ML20246M845
| ML20246M845 | |
| Person / Time | |
|---|---|
| Issue date: | 08/29/1989 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1752, NUDOCS 8909070264 | |
| Download: ML20246M845 (148) | |
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q UNITED STATES NUCLEAR REGULATORY COMMISSION i
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS j
In the Matter of:
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SUBCOMMITTEE ON REGIONAL
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PROGRAMS, REGION 1 'FFICE
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O Pages:
1 through 145 Place:
King of Prussia, Pennsylvania Date:
August 29, 1989 A31S Office Co?__' _
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1 PUBLIC NOTICE BY THE 2
UNITED STATES NUCLEAR REGULATORY COMMISSION'S 3
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4
S 6
7 The contents of this stenographic transcript of the 8
proceedings of the United States Nuclear Regulatory 9
Commission's Advisory Committee on Reactor Safeguards (ACRS),
10 as reported herein, is an uncorrected record of the discussions 11 recorded at the meeting held on the above date.
12 No member of the ACRS Staff and no_ participant at 13 this meeting accepts any responsibility for errors or l
14 inaccuracies of statement or data contained in this transcript.
15 16 17 18 19 20 21 I
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l' UNITED. STATES. NUCLEAR REGULATORY COMMISSION I
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 1
In-the. Matter of:-
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SUBCOMMITTEE ON REGIONAL
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PROGRAMS, REGION.1 OFFICE.
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- Tuesday, August 29, 1989
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Conference Room.
I 475 Allendale Road-King of Prussia, Pennsylvania
'I The meeting. convened, pursuant to notice, at i
l 8:30 a.m.
BEFORE:
DR. FORREST J.
REMICK Chairman, ACRS Associate Vice-President for Research Professor of Nuclear Engineering The Pennsylvania State University g
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University Park, Pennsylvania ACRS MEMBERS PRESENT:
DR. WILLIAM KERR Subcommittee Chairman Professor of Nuclear Engineering and Director of the Office of Energy Research University of Michigan Ann Arbor, Michigan
.MR. JAMES CARROLL Retired Manager, Nuclear Operations Support Pacific Gas & Electric Company l
San Francisco, California MR. CHARLES J. WYLIE Retired Chief Engineer Electrical Division Duke Power Company Charlotte, North Carolina l-
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i ACRS MEMBERS PRESENT:
(Continued)
MR. DAVID A. WARD Research Manager on Special Assignment E.I.
du Pont de Nemours & Company Savannah River Laboratory Aiken, South Carolina DR. IVAN CATTON Professor of Engineering Department of Mechanical, Aerospace & Nuclear Engineering School of Engineering and Applied Science University'of California Los Angeles, California 1
ACRS COGNIZANT STAFF MEMBER:
PAUL BOEHNERT O
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1 EB2REDIEGE 12 DR. REMICK: 'The meeting will now come to order.
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.3 This is a meeting of the Advisory Committee on 4
~ Reactor Safeguards, Subcommittee on Regional Programs.
5 I'm Forrest Remick, Subcommittee Chairman.
ACRS 6
members in attendance besides myself starting on my right:-
7 Jay Carroll; Ivan Catton; William Kerr;. David Ward; and 8
although I can't see him down there, Charlie Wylie.
9
.The purpose of the meeting is to review the 10 activities under the preview of the NRC Region
.? Office.
11 Paul Boehnert is the Cognizant NRC Staff member 12 for this meeting on my immediate right.
13 The rules for participation in today's meeting
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p have been announced as part of the notice of this meeting 14 15 previously published in'the Federal Register on August 7, 16 1989.
17 A transcript of the meeting is being kept and i
18 will be made available as stated in the Federal Register-19 notice.
20 It's requested that each speaker first identify 21
- himself or herself and speak with sufficient clarity and 1!2 volume so that he or she can be readily heard.
23 We received no written comments or request to 24 make oral statements from members of the public.
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1 comments why we-are here..Back some time ago the Commission V:
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2-asked ACRS to address operating plants more frequently than L-
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3 we had in the past.
We found that one of the ways that we 4
find out more about what is going on with the operating 5
plants is to get around and talk to the regional staffs.
6 We have been to all four other regions, Region l~
7 is the last one that we are visiting on our first go around.
8 I can say that.has been extremely refreshing.
We've 9
interacted informally with the staff and we find that.we get 10 1a lot of varied direct information on what's' going'on in the 11 regions, sometime more direct than we.can from headquarter 12 staff,.of course, the information goes through several hands 13 before getting to us.
So we have thoroughly enjoyed the
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14 opportunity to ge'. around to the various regions.
15 Now, we have found, especially in the early 16 meetings, a considerable amount of trepidation of whrf in 17 the world is ACRS coming to see us about.
What have ne done 18 right or what have we done wrong.
And I assure you that 19 there is no -- it's our opportunity to get around and talk 20 to you on various subjects.
21 Our reputation might have proceeded us.
You 22 might have heard that we're a bunch of impatient, nasty, 23 grouchy group of old men.
But I'm sure that Bill Russell 24 has assured you from past experience that we really aren't 25 that old.
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It is a pleasure, Bill, to be back.
I was here
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pleasure-to be back to your nice facility; meet with the 5
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I asked if any of my other subcommittee members 7'
have'any comments they would like to make.
8 (No response. )
~9 DR. 1NEMICX:
Seeing none, Bill. I turn the j
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(Slides be:..ng shown. )
12 MR. RUSSELL:
Thank you very much, Forrest, and I i
13-do'want to welcome the subcommittee to Region 1.
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11 4 My opening discussion'is goingLto be-15 familiarization'for.the subcommittee.
Introduce some of the
- 16). major players who you're going to be talking to.
The' 17 objective that we had in the structuring of the agenda in.
l 18 responding to the topics and identified all or many of the 19' ~ staff as we could in discussions with the subcommittee so.
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20 that you have an opportunity to meet them and maybe they'll q
1 21 describe what their responsibilities are in Region 1.
22 Within' the Region 1 administrator's office, I 23 have a number of direct reports.
12 4 The-viewgraph.that is up now, two with the dash i
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' lines, the Office of Investigation Field Office headed up by L
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v) 1 Chester White; administratively reports to headquarters.
2 But, in fact, we have a very close working relationship with 3
the Office of Investigations and we will be discussing that 4
more during the course of the next day and a half.
5 Public affairs similarly reports to headquarters.
6 We have two public affairs officers here in Region 1; we 7
keep them both very busy with the amount of activities going 8
on with Region 1 facilities.
Reporting to me in the state and government 10 affairs are two individuals: one, the stat liaison officer, 11 Marie Miller who interacts with the state policy statement 12 on the cooperation with the states; and John McGraff the 13 state agreement officer who is involved with the four states 14 which we have agreements in materials area for licensing and
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v 15 activities involved in inspection activities.
16 Regional counsel position is currently vacant.
17 Jay Gatergis recently left to join a law firm in Washington, 18 D.C.
That is posted and we have not yet filled that.
19 The enforcement coordinator, we have two 20 individuals assigned to enforcement.
Dan Valotti is the 21 regional enforcement officer, he's at the far end of the 22 table.
And Keith Christopher is an enforcement specialist 23~
working with him.
Some regions have larger enforcement 24 staffs; they have incorporated allegations into enforcement.
25 In this region I hold the division director responsible for Heritage Reporting Corporation
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1 the allegation process because that's where the resources 2
come for inspection and close-out of allegation.
3 There are four major divisions here in the 4
region.
The first division: Resourcs Management and 5
" ministration is all of the administrative support, 6
everythina from the facilities that we have here to the auto 7
pool, travel, and back budgeting process, tracking 0
essentially all support.
9 In addition, the personnel staff reports to the Division 10 Director of Resource Management and Administration.
11 The main line three divisions: the Division of 12 Reactor Pro 30 cts has the resident inspection program as well 13 as some regions make the inspectors reactor engineers and r~
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14 project engineers.
They manage the inspection program for 15 the region and they also chair the SALP Boards nnd have lead 16 responsibility for pulling together the SALP packages.
17 The Division of Radiation Safety and Safeguards 18 has two principal branches, but they're split along lines of 19 those of headquarters functions and is the materials 20 activities in one branch; medical, pharmaceutical industrial 21 users of byproduct materials.
End facilities, radiation 22 support in the other branch; that includes emergency 23 preparedness or incident response facilities here in the 24 region as well as safeguards, 25 The final division is a Division of Reactor
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1 Safety.
It has two branches: operations and engineering.
2 Within operations we have operator licensing.
And we have 3
something unique in this region in that we have cross-4 trained our examiners to also be. inspectors and they 5
participate in inspections of emergency operating l
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procedures, team inspections related to reactor operations, j
7 et cetera.
And we find that this has significantly enhanced l
8 both the regional response and, in fact, the courier l
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path for the examiners and inspectors.
It'gives l
10 them something to do rather than just a study diet of-j 1
11 continual examining.
12 We would like to get some day to the point where 13
'they work 50 percent of the time examining and 50 percent of I
14 the time inspecting.
Right now it's about 70/30 on average.
15 DR. CATTON:
What's the difference between 16 examining and inspecting?
17 MR. RUSSELL:
An examiner is an individual who i
18 prepares a written examine for a licensed operator:
19 administers.the examination: grades the examination: also 20 conducts a plant walk-through examine at the facility, one-21 on-one with the individual and then participates usually l
i 22 with two other examiners, possibly three, in evaluating the l
l 23 performance of the crew on the simulator.
24 They issue the licenses under Part 55 for senior j
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.1 requalification programs.
2 Inspectors would' inspect principally activities 3_
in the control room.
There may be specialist-inspectors, 4
materials,; health physics, civil engineers, electrical-5 engineers, et cetera, in their area of specialty.
We also 6
.have operations type engineers who inspect such things.as C
7-startup. programs. And we'll be discussing more of:those with 6
the individuals later in the presentation.
9 In the main examiners are not cross qualified as 10 inspectors and vice versa.
The other regions'have not
,11 started that yet, although that is being supported by 12
. headquarters and we find that it's a_very valuable asset.
A lL3 person who can judge a simulator, whether they're performing
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14 correctly ~or not is a very valuable asset to have on the 15 inspection team to judge whether the activities during power 16 ascension startup or startup from an outage are being 17
' conducted properly.
18 May I have the next slide, please.
19 Division o f Reactor Projects is headed by Bill 20 Caine.
He's currently at the morning meeting with his 21-branch chiefs and section chiefs.
We have Sam Collins, the 22 Deputy Director with us this morning.
. :23 This division is organized parallel with the 24-headquarters division.
We have just recently done that.
We
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1 organization.
We reorganized last July 1st into a four 2
branch to parallel the four branches in Washington, the l-3 project directors in Washington.
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And we hava the same project assignments in each 5
branch.
This has significantly improved communications 6
between the region organization and headquarters 7
organization by having a close parallel and assigned 8
responsibility between field activities and headquarters 9
activities.
10 The next slide, please.
11 Gene Kelly has the tech support staff which is 12 not shown.
He reports to the division director.
That 13 activity is principally involved with the coordination of
- Q(~T inspection planning and those activities which cut across 14 15 all four branches.
16 The Division of reactor safety: I mentioned 17 earlier we have an engineering branchy an operations branch.
18 There are some unique aspects here in Region 1 in 19 engineering. We have the nation's non-destructive 20 examination band process.
You will be seeing the laboratory 21 facilities.
I believe the trailer is still here.
It was; 22 it didn't go on the road.
It's normally on the road about-a 23 third of the time.
We run a six week cycle of two weeks of 24 inspection planning, two weeks on site at the facility, and 25 then two weeks ready to report. And during the time the Heritage Reporting Corporation
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planning is-going on you have a contractor move the mobile 2
. van to the site.
So we have the resources to conduct the 3 -:
inspections..It has, as you will see, dark room facilities; 4
facilities for all the non-destructive' examination 5
equipment, so it will be an independent non-destructive 6
examination at the site.
7
.I mentioned the operations branch already with 8
the licensing and examining the operations program section 9
as the section which handles principally.the startup of
'10 testing activities such as the Lemrick-2 startup which is 11 going on now.
12 Next slide, please.
13 Division of radiation safety and safeguards, we-gr( [
~14 are organized parallel to the headquarters activities in the 15 nuclear material safety branch on the three sections
-16 specialized.
They are not each identical.
They'do medical, 17 pharmaceutical, industrial gauge, radiography; and they are 18 organized to parallel with headquarter organization.
19 This was done approximately a year ago and that 20 has also improved the communications back and forth with 21 headquarters.
22 The facilities radiation safety and safeguards 23 branch are classic effluent. Facilities radiation 24 protection, both fuel facilities and recctor facilities, 25 emergency preparedness and safeguards.
That's the reactor L
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health physics and effluent activities.
2 Next s3 s,
please.
3 We covered most of the activities in the division i
4 of zesource management administration.
We have personnel 5
resource which is contract, procurement, travel; and then 6
the administrative support for word processing and office 7
services.
8 The last slide, please.
9 That was a very fast overview of who we are and 10 how we're organized.
Individuals will be talking to you in 11 the course of the next two days regarding their activities.
12 A little bit of what we do; and then I want to 13 focus on what I see are some of the major issues facing the
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14 region.
5 We have 27 units licensed to operate in ull 16 power.
One unit, Lemrick-2 which is in power ascension 17 which has a full power license.
So we actually have 29 18 units that have full power licenses; whereas, Shoreham has 19 full power license although its status is somewhat uncertain 20 at this point. Seabrook has e low power license and has 21 completed low power testing.
22 So if I take the three facilities which I call 23 NTOLs, that is: Seabrook, Shoreham, and Lemrick-2 and add to 24 that the seven facilities which are on the NRC's watch list, 25 the seven out of 13 in the United States are in Region 1.
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Calvert Cliffs-1 and 2; Pilgrim; Nine Mile Point-1 and 2; 1
2 and Peach Bottom-2 and 3, 10 of 30 facilities in this region 3
have extremely high visibility and augmented inspection 4
programs, a lot of resources being supported by headquarters 5
and in some cases we had resource support from other 6
regions.
7 We have also 17 test and research reactors.
Five 8
fuel facilities.
And over 3,300 byproduct materials 9
licenses that we maintain dockets for. Some of these 6te 10 broad scope facilities such as universities, major federal 11 installations.
I keep saying National Bureau of Standards 12 but they've got a new name.
NIST, National Institute of 13 Standards and Technology.
I'm still back in the old 14 National Bureau of Standards.
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t 15 That does not include the licenses in Maryland, 16 New Hampshire, New York or Rhode Island which are agreement 17 states and they have licensing and inspection authority 18 derivative from the NRC for which we conduct, review to 19 assure compatibility with federal requirements in programs.
20 Saxton keeps coming up from the standpoint of 21 levels of radioactivity on site and how well it was 22 decommissioned and we did a lot of correspondence on it.
23 Whether we are through with decommissioning yet, 24 we're not sure, given the recent congressional testimony on 25 what has been done at some reactor sites.
We identified 17 Heritage Reporting Corporation
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1 reactor-sites where there was authorized burial at site-2 during the congressional hearings and we have potentially a 3
number of material sites where there was disposal on site.
4 Waste disposal at reactor facilities or'-- what I'll 5
characterize as cleanup of spaces that become an emotional 6
issue with the press and the local communities, particularly ao in New York State where they're in the process of 8
attempting to cite a low-level waste facility and they've 9
been having public meetings around the state with 10 or so 10 candidate sites that have drawn literally a few thousand to 11 10,000 members of the public to these meetings.
12 In fact, the last meeting we had quite a bit of 13 public interest and news coverage up at Nine Mile Unit-1 rs 14 based upon a rad waste facility which has been -- not b) 15 decommiss!.oned, but it's not longer in use.
The built a new 16 rad waste facility and the old one had drum storage in the 17 basement level of it, which was floodsd.
The drums 18 subsequently overturned and spilled resins and sludge 19 bottoms into the room and the room has been inaccessible 20 since 1981.
21 The first time we became aware of tnat was when 22 it appeared on the news one evening up in Syracuse. We had 23 an inspection team up there the last week or so and issues 24 in the local community, having just had one -- the New York 25 State low-level waste meetings in the area.
It did very l
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much low-level issues in decontamination of cleanup.
2 DR. REMICK:
Bill, where do you put Peach Bottom-3 1 on your list?
4 MR. RUSSELL:
Peach Bottom-1; Indian Point-1 are 5
facilities in the region.
Peach Bottom-1 is decommissioned;
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6 Indian Point-1 is not listed on that, nor is TMI-2.
If you 7
count the facilities that still have a license there are 32 8
with Indian Point-1 and TMI-2; they're in a special 9
category, although TMI-2 still has significant inspection 10 resources dedicated to it because of the activities going 11 on.
12 DR. REMICK:
The reason I ask is that you give 13 these facts to Columbia, but not to the others.
I'm not
<-( )s 14 sure I understand how you're distinguishing Columbia, 15 Saxton.
16 MR. RUSSELL:
Just test reactors as comphred to 17 research reactors.
It was a demonstration prototype for 18 GPU.
19 DR. REMICK:
Was it licensed as a --
20 MR. RUSSELL:
I can't respond to that, I don't 21 know.
22 DR. REMICK:
All right.
- 23 MR. RUSSELL:
He talked to a number of states to 24 hecoming agreement states.
Pennsylvania has a limited --
25 very limited agreement with the NRC at this time as it
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1 relates to onsite inspection of completed waste packages for 2
shipment prior to going on to the highways.
3 The issue I think within the states is becoming 4
one of resources.
We've had some prohlems with some of the 5
states dedicating sufficient resources of programs.
And in 6
some instances they do get to be very highly visible issues 7
within the states.
8 So I'm not sure what it's motivating in all 9
cases.
But we have not seen a lot of interest on their part 10 to become agreer. eat states and take on the initial burden.
11 One of the things that was identified for the 12 agenda for unique activities in Region 1, I mentioned the 13 NDE van, non-destructive examination vans.
The other unique 14 activities that we have is, we run the nationwide TLD
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That program will be discussed in some detail 17 with you.
18 But broadly, these are the dosimeters which are 19 placed approximately two-miles, and then again at five-miles 20 in the terrains around the sites.
They are monitored on a j
21 quarterly basis.
We run the QA program for them.
We 22 process them here when we have the data in a computer and 23 publish quarterly reports.
24 We wil] be discussing some of the initiatives we I
25 have in that area.
We have about 10 who report the data.
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1 One initiative is to try to get the data into a data base 2
that is easily usable something like DEBASE-3 so that other 3
users can access the data and do studies, because it does 4
give essentially what has been the background, radiation 5
levels around the facilities for a long period of time.
It 6
shows what happens to seasonal variation.
And that 7
information we would like to be able to. provide to others 8
who are studying health effects around facilities.
9 There is a considerable variation of background 10 by about a factor of three around the United States and 11 background radiations that lies between sites.
That will be 12 discussed latti in the presentation.
13 Other-things which we have which other regions
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14 have, we have laboratory facilities for doing environmental 15 monitoring for samples that are brought back to the region 16 by inspectors.
I'll arrange for you to see those 17 laboratories and the accounting facilities as well as having 18 a mobile laboratory that can go to the sites and take 19 environmental samples and do environmental accounting of 20 facilities.
21 Under the category of major office. issues or 22 initiatives, the one that is most significant, in my view, 23 is the situation we're seeing right now for the need for 24 recruiting staffing and training the regional staff.
25 Thus far this year we have had -- this Fiscal
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'q) 1 Year -- 39 losses from the region.
2 MR. CARROLL:
How many total personnel?
3 MR. RUSSELL:
Okay, total personnel, the 4
authorized staffing is 273.
So we have about 15 percent 5
turnover thus far this year in losses.
6 Our gains thus far this year, we have only 7
brought on-board 15 people thus far and we have eight other 8
offers outstanding for a total of about 23, compared to the 9
loss rate of 39.
10 MR. CARROLL:
Is 39 losses --
11 MR. RUSSELL:
I can give you that.
We had eight 12 transfers to headquarters.
We've had 11 resignations to go 13 into industry or other employment.
Four retirements.
Six
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14 transfers to other regions.
Six transfers to the Department 15 of Energy. And three transfers to other government.
16 So it's still a mix, but there are good 17 recruiters in headquarters who used to be in Region 1 and 18 good recruiters in the Department of Energy who used to be 19 in Region 1 that are still recruiting staff from Region 1.
