. g' 1 x (,) 13 MR. JORDAN: These are operating plants. 1 14 JiR. REED: The design thing over the years, and 15 you should allow different designs,'.we have, and it's 16 indicative and leads to,.some day,. perfect standardized 17 design. s ~ 18 MR. JORDAN: I have' undersold the analysis ~that 19 the Staff-has done with the-data. We have sort of cut it 20 every way,possible, or every way that we have thought of so V 21 far. l 22 We have cut it by new bl' ants and old plants, by 1 23 nuclear steEm supplier and, you'know, reactor type. 24 MR. MICHELSON: You'll be trending it on a given 25 plant also, won't you, quarter to quarter? O-- i i /\\CE FEDERAL REPORTERS, INC., 202-347-3700 Nationwide Coverage Pui U6-6646 ~.. ~ -

.. =- E 4 30166.0 134 BRT O ~3 1 MR.. JORDAN: Yes. ,2 MR. MICHELSON: Do you expect to issue an annual

~

s 3 report as well as the quarterly reports, or will the 4 . quarterly reports do all the cross cutting each time? ji MR. JORDAN: The quarterly report will go back a 6 full year. . So-it's a complete report-itself. -7 MR. MICHELSON: 8 The quarterlies will look back~one year? 2-. 9 MR.. JORDAN: Yes. For instance, each of the U quarterly' reports.then compares the previous four quarters 10 f( -11 with the current. '12 MR. MICHELSON: Sometimes it might be a couple 1.k ) ~ 4 = 13 of years to see the trend. One year is fairly short for lf ~ E 14 isome things. Hopefully you don't get many scrams a year, [ 15 so looking back one year doesn't mean.much. Maybe looking 16 back two years would be more interesting for some 17 parameters. 18 -MR. JORDAN: Yes. 19 MR. SINGH: I wanted to say that covers six 20 quarters; four quarters in the bottom finger chart and six F 21 'e quarters on the top chart. 22 MR. JORDAN: Something I didn't mention, from ~ 23 the trial program to the implemented program, the trial 24: program compared the last quarter with the previous four 25 quarters,jnd for the implemented program we compare the v <, (/ r s ~ /\\CEJFEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646 i 3

'/h 30166.0 135 ~ B RT.. \\# 1 last two quarters with the previous four quarters. So that 2 gives-you then six quarters. 3 MR. MICHELSON: That's not too bad. 4 MR. SINGH: That's the optimum. 5 MR. JbRDAN: We needed more smoothing. There 6 are some quarterly jumps that are noise. Validation was very important to us and I sort 7 s 8 of short-changed that in discussion. The ways that we did i 9 a validation were comparing indicators against the 10 understanding based on SALP, the licensing performance. We 11 compared the indicators in multi-unit plants at a single 12 site with-one another. You know, if there are two or three. .,em,) 13 units at a given site with the same management, you would t

ehpect, if the indicators have validity, that they would 14 15 look similar.

You wouldn't expect one unit to be-bad and 16 the other unit to be good. That was generally the case, 17 .that they generally trended -- tended in the same 18 directions. 19 We compared, in some cases, multi unit sites 20 with different management at the same site. 21 Multi-sites, the Indian Point site, for instance, 22 with similar design but different management totally at the 23 same site, looking for anomalies, looking for where the 24 logic didn't hold up. I'm pleased to report that it was 25 reasonably consistent. <~ k-)< l ACE FEDERAL REPORTERS, INC. 212-347-3700 Nationwide Coverage 800-336-6M6

1 30166.0' 136- -l BRT . fh. .q)- 1 That's our story. 2 MR. MICHELSON: Okay. Any'other questions? ~ 3 I believe the only remaining agenda item, then, 4 is to decide which parts of this presentation this morning-5 should-be brought to the attention of the full Committee. 6 .The meeting is now completed. 7 _ (Whereupon, at 12:20 p.m., the meeting was 8 concluded.) .9 10 11 12 13 14 15 16 17 L 18 19 20 -21 22 23 t' 24 25 ( 3 . v' i ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6

~ ' CERTIFICATE OF OFFICIAL ~ REPORTER O - (V This is to certify that the attached proceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in the matter of:- NAME OF PROCEEDING: ADVISORY COMMITTEE ON REACTOR SAFEGUARDS REGIONAL AND I&E PROGRAMS SUBCOMMITTEE DOCKET NO.: PLACE: WASHINGTON, D. C. DATE: THURSDAY, MARCH 12, 1987 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission. (sigt) (TYPED) JOEL 'EITNER Official Reporter ACE-FEDERAL REPORTERS, INC. Reporter's Affiliation ' O -,:..-,.,,,-----.r .--,m-- .,-,-yr _-, ~..., - -. -r,--,,,,,c- --.----,--.--..rr-- ---g--,-y-.--m

% Q ~ yi PRESENTATION TO ACRS SUBCOMMITTEE ON ,Aj INSPECTION AND ENFORCENEllT PROGRAMS MARCH 12, 1987 I.- . FUNCTION'0F ENFORCEMEiiT STAFF A. ORGANIZATION'AND STRUCTURE FOR TAKING ENFORCEMENT ACTIONS B. STATISTICS ON NUMBERS OF ACTIONS TAKEN II. THE ENFORCEMENT POLICY-i A. - STdVCTURE AND OVERVIEW (8 kJ B. 1984' CHANGES C. VENDOR EHFORCEMENT D. 1987 CHANGES III. ENFORCEMENT ADVISORY COMMITTEE A.- DESCRIPTION OF COMMITTEE AND ITS WORK B. COMMITTEE RECOMMENDATIONS AND STAFF RESPONSE IVl OTHER PENDING ISSUES A. i',ATERIAL FALSE STATEMENTS b. HARASS' MENT, INTIMIDATION, AND DISCRIMINATION i

J s 9 .-.e>. ..., ~.- r_ O O PURPOSE OF ENFORCEMENT PROGRAM PROMOTE AND PROTECT THE PUBLIC HEALTH AND SAFETY E ENSURING COMPLIANCE WITH REGULATIONS AND LICENSES OBTAINING PROMPT CORRECTION OF VIOLATIONS O DeTeRaiNG eUTURe vi0tATiONS ENC 0URAGING IMPROVEMENT OF LICENSEES AND INDUSTRY ~ ~ O 1

[ i i l IDENTIFICATION OF NONC0&LIANCE - NRC INSPECTION ACTIVITY NRC INVESTIGATION - LICENSEE AUDIT, REVIEW, OR EMPLOYEE REPORT i - ALLEGATION, SUPPORTED BY INSPECTION OR INVESTIGATION 1 1 i -(

ORGANIZATIONAL STRUCTURE-FOR TAKING ENFORCEMENT ACTIONS <-); (./ IE HEADQUARTERS DIRECTOR, OFFICE OF INSPECTION AND ENFORCEMENT (IE) RESPONSIBLE FOR ENFORCEMENT PROGRAM. INCLUDES AUTHORITY T0: 1) ESTABLISH ENFORCEMENT POLICY 2) ISSUE PROPOSED CIVIL PENALTY ACTIONS 3) ISSUE ORDERS TO SUSPEND, MUDIFY OR REV0KE LICENSES OR IMPOSE CIVIL PENALTIES. O 4) PROVIDE GUIDANCE TO THE REGIONS ON IMPLEMENTATION OF THE POLICY. DIRECTOR, ENFORCEMENT STAFF, IE, MAKES RECOMMENDATIONS TO HIM REGARDING DEVELOPMENT OF POLICY, PROPOSED ENFORCEMENT ACTIONS, POLICY GUIDANCE. (1) HE HAS A STAFF OF SEVEN TECHNICAL REVIEWERS THAT REVIEW ALL ESCALATED ENFORCEMENT ACTIONS. (2) 0FFICE OF THE GENERAL COUNSEL PROVIDES ADVICE ON THE' LEGALITY OF PROPOSED ENFORCEMENT ACTIONS.

O s_s ORGANIZATIONAL STRUCTURE - PAGE 2 REGIONS 1) INITIATE ROUTINE ENFORCEMENT ACTIONS 2) PREPARE DRAFT ESCALATED ACTIONS AND SEND TO IE FOR REVIEW AND CONCURRENCE () 3) REGIONAL ADMINISTRATOR MAY SIGN PROPOSED CIVIL PENALTY ACTIONS IN THOSE INSTANCES WHICH THE DIRECTOR, IE, DEEMS APPROPRIATE AND AFTER HIS CONCURRENCE. OTHER OFFICES OGC AND NRR OR NMSS, AS APPROPRIATE, REVIEW PROPOSED ENFORCEMENT ACTIONS RECEIVED FROM REGIONS, NRR AND NMSS MAKE RECOMMENDATIONS TO IE,0GC CONCURRENCE IS REQUIRED, e O

a .i [ Qj ENFORCEMENT' CASES' RECEIVING IE REVIEW. i i 1 o 1984 1985 1986' p l: 1 b ' REACTORS 79 67 128 4 I o 1i -NON REACTORS 58 71 73 . TOTAL 137-138 201 1. l i: l L - LO r

a y

ENFORCEMENT ACTIONS i-L 1984' 19d5 1986 CIVIL' PENALTIES 74 66-86~ SL III N0'CP -30 35 -49 ORDERS. 13 9 13 OTHER 20 28 53 LO TOTAL 137 138 201 t e O.

e. Yl Lil 'THE ENFORCEMENT POLICY A STATEMENT PUBLISHED IN'THE CODE OF FEDERAL REGULATIONS WHICH EXPLAIN THE GENERAL-POLICY.AND PROCEDURES OF THE NRC IN INITIATING AND REVIEWING ENFORCEMENT ACTI0iis, O. 9 O

