ML20246G157
| ML20246G157 | |
| Person / Time | |
|---|---|
| Issue date: | 01/13/1989 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| References | |
| ACRS-2615, NUDOCS 8905150205 | |
| Download: ML20246G157 (34) | |
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ADVISORY COMMITTEE ON REACTOR SAFEGUARDS REGIONAL PROGRAMS SUBCOMMITTEE MEETING JANUARY 5-6, 1989 NRC REGION IV 0FFICE ARLINGTON, TEXAS PURPOSE: The purpose of the meeting was to review the activities under the purview of the NRC Region IV Office.
ATTENDEES:
Principle meeting attendees included:
ACRS NRC F. Remick, Chairman R. Martin
- C. Michelson, Member J. Montgomery J. Carroll, Member J. Milhoan W. Kerr, Member J. Callan D. Ward, Member J. Holler C. Wylie, Member T. Stetka P. Boehnert, Staff G. Sandborn J. Jaudon J. Gagliardo J. Pellet R. Bangart W. Fisher
- Acting Chairman:
A.M. session 1/5/89 PEETING HIGHLIGHTS, AGREEMENTS AND REQUESTS 1.
Mr. Michelson, Acting Chairman, noted that the purpose of the meeting is to obtain information from the regional level office perspective, including details on the operations of nuclear power plants in Region IV.
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Mr. R. Martin (Regio, IV Region;l Administrator) introduced the managers of his Office and provided a detailed organization chart (Figures 1-3). Mr. Martin noted that some agenda issues may be beyond their preview, but they would do their best to respond.
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Regional Programs Minutes January 5-6, 1989 1
2.
J. Milhoan (Director Division of ' Reactor Safety) discussed plant maintenance prograns from the perspective of the Region. Noting that the maintenance rule is now out for public comment, Mr.
Milhoan said that licensees' maintenance programs are seen as improving, but there is still room for further improvement. The Rule should help to better define what the agency will expect of the licensees, as well as help clarify the issue of the extent of balance of plant mainten9nce that will be required which is seen as a " grey area".
In response to Mr. Ward, Mr. Milhoan said the Office has no objective measure of the status of a plant's maintenance program, but based en' reports / incidents they believe there has been improve-ment (in the last few years). The. proposed Rule requested comment on development of a objective maintenance standard (s).
Dr. Kerr asked what Mr. Milhoan hopes to achieve with the Rule, and how will he know when he will be satisfied with the standard of maintenance at a given plant. Mr. Callan (Director, Division of Reactor Projects) noted that RIs spend considerable time evaluating plant maintenance activities.
However, there is no guidance available to the inspector as to what is " acceptable". He indi-cated that it's largely a matter of judgment. The Rule should help address this problem.
Dr. Kerr said he believes plant safety and reliability are of key importance and he doesn't see how the Rule would help. Mr. Montgomery (Dep. Regional Administrator) indicated that the Region relies on Rules to give structure and guidance to their efforts. They would not hesitate to tell Headquarters if they thought the Rule was either not useful or not wnrking.
Mr. Michelson asked what would be different if the Rule is issued.
Mr. Ct.llan said they expect the Rule will result in a batter husbanding of licensees' maintenance resources; for example use of
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l failure rate data for decisions on maintenance vs replacement of a given component. The establishment of a well defined maintenance standard is seen by Mr. Milhoan as the key benefit of the Rule.
Mr. Carroll asked in effect wh:,e does BOP maintenance end - where do you draw the line? In response to Dr. Kerr, Mr. Montgomery indicated th, a Rule should result in better agreement between NRC and the 1: > 1ees as to where and how maintenance priorities can be best applied.
In response to Mr. Carroll, Mr. Milhoan indicated that the NRC was somewhat disappointed that the Industry had not aggressively embraced the INP0 maintenance guidelines. Had they done so, the NRC may not have seen the need for a Rule. The lack of ability of the NRC to force a licensee to shape up his maintenance program was (and is) seen as a problem. However, the Region admitted that its not clear the Rule will help here.
In response to Mr. Wylie, Mr.
Milhoan said the Rule will provide a standard to assure uniformity in the programmatic aspects of the licensees' maintenance programs.
I Dr. Kerr opined that NRC should have the broad goal of focusing on l
how to assure the plants are operating safely, regardless of how l
gecd or bad their maintenance, training, etc., programs are.
Discussing what maintenance problems licensees have seen, Mr.
Milhoan said licensees have expressed concern that resources may be inappropriately shifted to maintenance in response to the Rules' j
requirements. Licersees also complained of a potential loss of flexibility given the strictures of e Pule.
In response to Mr.
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Michelson, Mr. Gagliarda sa'id that, by and large, the licensees that are using the INP0 maintenance guidelines are satisfied with them. Mr. Carroll observed that he has heard that so.ae licensees find INP0 a more onerous regulator than NRC.
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Regional Programs Minutes January 5-6,-1989 In response to Mr. Carroll', Mr. Gagliardo said he would provide him copies of the maintenance inspector instructions (TI's), and the reports of the NRC Team Inspections conducted in Region IV.