20 A more significant piece of that is the impact on 21 training and qualifications.
It takes on an average about 22 18 months to qualify an inspector who comes in new.
It 23 takes six months to a year to qualify an examiner based upon 24 background experience.
25 So if we continue to have a turnover rate of
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1 about 15 percent, with an average time in a pipeline of 12 2
to 18 months to train them.
At'any given point in time we 1
3 could have as much as 23 percent of the staff that are not 4
fully qualified and yet the budgeting process when you are 5
assigned FTEs assumes that everyone is qualified to do all 6
of the jobs.
7 This is a major area for recruiting activities 8
and we have significant efforts going on in the division of 9
radiation safety and safeguards, as well as our reactor 10 projects where we had high turnover rates.
11 The division of reactor safety has been fairly 12 stable, but they have been also involved.
13 The other activities as far as both initiatives 14 and unique activities in Region 1, for the problem 7-)
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15 facilities we started a process to improve coordination in 16 planning between headquarters and the region for certain 17 problem plants.
So we established a panel approach for 18 Peach Bottom, Pilgrim, Calvert Cliffs, and Nine Mile Point.
19 That panel process has been very effective for coordinating 20 inspection activities and ;eviews of licensee submittal and 21 it gives the licensee a single point of contact to discuss 22 issues with the agency.
We found that this has been quite 23 successful, although it is also quite resource intensive 24 from the standpoint of coordinating activities.
25 Three of the panels have been chaired by Region Heritage Reporting Corporation (202) 628-4888 m
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The Calvert Cliffs panel is being chaired by
'2 headquarters.
We have swapped with headquarters leadership 3
on theLpanel.
The' panels have been quite effective in 1
4' coordinating activities.
5-Other unique or somewhat unique approach here in 1
6 Region 1 is our approach to the overall inspection program.
7 We asked senior managers last September -- and looked at-
-8 implementation of the new inspection program that came out 9
from the Office.of Nuclear Reactor Regulation and we decided 10 on some lead areas of' responsibility for the division 11 directors for implementation of that program.
12 For the coordination planning activities and 13 tracking of the inspection plans for each' site, we decided
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14 that was a lead responsibility of the reactor projects.
And 15 for all of.the support in implementing that program we 16 initiated the technical support staff of which Gene Kelly is 17 the section leader.
That part of it is fairly standard with 18 respect to the other regions.
19 The part that is unique is that we have assigned 20 the division of reactor safety lead responsibility within 21 that for planning and executing the major team inspections 22 to come out of the region.
Such things as the NRR
- 23 initiatives and for team inspections, emergency operating 24 procedures, maintenance inspections.
25 But there are other team inspections which are
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conducted.
That's not to say that the other divisions do 2
not lead or participate in team inspectichs: they do.
But 3
in this instance we did assign lead responsibility to the 4
Nuclear Reactor Safety.
5 MR. CARRCLL:
Is that also done in other regions?
6 MR. RUSSELL:
No, it is not.
7 We piloted it and we found it to be very 8
effective and we continue to use it.
The only other region 9
that has problem facilities right now is Region 2.
Whether 10 Stu Ebr.etter having come from Region 1 and participated in 11 some of those panels chooses to use a panel approach, I 12 don't know.
But the TVA facilities essential.'.y have a 13 dedicated resource for special projects; it's comparable to 14 a panel.
But whether Stu feels a panel is appropriate for g)
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15 Turkey Point and Surrey is for him to decide.
I think that 16 he's not using one on either at this point.
17 Another area that I think is not unique but it is 18' one that I would like to mention and that is, in the 19 byproduct materials area we have some facilities or some 20 response to events that are significant in the amount of 21 resources that are required utility event.
It would include 22 the problem that we had last year with the 3-M Company, with 23 the static eliminators, the polonium devices and air guns, 24 which essentially took the resources in that entire section 25 and that section leader from the period of time of about Heritage Reporting Corporation r~g (202) 628-4888 C1
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1 January through springtime and responding to contamination 2
in industrial sites from these blowing air guns.
3 Another example is the extreme resources that are 4
involved right now with the safety light facility.
5 DR. KERR:
What is a blowing air gun?
6 MR. RUSSELL:
It looks like a garage mechanic air 7
gun that's used to clean tools and you put a round cylinder 8
on the end of it and you line it with polonium and foil, 9
which is a
.0 xy strong alpha emitter and the alpha field 10 removes the static from the air so that you can use it in 11 devices such as bottle washers, photo processing equipment, 12 high speed printing presses, they're used for printing 13 anything where you need to remove static.
And these devices
()
la have an adhesive that is developed by 3-M that broke down, 15 and the little polonium beads would blow in the air stream 16 and contaminate the facility and you had a fairly 17 significant health and contamination problem.
18 Other facilities that have been somewhat unique, 19 safety like facilities in Bloomsburg, Pennsylvania, 20 facilities that have been contaminated for some time, we 21 don't have a good understanding of the level of 22 contamination.
We've issued orders to them to require them 23 to characterize the site and cleanup.
The facility has 24 joint owners, U.S.
Radium as well as the Safety Light and, 25 in fact, they do not have sufficient funds to complete
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We have recently issued an 2
order requiring them to set aside funds on a certain payment 1
3 schedule into a trust in order to complete characterization 4
of the site as to the types of radioactive materials and the 5
extent on site.
6 That facility has essentially required a 7
dedicated project manager, and yet, if you look in budget 8
space and materials with 3,000 materials and a staff of 9
about 25 to handle it, you will find that you cannot 10 dedicate three people to a single licensee without having a 11 substantial impact on how it's approached.
12 So those high visibility materials activities, 13 because of the need for focused attention, we did create a
()
14 division project manager to be able to handle special 15 projectu just as we ' ave the panels for handling special 16 reactor projects.
We have a dedicated individual for 17 managing those activities within DRSS.
18 The issue of maintaining consistency amongst 19 regions and how we do that, I will describe some of the 20 programs, but these are really headquarters activities to 21 oversee the regions to ensure consistency.
22 Some of the things that we do have, we have 23 frequent counterpart meetings at the division-director 24 level.
Also, at the regional administrator level we gather 25 at least twice a year and relieve the status of all the
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24 it 1l-complaints'ont regions.
2-In addition,-headquarters program offices conduct 3'
. reviews of their-programs in the' region. 'They essentially _
4 compare our performance to the contract which is' developed-5 at the beginning of the year.. The contract,in this case is 6-the region operating plan which. describes what we're going 7
to do with the resources we're given from headquarters; and 8
then they evaluate our performance against that operating 9
plan and the policies that are issued by the program 10 offices.
11 There are specific staff members assigned 12-responsibility within each of the program offices to oversee
.13.
on a continuing basis in addition to the more formal
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14 reviews.
15 And then the activities are coordinated with'a-H16 ~
single point of contact.
For example, enforcement which we 17' will be discussing in the next session, all escalated 18 enforcement cases and certain non-escalating cases are 19 coordinated with headquarters, with the Office of 20 Enforcement and the other offices prior to issuance to 21 ensure there is consistency in enforcement.
22 I think there is within each region, the region 23 somewhat takes on the character of the senior managers in 12 4 the regions and what they emphasize as being important.
25 There will be personnel links to the regions.
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1 organizations are run by people.
2 But as it relates to major programs and what we 3
do by way of enforcement activity, how effectively we 4
implement the headquarter's programs there is some leveling 5
that occurs as a result of the headquarter's oversight.
6 I will also submit that licensees probably 7
perceive that the grass is greener on the other side and 8
therefore complaining about their region and how they're 9
being beaten up on and they really don't have a good 10 impression of what it would be like to be in another region.
11 So I take with a grain of salt sometimes those 12 comments.
I know that we have made significant strides in 13 the area of operator licensing to ensure consistency in the 14 regions.
And I know that from firsthand experience, having g-)
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15 been in headquarters three years ago with responsibility for 1G that program.
And there within headquarters we would see 17 significant differences in approach being taken region-to-18 region.
19 I think we're getting better.
I don't feel that 20 it's necessary to have absolute consistency in all areas.
21 In that context there may be something that a region is 22 doing that is better, that's been effective through vehicles 23 such as counterpart meetings and program reviews.
You see 24 new ideas or approaches and that can be passed on.
I think 25 to cause everyone to conform, although it not necessarily Heritage Reporting Corporation
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.But it is one of the reasons that the senior f
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staff has received the direction from Dr. Murley to iniLiate i
4 a review of regulatory effectiveness.
And we will be gsing 5
out, regional administ.vators and other senior staff, to all 6
five regions to interview a number of licensees as a 7
spectrum of licensee management and staff in a number of 8
areas to solicit their views.
There will not be attribution 9
comments and people from Region 1 will not visit facilities 10 in Region 1.
11 For example, I'm going up to Region 5 and will be 12
' talking to people at Diablo Canyon and Haliberti.
This is 13 similar to the study that was headed up by Jim O'Reilly back 14-in 1982 I believe was the time frame, shortly after TMI when
~'
15 we were hearing concerns on the part of the industry that 16 there was too much coming out after TMI, and while 17 individual requirements could be justified, the number of 18 requirements were detracting from overall safety.
19 We' re hearing concerns about the imposition of 20 generic requirements, too many.
We're hearing concerns 21.
about the inconsistencies between regulation and regions; 22 that the NRC is inspecting for excellence.
23 So what we decided to do is try and gather some 24 firsthand information and make sure that tr.e communications 25 and the issues seem to be important inside the beltway are, Heritage Reporting Corporation (202) 628-4888
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3 DR.'KERR:.What has been the impact of the 4
.O'Reilly report?
5 MR. RUSSELL:
I think that the most significant 6'
leffect of the O'Reilly report was a recognition that too IS 7
many requirements too fast that are not well thought out to B'
have an adverse impact.
And I would submit that it probably 9
led to or at least had a significant influence on getting 10 control of.the issuance of regulatory requirements in the 11 backfit rule.
p 12 So I would submit that the O'Reilly report did 13:
have an impact, and whether it was just characterizing what
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14 was going'on in the industry and there were other things r
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that would have' caused that to happen in any event, I think 16 it did pull it together in one place.
17.
The pattern that we're attempting to go on, we're 18
.not making any commitments to change anything.
But at the 19 same time.we feel.we ought to find out what the concerns are l.
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.and if there are things that are not working well, we would 21-like to hear it firsthand.
22 DR. REMICK:
I ask my colleagues down there E
23 without a mike to speak a little bit louder to aid the court 24 reporter, if you please.
25 Going back about two months ago, I think, I heard o
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2 centralizing operator licensing and leaving inspectors and 3
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one office to get consistency; has anything developed on 5
that?
6 MR. RUSSELL:
Not as it relates to. operator 7
. licensing broadly.
But it has been proposed and it is under 8.
consideration as it relates to test of research reactor 9
community.
There has been a study ongoing by NRR, getting 10 input from the regions as to how should we best handle the 11 inspection program, the licensing program, and the operator 12=
licensing program as it relates.to research and test 13 reactors.
14 I can provide you my own views since the office O
15 director has not completed the study and forwarded it at 16 this point, but at least my comments were that I saw that 17 there were some potential advantages in that community 18 because the resources allocated to the region are quite 19 small.
We're talking less than one FTE and the inspection 20 activities probably less than an FTE as it relates to 21 examining.
22 And my feeling was that there were a number of 23 research reactors that are fairly standard, AGN-2-01s and 24 some-of the others; and that there may be some efficiencies 25 to be gained and clearly potent 4.a1 improvement in the Heritage Reporting Corporation (202) 628-4888
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that were more standardized.
Instead of having fractions of 3
people with the power reactor inspector part-time inspecting 4
a research reactor or the examination for research reactor 5
given by someone who is also examining power reactors that 6
there would be some efficiencies by consolidating.
7 At the same time there are some downsides.
The 8
first one that immediately comes to mind is the issue of, 9
what do you do if you have an emergency or a significant 10 event?
The research reactor that requires dispatching a 11 special inspection team.
If you have not been inspecting 12 that facility, if you don't have the records, if you don't 13 have the understanding, would the region be able to respond 14 or do you want to establish a separate response organization 15 at headquarters to come in and test the research reactor.
16 That issue i still under study.
I believe that 17 the are leaning to this point are to make some improvements L
18 on how we conduct business, possibly consolidating l
19 examination activities in headquarters, leaving the balance 20 of the program in the regions.
21 DR. REMICK:
There was another example at our 22 last month's meeting in which we received some testimony 23 that at one plant -- I think this is an example of 24 inconsistencies 25
-- where the plant was adding six inches to the entire Heritage Reporting Corporation (202) 628-4888 O
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1 security, fence between,'I don't know if it was tech specs or.
2 Lwhat, they were committed to an input fence and the 3
ihspector found that at one point it was 11-foot, 11'and a.
4
-half inches -- excuse me, 7-foot, 11 and a half inches; and 5
therefore they received a violation.
I don't know which1 6
region, so I can't say that was Region 1 or Region 2:or 7
what.
It's an example of just going around with a rule 8-making the height of fences.
9 MR.' RUSSELL:
I can't comment.
I'm aware that 10 we've had some issues that have come up along the lines of 11 how many grounds does the security guard have.
Does he have 12 18?
That is a revolver with six plus two more cylinders 13 with six each or does the gun only have five in it because-14 the chamber that's in line doesn't have a bullet in it.
15
.Does the security plan call for 18 and it has 17?
16 Well, that was a simple issue to resolve, it just 17 means the licensee to come in and say, we're going to have 18 17 instead of 18 because we like to have the security guards 19 not shooting themselves with an accidental discharge of the 20 firearm.
21 That is one that has occurred in this region and 22 that's a straightforward amendment to the plan.
Some of it, 23 I believe, is the fact that the licensees have not been as 24 careful as they should be in describing what they are doing 25 and they make commitments, in some cases, don't make good Heritage Reporting Corporation l
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2 This particular licensee did describe it. 'There 3:
areLothers that do not.
In this instar,ce they described 4
.that'they had 18' rounds and they had issued directions that.
5
.they should only have 17, so there was a difference between Es what the management.was telling'them to do and what the 1.
7 management told the NRC they were going to do.
8 MR. CARROLL:
.I think your security plan, Bill, I
9 requires --
10 MR. RUSSELL:
I really can't get into it; that's
. 11 almost on a specific basis and we would have to close the l
12-meeting to discuss the specifics in some security plans 13 which are protected.
In fact, we have very few copies and
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14 all our plans are contained in the vault.
You might ask
. 15 that question --
16 DR. KERR:
I wasn't asking about the specifics of 17.
the security.
-18 MR. CARROLL:
Bill, is this new effort that 19 you're involved in related in any way to some of the recent 20 state of the industry involved in --
21 MR. RUSSELL:
Certainly.
I would characterize, 22 yes, as a result of the lobbying or'the complaints from some 23 of the organizations in Washington where wo're getting
- 24 information hearsay or through their perceptions that the 25 staff has decided it ought to find out for itself firsthand.
Heritage Reporting Corporation (202) 628-4888
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And what we're hoping is that the lobbying 2
organizations have not gone'out to spread the word as to 3
what the answer is to the questions, but we will, in fact, 4
get added responses from utilities.
5 DR. REMICK:
This is a directed program, I 6
believe.
7 MR. RUSSELL:
I'm not sure whether --
8 DR. REMICK:
-- call in insurance company 9
inspections and NRC and so forth.
10 MR. RUSSELL:
It has been presented to the 11 Commission and the Commission is aware of it.
I'm not sure 12 whether I would characterize it that the Commission directed 13 it or it was a staff initiative of which we've informed the
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14 Commission what we're doing and the Commission has agreed.
15 DR. REMICK:
I thought I saw a staff requirement.
16 MR. RUSSELL:
There is a Commission paper that 17 describes the program.
18 MR. CARROLL:
When we were in Region 4 they gave 19 us some statistics of the number of violations.
Are the 20 regions except Region 4 had 8.8 violations and they had 21 25.5.
Looking at your number of violations they have gotten 22
-- it looks to me like there's a heck of a big difference.
23 MR. RUSSELL:
That issue has come up several 24 times.
It's usually characterized that Region 1 is soft on 25 enforcement.
I think the.2a1 answer is with respect to how Heritage Reporting Corporation 7'
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you see a number of violations and which you see what the i--
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emphasis with utility rather than handling them as 9
. individual pieces.
10 In fact, the tendency is more to group Oiolations 11 in the package that we issue rather than treat them singly,.
12 particularly.for escalating cases.
And that's not as true 13-for lesser vi.lations, although there is some tendency to do 14 that.
- O 15 MR. CARROLL:
I specifically asked that question.
16 MR. RUSSELL:
I think that it takes reading of 17 some of the cases and seeing what we do.
I'm not trying to 18 take sides on the issue.
I believe that headquarters can 19 address that, and generally the quality of the enforcement 20 packages and the actions that have been proposed by the 21 region have been sustained; we don't see substantive changes 22 to the packages that we submit.
I think that they are 23 fairly well done.
24 The emphasis I think should be on the corrective 25 action that you're trying to elicit and not on the count of Heritage Reporting Corporation (202) 628-4888
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We have those statistics, they're 2.
in the SALP reports.
We may instead of multiple violations, 3
we may characterize multiple examples as the same violation 4
and give it more emphasis rather than counting them 5
individually.
6 I have seen packages that have counted things 7
individually in order to increase the size of the beam post, 8
and'that's appropriate; and there may be others where it's 9
better to focus on what was really the root cause that lead 10 to the multiple violations.
11 So you -- and I think the statistics will speak 12 for themselves.
I would submit that the best way to get to 13 the bottom of that is to review a sampling of enforcement
( )
14 packages and reach a judgment as to whether there are things-15 that should be done.
16 MR. CARROLL:
Is this being done by headquarters-17 on a periodic basis?
18 MR. RUSSELL:
Oh, yes, they look at -- I think 19 the last time through when they looked at how the regions 20 were handling some very level fours.
21 MR. CARROLL:
So they go down as low as four.
22 MR. RUSSELL:
Oh, yes.
They sample the level 23 fours and they review them to determine if they should have i
24 been forwarded to headquarters for consideration as a three 25 or whether they were examples of repeat violations that l
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They review those 2-packages and'then they have correspondence back with us, and 3
.I don't recall what.the totals were, but.out'of some 100 4-packages:that theyLreviewed in Region 1, I believe, they had.
5
.four that they had questions on and even though they had
~ questions.those were not changed; they concurred with.our 6
7 disposition on them.
1, 8
Dan can' address some of that in his talk on itt 9
enforcement which is' the next tal?c.
10 It is an area that licensees tend to' emphasize, 11 and the statistics don't add up evenly.
12 MR. COLLINS:
If I could make just'one point.
13 I think you have to go beyond the context of the
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14 numbers of violations and look at the purpose.of' improving-15-it.
Not only in this region but in other regions, there are 16 a number of enforcement tools that are reopened by the l
17
. staff.
18-I think you have to be a little careful.in using 19 the numbers themselves; looking at, is the appropriate 20 action being taken by the agency, albeit in this' case the 21 region.
22 MR. RUSSELL:
I think maybe what we ought to do -
1' 23
-this discussion can uo on and it might be useful to go into L
24 the next topic which is ample loading.
Oh, you're right, we 25 are further behind schedule than I thought.
We have to do Heritage Reporting Corporation O. -
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inspector; qualification and then'if we could hold'these-L 12 questions until we go into enforcement.
3 DR. REMICK:
I had an opportunity to. talk to a' 4
regional meeting of' resident inspectors about.ACRS and I 5
gave them some of the examples of the-type of thing'we do, 6
.our recommendation that consideration be given to research-7
.on the selection, training, qualification of resident 8'
inspectors.- I kind of stepped into a hornet's nest, perhaps 9
rightfully-so, but the reason I thought-that it would be 10 prudent to tell us a little bit about what they currently do
.11 for resident inspectors now.
If that's the origin of this 12 subject, then we welcome it.
13-(Slides being shown.)
()
14 MR. BETTENEAUSEN:
My name is Lee.Bettenhausen,
~15 and the subject is a little broader because we thought we 16' would take a few minutes and tell you what we do to qualify 17 all of our inspectors.
18 The process is very similar for all of them.
19 Each has got its unique characteristics, and I've handed you 20 the inspection manual chapter that describes the 21 qualification process.
12 2 This is a lot like a college curriculum.
It's 23 got some required technical training and these are classes.