O CURRENT POLICY FIVE SEVERITY LEVELS FOR VIOLATIONS I MOST SIGNIFICANT II III 0F SIGNIFICANT CONCERN IV V 0F MINOR CONCERN O EIGHT AREAS SUPPLEMENT I REACTOR OPERATIONS SitPPLEMENT !I FACILITY CONSTRUCTION SUPPLEMENT III SAFEGUARDS SUPPLEMENT IV HEALTH PHYSICS SUPPLEMENT V TRANSPORTATION SUPPLEMENT VI FUEL CYCLE AND MATERIALS OPERATIONS SUPPLEMENT VII MISCELLANE0US MATTEPS SUPPLEMENT VIII - EMERGENCY PREPAREDNESS g

e O

{

'N HISTORY OF ENFORCEMENT PROGRAM 9 1954 - 1969 VIOLATIONS INDICATED IN INSPECTION REPORTS AND NOTICES OF VIOLATION, REACTOR ENFORCEMENT THRU DISCUSSION AND CENTRALIZED: NO FORMAL POLICY, NO CIVIL PENALTY AUTHORITY, ISSUED ORDERS 1969 5234 GIVING AEC CIVIL PENALTY AUTHORITY ADDED 10 ATOMIC ENERGY ACT OCT 1971 FIRST CIVIL PENALTY ISSUED OCT 1972 FIRST FORMAL CRITE" A FOR P'C0f.#EMENT ^CTIONS PUBLISHED MAY 1973 FIRST REACTOR CIVIL PENALTY ($38,000) l JAN 3, 1975 CRITERIA REVISED DEC 3, 1979 CRITERIA REVISED (TRANSPORTATION) JUN 30,1980 CIVILPENALTYAUTHORITY15CREASEDFROM$5,000 O ^" $25,000 CEILING FOR 30 DAY PERIOD ELIMINATED

T~i PAGE 2 X) SEP 4, 1980 COMMISSION APPROVED PROPOSED GENERAL STATEMENT OF ENFORCEMENT. POLICY TO BE USED AS INTERIM GUIDANCE. OCT 7, 1980 POLICY PUBLISHED IN FEDERAL REGISTER FOR COMMENT. MAR 9, 1982 POLICY PUBLISHED IN FEDERAL REGISTER EFFECTIVE IMMEDIATELY. MAR 8, 1984 MINOR REVISIONS TO POLICY PUBLISHED IN FEDERAL .( REGISTER EFFECTIVE IMMEDIATELY. COMMENTS ON CHANGES SOLICITED TO BE CONSIDERED BY ENFORCEMENT ADVISORY COMMITTEE. NOV 20, 1985 REVISIONS.T0 POLICY DESCRIBING HOW ENFORCEMENT POLICY APPLIES TO VENDORS PUBLISHED IN FEDERAL REGISTER, EFFECTIVE FEBRUARY 18, 1986. MAR , 1987 REVISIONS TO POLICY REFLECTING COMMISSION APPROVED CHANGES RECOMMENDED BY ENFORCEMENT ADVISORY COMMITTEE (EXCEPT MATERIAL FALSE STATEMENT) PUBLISHED IN FEDERAL REGISTER, EFFECTIVE I'MMEDIATELY. ~

e f~')5 ENFORCEMENT ADVISORY COMMITTEE -v THE COMMITTEE WAS ASKED TO ADDRESS THE FOLLOWING QUESTIONS 1. IS THE CURRENT ENFORCEMENT POLICY IMPROVING COMPLIANCE WITH THE NRC REQUIREMENTS BY: A) OBTAINING PROMPT AND CORRECTIVE ACTIONS;-(B) DETERRING FUTURE-VIOLATIONS; AND (C) ENCOURAGING DEVELOPMENT OR IMPROVEMENT OF A LICENSEE'S OWN PROGRAMS FOR DETECTION OF INCIPIENT PROBLEMS? 2. DOES THE' CURRENT ENFORCEMENT POLICY AS WRITTEN OR IMPLEMENTED HAVE ANY NEGATIVE IMPACTS ON SAFETY? O \\.J 3. ARE THERE ALTERNATIVE OR MORE EFFECTIVE ENFORCEMENT OPTIONS AVAILABLE TO THE COMMISSION TO IMPROVE COMPLIANCE WITH ITS REQUIREMENTS? COMMITTEE CONCLUSIONS: "THE POLICY'S IMPACT HAS BEEN MODEST IN MAGNITUDE AND PSYCHOLOGICAL IN NATURE...THE INTENT OF THE POLICY CONFORMS REASONABLY WELL TO MOST OF THE COMMITTEE'S CRITERIA." COMMITTEE'S RECOMMENDATIONS INCLUDED MAJOR CHANGES IN THE AREA 0F MATERIAL FALS'E STATEMENTS AND MINOR CHANGES IN OTHER AREAS.

e MATERIAL FALSE-STATEMENTS () PRESENT NOT REGULATION PRESENT DEFINITION DERIVES FROM SECTION 186 0F THE ATOMIC ENERGY ACT AND THE COMMISSION'S APPLICATION OF THAT STATUTE IN THE VEPC0 ENFORCEMENT ACTION PRESENT DEFINITION OF MATERIAL FALSE STATEMENT MATERIALITY IS TO BE JUDGED BY WHETHER INFORMATION HAS A NATURAL TENDENCY OR () CAPABILITY TO INFLUENCE A REASONABLE AGENCY EXPERT KNOWLEDGE OF THE FALSITY OF A MATERIAL FALSE STATEMENT IS NOT NECESSARY FOR A hATERIAL FALSE STATEMENT MATERIAL OMISSIONS ARE PUNISHABLE TO THE SAME EXTENT AS AFFIRMATIVE MATERIAL FALSE STATEMENTS e O

9 MATERIAL FALSE STATEMENTS (CONTINUED)
g) u PROPOSED A PROPOSED RULE IS BEING PUBLISHED IN THE FEDERAL REGISTER THIS WEEK WHICH ESTABLISHES A REGULATION THAT REQUIRES LICENSEES TO PROVIDE THE COMMISSION WITH INFORMATION THAT IS " COMPLETE AND ACCURATE IN ALL MATERIAL RESPECTS" MAINTAIN ACCURATE RECORDS DISCLOSE INFORMATION IDENTIFIED BY LICENSEES
([)

AS "HAVING FOR THE REGULATED ACTIVITY A SIGNIFICANT IMPLICATION FOR PUBLIC HEALTH AND SAFETY OR COMMON DEFENSE AND SECURITY" i FAILURE TO DO ANY OF THE AB0VE WILL RESULT IN A CITATION FOR A VIOLATION OF THE REGULATION, SEVERITY LEVEL I TO V ( THE TERM " MATERIAL FALSE STATEMENT" WILL NOT BE USED EXCEPT FOR " EGREGIOUS" SITUATIONS WHERE THERE l IS AN ELEMENT OF INTENT: USE OF THE TERM WILL BE l DETERMINED ON A CASE-BY.-CASE BASIS O l i

L ;, HARASSMENT, INTIMIDATION, AND DISCRIMINATION -l(~)- MAJOR POINTS OF NRC POLICY -1. ~" Pit 0TECTED ACTIVITIES" INCLUDE HAISING POTENTI AL SAFETY CONCERNS TO MANAGEMEliT - NEED NOT RAISE CONCERN WITH NRC 2. NRC NORMALLY AWAITS COMPLETION OF DOL PROCEEDING, UNLESS POTENTIALLY SIGNIFICANT PUBLIC HEALTH AND SAFETY. ISSUE ~ DOL DOES NOT ACT CASE IS SETTLED 3. LICENS$ES' RESPONSIBLE FOR DISCRIMINATORY ACTIONS OF'THEIR CONTRACTORS O -4. ENFORCEMENT POLICY PROVIDES EXAMPLES ILLUSTRATING H&I AND DISCRIMINATION VIOLATIONS. e O J

4 o EFFECTIVENESS OF ENFORCEMENT PROGRAM -~ k.,s)' WE BELIEVE IT HAS BEEN EFFECTIVE IN ENCOURAGING COMPLIANCE AND IMPROVING PUBLIC HEALTH AND SAFETY ORDERS VERY USEFUL TO ACHIEVE SPECIFIC CORRECTIVE ACTIONS MANAGEPNT AUDITS TO IDENTIFY ROOT CAUSES OF PROBLEMS SELF-APPRAISALS IN SPECIFIC AREAS WHERE PROBLEMS IDENTIFIED AUDITS OF DAY-TO-DAY ACTIVITIES AS INCENTIVE TO COMPLY CIVIL PENALTIES PROVIDE ONE OF A SERIES OF PROGRESSIVELY MORE SIGNIFICANT ENFORCEMENT SANCTIONS () INDICATE 3 SIGNIFICANCE NRC PLACES ON VIOLATION DETERRENT EFFECT NOT JUST FROM FINANCIAL EFFECTS BUT ADVERSE PUBLICITY DETERRENT EFFECT ON OTHER LICENSEES i i ()

y / ho ^ 78 9 1 2 1 HCRAM SE I m T I V I 1 T 1 CA o H c C e N e O A S R B S EC N e A e, R R U O e S F S e A 1 Y o T I A L A t A, UQ e N l O e< G N S. I F E C I A R B RS EN LI LK IW MA .H J.C T RK EN O BA UR HF 1 l1lll lll1ll1 1

j-L 2 BACKGROUND 4 QA REPORT TO CONGRESS (NUREG-1055, MAY 1984) 1 i i QUALITY ASSURANCE PROGRAM IMPLEMENTATION PLAN (SECY-85-65), FEBRUARY 1985 NUREG-1055 AND QAPIP ADDRESSED BROAD MANAGEMENT, QUALITY PROGRAM PERFORMANCE AND LICENSING ISSUES I AS WELL AS TRADITIONAL QA; SOME ISSUES: T LINE MANAGEMENT PRIMARILY RESPONSIBLE FOR ACHIEVING QUALITY 4 SUBSTANTIVE, TECHNICALLY COMPETENT CHECKS BY QA CRG COMPETENT TECHNICAL OVERSIGHT BY NRC EARLY PROBLEM DETECTION CAPABILITY MANY QAPIP INITIATIVES HAVE BEEN INCORPORATED INTO, OR INTEGRATED WITH, OTHER AGENCY INITIATIVES PARTICULARLY AS THEY ADDRESS BROAD MANAGEMENT AND LICENSING ISSUES j } I 2