In response to Mr. Michelson, Mr. Milhoan indicated that most licensees' programs designed to determine the root'cause(s) of an event have been found wanting by the region.
Regarding the need to enhance skill levels of licensee's mainte-nance personnel, NRC indicated that in Region IV, their experience leads them to conclude that the workforces are highly skilled.
Career progression for personnel in the maintenance area to other disciplines is seen as difficult.
In response to Dr. Kerr, Mr.
Montgomery said he doesn't see a need for NP,C to become involved in this area. Mr. Milhoan said knowledge of plant systems and operations by maintenance personnel would be helpful in reducing reliability problems.
Mr. Ward indicated that he was told that good maintenance programs can have two distinct styles. He asked if the Rule may force a licensee to gravitate to one or another to the overall detriment of their specific program. Mr. Callan indicated that the Rule should -
not result in such a problem. Mr. Michelson asked if the Region feels formal accreditation of maintenance porsennel is desirable.
The Region said that INP0 is forcing this pursuant to their Program. The region believes that individuals are expected to be certified or approved to perform their maintenance function:.
Use of hands-on training facilitie's are seen by the Region as very l
helpful. Not all Region IV licensecs have such facilities, however as some licensees don't yet have operating simulators on site.
Regional Programs Minutes January 5-6, 1989 Dr. Kerr asked if the Region is concerned.that NRC is moving towards management of the plants. Mr. Callan said their Office worries about this and feels the maintenance rule should help here given the more prescriptive guidance of a rule.
In response to Dr.
Kerr, Mr. Montgomery indicated they do not attempt to manage the licensees plants.
However, they believe they have a duty to comment on aspects of plant nanagement, particularly if they are seen as root cause contributors to incidents.
Mr. Wylie asked if they have seen any instances where licensees have had problems getting needed funds for operations and mainte-nance. Mr. Callan said they would address this point in detail later'in the meeting, but in general they have not seen this problem. The maintenance Rule may head-off a problem here vis-a-vis the licensees' PUC's.
3.
The topic on in-situ valve testing was discussed. Mr. Milhoan noted there is a proposed NRC Generic Letter under preparation that will extend testing requirements to valves in all plant safety systems. The Region has nearly completed inspection of all plants for compliance with NRC Bulletin 85-03.
Mr. Michelson asked a number of questions on this topic.
Key points noted included:
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- The Region has designated a " valve expert" in order to assure I
compliance with MOV-related requirements. However, the Eegien I
has yet to evaluate the scope of the inspection requirements vis-a-vis the above Generic Letter.
Use of a team inspection l
approach (withjointNRR/regionpersonnel)mayalleviate problens here.
l TVA conducts a 3-day training course on Limeritorque M0V's.
Several of the Region's RI's have attended this course.
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Regional Programs Minutes January 5-6, 1989 TVA conducts a 3-day training course on Limeritorque MOV's.
Several of the Region's RI's have attended this course.
- It was noted that onc the valve problem became apparent, the industry has provided a good responsive effort.
To the Region's knowledge, most of the plants have not seen the draft Generic Letter. None of the licensees have ex-pressed concerns to the Region regarding the proposed require-ments. Licensee feedback on Bulletin 85-03 has also been nonexistent.
The Region noted that the NRC NPRDS is not user-friendly.
Only a few people in Headquarters are well versed in obtaining data from the system. Mr. Carroll was surprised the Region is not routinely accessing NPRDS to aid inspection efforts. The Region said the licensees provide information available from NPRDS to them upon request. The major problem with dissemina-
' tion'of the NPPDS data is that INPO holds this material proprietary.
The Region is involved in the dissemination of operating event information via participation by telecon in the weekly event meeting held at Headquarters. LERs and the daily event reports are also evaluated.
Events are addressed immediately, with follow-up via LER's and an "open-item" list until all concerns are fermally closed out.
4.
Mr. J. Holler addressed problems / concerns with large chilled water systems (i.e., South Texas plant). The details of the system's p
configuration were noted. Noting problems at South Texas, Mr.
Holler said there have been tube failures seen in the CCW heat exchanger. Also, dealloying of aluminum-bronze components was. seen
Regional Programs Minutes January 5-6,'1989 i
resulting in through-wall leakage of various fittings. As a result, the licensee replaced the defective components with materi-al resistant to the dealloying mechanism.- In response to Mr.
Carroll, Mr. Holler said a corrosion inhibitor is used in the chilled water side of the system.
In response to Mr. Michelson, Mr. Martin said some system inter-action events are disseminated to the Region, depending on the immediate safety significance of the equipment disabled.
5.
Inadvertent actuations of fire protection systems at Region IV plants were discussed by Mr. Murphy. He noted that two Region IV plants have-had incidents: ANO and River Bend. The ANO plant has had three actuations which were detailed. River Bend also had three incidents. One incident resulted in a shorting out of some electrical equipment associated with a safety-related system when it was flooded with water.
6.
G. Sandborn and J. Montgomery reviewed the issue of enforcement.
Mr. Montgomery outlined the enforcement program.