24 mostly of the Technical Training Center in Chattanooga.
It 25 has got required regional training, reading the regulations, Heritage Reporting Corporation (202) 628-4888
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. reading instructions,' understanding the organization, S
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. understanding some of the-roles and missions.
3 Then there's the on-the-job component, the 4
inspection. accompaniments.
And these typically take place i
5 early in the new' inspector's career as accompaniments.
.-9 6
There is a formal qualification 1 journal.
It's a nice big.
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thick looseleaf notebook that the individual keeps that 8
answers the. questions.
Checklist on reading, checklist on 9
plant walk-throughs, checklist on standards and codes that 10'
-they've read.
It culminates an oral examination.
11 DR. KERR:
Mr. Bettenhausen.
12 MR. BETTENHAUSEN:
Yes, sir.
13' DR. KERR:
Give me a little bit of an idea, if 1()
14' you would, on the qualifications of.a person who goes-in --
15 MR. BETTENHAUSEN:
If you allow me, sir, I have 16 those as the last item.
17 The goal for qualification is about a year.-
As 18 Mr. Russell told you, it typically takes us about 18. months; 19
.the manual requirements it two years to do this.
20 If I could have the next slide.
21 There are a number of tracks to qualify a 22 radiological safety inspector and there are several sub-23 species of these individuals, reactor health physics, the 24 fuel facility specialist, and the person who inspects 25 materials licenses.
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The reactor operations inspector-is the category 2
that encounters the resident inspectors and many people here 3
in the regional office.
All the inspectors and division 4
reactor projects are qualified in this manner except for the 5
very few inspectors we have left.
And very many of the 6
division reactor safety people are also qualified as 7
operations inspectors.
8 Instruction is a dying breed.
Engineering 9
support, typically, we take the specialist engineer here, 10 the electrical engineer who is a regional specialist, the 11 fire protection engineer and provide the fundamental reactor 12 systems for him.
There again, there are not very many of 13 these people in the region.
Most of our staff qualify as a
14 operations inspectors in a broad sense.
\\
15 We also qualify safeguard inspectors who have the 16 unique job of looking at the safeguards and security and 17 emergency preparedness which also includes several reactor 18 engineers.
19 The one I don't intend to spend a lot of time on 20 are the license examiners.
Mr. Gallo can speak to that, if 21 there are any questions.
22 But these are the kinds of instruction tracks 23 that we have.
24 And now to Mr. Kerr's question, the last slide.
25 We don't start at the beginning; we start with Heritage Reporting Corporation (202) 628-4888
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people who have considerable experience and these typical 2-beginning inspectors.
A_former Naval Officer who has been 3
an engineeringfofficer, who'has.six or'more. years of Navy.
4 experience.
A graduate engineer who has worked his way-5
.through.the. shipyard as a shipyard test engineer.:
Someone who has been a utility technical advisor <n: specific 6
7 discipline engineer with a utility, again with three to five 8-years experience.
9 In.the health physics side, again, the-physical-10' profile is somebody with advanced degree in health physics 11-
-or advanced experience in_ health physics and three to five:
12 years experience.
13 So we're starting at a fairly'significant high
-()
14 plateau then you might think.
We do'and have considerable 15;
. success taking new college graduates, qualifying them and 16 getting them the kind of experience that has made them very 17-valuable.
I guess we've got about 12 that I-can think of'so
-18 far.
19 The process takes longer, obviously.
One of the 20 things we try to do is get them considerably more experience 21 at power plants, experience at a number of facilities, 122 assignment as a junior-junior resident for periods of time 23 with six months at one plant and six months at another so 24 that they get the flavor of different plants.
25 I hope this is responsive to your question, Dr.
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'2 DR. REMICK:
PRien you say,-graduate engineering,.
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are you talking Mbout Bachelor Degrees?
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HR. BETTENHAUSEN:
Yes, sir, BS'in engineering.
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DR. KERR:
At the end of this qualification p
6 process.are there examinations?
i 7-MR. BETTENHAUSEN:
There is_ supervisory review-8 all along.- There is no written examination, but there is an 9
oral board, duration two to three hours meeting at a Board 10 of typically four people.
11-DR. KERR:
Do you have requal examinations which 12 require the --
13 MR. BETTENHAUSEN:
We do not.
The manual chapter 14
.does require a requalification, I believe it's a two year 15 cycle now, for people to go back to'take the simulator-16 course at' Chattanooga on a reasonably periodic frequency to.
17 renew and refresh.
And in those courses an examination isL L18 given and expected to be passed.
19 DR. KERR:
I'm not sure whether the answer is yes r
20-or no?
21 MR. BETTENHAUSEN:
We do not have a formal -- we 22 do not have as formal requalification program as operator 23 licensed -- as licensed operators.
- 24 DR. REMICK:
Dave.
25 MR. WARD:
For the full-time inspectors, roughly, Heritage Reporting Corporation
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1 what's the mix of the backgrounds?
Are most of them from
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What fraction of them, for 1
3 example, have the experience?
a 4
MR. BETTENHAUSEN:
I would say, roughly without 1
5 being able to sit down and calculate it, that we have l
l-6 somewhat limited to the experience, 20 percent or so.
Most 7
of the people we have come from the government side.
8 NR. GALLO:
About six licensed operators.
l 9
DR. REMICK:
Identify yourself for the court 10 reporter.
11 MR. GALLO:
Robert Gallo in the operations l
12 branch.
13 DR. REMICK:
Do you have any kind of continuing
()
14 training for these people other than the simulator example?
15 MR. BETTENHAUSEN:
Yes.
Once someone gets --
16 well, I guess there are two ways to do this.
One is to 17 become the specialist, the expert, and we certainly support 18 people in continued education.
We do have -- again, the 19 manual chapter that I have handed does not indicate a 20 revised curriculum in health physics which we're about to 21 undertake.
We will shorten the front end and add things as 22 supplementary courses that are available, the technical 23 training centers have undergone some considerable changes in 24 the health physics area and we will be doing a lot of our 25 own health physics training instead of having to go to Heritage Reporting Corporation iO (202) 628-4888
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Harvard or some'other, Oak Ridge and associated universities l
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We will be doing'a good bit more i
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So specialist development tends to take advantage 5
of specialist courses, specialized workshops and the-like.
6 The other thing that we, I guess, done when the 7
individual. desires it and it seems to be good for the 8
organization is to cross-train.
Occasionally had health 9
physics who qualify as operations inspectors and become 10 resident inspectors.
We've got a fair sprinkling of reactor 11 engineers throughout the entire organization.
Emergency 12 preparedness specialist, safeguards inspectors and the like, 13 people who actually have nuclear reactor and test experience
()
14 now doing safeguards work or emergency preparedness' work..
15 DR. REMICK:
What do you do for these people to
.16 keep them current or to learn -- when they come from outside 17
-- to learn the Commission's regulations?
18 I know of a case recently where a research 19 reactor facility had to remind the region that they were 20 being cited for part of a regulation that didn't apply to 21 research reactors but applied to power reactors.
How do you 22 keep people up to date on that, especially when they go from-23 power reactors, research and test or vice versa?
24 MR. BETTENHAUSEN:
I guess the best thing is, 25 continued awareness of the regulations.
We don't have any O
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l
~
1 formal structure for it,.but.we certainly do characterize-2 them as region reactions, but we d have to see from time-to-3-
time the need'to emphasize a point and conduct some sort lof 4
specialized training ce.mpaign for it.
5 MR. COLLINS:
Sam Collins, if I could make a 6
couple of comments.
There was an earlier question on exams;
'ar 7
we.do have varied a little bit -- I'll speak for.the 8-resident program, reactor-inspector program, the division of 9
-reactor projects.
10 We do have a plant walk-through that's required 11 for the individual.
That prior to going to the lower Board.
12 The lower Board is conducted and has to be -- consensus of 13.
the Board as far as passing the qualification process.
14 That qualification process, as Dr. Bettenhausen 15
'has mentioned, does include a specific portion of 16 regulations as well as application of those regulations, if' 17 you will.
18 Provisional qualification to new inspections and 19-acknowledgement for specific inspections being completed
-20 satisfactory with overnight from responses.
21 As far as the test in research reactors that, of 22 course, a different part of the license.
Typically we use g
B' 23 inspectors who are qualified by power reactors to also find 24 them as research reactors.
25 We look for supervisory oversight to get involved Heritage Reporting Corporation (f
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.li in.this, also. 'The inspection findings that are also lJ 2
' preliminary.
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'Our mix is approximately 25 percent perhaps being 4
in. nuclear background;;50 percent in Navy nuclear 5
background;.25 in the area of commercial experience.
.6 DR. REMICK:
I would think they would have a' lot 7
to learn about the regulations which are complex.
8 MR. COLLINS:
Yes, that's a new -- even with an
.9 extensive operating background, whether it be commercial or 10 Navy experience, the application of the Commission's 11 regulations --
12 MR. RUSSELL:
Lee, if you could put the slide up 13 and have the backgrounds coming in there is one point I
'( )
14 would like to make before we go on to the next area.
15 What this is, this is what we have been 16 successful of'doing in the past and we're seeing an erosion 17 in our ability to compete for people that have this type of 18 background and experience, just based upon the salary 19 structure of what we're able to offer.
20 We still see them coming in.
They're still 21 looking for jobs and they still have resumes out.
And we 22 review them.
But we're having more and more cases where we 23 are not competitive salary-wise and people are taking 24 positions other places for higher pay.
That's becoming a 25 real issue and that's affecting our ability to recruit and O.-
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high experience.
2 As a result we're looking at having to go to 3
bringing in entry level candidates, people out of college 4
and train them ourselves.
5 And the programs that we've described have been 6
programs that were laid out based upon some experience 7
coming in the front end.
We have to structure programs for' 8
entry level; that's going to cost us resources because you 9
will have to put more people into it.
They're going to be 10 in training for a longer period of time and you're going to 11 have to dedicate resources to getting them trained and 12 qualified.
13 That's going on now on a limited basis with an
()
14 intern program that is being supported by headquarters.
15 We're going to also have to look at doing something on our 16 own in the region just based upon our high turnover rate in 17 getting people qualified.
18 That's why I mentioned earlier that staffing is a 19 turnover and the amount of time for training is a 20 significant issue and in my view it's one that is not 21 budgeted as one.
22 DR. REMICK:
Is there another comment over here?
23 MR. DURR:
Jack Durr, engineering branch.
24 The division of reactor safety every Monday 25 morning has training sessions for inspectors.
And the
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spectrum of topics covered range from having private j
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2 industry would then give us some technical dissertations to 3
discussions of the regulations and implementation of it and l
4
.that kind of thing.
5 So every Monday morning that happens with the 6
inspectors to keep them updated.
)
7 MR. WARD:
One more question about thise 8
Other than these professional backgrounds, when 9
you interview and select people for these jobs, do you look 10 for any particular characteristics that you think make the 11 inspectors?
What makes inspectors who can contribute to 12 your program other than professional background?
13 MR. BETTENHAUSEN:
I think the most useful 14 characteristic is having an inquiring person.
And again, an O
15 inspector also has to function a good bit on their own.
So 16 if the person who spent his life on a research program 17 somewhere in a room where he just passes paper back and 18 forth is not a very useful inspector to us.
So, yes, we do 19 look at the kind of person we are hiring as well.
We want 20 someone who is inquiring, who can deal with people.
Who can 21 write.
Who can travel from point-to point and be able to
'i 22 confirm himself or herself rapidly.
These are the kinds of 23 characteristics we look for.
24 Again, you find it useful to have a broad 25 spectrum of people, too.
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DR REMICK:
Jay, do you have a question?
2 MR. CARROLL:
Well, I guess this all started with 3
human factors originally.
One of the longstanding technique 4
with the knowledge that you do is just sort of profiled is 5
people that are successful in their job, give them a series 6
of aptitude tests and see if there is a correlation between 7
the group that passed and the ones that didn't.
8 I think the resident inspectors have been much 9
more successful than I guess it was going to be than when it 10 started.
I think it's a real credit to the NRC that they 11 have, in general, picked darn good people.
12 But on the other hand you can improve any process 13 like that and the more we get to know human factors types
()
14 the more we love them.
I mean, they are very good at 15 aptitude tests.
To an old operating guy like myself I 16 really resented them coming in and looking at my control 17 board layouts, but they bring something to the party.
18 And I guess my question is: do people here in the 19 region think that there might be something to be gained by 20 having them take a look at the way we select resident 21 inspectors?
22 MR. RUSSELL:
Let me respond from my background 23 having been involved with human factors as a director of a 24 division of human factors safety and then human factors 25 technology.
(~%
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,. s I I 1
And there is one thing I would like to add before 2
I do that. In Region 1 we do not assign inspectors directly 3
to resident sites as initial employment action.
They are 4
brought in and they go-through a qualification program.
5 And, in fact, to qualify as what we call an "a candidate" to 6
go to a site, they need to first qualify as a region-based 7-inspector at the understanding of the NRC.
And there is a 8
continual evaluation of that individual's performance and 9
then a determination of its aptitude based upon individuals 10 that will be put out in the field, 11 But we do not use an aptitude type test.
If the l
12 question is --
13 MP CARROLL:
Is what you're describing true of 14 all regions?
15 MR. RUSSELL:
No, that's not.
Some regions 16 assign people and recruit directly for sites.
We feel that 17 it's a key position and we want to make sure that the 18 resident clearly understands not only the NRC regulations, 19 but the regional organization and the importance of 20 communications.
And we have some feel for their ability to 21 perform in that based upon how they performed as a region-22 based inspector.
23 MR. RUSSELL:
Part of the process that I think is 24 significant that could be used I think to some extent is 25 being considered by the steering group that interacts with Heritage Reporting Corporation (202) 628-4888 O
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1 Chattanooga is development of job task analysis for the 2
position, development of learning objectives and what should 3
be the structured. training program and the qualification 4
profile.
5 Once you've defined that, and that clearly is a 6
function of who you bring in, some kind of a screening test 7
to screen applicants may be appropriate.
8 I am just not sure in the priority of where we 9
place our training and resource dollars that that activity 10 would be a higher priority, that is, working on screening 11 exams, as compered to doing a job task analysis or improving 12 the learning objectives, the job description of the 13 position.
And that is the judgment that has to be made.
14 Right now we are trying to provide the technical fs km 15 information.
We are not in the analysis phase.
We are not 16 going out and doing task analysis.
We are not developing 17 learning objectives.
18 We are in course development based upon 19 experience and jydgment of what should be provided using a 20 steering committee and experts to give those courses.
21 MR. CARROLL:
Who is on the steering committee?
22 MR. RUSSELL:
For Region 1, Sam is the regional 23 representative to that steering committee.
When I was in 24 Headquarters I was on it for a while back in my Headquarters 25 role.
So that is the process that we follow.
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MR. KANE:
My name is Bill Kane.
I am Director 2
of the Division of Reactor Projects.
3 I guess my comment would be that conceptually the 4
idea sounds reasonable but I guess I am a little troubled by 5
singling out a single element of the inspectfan task force 6
or indeed the agency, and establishing certain requirements 7
or certain attributes to that position whereas if it were 8
applied more generally I think it would probably be more 9
helpful because I think thst is, I think that could create a 10 problem by just singling out a group.
11 MR. CARROLL:
I guess I view the resident 12 inspectors and particularly the senior residents as being 13 probably the most unique position in the NRC.
The guy is 14 basically the eyes and earc of the NRC on a site.
It is
(}
15 probably the most difficult personnel selection choice 16 anybody in the agency ever makes is sending a guy to a site 17 for five years.
It's almost irrevocable.
18 If he turns out to be a real loser, you're still 19 going to be very reluctant to pull him back.
You've 20 invested so much in moving he and his family there and so 21 forth.
I just see it as being a very unique position.
And 22 I guess you seem to be saying well, what's different about 23 it.
24 MR. KANE:
Well, I think from my perspective, I 25 think all of our inspectors are certainly important, whether Heritage Reporting Corporation
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they'are region-based or residence based.
2 MR. CARROLL:
Yes.
But there's more checks and 3
balances on the region-based inspector.
4 MR. KANE:
I'm not cure that's the case.
I 5
believe that there are lots of checks nnd balances on the 6
~ resident inspectors as well.
7 Certainly the management, section chief, branch 8
chiefs, deputy directors, division director, regional 9
administrator, deputy regional administrator, to the extent 10 we can time it at the sites, to try to make sure we 11 understand the way they are approaching the job, and it is 12 given very serious potential, recognizing just what you say 13 that they are spending most of their time away from the
()
14 region.
And so we are very conscious of the issues that you 15 are talking about and very careful to make surc that those 16 issues are dealt with.
17 MR. KERR:
I would conclude that you people are 1B quite satisfied with the present selection process.
19 MR. KANE:
Well, as you indicated, I believe the 20 selection process, you can always improve.
But I think that 21 our process of bringing the resident inspectors in here 22 first, making very sure that we understand -- potential 23 resident inspectors -- making sure that we understand very 24 well that they are capable of going out to a site, I think 25 is a very important part of the process.
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And it is done in recognition that if you assign 2
an individual directly to the site, a new hire, you don't 3
have the advantage of understanding that person's ability to 4
do the job in every respect.
So that part of it is very 5
ie.portant to me.
6 MR. MARTIN:
This is Tim Martin.
Because there's 7
additional retoonses necessary.
First of all, they are 8
hired and brought into the regions, to train here, 9
demonstrate some skill here.
They are not sent out as 10 senior residents.
11 They are sent out as residents, and they function 12 under a senior resident who is a supervisor, an individual 13 who has already demonstrated his skill to function in that
~(
14 environment and do well enough if we feel comfortable in 15 promoting him to a supervisory position.
16 So he's not out there by himself in a non-17 supervised situation.
And we have brought people back in 18 shorter than the five years when we have not been satisfied 19 with their performance.
20 MR. CARROLL:
Maybe an aptitude test might reduce 21 the number of times you do that.
22 MR. COLLINS:
Sam Collins.
23 Let me temper all that by saying that I think if 24 you approach it -- There is always room for improvement in 25 any process.
And certainly an understanding of what makes O.
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I the good people better than others, what attribute is there, l
l 2
if it is not technical than what is it?
3 Is it communications ability, is it writing, is 4
it a philosophical approach that they bring to the job?
Is 5
it their background?
6 Understanding what could make that happen would 7
certainly enhr.nce any process that we had if it was 8
definable, which is why I think we are all a little 9
hesitant.
10 I don't think we're saying that the process 11 doesn't have merit.
I think what we're trying to say.is have checks and balances into the 12 that we have some, u s
13 system.
De-enhancement would be certainly welcome.
But we 14 need to understand why it's being done and why it's unique, O
15 because you are dealing with personnel here, people who j
16 already have the positions.
17 And you certainly have to be careful on the 18 impact of those types of studies, why they are perceived to 19 be done and how the information is used.
l l
20 But that doesn't negate the possibility of doing l
l 21 it and looking at the information in terms of what does it l
22 mean and then applying it as appropriate.
23 MR. CARROLL:
One final comment.
We briefed the l
24 Commissioners, ano this subject came up.
And German Carr i
25 did make the comment that the Navy shrinks have been
]
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studying what makes a good submar!.ner for 30 years, and he 2
doesn't think they've figured that out yet either.
3 MR. RUSSELL:
I would also submit that we don't 4
have that many candidates to apply a screening test to once 5
you go into the resident program.
And if we were looking 6
for entry level inspectors that had that potential and we 7
were using it as a screening at the college graduate level, 8
it may provide some insights that will be useful to reduce 9
the ten candidates now that we screen for each position to 10 hire.
11 MR. REMICK:
My response to that, though, Bill 12 would be it need not necessarily be screening.
13 It might be a way of identifying weaknesses and 14 therefore those can be supplemented with some specialized g
15 training to make that person better.
It depends, I think, 16 on how you look at it.
17 MR. MARTIN:
Okay.
My name is Tim Martin.
I am 18 the Deputy Regional Administrator.
And the subject is 19 Enforcement.
Dan Holody and I will trade off on this 20 subject.
21 The enforcement purpose is to promote compliance 22 with our rules and regulations; to assure that there is 23 timely and effective corrective action; to deter violation L
24 by the threat of it being present and the fact that once an 25 event has occurred, the knowledge that a repetition of that Heritage Reporting Corporation r'
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1 problem, therefore an effective corrective action, can 2
result in more severe escalated enforcement action.