SUMMARY

OF QA AND OTHER AGENCY INITIATIVES BROAD LICENSING AND INSPECTI0t: ACTIVITIES DEALING WITH OVERALL LICENSEE PERFGRMANCE AND ACHIEVEMENT OF QtlALITY IMPROVED INSPECTION METHODS (PRODUCT ORIENTED, DIAGNOSTIC TEAM INSPECTIONS (SUCH AS SSFI, SSONI, IDI, CAT,ETC.) PERFORMANCE INDICATOR PROGRAM t:RC SENIOR MANAGEMENT MEETINGS GREATER USE OF ENFORCEMENT TOOLS (50.55(f) LETTERS, ORDERS / CONFIRMATORY ORDERS, CIVIL PENALTIES)- EXPANDED RESIDENT PROGRAM INITIATIVES RELATED TO IMPROVEMENT OF LICENSEE QUALITY VERIFICATION ORGANIZATIONS REORIENTATION OF NRC "QA" INSPECTIONS FROM PROGRAMMATIC TO PERFORMANCE OR EFFECTIVENESS REVIEWS, READINESS REVIEWS RECOGNIZE BROADER AGENCY INITIATIVE.AND TO FOCUS MORE EFFECTIVELY ON QA QA PLAH BEING UPDATED EFFECTIVENESS AT OPERATING PLANTS (3/87)

( REORIENTATION OF QA INSPECTIONS TI 2515/78, " INSPECTION OF QUALITY VERIFICATION FUNCTIONS" ISSUED JAN 87 1 GUIDANCE ON METHODS FOR FOCUSING ON AND ASSESSING PERFORMANCE OF LICENSEE QUALITY VERIFICATION ORGANIZATIONS ASSESSES EFFECTIVENESS IN IDENTIFYING POTENTIAL TECHNICAL AND SAFETY ISSUES, I.E., INTERNAL DETECTION CAPABILITY 4 UTILIZES,RESULTS OF OTHER INSPECTIONS AND EVENT AND DETERMINES CONTRIBilTIONS AND INVOLVEMENT (OR LACK THERE0F) 0F LICENSEE QUALITY VERIFICATION ORGANIZATIONS BASIC APPROACH: STARTING WITH KNOWN. PROBLEMS ASK "WHY DID QA NOT HELP PREVENT THE PROBLEM?" PROVIDES INDICATION OF TOP MANAGEMENT COMMITMENT TO QA (RELIANCE ON AND ADEQUACY OF TECHNICAL RESOURCES AND SUPPORT GIVEN TO QUALITY VERIFICATION ORGANI7ATION) l f JOINT REGIONAL /HEADOUARTERS TRIAL INSPECTIONS i

.n

- i.

k ' * '.)

44. a.

T \\ 4 MW M M W 0' OE M - L H e E - E W M Z E. O H W 3 m x 3 s -M D l O C# W W 2. M H M J k 4 4 M m H 4 E U x W H O E E I C 4 O i_ E M M W E O M 4 W W + 4 0 4 J K M J M D 4 W D A M c C W W M M 'M Q .H m E C - 4 W E .Q. H g 3 J J ~ L 4 D 4 M W O C H E C A H W Z Z 4 O E H W. E M 4 W E E O H U U C E H E C D 4 O W M H O 3 M C a H a 1-A w C 0 'M M O H a W m I M A-4 m 3 L C C W E W 3 W C H 3 E E - A E U W 6 2 O m A 4 O z W w M = m M ,. t W W 7 O - Z W C E W J W' O W H H 4 i E m U H E W U E E 4 H 4 E E A U C E E M W 4 W E H J ~ H D M C H E W 4 A E H J W 4 A W J H W W D W O E E' W-H A U Z J U W 4 ' U J O W E H M C E 1 - C E O O O U O W M 4 W t

4 4

U U E O W g W W C E 4 E g D M E H C w W L. W M E E E O C O E C W W H 4 H E H W E 4 U = - O W E H 4 M M w 4 m 1 J K C 3 W E M J W J J D W W E W M W E 4 A H C M W Q E E m C O E C I O W c E O -J 4 O E ?, W D W 4 W = H w H 4 J K ~ K A H W M o 4 ( ~H H C 4 W U W U W j O M J E C W M C E C O M 4 E A D E O 6 C M 3 W H U M M M 4 w 4 M W M E E O E C H H E M H W E M E M W D E H W i H E E H H J W X H i-l W W E W W 4 W O C 4 E 2 M E W W H 3 m J M U s H U Z W H m W m M M C E W W U E H W 3 M 4 ~ W W Z 4 J m O r O M W O H U E E E l' H M M U E m E U 4 4 C D 4 5 G G W W W C W m O I J O W G V O W C C N W M ] D 3 M J W U C W i - O C J W X D E E E W C A W H W W W C E A E N W f-M U C H M H Q c M W ~ H E E E E O C J m A 1 W 7 M 4 W W O W J 4 3 1 C C E O U C U g C"N H C M E M E A A C 4 4 E E H A A L W J W Q 4 W U 4 4 M A H E e O W 2 W = O C W Q C U J O 6 m E q a W C s M o W A 0 6 6 6 A 0 0 C e a w f I ,-,,-w,,.,,,m--- --,n,,,-,.,.rn.,,.,,,,,.,,n.-,,,,,,,,,,__,_n.-,n, ,,e. ,,-e-,- an, ,.-,,,,..nw. a .nn,,.,,., - -, n-,-, -, _.,, -

4 , ;. 4 l m .t t .I I 1 i. NRC REORGANIZATION I ? i NRR QAB TO FOCUS ON OPERATING REACTOR-SAFETY l l l i STANDARDS ACTIVITIES TO RES l i WASTE MANAGEMENT QA RESOURCES AND RESPONSIBILITY TO NMSS a P h i i ? .i ~i -i y e r

D paneuq\\ UNITED STATES p O j NUCLEAR REGULATORY COMMISSION 5 OFFICE OF INSPECTION AND ENFORCEMENT t,,,.....,,g Washington, D.C. 20555 INSPECTION AND ENFORCEMENT MANUAL QAVT 1 CHANGE NOTICE 87-01 SUPERSEDED: TRANSMITTED: Number Date Number Date 2515/78 01/12/87 REMARKS: This TI marks the formalization of movement from QA programmatic reviews to performance oriented QA inspections. The TI is meant to be used at selected sites, and it can be used alone or as part of a team inspection. Comments on the experience gained from its use are desired and will be used in development of the permanent procedure. DISTRIBUTION: Standard ONJ [ l Issue Date: 01/12/87 i

s >R Rf Cg h 0 -m e-UNITED STATES E NUCLEAR REGULATORY COMMISSION F OFFICE OF INSPECTION AND ENFORCEMENT g ,/ Washhgton, D.C. 20555 < INSPECTION AND ENFORCEMENT MANUAL QAVT TEMPORARY INSTRUCTION 2515/78 P INSPECTION OF QUALITY' VERIFICATION FUNCTIONS 2515/78-01 INSPECTION OBJECTIVE To assess the effectiveness of licensees' quality verification organiza-tions. 2515/78-02 BACKGROUND Quality verification is synonymous with systems of checks, ~ ardits, inspec-tions and other forms of verification. Licensee managemen; has a number of organizations which perform those verifications. Thef include the Quality 's Assurance (QA) organization, the Quality Control (QC) organization, the cm Quality Engineering organization, and independent review' groups, such as L:) the Independent Safety Evaluation Group (ISEG). ( Quality verification organizations act in a measuremenY and advisory func-tion, monitoring the overall performance of the plant; identifying substan-dard or anomalous performance, or precursors of potentigi problems; report-ing findings in an understandable form in a timely foinion to a level of line management having the authority to effect corrective action; and promptly verifying the effectiveness of the corrective action und reporting - those verification results-back to line management. An effecti\\e quality verification organization is technicalb and performance oriented; it fo-cuses its efforts toward end products as opposed to being concerned only with processes and procedures. The organization should have technical re-sources available to it, and it - should be aggressive in searching for, identifying, and following up on problems. 1 3 2515/78-03 INTRODUCTION TO THE INSPECTION This temporary instruction (II) provides a mews (1) to ensure that quality g verification organizations are effectively contributing to ther identifica-i tion, solution, and prevention of safety significant technical probbms and deficiencies in plant systems and operations and (2) to measure tna effec-tiveness of line management in ensuring that identified quCity defician-cies are responded to promptly and completely. This i ne.nec tiot; will ra-quire the inspector to make objective and subjective judgments based on information obtained through interviews, observations, and rt: view of avail-able documentation. Issue Date: 01/12/87