Enforcement actinn at a Severity Level III and higher requires Headquarters concurrence.
The Region IV enforcement statistics for 1988 were reviewed (Fig-ures 3A-4).
In response to Mr. Carroll, Mr. Montgomery said the Region has been labelled an " outlier" for the large number of violations issued to operating plants given their smaller size (Figure 5). Further discussion lead to Mr. Montgomery saying that the Region believes they are ferreting out valid violations, but he had no ready explanation for the discrepancy among the regions.
Headquarters Office of Enforcement has nct expressed any displea-sure with the Region's actions in tnis regard. The Region believes the fines issued have a positive effect on reactor safety.
Regional Programs Minutes January 5-6, 1989
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i In response to Dr. Kerr, Mr. Martin said the recent revisions to the enforcement policy allow more latitude in crediting a licen-see's' corrective actions to a violation. Dr. Kerr observed that he is not convinced that enforcement actions lead to improved licensee performance per se.. Mr. Martin agreed that the long term impact on performance is difficult to assess.
In response to Mr. Carroll, Mr. Martin said licensees have expressed displeasure with the high number of enforcement actions.
In response to Mr. Ward, Mr. Martin said his analysis of the enforcement situation is that he wants to assure.the inspectors are doing a thorough job independent of the number of enforcement actions.
Further discussion focused on the i
danger posed from radioactive sources. Mr. Martin noted there was an incident in-the Region some years ago where loss of proper control of a source resulted in a fatality.
Mr. Montgomery said the revisions to the enforcement policy should aid their enforcement effort, given the flexibility now allowed.
Their chief enforcement problem is with materials licensees.
7.
Dr. Remick, in taking chairmanship of the meeting, noted that in his experience, the regional meetings provide detailed information on reactor operations, not available at Headquarters.
Mr. Martin discussed Region IV's operations. He detailed the organization structure of the Office end specified Office func--
tions. He noted that in the smaller region offices (such as Region l-IV), the inspectors tend to be " generalists".
In response to Dr.
l Nemick, it was noted that 10 of 14 states in the region are Agree-ment States.
Low level waste disposal responsibility is split.
Headquarters will license the rites:, Mr. Martin expects his Office will be performing some (or most) of the oversite functions, i
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I Three activities / situations unique to the region were noted:
(1) a high number of well-logger licensees. The mobility and casual business ethics of these licensees pose unique problems from a regulatory perspective; (2) the Fort St. Vrain plant (only U.S. gas cooled reactor); and (3) the uranium recovery field Office in Denver, CO.
In response to Dr. Remick, Mr. Martin said, in general, the Office is satisfied with the conduct of the Agreement State's programs.
Mr. Martin cited several incidences involving contaminated material were cooperation from agreement states was crucial in resolving the particular concern.
Noting the problems associated with the operation of Ft. St. Vrain, Mr. Martin said, problems aside, the fuel performance and very low occupational exposures seen'at the plant were outstanding. Dr.
Remick said when he had occasion to visit the plant, its physical condition was, in his opinion, deplorable. He asked why the Region allowed this. Mr. Martin said the licensee's argument was that the plant was "special" and deserved special treatment. Also, the fact that two of the chief utility Officers are now in prison speaks to another aspect of the problem. The plant's physical condition subsequently improved dramatically after the above two people were removed.
Noting new office initiatives, Mr. Martin said the recent reorgani-ntion of NPC {particularly NRR) greatly improved region /Fead-quarters cooperation end communication.
Yn response to Mr.
l Carroll, Mr. Martin said the NRR plant Licensing Project Manager is usually present at the region when his licensee is in for a confer-ence. This is a big change from the past.
In response to Mr.
Ward, Mr. Martin said the regionalization effort largely impacted mater'als iicendirig of fort. As for reactor licer. sing, only licens-ing of reactor operators has been fully regionalized.
Regional Programs Minutes January 5-6, 1989 Mr. Martin also noted that the region is beginning to apply closer scrutiny of material licensees in order to weed out individuals who.
should not be allowed to possess such licenses.
Messrs. Martin and Montgomery noted that cultural attitudes unique to the Midwest work to the Office's favor vis-a-vis enforcement of regulations.
.Concerning consistency of regulation among the regions, Mr. Martin said inconsistencies do exist, and some are potentially-significant. He indicated that some of the inconsistency is the result of insufficient guidance from Headquarters. There is a lack of direction from NRC as to what or how the Office shouid change to correct the problems.
Improvement of the Headquarters regional audit oversight process is needed.to resolve this problem.
In response to Dr. Remick, Mr. Martin indicated that he is con-tinually concerned with the gulf between what the industry claims for engineering excellence and the actual experience he sees at the plants. Because of this, his focus has had to be on regulating to
" adequacy" instead of regulating to " excellence".
In response to Mr. Ward, Mr. Martin said he relies on development of a " confidence level" of good attributes on the part of a utility in order to govern his reaction to dealing with them when a problem arises.