It's 3
also to encourage and improve performance of licensees.
4 For those who wish to avoid being cited, we hope 5
that they learn to control their work better, to identify 6
their problems themselves in an effective quality assurance 7
program, to promptly report those problems and to take 8
effective corrective action.
This way they can avoid the 9
citations, and avoid the need for enforcement action.
10 Later on when I talk about philosophy, I think 11 you will see the reason there.
But it encourages improved 12 performance not only in the targeted organization that has 13 violated our rules and regulation but because of the (v~)
14 publication of the information by example to other licensees 15 who become privy to the knowledge and as a result decide 16 that they are going to avoid that behavior which resulted in 17 the ite:n of noncompliance.
18 Now, on philosophy, our focus is on safety.
As 19 one utility pointed out, he would hcpe that we would focus 20 on hits, not myths.
What he was saying, don't distract us 21 by focusing on the myths not important to safety.
Focus on 22 those things which are important to safety and we will work 23 to correct our problems.
24 We work to avoid that distraction by picking out l
25 the isolated example and pulling out all our tools to l
l l
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1-prosecute the enforcement process.
A single failure to sign 2
a document because the administrative procedure says you are.
3 supposed to sign that document is a valid citation.
And you 4
could legally make that citation.
5 But if you review 15 and 20 documents and there 6
was oneferror in signing these documents, it is not an 7
effective use of 'our manpower or of' the licensee to cause a 8
citation for an isolated problem.
9 So philosophically, we do not focus on the 10 isolated event that has ac>t produced impact on the'outside 11 world or even on the licenAce*s operation.
.12 There is an element of carrot and the stick
. 13 obviously in enforcement and we recognize that.
We also
- L 4 recognize that if you use the stick too often, you
{}
15 desensitize Piling on doesn't help.
p 16 If you have 16 examples of the same problem or 17 the problem with the same root cause, it doesn't help to 18 make 16 separate violations.
We will package those as a l
19 group of violations and maybe escalate the particular 20 enforcement action based upon a pervasive problem or a 21 failure of the licensee to identify his problem ar.d to get 22 on with correcting it given the multiple examples he had for 23 finding those problems.
24 But you run a real risk of desensitizing the 25 industry to the tool if you use it too frequently.
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1 Another example is covered in the enforcemerit 2
policy.
If we have a licensee that has been subject to 3'
major escalated enforcement action and we subsequently find H
.4 additional examples of problems that are the same root 5
cause, what advantage is there to us to again cite the same 6
problem if it had the.same root cause and he hasn't had time l
l-7 to correct the problem?
8 The enforcement.is ultimately to produce 9
corrective action.
We don't have quotas.
We don't assign 10 our inspectors out there to get X number of violations.
We 11 don't give them a lot of credit just for uncovering X number-12 of violations.
There is no quota on numbers.
13 The enforcement is a tool.
It is not an end in
. ( ),
14 itself.
There is no great benefit to us to say look at all 15 the enforcement we took, if we can't point to the corrective 16 action'that resulted, that prevented a recurrence of those 17 events.-
It's a process that we use.
It's a bag of tools.
18_
hit's the confirmatory action letters.
There's a notice of 19
. violations.
There's civil penalties.
And there's awards.
20 And those are tools and they are all meant to do 21 the same thing:
to correct the probJem, to prevent 22-recurrence not only at that licensee but at other licensees, 23 to get the appropriate corrective action.
24 MR. WARD:
I haven't heard anything I would 25 really characterize as a carrot.
I mean, there is perhaps Heritage Reporting Corporation L
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I the absence of a stick.
2 MR. MARTIN:
You're going to get a carrot.
1 3
MR. WARD:
Okay.
4 MR. MARTIN:
Because what you'll see is in the 5
actual implementation of our enforcement policy, we give a 6
lot of carrots and mitigate the consequence and in some 7
cases even write it off as a result of licensee 8
identification, prompt reporting if required, and effective 9
corrective action.
10 We will actually give them a plus not only in the 11 inspection report that identifies the fact, but in the 12 process that points out you've got an effective self-13 monitoring program that has been able to surface these
/~T 14 isolated violations.
You've been effective in getting them
\\_)
15 to management's attention quickly, getting them reported and 16 getting corrective action going.
17 Obviously, with the small size of the NRC staff, 18 we cannot find all the violations out there.
The licensee 19 has to have an effective corrective action program and 20 feedback process that is self correcting on its own process.
21 We try to foster that program by giving the 22 licensee credit for it.
We have authority under the 23 enforcement policy that Dan will talk about, of basically 24 acknowledging those and not citing the Level 5s and some 25 Level 4s.
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'1' MR. REMICK:
Isn't it inevitable, as Congress i-
.2 places greater and greater emphasis on the NRC_to bring in.
3
'more:and more of its budget-for licensees to increased 4
numberfof findings and increase the amount of the findings?
5 MR. MARTIN:
That goes directly.into the 6
treasury. It does not go --
7 LMR. REMICK:
I realize it doesn't come to the 8
agency.
9 MR. MARTIN:
What they are looking for is the fee t
[
10 process to-support the -- But we see none of this money.
I know it doesn't'come in.to the 12
. agency. -But it seems to me as Congress expects the agency 13 to generate a greater percentage that there would be a (f
14 tendency to increase fines and the number.
You don't see 15 any evidence of that?
16 MR. MARTIN:
I see no evidence of that.
17- -Certainly everybody I've talked to recognizes that it 18
-doesn't line their pockets or the NRC's.
19 And to be quite frank, it might be 20 counterproductive to do so.
We are a safety organization.
21 Our focus is on safety, to enhance and get licensees to 22' maintain an appropriate level of safety, to give us some 23 type of financial credit for the ability to identify a lot 24 of myths.
You basically start issuing tickets, trying to 25 raise your quota so you can make sure that next month's
,("}
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l' salary can still be paid.
That is not what we think is I
2
. appropriate to do.
1 '..
3 Now, I think I need to speak to process a little 4
bit'.
'So let me jump to another slide here.
Because you 5
will'see that in almost every stage'in the process, we try 6
to get early and timely corrective action.
7 The process I'm going to speak to is the actual 8
sequence, what communication occurs in that process, who has 9
responsibility for the various aspects, what coordination y
10-occurs.
This'really' addresses the' issue of uniformity 11' across regions.
What kind of goals we use in the 12.
enforcement process.
13 Can'I have that separate slide here?
I'm going 14.
to jump off this one.right now.
15 First off, you have to have a problem first.
l <6 There 1.s the earlier issue of how does one region have more 17 violations than the other. 'Well, obviously.there is going 18 to'be some variability in performance.
So you have to have 19 a problem first that needs to be identified.
20 Second, then, you need to have the resources to 21 do the identification.
If all your resources are devoted to
-22 for instance problem plants and you have not been able to 23 put as many resources on some of the other plants, you have 24 less opportunity to find the problems at those other 25 facilities.
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l' And then there'is process, which basically says 2
tyou don't-cite for certain types of activities which you've f
3 already got corrective action in process, you have a major 4
violation which:you have already used escalated enforcement 5
process to get. commitments to corrective action, and the 6
corrective action is not complete. -So those violations are 7
then folded into the previous. action.
There are just' 8
additional items that must be addressed in the licensee's-9 corrective action program.
- 10 So the number count can be very confusing and 11 really not representative of how aggressive a. region.is lL2 approaching the problem, because there is a lot of fingers 13 in the pie, i
14 The utilities and how well they perform, that can
'15 vary between region to region and year to year.
And what' 16 Dan's'atatistica will show are, in some years we have more 17 violations in other regions, and in others we have less.
18 Two, the ability to define or find the problem.
19 If we are running short on staff or if we are devoting all 20 our attention to problem facilities,.then we don't get the 21 opportunity to identify as many violations.
If the licensee 22 does a better job in self-identification, those things are 23 not cited.
24 And finally, the process which tells you that you 25 should take credit for any previous escalated enforcement Heritage Reporting Corporation
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'1' action of which the problem you have: identified is simply l2-
-another aspect'of that and it-is already addressed.in the 3
licensee's corrective action program and only_needs to be 4
folded in.
l S.
So, that gives you some ways to vary those 6
' statistics and.not necessarily a reflection upon the 7
region's aggressiveness.
L 8-
.Once a violation is identified, the inspector's 1
k 9
. job right then-and there, before he even talks to his
- 10' management, is to get that information to the licensee'so he 11 can initiate corrective action.
L
~
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12
.After the inspector has. completed his inspection, 13 he goes to an inspection exit.
There he is supposed to exit
' ' ()
14 with the most senior licensee individual onsite where he l'
- 15~
again is expected to communicate the problems that he has
- 16 been able to identify and understand what the licensee is 17
' planning to do short term to deal wit ~a that problem.-
u 18 So he is confirming that the licensee has 19 knowledge of the problem and is moving in appropriately 20 corrective manner.
21-Then the inspector comes back to the region.
- 22 During that first week he is back in the region he has a 23 couple of things he has to do besides read his mail. -One of l
- 24 them-is to debrief, not only with his own management, but 25 with the section chief of the project organization, who has l
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responsibility for that project, to let them know what 2
findings he has had.
3 That week, he is given to get the system engaged, 4
to evaluate the problem, to determine if there is a 5
potential for escalated enforcement action.
6 At the end of that week, if that is concluded, 7
that there is a potential escalated enforcement action here, 8
we get an enforcement number from Dan and we move on to an 9
expedited writing of the inspection report to-document our 10 observations.
11 The inspection report is supposed to be completed 12 and out the door within three weeks from the end of the 13 inspection.
(o) 14 When we know we are going to have the inspection 15 report out, we contect the licensee again and confirm that 16 the licensee is prepared to meet with us in an enforcement 17 conference, that he has in fact moved forward with his short 18 term corrective action, and may be able to discuss some of 19 the long term corrective action that he has already engaged 20 in.
21 But the purpose here is you are getting the 22 inspection report, here is our understanding of the facts, 23 this is another notification of you of what the issues are 24 and we are scheduling an enforcement conference where you 25 can come in and talk to us, and this is what the enforcement Heritage Reporting Corporation (202) 628-4888
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conference is to do.
l
-. 2 The inspection report is provided to the licensee 3
between.the third and the fourth week, and he gets that.he 4
' sees what we've set about and he sees what we understand was 5
-the event.
((
6 He.may modify his corrective. action plan, because 7
he understands a little different nuance.
Hopefully that-is l
8 not the case.
Hopefully he already understands what our 9
problems are.-
-10 The enforcement conference-is then usually held 11' in the regional office although:on occasion ~we-have held
'12-them at sites.
13 The purpose of the enforcement conference is to
)f 14 give the licensee an opportunity to' clarify the facts we H
15-presented in the inspection report, to. clarify for us the-16 safety significance of the potential violation that has been 17
. identified, to communicate to us what his corrective actione 18 plans are, both what he has already undertaken and what he-19 plans to take to bring this thing to resolution to prevent 20 recurrence.
21 We have a job of making sure he understands the 22 significance that we see in the event and if we have 23 problems with the corrective actions that he is proposing or 24 has planned to take, we communicate those.
25 So it is a very open, honest dialogue meant to be Heritage Reporting Corporation (202) 628-4888 j
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. f-q V-1 a clarification of' facts, so that the NRC can then get'on 2
.with'doing its job, developing the escalated enforcement 3
action to make sure that the corrective action that'the l
4 licensee takes is appropriate and will prevent recurrence.
-5 The next thing, right after that, there is a-6
. closed: meeting-for the NRC staff to determine what is the.
7 appropriate enforcement action.
8 That might be simply notice of violation; We 9-don't normally use-an enforcement conference if we have.
10 anticipation that is the way it is going to come out.
But 11 we have on occasion done that when it is a close call.
12 The next level up, the civil penalty, that may be 13 the tool chosen because we don't see any need for a specific 14 change in this license which an order really gives.you.
x_
d
. :L5 We see that there is necessity to let them know 16 how important we think the thing is and the enforcement.
17 policy basically sets up tiers of civil penalties that are 18 based upon significance and they are pluses associated with 19
-licensee identification, effectiveness of corrective action, 20 timeliness, and then.there is also negatives if there is 21 repetition or it is very slow in corrective action, et 22 cetera.
23 Dan will get into those mitigation and escalation 24 factors.
25 Once the decision has been made on what the Heritage Reporting Corporation (202) 628-4888 l
I appropriate. enforcement action should be, and by the way, 2-the enforceiaent conference is usually attended by a' 13 representative of the Office of Enforcement, either.via 4
-telephone or telecommunications link with the video,.the 5
slow scan-TV, or in some cases, by personal presence, 6
depending upon the significance of the event.
D 7.
The region is expected to got its package out, 8'
its proposal out, by the end of the week.
That proposal has 9-received the. internal concurrences of the region.
10 There is a cover letter that explains why we are 11 going-the' route that we are proposing and we are now seeking 12
.the Headquarters concurrence, which includes the program 13 office review of the package and the Office of Enforcement
)
14 and OGC, all three have reviewed them.
The regional. counsel l
15 has been involved in the regional aspect of it.
And there's 16 program negotiations obviously.
17 And by the seventh week the package should be out 18 on the street.
l 19' Those are hard targets to meet, because there are 20 a lot of concurrences and a lot of negotiation that occurs 1
l 21 to make sure that we are taking the appropriate enforcement 22 action that-will get the kind of corrective action we want.
23 The licensee then evaluates and may again modify 24 their response to the earlier identification, amplifying or 25 changing their corrective action program.
Then they submit
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If we don't think it is i'
1 a response which NRC eva3uates.
2 still acceptable there are some negotiations that occur
.3 there.
4 And. finally, when everything is worked out, there 5
is acceptance of.the licensee's response.
6 Then the licensee completes their corrective 7-
-action program and' finally the NRC comes back and confirms 8-the effectiveness of that corrective action program.
9 So multiple relooks at the corrective action to 10 make sure that it has been effective in correcting the 11 problems.
12-Can we go back to the second slide, please?
13-There are really four tools here that I have P)
(,
14 articulated under the role.
15 A confirmatory action letter is a mechanism that 16 the regions have.
It is not specifically enforcement, but a 17-lot of people regard it that way, so-let me tell you what it 18.
is.
- 19 It is a fairly quick gentleman's agreement.
It 20 has no legal stature.
But basically it is an agreement that.
-21 has_been negotiated between the NRC and the licensee that 22 the licensee knows full well that we could have backed up 23 with a confirmatory order if we felt it was necessary.
24 But the confirmatory action letter documents our 25 understanding.
It is a public record.
It communicates to
/*
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the world what we understand the licensee is planning to do.
2 The notice of violation is a very formal 3
communication between us and the licensee and it requires a 4
formal response and a formal commitment to the corrective 5
action program.
6 The civil penalty is a notice of violation with a 7
dollar figure attached.
And the civil penalty starts to 8
really get the licensee's attention because it causes bad 9
press, not because of the dollars.
If you look at the 10 dollars, until you get up around $500,000, $1 million, 11 you're not hurting the pocketbook.
Where you're hurting 12 them is the press in the SALP process and ultimately in the 13 financial markets.
14 MR. KERR:
I was going to say you certainly hurt
{'}
v 15 them in the pocketbook with the SALP ratings.
16 MR. MARTIN:
That's right.
17 MR. KERR:
So it's a little bit of an 18 oversimplification to say that the fine doesn't.
19 NR. MARTIN:
It is the consequence --
20 MR. KERR:
Yes.
21 MR. MARTIN:
-- of it.
We include the fact that 22 they have had escalated enforcement action in our 23 consideration of SALP.
24 But to be quite frank, if that is an isclated 25 event, surrounded by very good performance, it doesn't have i
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a heck of a lot of weight.
It is the frequency of those
.2 escalated enforcement actions, the inability of the licensee 3
to cope with his problems, inability for him to correct 4
those problems, which get a lot more weight in the SALP 5
process than -- It's a systematic assessment.
It's not 6
point assessments.
7 And so the escalated enforcement action, 8
depending upon how frequent it is, will determine a lot of 9
how the SALP is driven.
10 The SALP, though, we have been told by a number 11 of licensees, drives their financial market.
And so it 12 ultimately does come back and hurt them in terms of dollars 13 in the financial market when they go out to borrow money.
()
14 For the materials side, some of the materials 15 licensees tell us some of the penalties we propose will put 16 them out of business.
They would not have the money to 17 implement corrective actions if the penalties were as large 18 as the regulations would allow.
19 So in their case, we have to watch out for that.
20 Our desire is not the penalty.
Our desire is the corrective 21 action.
22 Now, there are times when they shouldn't be in 23 business any more, and there is the order.
That is when 24 you use the order.
When you have to remove an individual 25 from an activity, then the order is the appropriate route,
/~'
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not tax them out of existence.
2 The order requires a great deal of care because 3
it may put them on a path that is not appropriate for their 4
organization in correcting the problem.
5 We probably don't know enough about the internal 6
workings in our organization to be very prescriptive on how 7
to fix something.
So frequently you will find orders for 8
removal of individuals, change of license conditions, the 9
requirement for them to have a third party come in and 10 perform a detailed assessment, the requirement for them to 11 develop a detailed action plan, but not prescriptive on how 12 to do it.
Those we leave to a negotiation process and 13 discussion with the licensee.
O).
14 Finally, oversight.
The concurrence chain on the q,
15 escalated enforcement gets awfully long.
It's two lines 16 usually, could be up to 12 concurrences.
There are many 17 relooks at the process and verification that we are 18 proposing the right types of things.
19 The Office of Inspector General just recently 20 completed an audit.
I've got a copy of that report on the 21 enforcement.
There were five recommendations in there that 22 the staff has accepted and on a nationwide basis those 23 changes are going to be made.
24 The Office of Enforcement conducts periodic 25 audits.
Not only do they provide an assessmont of the
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regional performance but they audit things like severity 1
2-level 4s and whether they really should.have been severity 3'
level-43.
They look at how we have handled the three OCPs, 4'
et-cetera.
5 And finally, another oversight is the Regional' 6
ManagementJInformation System, and periodic attendance by 7
senior' regional management at the enforcement conferences.
~
8 The enforcement conferences are normally 9
conducted by division directors in this region.
.The senior 10.
management, the Office of Regional' Administrator will, on 11 occasion, have attendance to observe those enforcement 12 conferences, one, to understand what the licensee is
-- 13 proposing, but two, to QC the performance of the divisions
(
14 in proposing the appropriate enforcement action.
154 Now, having given you those preambles, I am going 16 to ask Dan to get into some of the details which I think are 17 probably more interesting to you.
18 MR. CARROLL:
What is the Regional Management 19 Information System?
20 MR. RUSSELL:
At a break, we'll show you.
It's 21 posted on a bulletin board in the Executive Conference Room.
22 It's the statistics I use to manage what is. going on in the 23 region.
I use that plus each area gets reviewed each 24 quarter.
25 Monday following a staff meeting, typically a Heritage Reporting Corporation
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1" program is reviewed, whether.it is.the. inspection program,,
2 enforcement program, EEO, every program that I am
- 3-responsible for gets. reviewed by me on a quarterly basis.
'4L MR. CARROLL:
Is this something unique to Region 1 5
1 or is it common to-all the regions?
6~
MR. RUSSELL:
It is not common to al1~the 7
. regions.- It is something that I started when I came up v.
8 here..
9-MR.'HOLODY:
Good morning.
My name is Dan i..
- 10 Holody. I am the Enforcement Officer of Region 1.
11-I-work for my Bill Russell.
And my primary'
- 12 responsibility is the preparation of the escalated 13
' enforcement actions, that is, the civil penalties, the b
14 orders.
After we have caucused, we caucus after the 15 enforcement conference, after we have gotten together and-16 caucused, then a decision is made by the division director 17 at that time which he then briefs the regional 16 administrator.
19 I go forward and prepare the action and send it.
20 through our concurrence chain, and then I coordinate and 21 deal with the Office of Enforcement after the package has 22 been sent down to Headquarters for the review of enforcement 23 as well as the other.officos, the program office and OGC.
24 By way of background, we have essentially five 25 severity levels of violations, 1 through 5.
We consider
~
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severity levels 1, 2 and 3 for civil penalties and orders; 2
level 4 and 5 generally result in just a notice of 3
violation.
We do consider civil penalties when notices of 4
violation are repetitive.
5 When we have severity level 1, 2 and 3 6
violations, we consider all those for civil penalties and we 7
also consider a number of escalating and mitigating factors.