e r This hspection will use either 'rignificant plant problems that have r@- cently. occurred or significant, NRC technical inspection findings as the vehicle for assessing quality verification effectiveness. This is appro-priate to assess the roles of the quality verification organizations and line management before and in resolution of an issue. Quality verification organizations have responsibility for ensuring that quality is achieved and problems are avoided. Thus, the presence of problems rc.ects on quality verification organizations' performance as well as that of line management. In performing an assessment of this type, the inspector should understand 2 the roles, responsibilit.ies, and interactions of all quality verification organizations. It is imfortant to examine all organizations that formally conduct quality verifications. The cumulative capability of these organ-izations in contributing to safe plant operations is indicative of the overall. quality verification program's effectiveness. lhis TI can be used alone or be integrated into an existing NRC team. It is anticipatad that it will be used selectively and at specifically chosen sites. 2515/78-04 INSPECTION REQUIREMENTS This inspec' ion assesses the effectiveness of the licensee's quality veri-t fication organizationy in identifying technical issues and problems having safeti significance and in following up to ensure they are resolved in a timely manner, as opposed to being procedure and process oriented in their activities. In general, the approa:n is to etaiuate why the licensee's quality verifi-cation organizations were not ef fective in identifying problems that have been identified by inspectio.'s of NRC-or other third parties; or similarly, why licensee quality verification organizations have not been effective in identifying and addressing the precursors or root causes to events. Quality verification organizations perform various types of verifications, such as audits, surveillances, and third party observations. They perform their verifications in a number of functional disciplines, such as mainten-ance, operations, and design' changes. 04.01 In the area selected for this assessment, the inspector should per-form a detailed analysis of existing problems. This should be accomplished througn direct observation of in process activities, interviews of plant personnel, and documentatiun reviews of a selective samnle of completed verifications performed within the past 12 months. 04.02 Based on the results of these activities, the inspector should as-sess and draw conclusions regarding how well the licensee accomplished the g l following: planned for each verification activity I a. b. ~provided individuals of adequate technical experience and expertise to conduct the verification activity Issue Date: 01/12/87 2515/78

i c. conducted the verification activity in adequate depth and with the rx appropriate emphasis on technical activities I ) b/ d. implemented its corrective action responsibilities 2515/78-05 INSPECTION GUIDANCE This guidance is meant only to provide helpful ideas in various areas and is not meant to be a check list for the inspection; it is neither all-in-clusive nor a minimum requirement. Inspectors who are comfortable with and experienced in this type of results-oriented inspection are encouraged to direct their efforts wherb they will be most productive and to provide com-ments which can be used to improve this guidance for less experienced in-spectors. 05.01 NRC Inspector Preparation a. Goal. The primary goal of this inspection is to establish whether the verification organizations are looking for and finding substan-tive technical problems. b. Method. The inspector should perform a detailed analysis of the selected issue (i.e., problem areas and occurrences of events) to understand the technical problems and events, why they occurred and what the roles of the verification organizations and line management were. For selected problems and events, this analysis should in-(m clude (1) determining the chain of events leading to the problem's t ) occurrence, (2) developing an understanding of the technical and V work activities associated with the issue, (3) determining the in-formation that is needed to understand its generic implications, (4) determining the extent to which the licensee identified precursors to the problem and investigated the facts surrounding its occur-rence, and (5) identifying the licensee's corrective actions to cor-rect the p. %m and the remedial actions taken to preclude its re-currence. c. Information Base. Plant-specific information, including the find-ings of previous NRC inspections and information obtained from dis-cussions with the resident inspectors, should be used to perform the analysis. Other sources, such as SALP reports, LERs, information notices, IE bulletins, employee concerns, PRAs, and current internal licensee plant status or problem reports, also should guide the in-spector. d. Selective Samples. Selective samples are samples chosen to provide a quick picture of performance and, thus, provide for a more effec-l> tive inspection. Items should be selected in areas where known or i suspected deficiencies exist. The size of the selective sample is jo Established when the inspector is satisfied that sufficient data have been reviewed and documented to support a conclusion about the area sampled. l e. Experience and Expertise. It is important that inspectors be ac-l companied by individuals having the necessary technical or opera-tional experience and expertise when assessing areas other than their own areas of expertise. 2515/78 Issue Date: 01/12/87

05.02 Inspection Requirement 04.02a a. Preparation. The inspector should assess the licensee's planning to assure that it takes into account trends in performance and responds to events. The development of a written audit plan and the selec-tion and orientation of the auditors should be reviewed to assure that the effort is well organized and completed in an efficient man-ner. b. Depth. Time spent on a verification, when compared to the complex-ity of the subject matter being verified, should provide insight into the depth of the verification and its importance to the licensee. The level of the verification's detail should be deter-mined. For example, is the licensee's design verification activity only a check to verify that the calculations and analyses have been performed, or is it a check of the calculations' validity and a ver-ification of the engineering basis for them? c. Scheduling. Scheduling should be dynamic. Successful verification programs use a "living" schedule that permits important plant ac-tivities and events to be verified and documented as they are oc-curring, or shortly thereafter. This provides for the greatest im-pact and most effective followup. 05.03 Inspection Requirement 04.02b a. Personnel Experience and Expertise. The importance of having per-sonnel with direct experience and expertise in the area they are reviewing cannot be overemphasized. Personnel interviews will pro-vide useful information. Likewise, qualification records, which should be current and readily available, are useful for evaluating an individual's capability to competently verify a specific area. However, this should not be u ed as the sole basis for questioning an individual's ability. The fewer technically experienced person-nel a quality verification organization has, the more closely th? licensee's verifications should be assessed to determine its ability to detect operational and technical quality flaws. b. Use of Outside Assistance. For members of the organization to function effectively in areas other than their own area of exper-tise, it is essential that they be accompanied by individuals who have the necessary technical or operational background to be able to find significant, but often subtle, quality conditions requiring corrective action. 05.04 Inspection Requirement 04.02c a. Types of Verifications. Organizations perform various types of ver-ifications. Audits are the most obvious. The inspector should be aware of the various types of verifications and their relation to other parts of the quality verification program. b. Achievement Orientation. The licensee's verifications should be in depth, not superficial, and should emphasize technical achievement more than programmatic conformance. However, the results of an achievement-oriented quality verification may indicate that wider Issue Date: 01/12/87 2515/78

problems exist. In such a case, the quality verification organiza-tion should then examine the programmatic implications and identify ,' ~ other technical areas where review is warranted. ) / c. Verification Activity Report. It is important for the verification report to accurately reflect the collected data. Otherwise manage-ment would be receiving an incomplete or biased perspective of the plant's quality achievement. A report that overstates the effort expended or draws positive conclusions from superficial verifica-tions should be identified as a weakness in the verification pro-l ', gram. Problems with timeliness, clarity, or accuracy in reporting i may hamper the corrective action process and may indicate attitudinal problems as well. Listen for symptoms of these problems during personnel interviews. d. Communication and Cooperation. Through personnel interviews, the j inspector should evaluate the adequacy of communication and coopera-tion between the verification organization, the functional disci-plines and line management. I 05-05 Inspection Requirement 04.02d a. Corrective Action Response. The inspector should evaluate each re-sponse and the organization's actions subsequent to the response for adequacy. The actions should correct root causes, not merely the symptoms of those causes. The implications of the deficiency on other plant activities should be a consideration in the assessment of the response. Appendix B to 10 CFR 50 requires that the cause of (x; the condition is determined and remedied to preclude repetition. \\"/ For each analysis reviewed, the inspector should evaluate the re-ported root cause and the adequacy of the steps taken to determine the actual root cause. b. Followup. The organization should follow up corrective actions in an aggressive manner. It should have access to upper line manage-ment and the authority to effectively use that access. The inspec-tor should determine the extent to which the quality verification organizations are actually meeting with line management as this is a key indicator of their effectiveness. c. Escalation. The inspector should assess the effectiveness of the verification organization and line management to determine whether identified quality deficiencies are responded to promptly and ef-fectively. Although a separate escalation procedure may not be re-quired, the organization should have established a means to bring the attention of upper management to those problems which are not promptly and adequately corrected. Examples of significant correc-tive actions remaining open for excessive periods or being extended repeatedly without apparent reason are indicative of an ineffective corrective action followup program. Those examples also may be in-o dicative of a line management problem. d. Closure. Closures should not have been based on superficial reviews or completed without a determination that the corrective action will be effective in preventing recurrence or emergence of similar prob-lems. 2515/78 Issue Date: 01/12/87

e. Trending. The organization should have an established and effective program designed to identify significant trends. f. Corrective Action Tracking Systems. Various deficiency tracking and corrective action systems exist inside and outside of the organiza-tion. The total extent of those systems and their overlapping re-sponsibilities and requirements, if any, should be identified. The more overlapping and ambiguous the system control, the more likely it is that problems will occur, such as a deficiency being tracked in a system which is not monitored by the group responsible for the corrective action. 2515/78-06 REPORTING REQUIREMENTS Document completion of this inspection in routine inspection reports. 2515/78-07 EXPIRATION This TI will remain in effect for twelve months after issuance. 2515/78-08 IE CONTACT Questions regarding this TI' should be addressed to Frank Hawkins on FTS 492-8490 (or 301/492-8490) or Wayne Scott on 492-4220. 2515/78-09 MODULE TRACKING SYSTEM INPUT Record actual inspection effort against Module Number 25578. This TI is to be performed at licensee sites using the inspection hours allocated by IE for the performance of the following inspection procedures (IP). The requirements to perform the following IPs are held in abeyance during the effective period of this TI. However, those IPs may be useful for a more detailed review in their specific subject area and would be es-pecially useful if the inspector feels that an in-depth compliance-ori-ented inspection is needed. 2 Title 35701 Quality Assurance Program Annual Review 37703 Tests and Experiments Program 38701 Procurement Control Program 38702 Receipt, Storage,and Handling of Equipment and Materials Program 39701 Records Program 39702 Document Control Program 40700 Cnsite Review Committee 40701 Offsite Review Committee 40702 Audit Program 40703 Offsite Support Staff 40704 Implementation, Audit Program END Issue Date: 01/12/87 2515/78