Dr. Kerr said he is uncomfortable with the attitude (he's seen in some SALP reports) that a utility must improve performance (from a "3" to a "2" rating, say) when a "3" means, in effect, the plant is operating safely. Mr. Martin indicated that there has been a rising standard of expectations by the NRC for licensee performance L
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l 8.
Issues associated with reactor operations were discussed. Concern-ing problem plants, Mr. Collan cited their one problem plant - Ft.
l Calhoun. The central problem the licensee had was a set of pro-grammatic weaknesses in the areas of operator training, radio-I' logical controls, and engineering support. These problems were illuminated by an operational event (intrusion of water into the safety grade instrument air system) last summer and the license's subsequent inadequate response. Attitudes such as " keep the plant running" and " shoot the messenger" (if a safety problem is raised) contributed to their woes. Also, an outstanding operating record (long runs at power) masked the utilities weaknesses.
The licensee has developed a long-term action plan (extending to 1990) to resolve the concerns. The Region is satisfied with their progress to date.
9.
Mr. J. Jaudon discussed the issue of technical specifications (TS).
The thrust of his comments were that equipment that is TS'ed is generally better maintained and there is some concern that retest-ing of systems is not generally well done at most plants.
Preven-tive maintenance is also an area where relaxation of TS may be a problem.
Relaxation of TS requirements should help reduce unneces-sary testing. Mr. Milhoan expects that the number of licensee amendments should be reduced as a result of the TS improvement program.
- 10. SALP and Performance Indicator (PI) programs were reviewed by the Region. A summary of the SALP scores for the seven Region IV plants were noted (Figure 6). Because of a May 1988 revision in the NRC Manual Chapter, a number of previous categories have been deleted (N/A's on lower half of Figure).
Mr. Callan said SALP Board reviews are very labor intensive. NRC Staff rating discussions were characterized as " vibrant and
1 Regional Programs Minutes January 5-6, 1989 robust".
In response to Mr. Carroll, Mr. Callan said often the meaning of a SALP rating is explained to the licensee (i.e. perfor-mance increased recently, etc.). The region strives to make the ratings as objective as possible. The role of the RI in the rating selection is carefully considered in an attempt to preclude their dominating the ratings with their personal biases.
Further dis-cussion noted that RI's tend to be too reticent in either criticiz-ing or praising licensee performance out of fear of appearing too biased (pro or con).
In response to Mr. Michelson, Mr. Callan said a "close call" is usually resolved by asking whether or not more inspection resources should be committed to the area (s) ut.ier dis-cussion.
In response to Dr. Kerr's question, Mr. Montgomery indicated that the SALPs are used to help allocate the inspection resources of the NRC. Dr. Pemick asked what is the Region's impression of the licensees view of the SALP. Mr. Montgomery said he is sometimes concerned when licensees use SALP reviews as "scorecards" rather than taking the Staff's concerns to heart.
Some utilities tie managers' bonuses to SALP ratings.
Concerning PI's, Mr. Callan said the region does not interact with the licensee regarding the PI ratings - pursuant to Headquarters direction. PI's are not used to evaluate licensee performance; rather they're used as a indirect check on performance. Dr. Kerr asked what the purpose of the PI's are then, given that the region doesn't use them to evaluate performance. Mr. Montgomery indicated that he sees PIs as useful for long-term trending of performance, particularly for the benefit of the Commission and Headquarters senior management staffs.
On the topic of the impact of PVC actions on plant performance, the region cited the case of the River Bend plant, where the PUC disallowed $1.4B in construction costs.
Impacts seen were:
(1)
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Regional Programs Minutes January 5-6, 1989 salaries were frozen for over 2 years, (2) turnover of technical personnel was generally stable, and (3) nonsafety work items were delayed; however safety was not directly affected.
In summary, although safety was not directly affected, there may have been some measurable indirect effects on individual perfor-mance. The region indicated that the River Bend utility is con-sidered a solid performer.
In response to questions, Mr.
Montgomery said Ft. St. Vrain may cease operation due to denial of funds by their PUC.
The inspection activities of the region were noted. There is a program to implement a "N+1" criterion for the number of RIs per units at a site. Regional inspectors have a goal of 32% of their time spent in direct inspection activity.
Commenting cn the impact on licensee performance of NRC team inspections, Mr. Milhoan said team inspections give a broader gauge of a licensee's performance.
He believes these inspections have a positive influence on performance.
The pros and cons of the use of RIs were discussed. On the pro side, response time (given an incident) is short, they are NRCs
" eyes and ears".
RIs direct inspection time is higher compared to regional inspectors (50% vs 30%). NRC managements resources are more flexible, and the cadre of experienced inspectors is a plus for the Agency as a whole. A RI can also minimize the negative impact of NRCs operations.
On the con side, RI's are isolated from the work environment as being outsiders. Normal office routine is lost to them. There are personnel hardships associated with the necessary rotation schedule (5 years).
RI's sometime beco-too involved in plant activities (tendency to supervise).
Finally, the
Regional Programs Minutes January 5-6, 1989 ever present concern with possible " capture" and/or " burnout" is a problem.