8 Those considerations are done at our caucus after 9
the conference.
And they are also set forth in the policy.
10 They are things like whether the licensee had 11 identified the violation or not, or we identified it or 12 found out through some other mechanism such as notification 13 for the state, how well their corrective actions were and 14 how comprehensive they were, how prompt they were in
{}
15 initiating those actions.
16 What their enforcement history has been like, or 17 their history in general, looking at SALP ratings.
18 If it was a good history, we would mitigate, 19 provide some basis for partial mitigation of the fine.
If 20 it was a poor history, we would consider escalating the 21 fine.
22 Whether they had prior notice of these kinds of 23 problems via internal audits.
Licensee notifications.
24 Industry notifications.
Information notices from the NRC.
25 Those kinds of things.
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1 Whether there were multiple examples of.the 2.
violations.
Whether the violations existed for an extended.
3 duration.
Those kinds of things we take into consideration-
~4 in determining whether a fine'is warranted or not when we 5 'Lhave these severity level 1, 2 and 3 violations.
-6 You can put-up the first slide.
7 I have a number of slides here and essentially L8 they cover three areas on the agenda.
9 One is the past experiences.and current problems 11 0 in the' area of enforcement.
11 Second, the latest revisions to the enforcement 12 policy.-
-13 And third, some ideas on suggested changes to the.
- 14 policy.
15 This first slide is a presentation ef escalated 16 enforcement in Region 1 in fiscal year-1989 to date, 17 compared to what the number of actions was we had taken in 18 fiscal years'1984 through 1988, the average for those years.
19 As you can see, the number for the reactors, the 20 power reactors, the number of fines has increased.
21 I will point out, though, that four of those 22 involved a special equipment qualification enforcement 23 ~
policy.
That was a policy that was approved by the 24 Commission originally I believe in 1985 or 1986 and then it 25 was revised in 1988.
And it was to cover a backlog of p
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1 enforcement' actions that were pending in the' area off 2
equipment. qualification.
3 And then once.the policy was approved in early 4
1988,- there were some 20 to 25: actions that were' issued 5:
across all regions involving'the equipment qualification:
6 area.
'7-MR. KERR:
Was this because nobody quite knew 8
what the rules.were and hence what to do about them?
9 MR. HOLODY:
I think that was, I think the issue 10 was we had a policy that called for $5,000 per violation per
-11 day,'for any licensee that was not in compliance with the 12 rule as of November of 1985.
13 And here we were sitting in 1987 to 1988 time l(~T-14 frame asking ourselves are we going to issue these ten.or V
lL5 twenty million dollar fines to these number of reactors or 16 is-there a more reasonable policy here?
171 The staff developed what they thought was a more 18 reasonable policy and submitted that to the Commission and-19
'then once that policy was approved, the staff moved forward' 20 with those findings.
-21 MR. KERR:
In your view, this particular action 22 has enhanced safety significantly?
23 MR. HOLODY:
I don't know the answer to that.
24 MR. KERR:
I'll withdraw the question.
25 MR. CARROLL:
When we heard the presentation from Heritage Reporting Corporation (202) 628-4886
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Joe Colvin of NUMARC the other day, he had a slide showing; 2;. thel number of civil penalties as a function of year.
3 And I guess the point he made and I think it is a 4
very interesting one, is that.I guess it generally agreed 5
that.the industry.is improving.
People-are doing things 6
better.
The plants are performing better, infall respects.
7.
It seemed inconsistent to him and I guess it_does 8
~to me that if that's true, why has the number of civil
~
. 9-penalties increased in the last year?
Among other things.
10 He had a whole bunch of things that were going lup.
11-MR. RUSSELL:
I'm not sure that I understand the 12 trend.
But I would submit that in recent past the NRC had 13 been focusing more on human performance issues than on
( )-
14 hardware performance issues and that the reason utilities 15 may be improving is because we are looking harder at some of 16 these issues and when we find them we are in fact,taking 17.-
appropriate action.
18 The slide that is up right now shows that we are 19 in fact taking stronger action in 1989 than we did over the 20 1984 through 1988 average.
The issues that we are focusing 21 on now relate to human performance, conduct of operation,-
22 procedura1' compliance.
And I think that is appropriate.
23 And I think that that emphasis by the agency, by 24 INPO and by others, is having an effect on improving 25 performance.
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And I'm not sure you can point to a cause and 2
effect relationship amongst those parameters other than to 3
acknowledge in general performance is improving, when we 4
.have some utilities where that is not the case, and there's 5
is declining.
And when you put the tail of distribution in, 6
I'm not sure that you can reach those conclusions.
7 MR. HOLODY:
In the materials area I think we 8
certainly got more aggressive.
Of course, we have many more-9 licensees.
We have increased over the past year both in 1
10 Region 1 and in the next slide, which shows all regions, the 11 number of civil penalties as well as orders.
12' Traditionally, we seem to have issued more fines 13 to power reactors across all regions, although in Region 1
()'
14 we seem to have more in the materials area, but issue many 15 more orders to the licensees, materials licensees than we do 16 to the' power reactor licensees.
17 Essentially three types of orders:
either a 18 suspension order, or a revocation order; the second type is 19 an order where we will have problems in a certain aspect of 20
-program, like radiation protection.
We may have done three 21 or four inspections and find continuing problems, recurring 22 problems, and we will issue an order which requires them to 23 do an independent, to do an audit or assessment of their 24 program to ascertain what the deficiencies are in this 25 program and then to develop an improvement program based on Heritage Reporting Corporation O
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those assessment findings.
2 A third type of order we use also which we have 3
seen many more times in the materials erea is an order where 4
we remove individuals from activities.
5 The order was actually issued to the licensee but 6
an aspect of the order is that it would preclude a 7
particular individual from any involvement in the use or the 8
supervision of use of the licensed activities.
9 And these orders have generally been reserved for 10 wrongdoing matters, deliberate false statements, deliberate 11 falsification of records, deliberate violations of our 12 requirements.
13 The next slide is as I indicated just an 14 indication of the same data I put up for all regions instead 15 of just Region 1.
16 I don't think there has been any increase this 17 year, if you subtract for power reactors, if you subtract 18 off the approximately 10EQ civil penalties.
You are looking 19 at about 40 fines, non-EQ fines.
20 With a month to go, my guess is we will be 21 slightly below the number of enforcement actions issued in 22 the past five years.
23 Me issued about on the average of four orders per 24 year in the reactor area and 11 in the materials area.
And 25 many of those, as I said, are accounted for because of these Heritage Reporting Corporation
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I wrongdoing type orders that we issued to some of the 2
individuals in the materials area.
l 3
The next slide, the next five slides, actually, 4
are just presentations of some of the deficiencies that have 5
Leen identified in the reactor area.
6 The first is some of the violations we have 7
identified in the reactor operations area.
They generally 8
involve tech specs, technical specifications that have been 9
violated, such as the pump room coolers and emergency core 10 cooling system pump room cooler being inoperable, safety 11 limit being violated at a facility because two recirc pumps, 12 their valves were not in the open position as required.
13 Whenever we write an enforcement action and
()
14 whenever we conduct an enforcement conference, although we 15 go thraugh what i.appened, which is in the left column, our 16 fundamental focus in those enforcement conferences is why 17 did that happen.
18 And that is the focus that is reflected in our 19 enforcement letter that is transmitted generally to the vice 20 president or president of the company, focusing him on what 21 our underlying concerns are and what the underlying causes 22 we as we see them and what are the things that they need to 23 do to make sure these things don't recur.
24 The next slide covers some of the same problems 25 that were identified in security, the area of physical Heritage Reporting Corporation O4 (202) 628-4808
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1 security.
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2 The majority of the fines issued in Region I this l
l 3
pact year have been in operation security or equipment l
4 qualifications and there was one issued in the area of 5
And these four slides cover such 6
areas.
7 We can go on to the next slide.
8 I think what you will find in many of these cases 9
is that the kinds of things that happene is people don't 10 follow their procedures.
As a result, they may be doing a 11 test and after completion of the test they may skip an item 12 on the test and as a result the valve is not put back in a l
13 position it should be put in or a breaker.
14 There is maybe not a good post-maintenance test 15 performed.
There may be modifications made to the facility 16 and the post-modification testing is deficient.
17 You may have inadequate procedures because cf 18 inadequate reviews by the people who are evaluating those 19 procedures, the plant operation review committees, et cetera 20 may utilize individuals who are not adequately trained or 21 inexperienced.
22 Those are the kinds of things that we focus on in 23 our enforcement ection.
And those are the messages that we 24 send, whether it is a civil penalty or an order or no l
l 25 action, severity *. <el 3 without a civil penalty, et cetera.
l l
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1 You can go over, Tim, move over a couple slides 2
to the latest revisions to the pump sequence.
3 MR. CARROLL:
At some point I wanted to hear more 4
about the civil penalty in Limerick involving the prob 1cm l
5 with the operators not understanding the protection action l
6 level.
7 Is th!,s a good time to talk about that?
8 MR. HOLODY:
That's the issue that you raised.
9 There were two issues involved in this 10 enforcement action.
They were classified as severity level 11 3.
12 Our inspectors went out there, I believe it was 13 May and June time frame.
And I think it was four or five of
(}
14 the, four of the five or five of the six shift supervisors 15 or shift superintendents, who were responsible for making 16 emergency classifications.
17 Our inspectors found that they were unable to 18 make the necessary classifications given certain scenarios 19 or fast-breaking accidents.
That is, they were unable to 20 classify something either as an unusual event or a site 21 emergency, et cetera.
22 The second issue --
23 MR. KERR:
Excuse me.
I realize that news 24 releases are not written by you people.
But the language 25 used in the news release dated August 15 says the inspectors Heritage Reporting Corporation
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' found that the shift superintendents were unable to-
- 2 effectively uselthel classification ~sch'eme.
3 What does that mean,-to effectively use it?
- 4-
,Does it mean for example that he.couldn't do it
.5
- from memory, because'it was a fast-moving system?. Or given 6
the' written procedures he couldn't classify it?
Or none of.
7 the above?
8 MR. HOLODY:
I think in this case.it was the, 9
they were presented with certain scenarios and given those i
L 10 scenarios they weren't able to utilize the. procedures.to 1
11 determine what' the appropriate classification of that
-12 scenario was,.either as an' unusual event or et cetera.-
13 HR..KERR:
What did.the fast breaking scenario 14 have to do with it?
~
15
}Gl. RUSSELL:
That's because :that's' an event that-16 Lis classified, essentially when you're on shift, when you
~
17 don't'have the tech support center and'the others providing
.18 a backup.
The shift superintendent is the emergency 19 director in the early portion of an event before you go to 20 an expanded activation.
So most utilities for example, you 21 would. expect the shift supervisor to be able to classify an-22 alert at which point they would staff and other people would 23 come in and assist.
24 But if it is a rapidly moving event which should 25 be classified in a higher level, nite area or general Heritage Reporting Corporation
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emergency, and he is' unable to take the symptoms from.the f
2 scenario that is being played out-on the simulator,'and
'3 properly classify that within the time frames provided,zthen 4'
that is the failure that we are talking about.
L
-5 MR. COLLINS:
That subrequent classification will
[
6 provide for the appropriate off-site qualifications.
It's L
7
.the trigger that provides the correct emergency response 8
early enough in the scenario so that protective actions can 9
be taken in a timely manner.
That is the significance of 10 the function.
11 MR.' RUSSELL:
And if he is unable to properly 12 call an alert early, the rest of the organization doesn't 13 respond, the NRC doesn't respond.
In fact, we have had some (f
14 drills with utilities where the utilities have failed to l'
15 notify the NRC and we've had site teams sitting in motel l
16-rooms waiting for them to call alert, and they didn't call 17 the alert.
H 18 So our process really breaks down if the people 19 on shift are not able to assess what is going on in a plant e
L 20 and give it the appropriate civ. ossification, because that is 21 what triggers the rest of the emergency response.
l l~
22 MR. CARROLL:
Okny.
Given all the problems PECO 23 has been through at Peach Bottom, and the glorring 24 presentation Limerick gave ACRS, how in the heck did this 25 fall through the cracke?
This seems almost unbelievable to l
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HR. RUSSELL:
Well, this issue I reviewed withL 3
the Commission, at the Commission briefing on Limerick 2 4
full, power licensing.
It clearly.was a deficiency in 5
training as it' relates to the operating' crews and they went 6
and'did remedial training and we went back in and re--
'7 examined a month, two months later.
8 That problem had previously been' identified and-9 corrected'at Peach Bottom as a part of their activities down.
10 there, but that.information had not passed to Limerick.
11
~In addition, the corporate issues that were
'12 identified, they had had quality assurance audits of'their 13 programs; they deficiencies were known; they had not taken
- (k 14 effective corrective action to correct those deficiencies as 15 it related to Limerick.
16 We felt that was a corporate breakdown.
It was l
17 almost the Peach Bottom scenario in reverse where previously 18 Limerick was performing well and Peach Bottom wasn't and 19'
.there wasn't effective corporate oversight.
They have done 20 some things in the corporate oversight area, including 21' bringing-a.new manager in and proposing some longer term 22 corrective actions which we've been reviewing.
l 23 But there were breakdowns in that area and the l'
24 messages and the lessons learned from Peach Bottom were not 25
.being passed up to Limerick as it relates to emergency Heritage Reporting Corporation (202) 628-4888 l
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2 MR. CARROLL:
I guess the other kind of. troubling
~
3
. thing is then a SALP 1' plant, emergency planning, presumably 4-that means they have had good drills or good exercises.
And'
-5
~ to me a good exercise would have-smoked this kind of a 6
problem out.
7 MR. RUSSELL:
Not necessarily.
A good exercise 8
is a scenario which is intended to drive to off-site 9
releases, to exercise the off-site response and it is not 10 necessarily the' fast breaking exercise which would be over 11 very quickly.
12 MR. COLLINS:
In a typical exercise they would 13 have had the TSC and the other support necessary to help the 14 individual make these types of determinations.
In a fast
{;
15 breaking scenario you don't have that.
16 MR. RUSSELL:
In fact, a staged exercise is one 17 in which you go from an unusual event to alert fairly 18, quickly but then you spend time at the alert so that the 19 tech support center gets staffed and they can communicate 20 with the state, then you go to the site area emergency and 21 you've got literally a few hours between each stage.
22 MR. COLLINS:
I think the issue is their 23 correcting the previous problem is of not insignificant 24 concern to us, the fact that they knew of the issue but they 25 did not have the process to provide for it to be fixed until l
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1 we went back to test it again.
'~
2 MR. RUSSELL:
Which is of course why we gave them 3_
the civil penalty in the escalator.
We escalated it to a 4
civil penalty level.
5 MR. CARROLL:
Now, in our September full 6
committee meeting when I ask Region 1 have they checked that 7
the Public Service of New Hampshire has their act together 8
in this area, I'm going to get a strong affirmative answer?
9 MR. RUSSELL:
I won't project.
We have not had 10 the meeting with the company yet.
At this point, we have 11 the company's report, we have the staff's report.
We have 12 not had the enforcement conference.
That's scheduled for 13 the 7th of September.
14 MR. REMICK:
If that meeting gets delayed to
(
15 October, the answer will probably be yes.
16 MR. CARROLL:
I was speaking of this issue, not 17 the other public servi:e issue.
18 MR. RUSSELL:
That issue was discussed at length 19 during the onsite exercise and in fact that was a motion to 20 reopen before the lower r;ver licensing board on their 21 onsite capabilities as it relates to managing an event, and 22 we provided additional filings before that board and the 23 record was not reopened.
24 We are generally satisfied there is presently a 25 request for a schedule or exemption to not conduct another Heritage Reporting Corporation
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exercise which'we've not acted on yet.
2 MR.' CARROLL:. Seriously, though, have you looked 3) at other plants in the region to see that --
'4 MR. RUSSELL:
That's.how we picked this up.
We
.5 are looking at plants, we look at it as part of our EOP 6
reviews and also a part of the inspection program,'which is 7
how we.found it.
Through a routine inspection 8
MR. COLLINS:
Through a routine inspection.
9 MR. CARROLL:
And have you found a similar 10 problem elsewhere?
11 MR. COLLINS:
In some cases we have.
Not perhaps 12 to this extent.
We went back specifically to look at-this 13 because we knew it was previously a problem.
When we have a
()
14 tendency-to out with these inspections we go back and 15 recapture outstanding items if you will to be sure that the 16 corrective action has been implemented.
So this particular 171 inspection is a little more focused than most.
18 But we do sit down with the operators routinely 19 and go through the scenarios and have them classify.
20 MR. RUSSELL:
In fact, that role of emergency 21 director is a role that is routinely looked at as a part of 22 requalification examinations.
We look at it in the EOF 23-inspections.
And so that ability to function when you've 24 got a simulator driving a scenario is looked at routinely by 25 the staff.
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1 MR. CARROLL:
In my experience, shift supervisors 2
take that responsibility very seriously.
I mean they know 3
they have that hanging over their heads.
4 MR. COLLINS:
In many cases, though, it is a 5
function of what information, what tools are provided.for 6
them to make their decision.
In this case it is not a 7-
. reflection on the capability of the operators as it is as 8
much as the tecla that are provided to them to make their 9
classifications under conditions that we provide.
Then they 10 have to fit that information into the mechanisms.
Its the
'i 11 process that broke down in this case and not the 12 individuals.
l 13 MR. KERR:
One other comment.
Again, the news eg
=
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NRC found that a basis existed for increasing the 15 fine by 100 percent because the violations were ident!fied 16 by the NRC.
j 17 It's hard for me to see how else they could have 18 been identified if the inspector was there watching the 19 process.
20 I didn't understand the implications of that 21 language and I realize it's not your language.
j 22 MR. HOLODY:
The reason for that was the policy l
23 was changed and I guess our next subject is revisions to the 24 policy.
j i
25 And it was changed in October of 1988.
One of
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2 escalating and mitigating factors that we' re tasked-with R
3 looking at,.whatever we decide on the amount of the fine.
'4 One of the mitigation factors is called 5
. identification'in reporting.
And in the past, if the 6
. licensee identified and corrected a problem, we could n
l7 provide partial mitigation'for that.
8 If we identified it, then'it was just a watch.
9 There would be no' adjustment to the fine.
10 When'the policy was adjusted, I mean'was' changed,-
11
'in October of last year, the NRC,'the Commission approved 12 escalation'of the' civil penalty amount by 50 percent 13 whenever NRC identified the problem, and the staff believes j
)
14 that the licensee should have reasonably identified-that 15 problem before the staff had.
16 MR. KERR:
This was something that was observed 17 during an exercise.
18 How could you, were the shift supervisors unaware 19 of the fcct that they couldn't identify these?
20 MR. MARTIN:
You have to remember, the same 21 corporation that had identified the problem at Peach Bottom, 22 here it was, they were on previous notice that they had a 23 corporate problem.
Wait a minute.
This talks about 25 violations.
The violations were identified by the NRC.
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- 1 implication-is that-theLpeople who were involved in'the 2
exercise were unaware of what was going in).
3 MR. MARTIN:
It should not be our test that-4-
identifies that deficiency.
5 MR. RUSSELL:
As it relates to escalation and 6
-mitigation factors, we.can fully' mitigate'even under 7'
-instances where NRC identifies the problem.- Our packaging,.
8 where we discuss escalation and mitigation factors, while we 9
have that capability, then we could mitigate even when NRC 10.
identifies a problem.
We did not fully mitigate in this 11 case and I think there.-is some language there that is not as 12 precise.
13 We have that capability,'but we did not, even.in
)-
14
. consideration of the prior good history and SALP scores at
~15-the facility.
w-escalated.
It was 16 And in fact, as I recall, 17 two, what was tlus finding on this?
18 MR. HOLODY:
S75,000.
19 MR. RUSSELL:
We escalated the fine 50 percent 20 because they had prior opportunity and prior notice and 21 should have identified it themselves and fixed it.
22.
MR. HOLODY:
One of the other issues was, one of 23 the other violations was their failure to take corrective 2s action for their own internally identified QA deficiency.
25 Their QA department head identified some deficiencies, other Heritage Reporting Corporation (202) 628-4888 i
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1 deficiencies in the EP program.
2 MR. KERR:
Any idea of why they didn't?
3 MR. HOLODY:
I think the indication at the 4
enforcement conference was that they had not given 5
sufficient corporate management attention to that aspect of 6-
.the program.