g U.S. NUCLEAR RETULATORY COMMISSION OaGANIZ ATION CHARI 0FFICE OF NUCLE AR REACIOR RIGtn A110N lap'ements regulations, and develops and implements policies, programs 44 proc edures for all aspec ts of lic ensing and inspectsun of; (1) manuf ac t ur ing, production and utilization f acilities, recept for those con (erning f uel reprocessing plants and isotopic enrichment plants; (2) rec e ipt. possession and ownership of source, byproduc t, and special nuc lear material used or produced at f acilities licensed under 10 CIR Part 50, (3) eperators of such f acilities; (4) emergency prepareduss at suc h f acilities, and (5) contractors and simpliers of such f acilities. Identifies and takes action regarding condities,s and licensee performance that may adversely af fect public health and safety, the environment, or the saf eguarding of nuclear reactor f acilities; and assesses and rec-comends or takes action regarding inc idents or acc ident s. Provides spec ial assistance as required in matters involving reactor facilities esempt from licensing Provides guidance and implementation direction to Regional Of fices on reactor licensing and inspection prograss assigned to the Region, and appralses Regional program performance in terms of ef f ec tiveness and unif ormity. Performs other f unc tions required for implementation of the reactor licensing and inspection programs. Director lhomas E. Murley Deputy Director James N. Snierek PR(fA AM MAN AGE ME NT, POttCY. DE VE LOPME NT. 8 ANALYSIS ST AF F I i (See Page 39 l A%0CIATE DIRECTOR FOR PROJECTS ASSOCIATE DIRECTOR FOR INSPECil0N A'iD TECHNICAL ASSESSMENT Responsible f or overall projxt management activities related to lic ens ing and inspection of power and non power reac tors and Re:ponsible for management direction of technical evaluations, standard reactor designs; and interactions with the other Associate inspections. operator Ilcensing, licensee management performance; Director and Staf f Director to resolve or recossend resolution of assessment of assigned technical activities; and it.teractions with policy and of fice-level programmatic issues, the other Associate Director and Staff Director to resolve or l Frank Piraqlta mccamend usolution of polky or major Wke hvel pgammam l issues. l Richard Id. Starostecki DIVtMON OF flE ACTOR PRO JE CTS -- t.11 DevISION OF E NGINE E RING ,% p, y & SYSTEM IE CHNOL OGY l DIVISION OF RADIAT'lON PROTECTION (See Pase 38) & EME RGENCY PREPAREDNESS DIVISION OF RE ACIOR PROJE CTS (See Page 411 Ill. IV. V AND SPE(.1 AL PROJE CTS DIVISION OF OPE RAllONAL EVENTS ASSFSSMENT (Scr Fear 3h (See Page 391 OlVISION OF LICENSEE PE RF ORMANCE & OUALITY EVAL UAIK)N DIVISION OF RE ACTOR INSPECTION & SAF E GUARDS (See Page 41) (Sw Page 40) FESAUARY 6.1sB7 PA=.E 38 l J

Q 'Q v U.S. NUCLEAR REGULATORY COMMISSION 000aNtf a f rON (MaB3 PROGRAM MANACIMINf, P01 ICV Of Vf LOPMENT, AND AN4tVS15 STAFF Provides overall policy and management direction for of fice aministra-t i ve, resource, management information, technical support to the Direc-toe, NRR, and policy development activities; and interacts with the Asso-ciate Of rectors to resolve or recommend resolution of policy and of fice-level programmatic issues. Coordinates reactor licensing and 6nspection policies, programs and guidance. Provides of fice focal point for R15 ac-tivities which af fect of fice prograes. Performs reviews and evaluations related to reactor insurance, indemn6ty and antitrust matters. Director Vacant Planning, Program and Management Support Branch Policy Development and Technical heport 8 ranch Inspection, ticensing and Research Integration Branch Provides arbetnistrative management and coordination of the programs and resources of the of fice. Establishes sponds to enternal policy-related inqu6res'Y * ?" ' ** "9 C '" provides guidance and programs for reactors undee construction' technical assistance and support to the Director NRR. and operating reactors. Maintains NRC Inspection Man-priorities, sc hedules and resource allocations; per-forms long-and short-range planning, budget develop-Serves as NRR staf f interf ace with organizations such mal and Standard Review Plan. Performs special review ment and execution. Provides aministrative and man-as ACR$ and CRGR; performs cost-benefit analysis; co-and analyses, and participates in inspection as neces-agement support, including personnel management, train

ordinates the NRC allegation programs; and performs sary to coordinate policy procedures, guidance and pro-ing and manaoement information systems. Manages NRR reviews and evaluations related to reactor insurance, grams. Provides of fice focal point for RES activities c ont rac ts, indemnity and antitrust matters. Coordinates of fice.

which af fect licensing, inspection and regulation of vide regional assessment. nuclear reactors. Chief James L. Blaha Chief Jesse L. Funches Chief Frederick J. Nbdon 9 G 6RUART 4.19B PAGE B

U.S. NUCLEAR REZULATORY COMMISSION ORG ANI2 AllON CH ARI Olvl510N Of REACIOR PROJECTS-l/II implements the policy, programs and activities, including coordinating Incensing, inspection, technical review and liceesee performance, asso-c 6ated with the overall safety and environmental project management for individual power reactors loc a ted in Regions I and 18. Participates in special team inspections, and assesses Regional project activ6 ties. Director Steven A. Varga I I I Assistant Director f or Region I Reactors Assistant Director for Region 11 Reactors Plans, directs and supervises the project management activities and Plans, directs and supervises the project management activities and monitors daily reactor operatiens for power reactors located in monitors daily reactor operations for power reactors located in flegum 1. e= cept for the reactors essagewd to the Of fire of Sswaal Protects Regeon II. except for those amagned to the Ottace of Special Peosects Bruce A. Boger Gus C. Lainas Project Directorates I-I through I-4 Project Directorates 11-1 tIvreugh Il 3 Performs the overall safety and environmental project Performs the overall safety and environmental project managemer t and monitors daily operations of power reactors management and monitors daily operations of power reactors in Region ll. (Reactors owned by one utility or related in Region I. (Reac tors owned by one utility or re lated utilities will be assigned to the same Project Di rec - utilities will be assigned the same Project Directorate. ) torate. ) Manages the review and processing of appIlcations Manages the review and processing of applications for limited work autherirations, construction permits, operat-for limited work authoritations. Cons truc tion permits, operating licenses, implementation of agency approval ing licenses, implementation of agency approval require-requirements, and licente amendments. Serves as Head. ments, and license amenchments. Serses as Headquarters

== contact with licensees and applicants. Coordinates the quarteis contact with licensees and applicants. Coordinates preparation of Safety tvaluation Reports and Enviroceental the preparation of Safety tvaluation Reports and Environ-mental Impact statements, and routine inspections. Coords-Impact Statements, and routine inspections. Coor9tnates and provides presentations to the Commission, ACR$, industry nates and provides presentations to the Commission, AC#5, industry groups and other government of fices on specific groups and other government of fices on specific projects and subjects. Participates in special inspections. projects and subjects. Participates in special inspections. Directorate 1 Director ( Acting) Robert A. Capra Directorate 11 Direc tor fl6aor G. Adensan Directorate 1 Otrector Walter R. Butler Directorate Il Director tester 5. Rubenstein Direc torate 1 Direc tor vin (ent 5. Noonan Directorate ll Director

8. J. Youngblood Direc torate 1 Director J. Stoir l

nenuany e. tes7 PAGE N P l fA%

( g U.S. NUCLEAR REGULATORY COMMISSION DIVis!ON Of Rf ACTOR PROJICT5-Ill/lV/V ANO SPtCI AL PROJECIS ~ ORGANIZATION CHARI Implements the policy, pengrams and ac.tivities, int.luding coordinat ing licens-inq inspection, technical review and licensee performance associated with the overall safety and environmental project management f or individual power reac-inrs located b Regions !!!, IV, and V; fi41*2 Cleanup; reactors in the Inte-grated Saf ety Assessment Program; non power reactors; 00(/D00 reviews; reac-tors whose construction has been indefinitely deferred, decnamiissioned reac* tors; and standard plant designs. Participates in spec ial team inspections, and assesses Regional project activities. Direc tor Dennis M. Crutc hf ield m a r Assistant Director for Regions ill and V Reactors Assistant Director f or Region IV Reactors anaf Special Projects Plans, directs and supervises the project management activities and non-Psans derce ss arwt esprewrirs the swn,ert man.my niene misveter s arvt rnem.t.ws da.ty nper e== itors daily reactor operation for power reactors located in Regions !!! of umer re m enes locateet en Reepen IV, eurept for show aument en the Off ere af Se rv e.et t L 4, s v co ep Ine sher aswinnt so the Off a.c of Sergist Proen.n Proicces. norgwmer reatters. DOF 'DOD reverws. readors whnw a nnsteus own n *=h4 n.se4v tirlerretf derotninct5sortal rem sors. arWf sterwi.arrf P.ent 81r%F5s l Gary Holahan f ranit schroeder Project Directorates Ill-1 through III-3 and V Project Directorate IV Performs the overall safety and environmental project management Performs the overall safety and environmental project management and monitors daily operation for power reactors in Regions !!! and monitors daily operation for power reac tors in Region IV. and V. (Reactors owned by one utility or related utilities wilg Manages the review and processing of applications for operating tie assigned to the same Projec t Directorate. ) Manages the review licews, implementation of agency approval requirements, and and processing of applications for limited work authoritations, license amendments. Serves as Headquarters contact with lic ensees ses and applicants. Coordinates the preparation of Safety (valuation construction permits, operating licenses, implementation of agency approval requirements, and Ittense amendments. Serves as Head. Reports, and routine inspectians. Coordinates and provides pre-sentations to the Ccamission. ACRS, industry groups and other quarters contact with licensees and applicants. Coordinates th, = preparation of Safety Evaluation Reports and Environeiental Impact government of fices on specific projects and subjects. Part 6c 6-pates in special inspections, Statements, and routine inspec t ions. Coordinates and provides presentations to the Commission, ACRS, industry groups and other Director Jose A. Calvo government offices on specific projects and subjects. Partici-potes in special irspections. IMI-2 Cleanup Project Directorate Provfdes overall direction of IMI-2 cleanup operations, inc luding Directorate ill Director ( Acting) Martin J. Virgilio technical and management supervision of related NRC inspection, Directorate Ill*2 - Director Daniel R. Muller licensing, and analysts; monitors cleanup activities f rom the site Directorate 111 Director ( Acting) Steven D. Richardson and provides necessary oversight functions. Reviews safety eval-Director V - Director George W. Itnighton uations prepared by the licensee to support various activities associated with the cleanup operation; provides ledependent esti-mates of occupational radiation exposures resulting f rom the Cleanup. Manages and directs preparation of Programmatic inviron-mental !spect Statements and related assessments; and coordinates all NRC activities relating to the cleanup which involve otiter Federal agencies, state and local governments, and groups or mem-bers of the public. Direc tor william D leavers Standarderation and Non power Reactor Project Direc torate Performs overall saf ety and environmental project management for standard plant design reviews; directs, coordinates and perf orms NRR rew t ege activities for DOE and D00 facilities exempt from li-censing; performs project management and technical reviews for = non-power reactors, indefinitely deferred construction projec t s, indefinitely shutdown projects, and projects being decommissioned. Serves as Headquarters cont ac t with licensees and applic ant s. Direc t or Merhert N Berkow a Integrated Safety Assessment Project Directorate Performs overall safety and env ironment al projec t management and safety evaluations for operating power reac tors part ic ipat tag in NRC's Integrated Safety Assessment Program (15AP); and perf orms reviews and evaluations of followup issues resulting f rom Systema-tic Evaluation Program (SEP) plant integrated assessments. Serves as Headquarters conta(t. Di rec ti e Cor e l 0 thomas FEBRUARY 6.19BF PAGt 37 w