In response to Dr. Remick, Mr. Callan said the source (s) of RIs includes people with operator licenses, etc.
It is difficult to recruit R0s/SR0's primarily because of federal salary limitations.
Generally after two tours, an RI is assigned to a regional office.
There has been little loss of RI's to utilities in Region IV. A number of RIs have moved to positions in Headquarters.
- 11. 'The issue of safety management focus (i.e. where should the plant's/ utility's " safety conscience". lie?) was discussed. Dr.
Remick outlined the history of the ACP.S concern with this issue.
Mr. Michelson indicated that he believes a safety conscience must reside at the upper levels of utility management.
Mr. Callan said his experience is that the plant operators always impress him as having a strong safety conscience. He added that this conscience must be continually supported from above (senior managernent) in order to assure its viability and growth. He cited a positive example of a utility rewarding individuals for identifying safety problems in their plant. He said plant Operations is a " natural home" for safety conscience.
Mr. Martin said his experience is that there is one person in line management who act as a day-to-day safety conscience. The key relationship for a viable safety conscience is the interface between the plant manager and the corporate level individual he/she reports to.
If this interface is working well, there is almost never a problem in this regard.
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J Mr. Ward sees a safety conscience as one who consistently and with authority brings the safety perspective to all key discussions affecting the plant.
He noted that the Japaneese have a " safety
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officer" who is a senior-level line manager and acts in a sort of dual capacity.
Mr. Martin said the safety focus at the CEO level in the utility is via a nuclear safety subcommittee of the Board members.
Mr. Martin said industry's role:in safety management has been real and positive.
INP0 is providing excellent service to the industry but this opinion is not uniformly shared among the utilities (i.e.
some see INPO as another " burden"). The INP0 " assessment" (inspection) reports are reviewed by NRC.
If INP0 raises concerns with an area under HRC purview, Mr. Martin said he feels duty bound to investigate if for no other reason then to assure himself NRCs perspective is correct'(e.g., if INP0 and NRC have a disagreement on the status of a program, etc.) Mr. Martin added that NUMARC is effective in marshalling industry resources to address issues and is capable of doing a great deal of good.
In response to Mr. Carroll, Mr. Martin said they understand INPO shared many of the same concerns as NRC regarding the Ft. Calhoun plant.
In response to Dr. Remick. Mr. Martin said INP0 and NUMARC has resulted in a more integrated industry response to proposed rulemaking, etc.
During further discussion, Mr. Ward remarked to Mr. Martin that he (Martin) is the third Regional Administrator who has said he is motivated in part by threat of Congressional involvement. Mr.
Martin said, in reality, he is not overly burdened by demands from Congress. He will take action if there is evidence of safety i
problems at a plant via an allegation, "tip", etc.
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- 12. The effectiveness of plant safety review committees was discussed.
Both pros and cons were noted. Pros cited included:
- Pesults in periodic supervisory level interface to review issues
- Creates teamwork Pools the collective knowledge of plant personnel
' Provides the " big-picture" perspective on issues.
Cons cited included:
Time involvement of plant supervisory level personnel Potential to become too involved in details failure to delegate and utilize subcommittees
- Lack of knowledge of committee functions by members Failure to structure proper administrative' control and support
- Lack of QA involvement.
It was noted that for newer plants one of the more effective requirements of the technical specifications has been the requirement for the formation of an independent safety engineering group.
In response to Mr. Michelson, Mr. Martin said that in many (most) instances, the meetings of the plant safety review committees don't -
Regional Programs Minutes January 5-6, 1989
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stick to safety issues (i.e., they wear many hats at once). Mr.
Callan said that the Agency is encouraging all plants to form some kind of safety review committee as is required for the newer plants.
Commenting on use of performance based inspections versus in-spection of " paper" for quality, Mr. Milhoan indicated that NRC inspections are becoming more hardware oriented but " paper" in-spections are still required.
In response to Dr. Kerr, Mr. Milhoan indicated that inspectors are not under any " quota" (explicit or implicit) for reporting vio-lations. Mr. Martin said he would be concerned if an inspector spent a large amount of time crawling around a plant and never found anything (or very few problems).
In response to Dr. Remick, Mr. Martin said he does not want inspectors citing " nits".
How-ever, if a series of " nits" evidences a process or procedure problem then the inspector should cite them with an accompanying explanation.
Mr. Martin made the point that a " paper" inspection really is much more than that; the receipt of more resources has allowed him to conduct more performance based inspections.
In response to Mr.
Carroll, the Region indicated that the question of access to a utilities electronic mail system has not (yet) become an issue.
Predecisional documents obtained from a licensee are generally treated as status reports, as the region realizes issue positions are still being worked out.
- 13. Mr. Milhoan led the discussion of plant operator. licensing.
In response to Dr. Kerr, it was noted that none of the NRC examiners in the region have ever had an operator licenses. Examiners are L_____-______--___-_
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Regional Programs Minutes January 5-6, 1989 1
put through courses and receive "0JT" to become certified to perform examinations.