And that was one of the issues that we focused 7
on in that action.
8 MR. KERR:
But that is sort of a motherhood 9
statement it seems to me, that you have not given sufficient 10 corporate attention.
That covers anything.
11 To me, that would not be a very satisfactory 12 response in terms of I'm pretty sure it won't happen again.
13 MR. RUSSELL:
You have to combine that with the e-14 fact they changed the management out at corporate that was k j) 15 responsible for that area in addition.
So one could l
16 characterize that there was not a sufficient sensitivity on l-17 the part of the previous manager, that there was not a 18 responsiveness to QA identified deficiencies and that this 19 went on for some time and they now have a new manager 20 managing that program.
l l-21 MR. CARROLL:
Put the QA guy on the job, right?
22 MR. COLLINS:
There was a lack of accountability 23 for who is in charge of taking the specific findings, 24 whether they be PECO-identified or NRC-identified, in 1
1 25 ensuring that corrective action is done and tested.
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There was a transition problem, resulting in 2
organizational changes.
They had provided for that at the 3
2each Bottom-site by direct corporate onsite' linkage to thei 4
oversight.of that program.-
It had not been done at l.
5 Limerick.
6 So when you posed who was accountable to be sure 7
these things should have been fixed, that was where the gap 8
was.
.9 MR, RUSSELL:
Moving right along, Dan.
10 MR. HOLODY:
Okay.
The two other areas.
One is 11 the latest revisions to the policy which I talked about a 12 lit'-le bit.
13 I think the primary changes made in October of
() -
14 1988 was to provide greater incentives both positive and 15 negative to encourage the licensee to be aggressive in.
16 identifying and correcting problems when they exist.
17 Next slide, please.
18 Essentially, there were three, four ways that 19 that was done, that encouragement.
20 The first slide covers the first two.
And they 21 essentially provide the first one there when the licensee 22 identifies and corrects the problem.
Even if may have had a 23 poor history, if he now is on the right track and you go 24 through the escalation and mitigation factors and you still 25 go after the civil penalty, the staff has the authority, f -
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.with'the concurrence of the Deputy Executive DirectorTfor-2, Nuclear' Materials, et cetera, to mitigate that fine in.its 3
entirety; I
4' If_the licensee looks at a program, reconstitutes 5-the design basis, looks at a particular area like fire 6
protection on their own, and identifies a number of issues, 7
even.though the mitigation and escalation factors might as 8
you analyze them, might still warrant the fine,_the staff, 9
to reward that good performance, would not issue a fine in i
10 such cases.
11 If we had issued a civil penalty for certain 12 actions and then' additional violations are filed after the 13 fact as the licensee is still looking at that aspect of the n
14 program, we would not issue a fine'in such cases.
t) 15 The second bullet there, if after considering the 16 escalation and mitigating factors or considering these three 17 examples proposed above, the staff feels that an enforcement 18 action or civil penalty is still not warranted even though 19 application of the policy would suggest a fine, we could 20 exercise discretion based on the merits of the case and not 21 go forward.
But we would have to provide prior notice to 22 the Commission in such cases.
23 For the less significant actions -- the next 24 slide -- where we identify severity level 5 violations.
I 25 think those are the kinds that Tim Collins referred to as Heritage Reporting Corporation
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Even though the NRC might' identify those problems, we 1-nits.
2 now have the authority here.in the region not to' issue a 3
notice of violation for such cases, provided they are 4'
isolated and corrected by the licensee prior to'the 5
conclusion of the inspection.
6 And oftentimes those are issues like record 7
citations where a record may not have been completed in 8
total'or may not have been performed, those kinds of issues.
9 And the fourth bullet there is where the staff 10 has been given the authority to escalate fines in those 11 situations which are indicative of the licensee not being 12 aggressive in seeking out problems.
13 And one of them is the one we talked about
'( }
14 already.
The NRC identifies the violation and.we feel the 15 licensee should have reasonably identified them sooner.
If 16 they don't provide adequate response to an indication, if an 17 information notice by the staff had told the utilities about 18 a particular problem, they weren't aggressive in seeing if 19 they had that problem at that site, we went in there and we 20 found it, we could escalate higher based on those factors.
21 And there's a couple others indicated.
22 Those instances of enforcement discretion just 23 added to instances that already existed in the enforcement 24 policy, for example, severity level 4 violations, and those L
25 that were identified by a licensee.
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We have over several years not cited licensees 2
for those types of violations when they identify them if IE 3
they corrected them comprehensively, if they reported them 4
when reportable, if they were not wilful violations, and it 5
was not a type of violation that should have been corrected 6
based on some action taken in response to a previous 7
concern.
8 For p4Rnts in extended shutdowns, we have 9
refrained from issuing escalated actions, civil penalties 10 and orders, in accordance with the policy when the licensee 11 is implementing an aggressive program for identifying their 12 problems that are the cause of the shutdown and fixing those 13 problems.
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14 And again they're not wilful, they are concerns 15 that existed prior to the shutdown that led to the shutdown.
16 Those types of things.
17 We have one other area that is not in the policy 18 and that is an enforcement guidance memorandum that we have 19 received from Headquarters.
20 And that is an issue where we grant temporary 21 relief from tech spec LCO conditions when we feel that it is 22 for a short period and it would not have any safety 23 reduction from granting that relief.
24 They're generally for very short periods, couple 25 days, and they are used in situations where the licensee
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3 could create an unnecessary transient-on a' facility, or 41
.there is no safety' reduction by allowing'this.startup to 5
commence.
6 Problems seen in implementing the revised policy.
7 It'has been a year.
There has been no apparent problems 8
observed in implementing them.
9 I do point out though that there has been no 10:
significant decrease in the number of escalated actions 11 since that time.
There may have been a slight decrease in 12.
~the number of reactor civil penalties this year if you do 13 not. include the equipment.and qualification finds but there 14.
has been a significant' increase in the number of actions
{
-15 taken against materials licensees.
16 3md finally, any' suggested' changes to the policy..
17 The policy has changed a number of times'since 18 1980.
It has changed in 1980, 1982, 1984, 1987 and 1988.
19 I think it received constant evaluation by the 20 Office of Enforcement as well sa the regions.
Many of these 21 issues, putting in items that would encourage identification 22 and correction of problems by licensees, rather than the
' ;2 3 -
NRC, have been added during these periodic changes.
24 And the staff is always looking for ways to 25 encourage that.
Since we are only a small organization, we i
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sample theirLprograms.
They should be looking at their-2 programs in detail.
And we want to encourage that to the
'3 maximum extent possible.
4 LAreas where we may consider some changes, I'll 5
take the second one-first because that has been, the 6:
Commission has approved that policy.
And that.is the' 7
authority to issue orders directly to individuals.
8 We can issue orders now to licensees -- and that L
9-would be like a power reactor licensee, a hospital, a 10' radiographer -- as well as the licensed operator.
11-We cannot it sue orders directly to an unlicensed 12 individual.
13
.And the purpose of this would be-to understand 14 the whereabouts of the individual and to understand or to 15 become aware of whenever this individual intends to seek 16 another job in the nuclear. field, that would be subject to 17 our regulations.
18 Currently,.if we had an individual that engaged 19 in wrongdoing at a facility and we wanted to remove that 20 individual, we would issue the order directly to the 21 licensee, like the radiographer, and it would say this 22 individual is precluded from doing any radiography or 23 supervising any radiography at your facility because of his 24 past falsification of records or false statements to the 25 NRC, whatever the situation might be.
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That does not preclude that individual then from 2
gong and applying for a job at another radiographer's 3
facility.
4 The same with the technician at a hospital who 5
may have falsified some records, or an unlicensed person at 6'
a utility.
7 There is a good chance background checks and 8
screening at the utilities may identify that, but it may 9
not.
10 So the purpose of this would be to issue orders 11 directly against those individuals.
12 They would be case specific orders, but they 13 could say things as:
tell the NRC prior to seeking
().
14 employment in a nuclear field; tell your employer; inform 15 the employer of this order and the basis for this order.
16 Those kinds of things.
17 That policy has been approved by the Commission, 18 and the staff is currently, the Headquarters staff is 19 currently preparing appropriate rule changes as well as 20 proposed changes to the enforcement policy.
21 And the second issue that the staff is giving 22 consideration to is the issuing civil penalties and orders 23 against vendors.
24 We have the authority now to issue enforcement 25 actions to vendors.
I think it is against the responsible
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.1' Individuals, the directors or responsible officers of=a I
2 vendor, if.they were' engaged in wilful: failures to.make a
.l h"
3.
.Part'21 report.
- 4' But if you'have a' vendor that through negligenceL 5
supplies defective components'or parts, bolts, whatever, to-6
'several members of the industry, while we hold the
.7 individual licensees responsible-for the acts of their 8
contractors,.whether it is a security guard force or a 9-vendor or an HB contractor, it may be more appropriate in 10 those cases to take action directly against the vendors.
11 That's all.
12 MR. CARROLL:
Vendor in this context is a vendor 13 orsite?
( I-
~
14 MR. HOLODY:
No.
No, not contractors, but 15' vendors, people who are supplying. parts or services.
16 Westinghouse, General Electric, B&W.
Reactor vendors, or it 17 could be material vendors, pump _ vendors.
18 For example, many of our licensees utilize-19 contractor guard forces.
My_ guess is probably half in j
20 Region 1.
21-MR. CARROLL:
That's an onsite~ contractor.
I was
'22 trying to get the distinction.
I understand.
23 MR. REMICK:
Any other questions?
24 (No response) 25 MR. REMICK:
If not, according to the agenda, it
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must be 10:30.
We are supposed to take a 15-minute break.
I 2
So let's return at 25 past 11.
3 (Whereupon, a brief recess was taken.)
4 DR. REMICK:
All right, we will continue with our 5
agenda.
Next we take up the area of reactor operations.
6 MR. GALLO:
My name is Robert Gallo, I'm Chief of 7
the Operations Branch in the Division of Reactor Safety.
8 I would like to be able to move around.
9 DR. KERR:
You're probably going to have trouble 10 with that as long as you're standing in front of the speaker 11 because that's where you're getting some feedback.
12 MR. GALLO:
What I would like to talk about first 13 is the maintenance program, maintenance inspections that
/~()
14 have been conducted in Regic.a 1 and I have provided the 15 handouts.
Norm Blumberg is going to talk about one of the 16 sections that we've got here toda'.
17 What is provided us here in the front is i
18 maintenance programs supplied through -- with the inspection 19 reports that have been completed and are issued in the 20 public document room and we will make those available for 21 your review later on any time you would like to peruse them.
22 If you put up the first slide, please.
23 (Slides being shown.)
24 MR. GALLO:
The first question that we put on the 25 agenda was comment on the proposed policy statement.
We've
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been trying to put our camel's nose inside the tent to focus l
2 right on the policy statement which is coming out of 3
research.
We have to write some comments to NRR formally, 1
4 and we provided the comments informally to research, and i
5 expect to provide more in the future.
1 6
What we would like to see in the proposed policy 7
statement is special emphasis on certain areas where we 8
believe that it is most productive in the long range for 9
maintenance program improvement.
10 Well, it says, reliability centered maintenance 11 and what we believe would be part of the reliability 12 centered maintenance program as opposed to a corrective 13 maintenance program, corrective centered maintenance
(( )
14 program. LThat it should play emphasis on preventive and 15 predictive programs; engineering support; root cause 16 analysis; trending activities; and the application of risk 17 significant concepts.
18 In the original tree and maybe on the tree you 19 have -- each member sh;uld have a copy of the tree.
I 20 believe it's block 4.3 it says:
" Inspect the role of PRA 21 the maintenance process."
That's recently been changed to:
22
" Inspect the role of risk significance or acknowledgement of 23 risk significance," because some facilities do not have a 24 probablistic risk assessment and they should not be 25 penalized for not having a PRA at this time.
(~
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'1.
So.they're the things that we would like to see:
2 in the policy statement.:
-3=
The.second slide addresses a couple other id 4) additional areas'that are important, maybe not quite as. hight
'51. priority'and only be addressed by the NRC either in' policy l
.6 statement or reg guide activities.
7 One is contractor training and the reason we are 8
' mentioning-that here today'is because contractor training-L..
H 9
seems to be not. governed by the' accredited training programs di 10 at most facilities.
There are words in our draft-reg guide-11 that talk about training of contractors, but from our 12 experience it appears that'those folks get training from 13:
other than-the accredited training programs.
And that
()
14 interface needs to be at leas; addressed.
15 The second item which we think needs more -- and.
16 I.think this is covered in the advanced notice of proposed 17 rulemaking is -- dedication of commercial grade parts, that.
L l
'we are coming up with'some concerns in that area through the-18-19-vendor branch inspections that are being done and also 20 through the maintenance team inspections that are being 21 done.
It seems to be more and more that facilities are 22 going to commercial grade outfits to supply parts which end 23 up in safety related uses.
So the dedication becomes a much p
24 more important aspect of the maintenance program.
25 DR.HKERR:
What does dedication mean?
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1 MR. GALLO:
Dedication is a process, as I 2
understand or we understand, is an EPRI industry guideline 3
which provides four different methods of taking a commercial 4
grade part which is not pulled through a QA program or 5
safety related type approved vendor and then dedicated by i
6 the facility for use in a safety related system.
7 DR. KERR:
So you sort of sprinkle holy water on 1
8 it?
I 9
MR. GALLO:
The first method is probably the 10 easiest, it requires either special tests or special l
11 inspections to determine the components usability in the 12 safety related system.
So it may require testing of 13 hardness of the simple -- what we have concerns I think
(~()
14 mostly is for, not simply parts like nuts and bolts, 15 although there has been falsified or fraudulent equipment in 16 that area, but more complicated parts like breakers that 17 become -- at some facilities becoming purchased by 18 commercial grade Bs.
If you have a bow ring or a bolt or 19 nut or something like that it's not too difficult to 20 dedicate it.
But the more complicated parts require a 21 special --
22 MR. RUSSELL:
Bob, why don't you turn that thing 23 off, it's apparently not working.
Just talk loud so that 24 the reporter can hear you.
25 MR. GALLO:
There have been quite a few questions
('
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1 raised in that area.
The NRC I think in generic letter 2
E-902 is talking about fraudulent material providing a 3
limited or partial endorsement of the EPRI document which 4
contains the methods for dedication of commercial grade 5
parts.
That is still an area that I think the NRC has, as I 6
mentioned, there is a notice of proposed rulemaking in that 7
area, so there is still a lot of work to be done in that 8
area.
And it does come up in the maintenance activities.
9 One other area we have on here is the need to 10 consider current regulatory guidance.
There's a reg guide 11 1.33 and ANS 3.2 which addresses in general the maintenance 12 programs and specifically we've pointed out that there is 13 expectations on QA/QC overview which are not clear in the
()
14 policy stncement as opposed to the ANS document.
The ANS 15 3.2 would allow peer inspection of maintenance activities 16 whereas the rule -- not the rule but the draft reg guide 17 does not clearly address how far we expect QC to go.
It 18 doesn't seem to talk about the peer review, the ANS 3.2 19 document talks about.
There's a couple parallel paths there 20 that need to be clarified before there is a final reg guide 21 rule, if there is a rule.
22 MR. CARROLL:
3.2 allows either approach?
23 MR. GALLO:
Yes, sir.
As we understand it, it 24 allows traditional QC independent inspector activities or it 25 allows peer inspection or even it could -- the first or f~)
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second linefaupervisor inspection in lieu of QC activity.
2 The regulatory guide on maintenance programs is
-3 needed to define terminology in the policy statement.
4 There's quite a few terms in the policy statement which are 5
explained in much' detail'in the reg guide.
And it's a 6
little bit. difficult ' to use the policy statement without-7 that reg guide and being able to understand all that -- what 8
we' re talking about when we talk about preventive 9
maintenance, protective maintenance and maintenance 10 surveillance activities.
They're the principal things that 11 I'm thinking of anyway.
12 DR. REMICK:
Before you leave that, do you feel 13 that there is a need for a rule from the perspective of
' j ])
14 Region 1.versus the policy statement?
15-MR. GALLO:
We've been asked that by a lot of
.16 different people.
As a matter of fact, Commissioner Curtis 17 went to.3 and I spent some time up there with Commissioner l
18 Curtis while we were doing the maintenance inspection and my 19 conclusion was, yes, we -- I think we would like to see a L
20 rule, if nothing else, to move the -- make the NRC the 21 leader in the maintenance area and moving the industry in l
22 the direction that we want to see it move.
And I don't know 23 that we need it for an enforcement tool.
But I think we 24 need it as far as leadership guide, and perhaps a reg guide 25 could do that same purpose.
But I think a rule would be, in E
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the l'ong run, provide the NRC's leadership role in the1 4
2-maintenance area.
3 DR. REMICK:
How could NRC be a leader?
What' 4
would it do to be a leader in maintenance?
5 MR. GALLO:
Provide the basic constituents of 6
what the maintenance programs are expected to be and what we 7
really see the' industry doing rather than reacting to the 8
industry's proposal solely.
I would like-to.see some sort 9
of direction.from the NRC in performing the rule.
10 DR. KERR:
Would you like to see the NRC managing 11 the plants?
12 MR. GALLO:
No, sir.
13 DR. KERR:
That would really give you a
()
14 leadership role.
15.
MR. GALLO:
I think we have done this in the past 16 in the quality assurance area in 1971 '72 we issued Appendix a
17 B for quality assurance programs and those rules.-.that 18
,part of the rule provide that direction'to the industry is' 19-what an acceptable quality assurance program is.
That's the 20 direction I'm thinking.
'21 DR. KERR:
How do you decide when a maintenance 22 program is effective?
23 MR. GALLO:
We can get into that a little bit l
l24 more with the results of the tree.
I think some of the 25 interesting areas or some of the interesting results that l
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l' come-out of the maintenance team inspections indicate 2
particular areas of overall plant performance and program or 3
looking at 3t in the maintenance inspection as overall plant 4
performance which is reliability of facility; overall 5
appearance; and reliability of the facility; management 6
programs; and then finally management implementation of 7
those or worker implementation of programs.
Looking at it 8
in three different levels.
9 DR. KERR:
How do you measure plant performance?
10 MR. GALLO:
Some of the indicators of plant 11 performance are capacity factor.
And some of the other 12 things that we're looking at are radiation enclosure as an 13 overall.
Some of the indicators already exist that INPO 14 uses.
15 DR. KERR:
Okay.
What --
16 MR. GALLO:
Large picture items.
We' re also 17 looking at the inspection team that goes out on maintenance 18 team inspection in looking at the overall plant appearance I 19 guess or the availability of equipment.
And the plants that 20 we have been to where that's, I think, the first block on 21 the tree on the left should be in section 1 where we're 22 looking at the overall --
23 DR. KERR:
Is there some level of availability 24 that would satisfy you as plants having an appropriate 25 maintenance program?
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MR. GALLO:
No, I think that's a subjective part 2
of the judgment that's made, whether it's -- how the plants 3
consider whether it's good, satisfactory or poor.
4 DR. KERR:
If you're talking about availability 5
it can't be subjective, because you can measure 6
availability.
7 MR. GALLO:
Right.
I think one of the plants 8
that we've just been to -- the report is not issued so the 9
tree is not.on the board there -- does have a very -- I 10 think we'found the program to be quite well implemented and 11 functioning very well and the pit.st does have a very high 12 capacity factors.
So they do seem to generally go along 13 together.
14 DR. KERR:
One of the Paloverte plants, as I 15 remember, recently established a very high availability.
In 16 fact, they've had a good availability record and I believe 17 that Paloverte is under rather severe restrictions on the 18 part of the NRC at the present time.
19 So plant availabilities --
l 20 MR. GALLO:
It's one of the factors that's l
l 21 integrated into the final decision, really, from a 22 recommendation from a team.
23 DR. KERR:
My problem looking at maintenance as 24 an end in itself is maybe partly due to my background as an 25 educator.
See, educators and physicians both have the l
l Heritage Reporting Corporation
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1 weakness in that'nobody really looks at their products; they g
t 2
look at the process.
3 It seems to me that maintenance in itself is not 4
important.
What one wants is a product.
And I'm not sure 5
what a satisfactory product is.
I haven't seen anything 6
from the NRC yet 1r.: hhe policy statement or otherwise that 7
gives me an indication of what would be an acceptable level 8
of something which would indicate that the maintenance 9
program was adequate.