) U.S. NUCLEAR REEULATORY COMMISSION DIVl5 ION N INCINt(RING AND 5V51[M IlCHNOLOGY e r 'o**s systems and engineering related safety evaluations of licensee imple-ORGf.NIZ AllON CH A RT

ntation of apprnved NRC requirements, changes to esisting licenses, and l

+plications for new f acilittes or designs; and provides technical empert6se fur spec ial inspec tions, projects, programs and policy activities. j p e rec t or Lawrence C. Shao 4ecial Assistant James A Norberg E I E Ass., tant Derector f or Engineering Assistant Director for Systees Plans, directs and supervises the tec %n tCal reviews related to instrv-Plans, directs and supervises the technical reviews related to the engi, mentation, control, electrical, pleet and reactor systems; and provides neering disc ipl ines, and provides technical espertise for special i n-spections, projects, programs and policy activities. tl James Richardson Ashok C. Thadant Materials Engineering Branch Instrumentation and Control Systems Branch Rev s and evaluates functknal performance mquinments, design Reviews and evaluates materials engineering, inservice inspection, and performance of reac tor trip systees, engineered safety fea-and materials integrity related aspects of design and performance tures actuation systems, actuation instrumentation for essential of components and systems. Reviews spec ial f abrication problems a llan sup p t systm aW instrumentatM and control sysh and monitors component behavior, provided to initiate and regulate the operation of safe shutdown Chief ( Acting) C. Y. Cheng systems. Reviews and evaluates f unc tional performance require-meats, design and performance of plant instrumentation providing information regarding manually initiated and controlled safety Mechanical Engineering Branch functions. Reviews design criteria and loads, and static and dynamic analysis I*C8"I methods and inservice testing for mechanical systems and compo-pents. Reviews and evaluates seismic and dynamic qualification of equipment. Verif6es integrity, capac ity and margins assoc iated Electrical Systems Branch with mechanical equipment. Reviews and evaluates conditions asso-ciated with various postulated events, such as earthquakes, san-Reviews design and operation of of f site power grid systems with re-related hatards, floods, and pipe breaks, and their threat to the gard to inter-relationships between the nuclear unit, the utility r, rid and interconnecting grids. Reviews and evaluates funct6enal functional integrity of components. performance requirements, design and operation of onsite power Chief

1. Marsh systees.

Chief faust Rosa Structural and Geosciences Branch l Reviews design criteria and loads, analysis methods and inservice plant Systems Branch testings for s truc tures. Verifies integrity, capacity and margins leviews and evaluates functional performance requirements, design associated with structures. Reviews and evaluates conditions 4550-end p,,g,,mance of (1) essential ausiliary and support systees. clated with various postulated events suc h as earthquakes, and (2) reac tor containment and assoClated support systems and their threat to the integrity and functional performance of struc-(3) design features provided to ensure operator protection free tures. Reviews and evaluates issues related to geologic, seismo-releases of tonic and radioactive gases. Reviews the design of lug.c and bydrologic characterestecs of a rmactor me. new and spent fuel storage and load handling systems. Feviews radioactive source teres and reviews and evaluates the eiesign and Chief ( Acting) Goutam Bagchi performance of features provided to prevent the communicatican of potentially radioactive systems with other plant systees. Chemical Engineering Branch Reviews and evaluates issues related to chemical engineering, Reactor Systems Branch inc luding fire protection, hydrogen generation, post accident Reviews and evaluates design, process design parameters and per-

sampling, water chemistry, corrosion, decontamination and formance of reac tor thereal-hydraulic systees (reactor coolant dec ommis s ioning system, normal and emergency core cooling systems under steady-state, transient and accident tenditionst Reviews analyses of Chief ( Acting)

Conrad E. McCracken anticipated operational occ urrenc es, postulated accidents and actual operating emperience f rom the viewpoint of systems operation end transient dynamics. Reutews and evaluates nuclear and therinal-hydraulic aspects of the reac t or core under steady-state, trans* Gent, and accident conditient Responsible for issues pertaining to core physic s, fuel tvehav ior, and Core thermal-hydraulic performance Chief M. E Hodges FESAUAAY S. ToB7 PAGE N 9 e m 1

8 9 g I U.S. NUCLEAR REGULATORY COMMISSION OaO ANff AflON CH Aaf DIVISION Of OP1 RATIONAL (VIN 15 ASST % MENT laplements programs and procedures to systematically assess and screen daily reac tor licensee events; to provide daily reports; to recommend isusediate corrective plant-specific and generic actions; ans, to coor-I dinate the f ol low-up to events by assigning and trac king follow-up I actions to other divisions. Maintains and administers *en-call of ficer* l roster to assure notification of responsible :4RR projec t management I, for events requ6 ring prompt attention and provides NRR foral point for interf ac.e with Al00 on their studies and operation of Incident Response Center. Maintains $afeguards Emergency Response Plan, and serves as the Information Assessment Team contact. Develops and issues NRC correspondence (e.g. generic letters, information notices and bulletins) to address generic concerns resulting f rom event assessments. Develops J programs and guidelines to improve generic technical specifications and develops technical specification for plants under operating license i review. Participates in special inspections. Director C. E. Rossi Technical Specifications *anch Events Assessment Branch Generic Communications Branch Systematically assesses and screens nuclear power Develops guidamce and guidelines for immediate correc-Develops, maintains and updates staMard technical regulatory requirements, reactor operating experience and vendor reports of tive actions (e.g., generic letters, bulletins and specifications based on new new technical considerations and operating emperience; equipment deficiencies to identify significant events; information notices) resulting from operational events. performs or requests the Regions to perform detailed Issues all NRC generic letters, bulletins, and infor-develops technical specification impienentation guid-safety assessment. of significant events to determine nation notices relating to power reactors. ance; develops and evaluates technical specifications for plants under operating license review; and pro-plant specific and generic safety implications; and eldes NRR interpretation of specific technical specif t-rec omumends immediate corrective action where appro-pelate. Develops prewntation for and chairs the daily cations requirements, operating reactor event briefings; serves as the NRR f ocal point for interf ace and contact with AE 00, Regions, other NRC of fices and industry for operating event related issues. Maintains and acheinistees "on call 6fficer" roster to assure notification of project management for events requiring prompt action. Responds to emergencies, and assists in evaluating licensee emergency preparedness and safeguards emergency response plan, and serves as the Incident Assessment team (le.1) contact. Carl H. Berlinger Chief Edward J. Butcher. Jr. Chief ( Acting) Wayne D. tanning Chief ffenuAnye.tw7 9 PAGE 39 l

m p-t ,'4 U.S. NUCLEAR RE~ULATORY COMMISSION ORGANIZAllON CH AR1 l l OlVl5 ION OF Rf ACTOR INSPECTION AND 5AFEGUARDS l 1 Performs special reactor inspections, vendor inspections, reactor safe-guards licensing and regulatory ef fectiveness reviews (Rf R), and quality assurance reviews for reactors. Applies qu6delines for implementing the licensing (e.g. $RP) and inspection programs (e.g. SALP and IE manual). Provides team leaders for and participates in special inspections and assesses ef fect6veness and untformity of Regional implementation of pro-grams assigned to the Regions. Director James G. Partlow Deputy Director Brian Grimes Vendor Inspection Branch $afeguards Branch $pecial Inspections Branch Carries out NRC program f or the evaluation of the quay. Conducts safeguards technical and regulatory restews re-Dewlops programs for and performs special inspections ety assurance program implementation and physical ex. lated to power and non-power reactors. Reviews physical (e.g. $$f i/$50Mi and PAI) to systematically assess li-amination of materials, components and services produced security programs. Conduc t s onsite requ,latory effec-and/or supplied by arc hitec t-engineers, cons truc tors, tiveness reviews of safeguards systems as emplemented at censee operations and identify problems requiring atten-tion. Provides team leaders for special inspections, s miependent inspec t ion agenc ies, NS$$ suppliers, and licensed nuclear power reactors, and recommends improve-other companies supplying safety related materials or ments, es appropriate. Reviews inspection and evalua-services to the nuc lear industry. tion reports to identify generic reac t or safeguards issues. Develops guidance for use by Regional Of fices, and assesses effectiveness and uni formity of Regional Of fice igtementation of programs assigned to the Regions. Chief ( Act 6ng) Ellis W. Merschoff Chief Robert A. Erickson Chief (Acting) C. Haughney l l FEenUAnY S.1957 PAGE a0