Dr. Kerr expressed some concern that no NRC examiners ever had an operators license. Mr. Milhoen indicated he has great difficulty in recruiting R0s/SR0s due to salary limitations.
He also said he has.no qualms concerning the region's ability to give valid operator examinations (given the people he now has at his disposal). Dr. Remick speaking from experience as a R0, SR0, and NRC examiner said his preference would be to have examiners with R0/SR0 experience. Mr. Milhoan agreed.
In response to Mr. Carroll as to why the examiner turnover is very low in the region, Mr. Pellet said two reasons are:
(1) a high level of management support, and (2) the examiners want to live in the region.
Region IV conducts 1-200 replacement license exams. They budget for 60-100 requalification exams / year. There are 370 SRO and 160 R0 licenses in the region. Mr. Ward noted that there are a number
( > 100) of " hobby licenses" at the regions plants. He asked if this is seen as a problem. Mr. Pellet indicated that he doesn't have any real problem with this, as many of these individuals do function in a pinch (e.g. a strike) or do stand in in order to gain expertise, etc.
Addressing the experience of the region and suggested improvements, Mr. Milhoan said the examination program is becoming more stable -
which is welcome. He believes that operator exams for research reactors could be made more simple, by either eliminating or simplifying the writteq exam and going to a walk-through format, and has so recommended to Headquarters.
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' 19-January 5-6, 1989 The region does use contractors to develop exams; these people come from INEL, PNL and a private contractor.
Mr. Milhoan said they find the new examination format (revised Part 55)agreatimprovement. Concerning the use of plant simulators, it was noted that some plants simulators have significant defi-ciencies; in.at least one case in the region, rendering it useless for examination purposes. Of the seven Region IV LWRs, all but 2 plants have on-site simulators. Their vintage is recent enough to make them sufficient for examination use. Updating of the simula-l tors is an important and never-ending task.
The experiences resulting from the use of the revised requalifica-tion examination format were noted. Mr. Milhoan believes that, in the long term, the new format will be less labor intensive for the NRC.
Ft. Calhoun was the first plant to which the new format was applied in the region. Of the eight people tested, two failed the walk-through portion of the exam.
Some of the reasons for the failures were that the operators did not correctly use their procedures and did not have sufficient familiarity with equipment outside the control room.
In response to Mr. Carroll, Messrs. Pellet and Milhoan indicated that there is room for improvement in~the walk-through exam proce-dure on the NRC's part.
l Dr. Remick offered the view that he feels NRC will probably move towards a check operator concept for the recualification exams.
Mr. Milhoan indicated there is already an aspect of check operator in the exam. Mr. Montgomery indicated there is no real reason why NRC couldn't adopt this approach.
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i Discussing the development of the written examination, Mr. Milhoan said the biggest problem is generating good, fair, objective written questions. Use of utility personnel for development of the exam introduces the potential for compromise.
Drs. Kerr and Remick (referring to their background as professors), said they didn't see cheating as a problem for the open-book type exam that NRC now uses.
l tir. Ward asked what the NRC examiners do if during the course of administering an examination they discover a plant has poor proce-dures.
NRC immediately notifies site representatives, and if the deficiencies are significant, NRC is notified as well.
NRC will also monitor the licensee's corrective actions in this regard. Mr.
Pellet said that he feels E0Ps have become poorer at some plants, because the symptom based procedures tend to lead one to focus on issues peripherial to the central problem at hand.
Dr. Kerr suggested thought be given to training a standby "E0P crew" as nost E0Ps won't even be used, Dr. Kerr noted the Peach Bottom incident (sleeping operators) and the fact that NRC had l
I failed to uncover the problem. He asked if the region is confident they are not missing similar problems. Mr. Montgomery said such behavioral problems are difficult to detect.
He indicated that, given human nature, no one can guarantee such an event won't reoccur. He also said, based on his expertise with psychological testing, that such testing won't be effective in uncovering
" problem personnel" before the fact.
- 14. Mr. Bangart (Director Divison of Radiation Safety and Safeguards) led the discussion on fitness for duty (FFD). He noted the following points:
i
1 4
Regional Programs Minutes January 5-6, 1989
- Licensees' programs were varied in response to NRC the policy statement.
- Licensees support the proposed rule - with comments (e.g.)
this is a " drug program", not FFD (i.e. alcohol was not included); specificity /strengtheningisneeded.
Licensees' drug positives are consistent with the national average for reemployment testing, I
- Few instances of drug use by licensed operators seen.
- Impacts (of testing) on licensees not unacceptable, and benefits worth added costs.
Specific programs at region's plants were discussed.
In response to Mr. Carroll. Dr. Remick said all federal agencies drug programs reference the HHS action guidelines, pursuant to detection of a banned substance. The region said most licensees have tighter detection thresholds than the HHS guidelines,. believing that they should capture individuals who have had time to dilute the drug in his/her body.
In response to Mr. Carroll, Sir. Bangart said random screening is catchingevl% of those tested. The region has to-date had one licensed operator who lost his license after two positive tests.