10 And it seems to me before one gets very far into 11 establishing a maintenance rule or even a maintenance policy 12 statement there needs to be some indication of how one 13 identifies a satisfactory maintenance program.
14 MR. GALLO:
I think the NRC's AEOD is trying to 15 develop a specific individual performance indicator which 16 will come --
l 17 DR. KERR:
I think they are, too, but I haven't 18 seen very much evidence of success up to now.
19 MR. GALLO:
I would agree with that.
l 20 MR. MARTIN:
I think we would agree with you that 21 it is a p:ucess the.t we have been looking at because we can 22 look at how comprehensive the program is described; how well 23 people are trained; how well they seem to implement the 24 program which is described.
And look at things like LERs 25 and things of that nature.
l l
(]
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'm.
1 But you're right, we have been looking at 2
process.
3 DR. KERR:
Those are presumably methods to get to 4
an objective; and th's objective, it seems to me, is very 5
ill-defined up to tpls point.
6 MR. MARTIN:
I don't know that it will fit in, 7
but ['(have belief it will.
The toch spec improvement branch 8
is Working on a reliability based tech spec which will have 9
to use some measure of reliability of equipment to adjust 1
10 the frequency of testing on a real-time basis.
11 There may well be an integration of good 12 maintenance programs, high reli'Jbility; and therefore, we 13 use testing.
(_)
14 DR. KERR:
And, for example, it seems to me that 15 good maintenance is not the only way that one can achieve 16 higher reliability; you can achieve higher reliability by 17 paying more for equipment.
So it seems to me maintenance is 18 one part of a total program, but one needs to define what it 19 is one is trying to achieve.
And I do not see that as even 20 very poorly defined up to this point.
Tris is not a 21 criticism of use.
22 MR. MARTIN:
- 7. think that's good insight.
l 23 MR. CARROLL:
Futting aside for the moment this 24 issue of leadership role, do you have sa opinion as to how 25 good the INFO guidelines that have been on the street for I'T Heritage Reporting Corporation
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some time are?
Do you think those represent a good 2
maintenance program or what criticism do you have of them?
3 MR. GALLO:
The INPO guidelines, I've never even 4
seen them.
I couldn't comment on them.
We've tried to 5
basically do our own inspection techniques with the 6
direction of NRR, but INPO guidelines we've not really got 7
involved in beyond maybe looking at the performance 8
indicators that are available right now.
9 Okay, put up the next slide and we'll talk l
10 about the --
11 MR. WYLIE:
Let me ask a question, p
j 12 MR. GALLO:
Yes, uir.
What was your opinion of thts prohro3ed 13 MR. WYLIE:
Y r
14 draft rule that was developed?
s-15 MR. GALLO:
Personally, I really had no 16 opportunity to comment on it.
17 MR. WYLIE; You didn't comment On that?
If MR. GALLO:
No, we were not asked to comment or!
19 it, 20 MR. WYLIE:
T;id you review it?
21 MR.. GALLO:
Only after the fact.
Only after it I
PJ wars issued to the public.
23 MR. WYLIE:
Did you have an opinion on it?
24
)R. GALLO:
I have an opinion now: I guess I 25 think now it's a little bit superficial and has more items Heritage Reporting Corporation
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to.think about rather than what a maintenance _ program ought
[p
'2 to be.
S
'3 The next area we have to comment about is i
(,j f
4 regional experience with licensee's. maintenance programs; 5
and this is just a quick slide to let you know where we have
/
6 been -- we've done maintenance team inspections.
T The last one on the list, Millstone 1, 2, and 3, 8
the report is not issued so'the tree is not on the board.
9~
But their programidid come out very well.
The colors on the 10 tree indicate: green means functioning well; red means 11 functioning poorly; and yellow is kind of an intermediate zl2 stage and they're kind of along a self-category 1, 2,
and 3.
13-The blue' colors on the charts mean that the area is not
()
14
, indicated or not -- either data was missing or we didn't 15 have time to inspect-the area.
The guidance from NRR has 16 been--- when we did the first'one in this region it was one 17 of the pilot inspection, it was Peach Bottom and we tried to 18' do everything on the tree and we found that that gave us 19 scaewhat of a more of superficial look at the maintenance L
20 program.
21 We tried to cut out some areas in advance of the 22 inspection and just color them blue and say we'll not bother 23 with them and try to do a little more in-depth inspection in 24 some of the other areas where past performance or SALPs or 25
-the resident inspector has indicated that there is probably O.
Heritage Reporting Corporation (202) 628-4888
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(_)
1 a problem or could be a problem.
We tried to delve into l
2 those areas a little more carefully.
3 DR. KERR:
Of that group did you find any of the 4
plants that had what you would consider to be a satisfactory 5
maintenance program?
6 MR. GALLO:
Yes, the next slide gives that 7
information.
And unfortunately, the colors are a little bit 8
too far away from where you are now.
But we found that 9
overall five of the eight were functioning well and 10 inadequate functioning was one.
Now, the other two were in 11 the middle in the yellow area.
So overall we should have 12-five green leaves on the top block on the tree.
Five are 13 functioning well in one inadequate --
p
(_)
14 MR. CARROLL:
Is that the same one?
15 MR. GALLO:
The inadequate functioning, yes.
The 16 one overall, one in the plant performance, and one in 17 management support is all the same plant, that's.Tndian i
18 Point-2.
And that report is out an;1 we' re staiting for 'a 19 respouse from the utility w that.
20 MR. WYLIM:
Whero did you put Nine Mile Point?
21 MR. G 7.L l O :
I have to go lock at the chart, j
22 FT. WYLIE:
The 2 ast SALP you've got thet2 at 3.
23 MR. GALLO:
Their program, I don't think, is very 24 bad at all really.
25 MR. MARTIN:
The Nine Mile team is green overall
(
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114 1-top.
It's a mixture of yellows over here and green is 2
strong on implementation, a little bit of weakness on some 3
of the programs.
4 MR. GALLO:
I think we did that last. fall, and-5 overall the program came out pretty good.
6 DR. KERR:
I would'say there were five plants in
'7 which plant performance and maintenance implementation were 8
functioning well, but management support was --
9 MR. GALLO:
Only 3.
10 DR. KERR:
So there were two presumably --
11 MR. GALLO: ' Fell down in that area of management 12 support.
13 DR. KERR:
Management should leave them alone p
. i 14 because they were doing great without management support.
15 MR. GALLO:
If you look at ths Indian-Point-2 16 tree.you notice that there are two red blocks on-the left 17 ulde which is'the ovezall plant performance and management an eupport are both red;.yst, the maintenance implementation is 19 yellow which mear.s it's sati-3 factory, not wonderful but 20
_ satisfactory.
L 1
l;
<.1 So th., problem really at Indian Point-2 seem to 1
b 22 be more in the management support area than in the worker
-23 level and the actual maintenance going on --
J
'24.
DR. KERR:
But there would be some indication --
25 MR. GALLO:
-- in spite of the program.
L Heritage Reporting Corporation (202) 628-4888 L
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1 DR. F21NR:
There would be some indication.that
'the maintenance program might be better off if management 2
p 3'
.left:it al'ne, maybe.
o l
4 MR. GALLO:
I think we'll have to. wait to hear L
5' from' Indian Point-2~specifically.
L 6
MR. WYLIE:
What assessments appears to these?.
7 MR. GALLO:
They should be on the first slide.
8 The first one was in July of ' 88, Peach Bottom; that was our 9
pilot in'our region.
And Millstone was just completed in 10
. July of '89.
We're doing about two of these a quarter-and 11 we should be f3mished by the end of calendar year 1990.
l 12 Back in November Maine Yankee and Nine Mile over-13 less calendar year.
14 MR. WYLIE:
I guess what was confusing me was the-
{
15 SALP report showed that maintenance at Nine' Mile has slipped 16 from a 2 to a 3 in the assesament period 3-8B to 2-89; yet, 17 you say it was a good progrr.m.
Et's sort of confusin'J..
18 MR. GALLO:
That waa one of the inpute of ths 19 SALP.
I'm not sure I attended the SALP Board meeting 20 itself, but I think overall the program was quite Good --
k 21 theit implementation for the SALP.
22 DR. KERR:
Walc a minute.
Their program was 23 good,' but the implementation was -- what does that mean?
24' MR. GALLO:
I'm sorry.
25 DR. KERR:
I don't understand how you can have a Heritage Reporting Corporation
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1 good program if the implementation --
2 MR. GALLO:
Poor iculementation?
3 DR. KERR:
-- if the Implementation is poor.
4 What does a good program mean?
5 MR. GALLO:
Well, some of the things we're 6
looking at in the programmatic or management support, really 7
I guess is what I should be saying, management cupport is 8
quite a few things in the engineering support area, quality 9
control activities, radiological control.
They've had a 10 problem recently in that area.
The defining of the 11 maintenance requirements, allocating resources for the 12 maintenance activities, document control, maintenance 13 decision process.
S 14 DR. KERR:
I'm just a little puzzled --
(J 15 MR. GALLO:
Some of the things are more paperwork 1G originated.
They' re probably management support --
l 17 DR. KERR:
I'm puzzled that one can think one has 18 good me.nagement if the program -- if the implementation is 19 not very good.
20 MR. GALLO:
Results -- implementation results l
21 seem to be quite weak compared to the program, which is the 22 opposite of what we found at Indian Point-2 where management 23 support seemed to be weak.
But the program -- or 24 activities, maintenance activities seemed to be going along 25 reasonably well.
Heritage Reporting Corporation f')
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1.f) 117-11-DR. KERR:
I'm hearing words that I don't 2
understand and I apologize.
o, 3
MR. GALLO:
Well, I'm not _ sure we understand them c'
4 Leither really.
5 DR. KERRi' But to me I don't.see how you can 6
' judge that the management of a maintenance program is good. ;
7 if the program is not good.
8
.MR.
GALLO:
Management support - -
9 DR. KERR:
I don't know what management --
10-MR. GALLO:
Management support and program are 11 both basically the same activity.
Implementation is-
.12 separate.
13 MR. MARTIN:
Bob, for my own clarification, are 14-you talking about the two diagonals of each one of the
_O.
35-block?
16-MR. GALLO:
No.
We#re tri.1 king about clock --
11
-we11, it's 2.
3, and 4 on the treu with arabic aumn als 2, 18-3, and 4 are all management support of mainterence/ and that 19 has most of the programmatic activities in it such as 20 defining the program, allocating the resources, providing i
21 support in radiological controls, engineering support, and 22 those areas.
23 So when those progre.ns are established and 24 identified that this is how we do business, and we have this 25 many people and we have these many engineers and we have all
-)
( 0 6 8 4 88
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this QC support, and yet'the implementation occasionally
2 falls down.
And that appears to be the case in Nine Mile.:
y l:
3 MR. CARROLL:
I thought:I understood what you 4
were saying until you got me to a bleck roman.IV,..I don't-
'l 5
see that.
i.
I T
6 MR. GALLO:
Arabic numeral 2, 3,
and 4.
7 MR. CARROLL:
Oh, arabic 2, 3,
and 4.
8 MR. GALLO:
Right.
They're under roman numeral 9
II on that.
10 MR. CARROLL:
All right.
That's management
'll support, it's all.that stuff.
12 MR. GALLO:
Right.
And there's quite a few 13-things in there, none of.which are implementation.
14 Implementation starts in block 5, 6,
7, and 8.
15-MR. CARROLL:
And 8; I got you.
16 MR. GAL'.,01 3 cme of them do overlap.
Sometimes 17 it's hard to -- sometimes you'll have a good engir.eering 18 suppert and yet root cause analysis is actually-done on a 19 particular items supposedly by the engineering staffy r
20 MR. CARROLL:
One other question in looking at
~ here those various plants are in performance today: do you-21 w
22 believe their performance has been improving in recent 23-years; and to what extent do you attribute that to INPO's 24 efforts 25 MR. GALLO:
I believe that the program results Heritage Reporting Corporation (202) 628-4888
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that we've seen or the inspection results that we've seen to
'?
date are quite a bit better than I expected personally in 3
general.
And I do believe that there have been quite a few 4-
' improvements.
I would give some of that credit'to the INPO 5
activit J es, but also 'just the fact that we' re doing these 6
inspections and I think most of the facilities have done the 7
INPO self-assessment even as a direct result of INPO 8
prodding them or the NRC prodding them, they've gone back
'9 and redone their self-assessment or done it for the first 10 time, because they know the NRC is coming.
So,-yes, there 11-have been quite a few improvement programs we've identified 12, at,the facilities.
L13 That was one of the down grades at Indian Point-2
()
14 is that'they had done a self-assessment and they identified 15 quite a few problems.that we identified but they hadn't 16 taken any corrective actions er effective corrective 17 actions.
18 DR. KERR:
And y0u're convinced tnat there are a 19 lot of facilities out there that absent INFO and NRC would 20 not have maintenance programs?
21 MR. GALLO:
Would not have maintenance programs 22 or not have shown significant improvements?
I think the 23 improvements are coming because of the attention they're 24 recaiving, certainly.
25 DR. KERR:
Well, if you have a good program you Heritage Reporting Corporation
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1 don't need improvement.
And I was just curious as to 2
whether you think there are any facilities that absent NRC 3
and INPO would have a good maintenance program?
4 MR. GALLO:
Probably.
Probably -- the last one 5
we looked at which the report is in issue, I think without 6
any NRC or INPO incentive that their program probably has 7
been good for several years -- many years.
8 MR. CARROLL:
Would you say that's fair of the 9
majority of the plante?
10 MR. GALLO:
No, I don't think so.
11 MR. CARROLL:
Just the one in the region?
12 MR. GALLO:
One of eight that I would vouch for.
13 MR. CARROLL:
That would have had a good 14 maintenance program in spite of things.
(g
\\-)
15 MR. GALLO:
Regardless of the NRC or INPO, 16 MR. WARD:
I guess you probably answered my 17 questien then, I was going to ack you about Millstone and 18 with the three differe:At units there, the maintenance 19 program they have is common to all, it permeates the whole 20
- thing, 21 MR. GALLO:
As far as the programmatic areas, 22 yes, it is.
And personnel are different from unit-to-unit, i
23 but programs are common with Millstone.
So we probably 24 expect to see similar results.
25 I would like to go to the next slide which is l
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types:of deficiencies observed during the maintenance. team 2
inspection.
We have.this-broken.down in much more detail in 3
the next' slide and to save time unless'there are question 14 we'll go over the -- have more general discussion.
5.
Inadequate or unclear maintenance' program.
6-descriptions, that's -- I can tell you wh t block numbers 7
they are if you are interested.
8 Lack of vendor manual control, no updates, no.
9 system for some vendor manuals.
10 Many plants do not.use a risk analysis for-11- ~ preventive maintenance orfwork'priorization.
The. plants 15L that do have probablietic risk assessment are not actively.
13' using them.
Millstone is an exception, it is very active in
'14 that: area.
15 Equipmant histories lacking or hard to use, which 16 goes along with trendit.g -- number five, trending or failure 17 anclysis systems, it seems to be generally quite a few weak l;
11 8 zystems.
19 Maintenance procedures hard to follow or too 20 general.
There's a lot of generalities in maintenance 21 procedures.
There's a few facilities that are undergoing
- 22 extensive maintenance procedure upgrades and they're going 23 to take probably a couple of years to complete these 24 activities, 25 DR. REMICK:
A question along that line: when you g
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1 look at new maintenance procedures that are being updated, 2
is anybody taking some of the excellent graphics that they 3
use sometimes in training these people and putting them in.
4 the procedures so that they have the same graphics or 5
sketches in the procedures manual that they were trained on; 6
do you see any evidence of that?
7 MR. GALLO:
Yes.
At least one case that I'm 8
familiar with, Indian Point-3 has done an upgrade which is 9
about 25 percent of their procedure and they did use some 10 graphics in other original type of procedures.
11 DR. REMICK:
Thank you.
12 MR. GALLO:
Number seven was little or no QC 13 involvement at some plants doing peer inspection or just the
/D
(_)
14 undefined level of QC involvement.
15 System engineers not involved in maintenance.
16 Some system engineers are -- they're assigned to most 17 plants.
he've been doing all our inspections during outage:
i 18 and it seems that system engineers get hern-ily involved in 19 the outage and not in the maintenance areat and they get a 20 tendency to be quite overloaded with the work schedules 21 during outages.
22 DR. KERR:
What is a systems engineer?
23 MR. GALLO:
A system engineer is -- as I 24 understand it -- an INPO concept that some particular 25 engineer is assigned to a particular facility's system or
(
Heritage Reporting Corporation (202) 628-4888
T 123-1 systems ~and he is. generally responsible for keeping track of 2-various' work activities on that system.
3 DR. KERR:
Thank.you.
4' MR.;GALLO: 'Some facilities don't have a^ systems 5
engineer concept.. At least one that has a -- instead'of a.
6 systems engineer they have a component engineer.-
They are a
'7 group.that's in charge of all pumps; another group is in
~
'8 charge of all breakers.
And' engineering is broken up in
.9
'that more-traditional electrical mechanical area.
But most 10 of them do have systems engineers now.
11 MR. CARROLL:
But you're not suggesting having 12-systems engineers as an NRC requirement?
13 MR. GALLO:
No, I don't think it's a requirement.
)
14 I think it's probably a good practice. area.
15' MR. MARTIN:
It's different.
I think you've sean 16 a characteristic of so ne of the good systems are ones that 17 have. experience system engineers.. Usually the best ones 18 have been STAS initially have operational knowledge and 19 they're used to --
l 20 MR. CARROLL:
You're preaching to the choir, I
(.
21-believe in system engineers.
l
.22 MR. MARTIN:
There's no requirement.
23 HR. CARROLL:
But the way this one is written, 24 number eight, makes it sound like you've got to have them 25 and I was just curious as to whether --
O Heritage Reporting Corporation (202) 628-4888 I
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MR. GALLO:
We're more concerned that when they 2
do have them they're not necessarily involved in maintenance 3
activities; they all get extra duties in modification areas 4
or other control activities.
5 1R. WARD:
What's the difference between a 6
requirement and a criticism for the absence of something?
7 MR GALLO:
Well, we've been asked about that in 8
the PRA area, particularly a lot -- not a lot but I think a 9
few facilities in other regions were getting red marks on 10 their maintenance trees because they didn't have FRAs.
And 11 it's clearly not a requirement of a PRA, so we were -- all 12 the regions were directed when a facility does not have a 13 PRA that you don't cover that block in red.
It's not a 14 requirement.
r~
15 But the general requirement is something that has 16 to be in the rule in order of tech specs.
So a system 17 engineer is not in any of those right now.
I'm not even 18 sure it will be in the direct rule.
19 MR. WARD:
But I guess what I'm driving at is, if 20 you have as something you inspect against and will check for 21
-- if it isn't a requirement I don't know what you call it, 22 a criterion or something -- that a system engineer will be 23 involved in the maintenance on the systems.
24 Just from the licensee's standpoint, that seems 25 to be awful close to a requirement.
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MR. GALLO:
I think what we were looking at is-e L'
2-what their assigned duties are.
And if their assigned 3
duties are a systems engineer, but he is specifically 4.
directed not to be involved in maintenance that would be one
[
5 finding,'but if he is expected to be involved in maintenance l-l 6
that's another finding but he's not carrying out the p,
7 expectations of the facility licensee to do what a system
,8
. engineer -- they think a system engineer ought to do.
9 If.we see nobody involved from an engineering l'0 aspect in trend analysis or root cause analysis or that sort 11 of thing, we question it as to whose responsibility is it.
12.
A lot of times the answer comes back it's the system-
- c 13 engineers responsibility.
241 I'm not trying to make it a: requirement.
I-think 15 we're looking more at the licensae's program in determining o-16 is the program reasonable and are they-implementing it as 17 stated.
18 MR. MARTIN:
Dave,-I think two comments are 19 appropriate: one, our inspectors are sound, they're simply-20 as compliance verifiers.
If there is observation, a 21 consistent observation that raises the question, why -- for 22 instance, I might -- and I'm guessing what the observation 23 was -- a licensee probably had established system engineers
. 2:4 and had given them a number of functions and there was this 25 gap between there and they were involved in surveillance Heritage Reporting Corporation
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tests, they were involved in monitoring the operations.
2 They may,even have written some of the startup test.
3.