- ~- U.S. NUCLEAR REGULATORY COMMISSION ORG ANIZ AflCN CH ARI Olvtilog of RADI Af t0N PR0ffCTION AND (MERGINCY PR[ PAR (DN($$ Performs licensing reviews and safety evaluation and interf ace with FEMA for emergency preparedness at reactor facilities; develops approaches for applying PRA results to inspec tion and licensing; develops policy and guidelines and performs technical reviews in radiological protection areas; and provides technical expertise for special inspection. Director f rank Congel Emergency Preparedness granch Risk Application Branch Radiation Protection Branch Reviews and evaluates emergency plans associated with construction permits and operating licenses for power Applies the results of partial and full scope PRA to Reviews and evaluates Regional and local awteorologi-plant specific licensing and inspection decisions. cat conditions; reviews and evaluates the radiation reactors. Reviews and evaluates emergency plans for Develops approaches for applying PRA to licensing and effect on the public and plant personnel resulting research and test reac tors. Coordinates with FEMA inspection programs, from postulated accidents and normal operations. on emergency preparedness matters and reviews and evaluates itMA findings and determinations relating Provides technical emp*rtise for special inspections. to offsite preparedness of state and local govern-projects program and policy activit 6es. ments. Provides guidance to Regions on emergency pre-paredness and supports Regional inspection and euer-Cese aberrvatoons, Revseurs and evaluates rnues related to demogra@ec f Characteresists of a rearfor sete Chief David B. Matthews Chief (Acting) Richard J. Barrett l Chief (Acting) L. J. Cunningham FE BRUARY S. s957 PAGE at

~ U.S. NUCLEAR RE~iULATORY COMMISSION 01G AN12 AilON Cl4 A RI DIV!5!0N OF LIGN5EE PERFORMANCE AND QUAllTV EVALU4fl0N featuates ef f ectiveness of Iftensee performance by integrating input from programs and activities such as 5 ALP, enforcement, per f ormanc e indicators. AE00 analyses, event assessment, operator emanination and licensing and inspection. Develops programs for assuring quality and reliability of operations and construction. Assesses e f f ec tiveness and uniformity of Regional Of fice implementation of the programs assigned to the Regions; and provides technical empertise for special inspection. Director William T. Russell Deputy Director Hubert J. Miller 1 1 l l Performance Evaluation Branch Quality Assurance Branch Human Factors Assessment Branch Operater ticensing Sranch l lealuates the ef fectiveness of licensee per. Develops and implements a comprehensive NRC Monitors and evaluates industry maintenance Responsible for overall If tensing and regula-I f ormanc e by integrating input from programs program for assuring quality and reliabil6ty and training improvement initiatives and tory policy pertaining to Itcensing of opera-l and activities suc h as 5 ALP, enforcement, of reactor Itcensee facilities design, f abri-performance. Revleus Ots and uttitty tors pursuant to 10 CfR Part Provides performance indicators, Af 00 trends analysis, cation, construc tion, testing and operation. requalification programs for training and orogram guidance to Regional Offices for event evaluation, operator examinations and this encompasses licensees,

vendors, qualifications.

Revleus and evaluates administration of esaminations of operators licensing and inspec tion. Identifies the architect-engineers, constructors, and other normal operating procedures and guidelines, and senior operators and evaluation of I need for and recommends special laspection licensee agents. Revleus and evaluates of f-normal and emergenc y procedures and requalification programs. Develops and sall-for input to performance evaluations. quality assurarce aspects of applications guidelines, and initial /preoperational test dates testing techniques and standards for for construction reemits, operating licenses programs and special test programs. Provides evaluating candidat. s. Evaluates adequacy of and amendments. Provides technical empertise technical expertise for special inspections, facilities and simulators used in the conduct for plant inspections. projects, p mgrams and policy activities. of operator examinations. Assesses ef fective-Reviews human factors engmeervig design of the control ness and uniformity of Regior.a1 Office imple-i room and control centers cuisade of the meut control mentation and programs assigned to the I roent Regions. Chief ( Ac ting) Philip J. Polk Chief ( Acting) Arthur 8. Beach Chief William H. Regan, Jr. Chief (Acting) John llannon FEBRUARY a. 5857 PAGE a2 l 9 e 4

t O 1 l XRC Technical Training Center Presentation to the ACRS by Kenneth A. Raglin i Director. Technical Training Center O March 12.1987 l l l l l l1 Of 6! l O

O i XRC Technical Training Center General Information a TTC Curriculum a Students a O Use of Training Aids i 'l2 of 6 O

/ '4 O General Information

Mission

!

Line Organization

!

Location j
Facilities l
Budget
Staff: 23 FTE For FY8' O

i:

Experience
Licenses.' Certifications j
Degrees i
Instructor Qualification Program
Fiscal Budget: ~ $2.5 M l

l l !3 0f 6l O I:

TTC Curriculum O Based on Agency Needs

Spectrum of Courses j
Generic Courses
Reactor Technology Courses
Reactor Engineering Support Courses
Safeguards Courses l
Health Physics Courses j

Typically About 1600 Student-Weeks Annually l

Reactor Technology Training I
Reactor Vendor Coverage
Types of Courses

= Course Series O

Courses
Typical Topics
Stand-Alone Courses
Classroom Training
Simulator Training j
Specialized Technical Training
Use of Contracts
Examples
Future TTC Emphasis

! 4 0f 6 0

't O Students i !

Resident Inspectors Region Based Project Inspectors a

l

Engineering Support Inspectors j

Operations Center Duty Officers '

Operator License Examiners Technical Managers Other NRC Technical Staff j = Support for International Programs l
NRC Foreign Counterparts O
Foreign Courses l
Brazil (2) l
Egypt j

Republic of Korea (2) l

Mexico (3)
People's Republic of China i
Taiwan (2)
Yugoslavia l5 of 6 0

O Use of Training Aids j = Reactor Simulators l BWR Simulator j PWR SNUPPS Simulator (W) l Advantages l

Reactor Plant Models l

BWR Engineering Model PWR Engineering Model (CE) PWR NSSS Model (B&W) Hardware Training Aids

BWR Dummy Fuel Assembly O

BWR CRDM = BWR Jet Pump Assembly BWR HCU

PWR Dummy Fuel Assembly (W)

Surplus Material

Cancelled TV A Projects
Other Sources High Technology Aids 6 0f 6 O

e O PERFORMANCE INDICATOR PROGRAM FOR OPERATING NUCLEAR POWER PLANTS O ~ O l

1 O TASK GROUP CHARTER OBJECTIVE: DEVELOPAMINIMUMSikTOFPERFORMANCEINDICA RECOMMEND METHODS FOR USING INFORMATION TO MAKE TIMELY REGULATORY DECISIONS ABOUT PERFORMANCE, ASSUMPTIONS: 1. EVOLVING SALP IS THE CORNERSTONE OF EFFORTS TO EVALUATE LICENSEE PERFORMANCE. 2. TRENDING A SET OF SAFETY PERFORMANCE INDICATORS IS NECESSARY TO DETECT CHANGE BETWEEN SALPs AND PROVIDE ADDED OBJECTIVE INPUT. l 3. STRUCTURED DECISIONMAKING IN RESPONSE TO DECLINING PERFORMANCE IS NECESSARY. 4. DEVELOPMENT AND USE OF OTHER INDICATORS FOR SPECIFIC PROGRAM AREAS REMAIN WITH THAT OFFICE. l . O 2

(;> PI DEVELOPMENT PROCESS SELECTION OF PIs FOR TRIAL PROGRAM SELECTION OF PLANTS FOR TRIAL PROGRAM DATA COLLECTION AND REVIEW FOR THE TRIAL PROGRAM C0 ORDINATION WITH INDUSTRY '/ALIDATION/ CONFIRMATION OF THE PIs SELECTION OF THE MINIMUM SET ($) DEVELOP METHOD OF ANALYSIS AND MONITORING ?ROVIDE RECOMMENDATIONS TO COMMISSION IMPLEMENTATION CONTINUE DEVELOPMENT O 3

a b i SELECTION OF PIs CRITERIA (IDEAL ATTRIBUTES OF PIs): Pls RELATED TO NUCLEAR SAFETY / REGULATORY PERFORMAN DATA AVAILABLE TO NRC READILY AND TIMELY DATA NOT SUSCEPTIBLE TO MANIPULATION DATA COMPARABLE BETWEEN UTILITIES PIs WORTHY G0AL FOR UTILITY () Pls REFLECT A RANGE OF PERFORMANCE Pls INDEPENDENT OF EACH OTHER PIs LEADING OR PREDICTIVE OF FUTURE PERFORMANCE SET OF PIs BROAD EN0 UGH TO CORRELATE WITH SALP O y -._.,-r .r,

.O CONFIRMATION / VALIDATION VALIDITY THRV RELATIONSHIP TO LOGIC MODEL STATISTICAL ANALYSIS COMPARIS0N OF INDIVIDUAL PIs TO SALP COMPARISON OF PI SETS TO SALP O s Y -._.-.,,-,-.,,_y.,_ 3_,-_,. _v- .,e_._,.,,, _,__,,...-.,,m,,.-_.-,..-_.,_,m,c.....m,., _...._ .m