In response to Dr. Remick, Mr. Bangart said no licensee has raised the issue of costs for testing, but all agree its a cost / beneficial procedure. Regarding false positives, the chief problem seen here
)
has been contamination of the sample.
15.
Region IV's regulation of materials licensees was reviewed by R.
l.
j.
Bangart. He cited the scope of the activities for this topic
Regional Programs Minutes January 5-6, 1989 (Figure 7). Unique regulatory challenges are posed by the materi--
als licensees as noted earlier. Many are.small single-person busi-nesses run by non-professionals. As a result, the region has had a considerable number of escalated enforcement actions.
The region has a number of initiatives underway to address the
'above regulatory problems with material licensees. These initia-tives include:
Require submittal of a complete license renewal application Conduct relicensing visits Improve background / experience checks for prospective licensees
- Initiate telephone questionnaire to licensees not inspected-
' Issue an audit-type questionnaire between inspections.
In response to Dr. Remick, Mr. Bangart said a normal materials license is valid for five years.
In response to Mr. Ward, Mr.
Bangart said that NRC does license materials handlers at federal government facilities in agreement states.
In response to Dr. Remick, Mr. Fisher (Region IV) indicated the experience with medical licensees has been varied (very good to poor).
Lack of resources usually contributes to the poor perfor-mance of some licensees. The region recently hired an individual with expertise in the nuclear medicine area.
l In response to Mr. Ward, Mr. Martin said the region does routinely I.
assess the programs of the agreement states.
In response to Dr.
Remick, Mr. Martin said they expect to eventually have four low
Regional Programs Minutes January 5-6, 1989 level waste sites in the region. Texas is currently the lead state here.
Regarding the uranium milling industry, there are four operating mills, eight are shutdown, and 17 more are undergoing decommissioning. The mills have had to post financial sureties to assure funding for reclamation: post-operation (Figure 8).
It was noted that the cost / benefit for reclamation is not favorable, given the low health hazard risk posed by these operations.
i The issues surrounding the Sequoyah fuels conversion plant incident were noted (Figure 9). Operations have improved dramatically since their extensive response to NRC's concerns.
In-situ uranium mining is now being practiced. NRC requires a demonstration that after mining is complete, the groundwater purity 1
can be restored.
- 16. 'During an open discussion, Mr. Martin said he noticed that, in some cases, the region's response to our topics was limited, due to a lack of knowledge on what our specific concerns were. Another j
point is that the region suffers from being essentially an enforcement arm of NRC, rather than being able to broadening their perspective to look at design-based issues. This is an area in which they are somewhat lacking. Overall, the Region enjoyed the ACRS visit and that it benefitted them greatly, i
Mr. Carroll asked for an opinion on why the public utilities have been successful versus SMUD. Mr. Martin opined that the public in this region of the country have greater confidence that the utili-ty, in the long run, would represent their interests.
1 1
.,.4 f
1 Regional Programs. Minutes' January'5-6, 1989 f
Dr. Kerr asked what: role the region saw for itself for plant extension licensing. Mr. Martin said he saw their role to be the same as now - i.e. assure NRRs dictates are implemented and main-tained.
Dr.'Remick said the Subcommittee, as has become the norm for these regional meetings, was impressed with the region's depth of know-ledge and further that we appreciated NRC's candor and directness in response to our ouestions.
- 17. The meeting was adjourned at 2:47 p.m. January 6, 1989.
NOTE:
Additional meeting details can be obtained from a transcript of this meeting available in the NRC Public Document Room, 21?0 L Street, N.W.,' Washington, D.C. 20006,(202)634-3273, or can be purchased from Heritage Reporting Corporation, 1220 L Street, N.W., Suite 600, Washington, D.C. 20005,(202) 628-4888.
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REGION IV ENFORCEMENT STATISTICS FOR 1988 -- PAGE 1
- --. L.
A. ENFORCEMENT CONFERENCES CONDUCTED ----- 37 POWER REACTORS
-- 14 RADIOGRAPHER
-- 5 GAUGE LICENSEES
-- 5 WELL LOGGERS
-- 4 HOSPITALS
-- 4 RESEARCH REACTORS
-- 2 URANIUM IN SITU MINING
-- 1 MILITARY BROAD LICENSEE
-- 1 UNIVERSITY RESEARCH LICENSEE -- 1 B. ESCALATED ENFORCEMENT ACTIONS PROPOSED ----- 26 POWER REACTORS
-- 11 WELL LOGGERS
-- 5 HOSPITALS & NUCLEAR MEDICINE -- 3 RESEARCH REACTORS
-- 2 RADIOGRAPHER
-- 2 URANIUM PROCESSOR
-- 1 MILITARY BROAD LICENSEE
-- 1 GAUGE LICENSEE
-- 1
$')
r 1
REGION IV ENFORCEMENT STATISTICS FOR 1988 -- PAGE 2 C. ESCALATED ENFORCEMENT ACTION BREAKDOWN I. POWER REACTORS
- a. 11 CIVIL PENALTIES TOTALING $962,500 AVERAGE CIVIL PENALTY - $87,500
- 2. RESEARCH REACTORS
- a. 1 CIVIL PENALTY OF $5,000
- b. 1 CONFIRMATORY ORDER
- 3. MATERIALS LICENSEES
- a. 9 CIVIL PENALTIES TOTALING $124,600 (INCLUDES USAF C.P.
OF $102,500)
AVERAGE CIVIL PENALTY (EXCLUSIVE OF USAF) - $2,763
- b. 3 ORDERS MODIFYING L: CENSES (2 ISSUED IN CONJUNCTION WITH CIVIL PENALTIES)
- c. 2 ORDERS SUSPENDING LICENSES
- d. 1 ORDER REV0 KING LICENSE l
_---______]BALY
__. = _ _. _..
?,
/2 I
' Number of violations (levels V - I) for calendar year 1988 through November 1988:
l Region I 131 Region II 232 Region III -
155 Region IV 230 Region V 71
' Average number violations per site for all regions, less Region IV:
8.8 violations per site.
' Average number of violations per site for Region IV:
25.5 violations per site.
l 1
4
_--}
-..L :
[..
$0t'/25 Q
\\
L REGION IV I
SALP DATA
SUMMARY
I SALP FUNCTIONAL FACILITY AREA ANO-1&2 CNS.FCS FSV' RB WAT WC PLANT OPERATIONS 1
1 2
'2 2
2 2
RAD. CONTROLS I
1 3
2 2
2 2
MAINT. & SURV.*
2 N/A N/A 3
2 2
N/A EMERG. PREP.
I 2
2 2
1 1
2 SECURITY 2
3 2
1 3
1 1
ENG./ TECH. SUPT.*
2 N/A N/A 2
1 2
N/A SAFETY ASSMT. &
2 N/A N/A 2
1 2
N/A QUALITY VERF.*
l:
MAINTENANCE N/A 2
2 N/A N/A N/A 2
SURVEILLANCE N/A 2
2 N/A N/A N/A 2
FIRE PROTECTION N/A 1
2 N/A N/A N/A 1
OUTAGES N/A 2
2 N/A N/A N/A 3
~ QUALITY PRGS. AND N/A 2
3 N/A N/A N/A 3
ADMIN. CONTROLS LICENSING ACT.
N/A 1
2 N/A N/A N/A 2
TRAINING AND QUAL.
N/A 2
3 N/A N/A N/A 2
EFFECTIVENESS
- NRC Manual Chapter 0516 revision of June 6,1988.
l
- -- c m # -
=y REG 0s' IV VA-R A_S 3ROGRAM NUCLEAR MATERIALS SAFETY BRANCH OF 13 PEOPLE IMPLEMENT l.
830 BYPRODUCT MATERIALS LICENSEES 350 INSPECTIONS PER YEAR 600 LICENSING ACTIONS PER YEAR UNIQUE RIV DISTRIBUTION OF LICENSEE TYPES 86 WELL LOGGERS 54 RADIOGPHERS LEAD REGION FOR AIR FORCE BROAD MlUTARY UCENSE f)s 7/
r l
NRC-Licensed Uranium Mills Financial Sureties Mills State Amount Type Quivira Mining NM 20,600,000 Anaconda-Bluewater NM 24,300,000 Homestake Mining NM 15,800,000 Exxon Highlands NY 4.900,000 LOC Pathfinder Gas Hills WY 8,600,000 LOC Atlas Minerals UT 6,000,000 LOC UMETCO Cas Hills WY 10,566,000 Bond Western Nuclear KY 12,282,000 Bond Pathfinder Shirley Basin NY 5,060,000 LOC Petrotomics WY 1,921,000 LOC American Nuclear TY 4,081,000 GNMA Fund Bear Creek Uranium WY 11,296,000 PCG UNC Churchrock NM 24,934,000 Rio Algom UT 3,000,000 LOC BP America NM 10,951,000 Bond Minerals Exploration WY 2,768,000 PCG Umetco White Mesa UT 4,577,000 LOC Plateau Resources UT 1,999,000 LOC
- New Mexico licensees' cost estimates.
Actual amounts and sureties to be set after NRC approves reclamation plans.
l LOC = letter of Credit PCG = Parent Company Guarantee
(
l FM 8
?p
=.....,
SEQ 0YA 7
. E _S C0 s V E RS 0 s 7ACl _ "Y JE3 _E E) 3 ~0 J L 7AC _~Y ACCIDENT JANUARY 4,1986 CATALYST FOR NRC REVIEW 0F FUEL FACIUTY/ MATERIALS UCENSING AND INSPECT 10N PROGRAMS
$310,000 CML PENALTY PROPOSED / IMPOSED RESTART NOVEMBER 14, 1986, WITH INDEPENDENT OVERSIGHT ORGANIZATION AND CONTINU0US NRC INSPECTION COVERAGE NORMAL, BUT INCREASED, OVERSIGHT BEGINS LATE 1987 OCTOBER 1988, SFC OWNERSHIP TRANSFER TO SEQUOYAH HOLDING CORPORATION, A SUBSIDIARY OF GENERAL ATOMICS l
/Fu.11
--