O RELATIONSHIP OF Pis'TO LOGIC MODEL PLANT SAFETY 1 I LOW FREQUENCY HIGH AVAILABILITY INHEREN" DESIGN 0F TRANSIENTS OF SAFETY SYSTEMS FEATURES AND LOW POTENTIAL FOR C0GNITIVE ERRORS HIGi TRAIN LOW P0TENTIAL 'AVAI. ABILITY FOR COMMON- ~- CAUSE FAILURES Pts PIs PIs _A - SCRAMS * - FORCED OUTAGE' - CAUSE CODES - ESF ACTUATIONS - LC0 ACTION - ANNUNICATORS - SAFETY SYSTEM STATEMENTS - AUDIT ITEMS / ACTUATIONS* - SAFETY SYSTEM - MAINTENANCE - SIGNIFICANT EVENT FAILURES

BACKLOG FREQUENCY *

- TURNOVER RATE l - UNPLANNED SHUTDOWNS -gg ACTION INDEX** - INT. EXPOSURE - 0VERALL MAINT. IND.* 'SELEGIED FOR IliE OPTIMUM SET WITH SOME DEFINITION CHANGES

- SELECTED BY THE TASK OROUP, SUBSEQUENTLY DELETED AT COMMISSION O

DIRECTION l l l

(]) SET OF P!s FOR THE CU4 RENT PROGRAM 1. AUTOMATIC SCRAMS WHILE CRITICAL: THIS IS IDENTICAL TO THE INDICATOR, UNPLANNED AUTOMATIC SCRAMS WHILE CRITICAL, USED BY INP0. IN ADDITION, THE NUMBER OF AUTOMATIC SCRAMS FROM AB0VE 15% POWER PER 1000 CRITICAL HOURS AND THE NUMBER OF AUTO-MATIC SCRAMS WHILE CRITICAL BELOW 15% POWER WILL BE MONITORED. 2. SAFETY SYSTEM ACTUATIONS: THIS IS IDENTICAL TO THE INDICATOR, UNPLANNED SAFETY SYSTEM ACTUATIONS, USED BY INP0 AND INCLUDES ACTUATIONS OF ECCS (ACTUAL AND INADVERTENT) AND EMERGENCY AC POWER SYSTEM (ACTUAL), 3. SIGNIFICANT EVENTS: THESE EVENTS ARE IDENTIFIED BY THE DETAILED SCREENING OF OPERATING EXPERIENCE BY NRR AND IE, AND INCLUDE DEGRADATION OF IMPORTANT SAFETY EQUIPMENT, UNEXPECTED PLANT RESPONSE TO A TRANSIENT OR A MAJOR TRANSIENT, DISCOVERY OF A MAJOR CONDITION NOT CONSIDERED IN THE PLANT SAFETY ANALYSIS, OR DEGRADATION OF FUEL INTEGRITY, PRIMARY COOLANT PRESSURE BOUNDARY, OR IMPORTANT ASSOCI ATED STRUCTURES. (])4. SAFETY SYSTEM FAILURES: THIS INCLUDES ANY EVENT OR CONDITION THAT ALONE COULD PREVENT THE FUL ILLMENT OF THE SAFE 7Y FUNCTION OF STRUCTURES OR SYSTEMS. TWENTY-FOUR SYSTEMS OR SUBSYSTEMS WILL BE MONITORED FOR THIS !NDICATOR. 5. FORCED OUTAGE RATE: THIS INDICATOR'S DEFINITION IS IDENTICAL TO THE ONE USED BY INP0 AND THE NRC GREY BOOK (NUREG-0020), AND IS THE NUMBER OF FORCED OUTAGE HOURS DIVIDED BY THE SUM 0F FORCED OUTAGE HOURS AND SERVICE HOURS. 6. EQUIPMENT FORCED OUTAGES PER 1000 CRITICAL HOURS: THIS IS THE INVERSE OF THE MEAN TIME BETWEEN FORCED OUTAGES LAUSED BY EQUIPMENT FAILURES. THE MEAN TIME IS EQUAL TO THE NUMBER OF HOURS THE REACTOR IS CRITICAL IN A PERIOD DIVIDED BY THE NUMBER OF FORCED OUTAGES CAUSED BY EQUIPMENT FAILURES IN THAT PERIOD. O 7

C:) C0 ORDINATION WITH INDUSTRY JUNE 11, 1986: AIF/INP0/ UTILITY REPRESENTATIVES AUGUST 15, 1986: INP0 MEETING SEPTEMBER 15-16, 1986: ANS EXECUTIVE SEMINAR SEPTEMBER 15, 1986: AIF/INP0/ UTILITY REPRESENTATIVES INDUSTRY COMMENTS CONSTRUCTIVE MAINTENANCE BACKLOG REMOVED BASED ON INDUSTRY COMMENTS PLAN TO CONTINUE COORDINATION WITH INDUSTRY AS PROGRAM EVOLVES PLAN TO SHARE DATA AND-IDEAS WITH INP0 () (:) 9

.i ( ). SAMPLE REPORT FORMAT ' INDUSTRY

SUMMARY

TABLE LATEST SALP ? 3 4-QUARTER AVERAGE LATEST QUARTER PLANT PROFILE TREND LATEST QUARTER VS 4-00ARTER AVG DEVIATION FROM INDUSTRY MEAN DETAILED PLANT ANALYSIS CHART (]) QUARTERLY DATA (8 QUARTERS) INDUSTRY AVERAGE CRITICAL HOURS l l l 10

O PLANT A

Trends Performance Indicators otelined imPreved

1. Sereme, e) Tetel (2 Str. Ave. end SS-4)

.e E b) > f 52/3 000 Celt. Nre. (2 Qtr. Avg. end 88-4)-'////////////// ~4.4 s) < 185 Pewer (2 Str. Avg. and 88-4) =4 G

2. Setely System Aeteettene (2 Otr. Avg. end SS-4)-

.3

3. Slgnificent Evastte (2 Otr. Avg.end 56-4)-

1.4

4. $efety System Fellures (2 Qtr. Avg. end 88-4)-

.0

5. Forced Outo go itole (2 Ctr. Avg. end 88-4)-

. s.t

4. Equipment Forced Outeges/1000 Crit. Hre. -

-3.3 (2 Qtr. Avg. and 88-4) / -2.5 '2 -I'.5 -t -d.5 0 055 I 1.'S i 2.5 Devigtlene frem.*revleus 4 Otr. Plant Weene (Weesured in Stenderd Osvlettene) p'4 Ctg g ig g,y p_ty,- .,. p -.. ;,- t s-

- o: 1. Sera rs. a)Tetet (s Cse. Ave. ene ss-4) kii ///////////;

-4.s b) > 15%/t 00 0 crit. Hre. (4 otr. Av e e nd as-4) ////////////// - 3.6 e) < 15% Pewer (4 Qtr. Avg. end 8 8-4) ////////////// -8.8

2. $ef ety System Actuettene (4 Qtr. Avg. end 85-4)-

-9.9

3. Significant Evente (4 Qtr. Avg. end 8 6-4) -

-1.4

4. Sately System Feltures (4 Qtr. Avg. end 85-4)-

.3

5. Forced Outogo Itote (4 Qtr. Avg. end 85-4)-

-1.4

4. Equipment Forced Outoges/1000 Crit. Hre. -

- 3.2 (4 Qtr. Avg. end 8 6-4) / -2.5'2 -t'.5 -l -d.5 0 0'5 5 f.'5 k 2.5 evictions from Older Plant Woon Woosured in Standard Devlettone O lf -

1A. Total Scroms O PLANT A %i 85-1 to 86-4 is 2s00 t a.ad tz22 sere-. i4 - -1250 f -.., ei.., ei nnroe.. s, .,,,,y E & gg-

'".f',

\\. - 17s0 it e Critteel n OO b 6 10 - i L s ge - 1500 % O 5,, 8 - 4 j - i2 0 E LL \\ / O

j N... /

iOOO z g. E, ... '..s o ac - 750.2 x-4- = 3.. 3.. - 500 h s.* 2 Z6 2:0 6 '. 'f7.X 'k. 9.%. + 0 0 85-1 85-2 85-3 05-4 86-1 86-2 86-3 86-4 Year - Quorf er 1B. Scrams Above 15%/1000 Critical Hours v2-i: CcL-10 2500 Legend Q Setems 3- ~ Oider Pleni e .2000 E O ... Crilleet E& - 3750 it 00 Ue 6- - 1500 0 u M> %4 s.. - 12S0 oE o y 6L o je 4- - 1000 Z E5 '/ 750 'o e 1 2-1.7 - 500$ Y r-;! 2 + + m. 2 2.1 200 0 0 85-1 85-2 85-3 85-4 88-1 88-2 88-3 86-4 Year - Quorf er I e l1 - \\

O-MILESTONES FEBRUARY 1987 PROVIDE FIRST QUARTERLY-REPORT BASED ON PI DATA THROUGH DECEMBER 1986 MAY 1987 PROVIDE SECOND REPORT BASED ON DATA THROUGH MARCH 1987 AUGUST 1987 PROVIDE THIRD REPORT BASED ON DATA THROUGH JUNE 1987 NOVEMBER 1987 PROVIDE FOURTH REPORT BASED ON DATA THROUGH SEPTEMBER 1987 'I) DECEMBER 198'i REFINE PROGRAM BASED ON EXPERIENCE GAINED AND RESULTS OF CONTINUED DEVELOPMENT COMMISSION PAPER 4 O 13 .~}}

ML20212Q057

Text

SUMMARY

SUMMARY

Navigation menu

Search