But here these people that are really 4
knowledgeable of the system and not involved in maintenance 5
at all, it doesn't make sense -- and the question is asked 6
or. statement is made, a factual statement, they are not
'7 involved in maintenance.
8 There is an implication to a licensee consider 9
it; if it's not the right thing to do that's your choice.
10 But it doesn't seem' logical to us.
11 And if you look at our SALPs and you look at our 12 inspection force a large volume of the 1 ext in there is 13 observations.
And we do reach conclusions based upon those
()
14 observations which are not compliance conclusions.
'15 DR. KERR:
So although SALP is not a requirements L
16 and not part of the rules, you can have a negative impact on 17 a number of s
.ngs and the fact that the system engineer is 18 not involved in maintenance can have a negative impact on 19 SALP.
20 MR. MARTIN:
It can have a negative impact if the L
21 licensee hasn't filled the void.
If the maintenance people 22 are not being controlled by operations; they're not 5eing p
23 controlled by these people who supposedly have ownership..for 24 those systems, the systems engineers, and the licensee 25 hasn't established some other mechanism to do it, he may get O
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away with it for awhile'but ultimately it's. going to bite 2
him..
L 3
MR. WARD:
So this was really a -- I guess you 4
expect that a' function was missing, that there wasn't any --
5 MR. MARTIN:
That's my guess.
In the debriefings 6
I have heard on this one is where the maintenance people did 7-maintenance and there was no oversight by people who 8
supposedly had ownership for the system.
9 MR. CARROLL:
I can conceive of a situation where 10 I have an extremely competent maintenance organization ~that 11 feels they have ownership for the quality of the maintenance 12 that's done on the systems.
You don't need system engineers 13 or operations oversight or whatever.
14 MR. MARTIN:
Unfortunately, in the large complex 15 operations such unilateral action frequently gets people 16 into trouble.
17 I'll give you an example which really drove it 18 home to me.
A plant maintenance staff opened a service 19 water system and removed the back.
What they were.doing was 20 good maintenance practice.
Unfortunately, they also opened 21 a protected area barrier that now made a path from the 22 outside of the protected area into the protected area with 23 no controls on it.
They didn't tell security what they were 24 doing.-
The operations had turned the system over to them, 25 but they didn't realize what they were doing that actually
.i Heritage Reporting Corporation (202) 628-4888
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1 compromise the security barriers.
Now, these came outLof 2'
discussion and coordination.of maintenance activities at 3
'these' facilities; thel systems engineer.is one way to do it.
.4 MR.. WARD:. I think that's~a little different'than:
5 the point you were making.
- 6_
.MR.
CARROLL:
Yes.
7-MR. WARD:
I think it's obvious that operations 8-people have to be in control of the facility.
But I think 9
Jay was raising a somewhat different point.
10 MR. CARROLL:
Yes, I guess --
11-MR.100M):
I think what we're all sort of driving-1:2 -
at is.that the maintenance rule and even your approach to 13 inspection of maintenance activities seems to be forcing, 14 encouraging a certain style of management of maintenance.
O-15 And. I'm not sure you know or I' m not sure anyone knows
' 16 whether that really is the best style or whether it's 17 necessary for all plants to have' this style of maintenance 18 to achieve the product they want.
19 Maybe it's the only way you have of going about 20 it, but it's a little unsatisfying as Dr. Kerr keeps 21 pointing out.
22 What we're really interested in is the product.-
1 23 If there are several approaches -- a lot of ways to skin a l
24 cat'possibly.
And you seem to be forcing a particular cat k
25 skinning process.
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MR. HARTIN:
There's no doubt that one can have a 2
' simple black box control system with no feedback.
And if-3' you're awfully lucky and it's high quality, it will work.
4l It will do and produce the output that you wished to.
But 5
if there is a slight -- of that system to turn inside that 6
black box.and not feedback system, then you don't have the
'7 corrective action.
8 What we examine out there.without a rule to cite, 9
you didn't do this, you didn't do this, you didn't do this;-
10 our observation maintenance program is simply a set of 11 observations and where there are logical questions we ask
.12 the questions.
And that drives the licensee to look at 13 those and consider whether he's doing th( right thing or i
-14 not; that I think is appropriate.
But it's not requirements 15 and most of our licenseen are sufficiently mature to tell 16 NRC, yes, we see what you're saying but we don't think it's 17 necessary.
18 DR. KERR:
Mt. Martin, where you have something 19 impinging on the SALP reports and where you have SALP 20' reports having as much influence as they do on utility 21.
operation, the things that go in those SALP reports, even 22 though they're not regulations, have a lot of pressure-on 23 what a management does.
24 And the NRC, it seems to me -- maybe this is the L
- 25 only way to do it -- it seems to me the NRC through the SALP Heritage Reporting Corporation
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2 what I call management decisions.
3 I remember, for example, recently seeing a SAIP 4
report in which the criticism was made that management did 5
not take the proper disciplinary action against some person 6
in the operation.
I didn't know whether to laugh or cry.
7 I mean, when the NRC gets involved in that kind 8
of detail of management it seems to me it begins to approach 9
on managing a plan and I don't believe, number one, with all 10 due respect to the NRC staff who I thirk is quite good, I'do 11 not believe it's capable of managing plants.
And even if it 12 were I don't think that's the intent of the system.
The 13 intent of the system is to see that plants are Operated O
(_/
14 safely.
15 MR. MARTIN:
I don't disagree with what you say.
16 DR. KERR:
But the maintenance rule, for example, 17 it seems to me will have -- if it comes into existence and I 18 personally hope it does not -- will have inevitably a 19 straightjacket kind of effect.
It will tend to push all 20 maintenance programs so that at least on paper they look the 21 same.
Maybe that's good and maybe it's bad.
It is not 22 obvious to me that it's gcod because I don't think.-N have 23 defined the product.
And so until we have defined the 24 product we want, I don't see that we know exactly the way to 25 achieve it.
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It seems to me that we should be very careful 2
about what we're doing in an area which I must say, I think 3
is extremely important.
It is not that I don't think 4
maintenance is important.
I think it's extremely important.
5 But I'm not sure that there is only one right way to do it.
6 HR. MARTIN:
You're certainly not prescribing one 7
way.
And, in fact, I think if you look at the maintenance
'8 tree you will not even find in that the elements of a model 4
9 of the way to do things, but attributes of various systems 10 that provide the necessary descriptions of what maintenance 11 were done, training of individuals.
It doesn't go into the 12 description of what those are.
Providing the kind of 13 calibrated tools and necessary tools to do the job, f-)
necessary quality assurance and ultimately produce the 14 NJ 15 product.
16 These inspections are performance oriented.
The 17 program review is done back in the office well ahead of 18 time.
The coloring then of the blue areas here is nothing 19 to look at.
But one is deemed sufficiently well described 20 and there is no other indications to say that there is a 21 problem in this area; that's the reason they don't look at 22 those areas, where they have a number of LERs, where they 23 have a number of indications from the resident program that 24 there are problem areas, those are the areas that they 25 concentrate on.
And frequently, those are areas that turn Heritage Reporting Corporation
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out.to be red because they are procedure problems and we're
'2 trying to. understand them.
3 But then you again.get down in there and you 4'
finally. find that you' re below the requirement level, but 5
you're seeing some holes in their program implementation or 6
its description.
Those are articulated in the inspection 7
reports as observations such as system engineers are not 8
involved'in maintenance; that may be fine.
Tnere may be 9
some other people that are really involved in doing the job.
10 In that case I'm sorry that some of you make the 11 observation.
I hope that they made the observation because 12 they.saw a hole there which was logically not. filled by the 13
- licensee,
()
14 And the licensee by the way is. debriefed every 15 day during the inspection to.make sure that we're no'c going
-16 off on some tangent so that they can point out to.us, that's 17 true but it's covered by this over here znd then the team 18
>ks at that.
19 So I think that you will find that there is a lot.
20 of QC on the observations and more acceptance of the results 21' of the team because they really are trying to understand 22
. what is being done and what is not being done and why it's
- 23 not being done.
24 MR. GALLO:
Before we go on to the next area I 25 just want to -- there have been a few violations identified O
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part of maintenance inspection.
They've got some -- a 2
few photographs of problems that came up at one facility 3
with problems that were identified, that the same trend is 4
going to run with a seismic report which was not installed 5
in accordance with the drawing.
And the same area, some 6
heat tracers place on -- in the area last winter and stayed 7
there for several months and charred the cables and 8
transmitters.
We are 3ooking at the hardware, too.
And 9
this is an example of something that turned out to be a 10 notice of violation.
11 We would like to go on to section 3.
We do have 12 a couple slidos.
There were questions that have identified 13 5.hich plants had which problems and the EPRI reports here,
(].
14 if anybody is interested, we can look up the system engineer
'% J 15 problems.
I think there were three plants that system 16 engineer comments.
17 The next area we will talk about is licensee 18 efforts to enhance skill level / career progression of 19 mair/. nance personnel based on maintenance teams.
20 This is one of the block areas to look at i
21 training personnel and we have really not seen many major l
22 problems with training, this particular seismic installation 23 may have been a problem with training.
l 24 What we said here is the plant capacity and plant I
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I trained maintenance personnel and engineers.
2 The training programs that we've seen are more 3
formal.
Essentially all accredited in the region.
Use 4
improved facilities, mock-ups and spare equipment for hands-5 on training.
They' re geared for technical skill upgrades.
6 And they do include maintenance assist experience which --
7 MR. CARROLL:
What does that mean?
8 MR. GALLO:
What we're talking about there is 9
that some of the maintenance personnel are put on INPO 10 assessments at other facilities, so they do get to see that 11 the rest of the facilities are doing it.
12 Facilicy sponsored education creates 13 opportunities for advancement.
For progression change frou in
(_)
14 maintenance worker to technician level, the staff engineer.
15 It is possible at certain facilities, anyway, most 16 facilities have programs.
I'm fairly familiar with one that 17 GEU uses right now which allows just about anyone on the 18 staff to be applied for and possibly be selected and be sent 19 off to school with the company expense to go to college 20 education courses at the near facilities.
And that's not 21 just the licensed operators but the non-licensed people, all 22 sorts of technicians.
So there is a possibility for that.
23 The last thing we put down there was the NRC and 24 industry guidance, ANS 3.1, which is an endorsement of reg 25 guide e::pects the maintenance manager at least to be -- his
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So there 2
is still a level that somebody, to go from a maintenance 3
worker to a maintenance manager or plant manager has to, 4
right now anyway, to through that hurdle.
There are a lot 5
more facilities providing that educational opportunity.
6 DR. REMICK:
Do you happen to know that in Region 7
1 are most or are all of the maintenance managers 8
participants in the Tech Staff and Managers Training program 9
that installations would have?
10 MR. GALLO:
I'm not sure I can answer that 11 numerically.- But I'm just thil.? ting of a few of the 12 instances we have looked at where you have an active 4
13 training program, they are.
Dut I don't know that we --
r-14 DR. REMICK:
Okay.
(>}
15 MR. WARD:
Let me ask, Tim, do any of the 16 utilities in the region have maintenance training facili, ties 17 of the sort or even approaching the sort that we saw in 18 Japan, let's say, at the Consi Electric?
19 MR. MARTIN:
Dave, I haven't been at any of them, 20 so I can't speak of personal knowledge.
21 MR. BLUMBERG:
I don't know what you saw in 22 Japan, but one facility comes to mind, Millstone has an 23 excellent maintenance training facility and a tremendous 24 amount of laboratories and mock-ups and things like that.
25 So that pa: icular facility is good.
How it compares to Heritage Reporting Corporation
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someLother country, I don't know.
But we'll vouch that it's 2
the best I've seen anywhere, at least in Region 1.
3 MR.~ RUSSELL:
I guess I can comment on that 4
having been both' places and I think to most of the 5
facilities in. Region 1; and there are some that are quite 6
comparable, particularly as it relates to plant equipment 7-teing'used a part of a maintenance program.
8 Indian Point-3, for example, has recently 9
constructed a new training facility and has extensive mock-
^
10 ups.
Calvert Cliffs is the same way with their training
.11-facility.
12 Many of them are going to specific laboratories 13 that are intended to teach basic principles and be able to 14-
' troubleshoot and tent equipment where they're actuel.ly using Ef]
15-equipment from the plants.
16 So this is becoming more and more common.
In
.f l
y-17 some cases I believe that they are r.ot even or in fact l
18-better than what I've seen when I went to Japan.
So it 19 varies -- then a substantial upgrade within the last five 20 years, I have not seen the maintenance activities really 21'
-since '85 when I spent two weeks looking specifically at 22 maintenance in Japan.
There could be further improvements 23-in that area as well, but they're quite impressive.
24 MR. GALLO:
If you have other questions in that 25 area Norm will -- I'll ask Norm to address the last area, 4
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development.of. maintenance performance. indicators.
This is
.i
_2 an AEOD/S804B which you're probably familiar with, which is 3
the proposed indicator.
7
'4 HR. CARROLL:
This particular slide that's up or 5
was up there, this was because we asked you to comment on.it 6
or because you think it's important?
7 MR. RUSSELL:
No, it was specifically under B.
' agenda.
9 (Slides being shown.)
10 MR. BLUMBERG:.
I'm Norm Blumberg, I'm Chief of 11 the Operational Program Section and I work for Mr. Gallo.-
12' I was asked to comment on the development of 13 maintenance performance indicators.
I.might point out that
.O 14 as gare ef tae greerem. item e, if 1'm mot mistaken, later on 4
1 25 is going to talt about performance indicators in ge,neral, so d
16 we're a little bit ahead of the whole thing, 17 We had not been -- Reigion 1, to the best of my.
18 kr.owledge, I have not been involved, to my knowledge, or 19 Region 1 has not been involved in the development of-the L
20 performance indicators.
We have been -- AEOD has, the 21 contractors, AEOD has and we have over a period of time 22 received various reports.
I've gotten a couple of them 23 which have talked about the development of maintenance 24 performance indicators.
They were provided to us as 25 information.
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-Two older reports had a number of performance l
2 indicators under consideration.
The most recent one that I 3
have, this one is AEOD/S804B which was put-out in January, 4
only considers one performance indicator and that's the 5
change in the rate of reporting component failures per month 6
as reported on the NPRDS system.
7 In reading that report -- by the way, there is a 8
gentleman *from AEOD who next month is coming up to talk to 9-us about performance indicators, so I'm sure we'll get a 10 little more background than what we've had previously.
11 In looking at that I have a personal concern in 12 the use of the NPRDS to rate licensee performance, and I 13 have a note there that may affect data reliability.
And my n
(_)
14 reasoning for that, the reason for having people -- as I 15 understand it -- to report the system is to improve licensee 16 performance, get this information out here, have people look 17 at it, evaluate it and essentially improve things that are 18 happening at all plants based on problems that may be 19 happening at certain individual plants.
20 I would be reluct nt if that information 21 eventually goes into a system that's used to criticize 22 licensees.
It doesn't take long to get smart and possibly 23 be reluctant, number one, to report in the system or to 24 start looking at the kinds of things you're reporting, if 25 it's going to be used to beat you over the head with.
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1 So I think that if that's used to provide a 2
negative ~rather than a' positive use for the NPRDS, I
'3 Lpersonally.have'a. concern ebout that.
J 4
The other thing is, we should be careful about-5' using performance indicators, if we' re going to use; them,..
6 that the performance indicator.should be used to spot 7
adverse trends and not used to rank plants.
.I think that
~
8 we've always been concerned-about this ranking of plants, 9.
whether it be the SALP process or inspection process or, for 10 that matter, the performance indicator process.
We use
~11
'these raw numbers out here,.and plant A is better than plant 12 B because of some number of-failures or whatever we're 13-looking at.
And in my opinion, is not the right way to go.
(f
.14 It seems like AEOD for some reason has settled 15.
on, in this case, in this-report, a single indicator which 16 they feel is really the best indicator for looking at 17 maintenance performance.
And again, I'm not going to 18 mention that you can go to any signal indicator and do it.
19 Even when we do the SALP process and we write the plant, we 20 look at a lot of different things and come up with a 21 subjective reasoning based on the inspection process and 22 what a lot of different inspectors have looked at and come 23 to a conclusion, and I'm not sure a single indicator will do 24 that for you.
25 In the last part of this we have -- some of these Heritage Reporting Corporation
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1 havs.come up before in previous-AEOD reports as being-g, -
^2-maintenance indicators that could be used.
I'll rehash a l."
3 couple of them.
4 I'll say, combination of indicators should be 5
considered maintenance related to LERs, being one.
L 6-Equipment out of service being another.
And unplanned trips l
7-due to maintenance which we include testing, calibration and' 8
testing incidents would be things that you would ceasider.
f.
3 And those things that I thought of before, and those are l-10 L fimmer numbers and. easier in the kinds of things that are 11 going to have to be on'the-system, and those are things that 12 we need performance indicators, those are what we use.-
And 13 we would go with that.
()
14-And that's basically what I have to say on 15 performance indicators.
16 DR. KERR:
Well, suppose that you use some 17 combination of number 4, those are taings that one can. count 18 as numbers.
19 MR. BLUMBERG:
Yes.
20 DR. KERR:
What would be taken as a satisfactory 21 numbez/?
22 MR. BLUMBERG:
Well, I can't answer that 23 directly.
I think there's two things you need to look at.
24 You need to look at, number one, how this relates to what
.25 maybe the other plants are doing.
And number two, you have t
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to'look atz in'the SALP process, which is where we're going 2
.to use this information, I think you have to look at it 3-through what other inputs you're getting-through the 4-inspection process.
I don't have an answer for what is a 5
satisfactory number, and I don't know.
I thinkit's 6
something that you have to make a judgment on, based on 7
getting the data and comparing plant-to plant.
8 MR. CARROLL:
One of the more controversial-9.
things about the discussions I've heard on the maintenance 10 rule is bagging in at least some portion of balance of 11 plant.
Yes.
13 MR. CARROLL:
One other difficulty with item one,
()
14 the use of NPRDS is that it doesn't cover balance of plant 15 equipment.
'16 MR. GALLO:
In the AEOD report they 'o identify d
lL7 at least two systems on the main feedwater which are mostly 18 non-safety related and which are both in'the NPRDS.
So 19 their accounting data is in those two systems.
20-MR. CARROLL:
Okay.
I don't know where they're 21 getting it.
22 MR.-RUSSELL:
If we're through with this there's 23 one additional comment I would like to make'that relates to 24 how we conduct these inspections and the impact on licensees 25 of having a large inspection team come, particularly if it's Heritage Reporting Corporation (202) 628-4888
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1 during an outage which if.-you really want to see how well 2:
their maintenance organization is functioning they need to 3-have'something to do and_you do a lot during outages.
D
- 4
- If a system is going to breakdown it's going.to
'5 breakdown when it's under stress, when it has a lot of work 6
to accomplish otherwise.
7 I wanted to relay that we are sensitive to that, 8
and in some cases --- the specific example is Maine Yankee, 9
-we did' break up the inspection we conducted, I think it was 10 two weeks errly-on with fewer people involved in the 11 inspection early in the outage; and then we went back and-12 did one week supplemented with resident support toward the 13 end of the outage to look at the process of restoration of
)
14-systems and equipment following maintenance.
15 We need to be sensitive to those impacts, but at~
16 the same time.we've seen a tremendous value to a 17 comprehensive look, looking at the total program rather than 18 just pieces of the program and not focusing or directing a 19 licensee's activity to one area when you really don't 20 understand what the impacts are in other areas or what the 21 problems may be in other areas.
You end up substituting 22 your judgment.
23 Our ability to drive them is quite good.
There 24 is no doubt that we can get their attention.
And so a 25 comprehensive look in an area to really understand what is O_
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there, what's working well and what's not working allows 2
both utility and the NRC to reach agreements on what are the 3
priorities for what work ought to be done.
4 Bnt we do need to be sensitive to the resource 5
impacts of 1Lige teams coming in and the scheduling of those 6
teams.
And I think we're doing a better job in that area 7
and we do it as a part of our inspection planning 8
activities.
9 tm. GALLO:
I might also comment on one other 10 aspect.
A~ number of the licensees that had been informed 11 that we are scheduling the maintenance team inspection and 12 will initiate their own self-assessment using the tree to 13 come to a conclusion even before we arrive where their holes
()
14 are.
And self-assessment is probably more effective than 15 our actual inspection identifying their problems because 16 when we talk to them it's much easier, obviously.
17 But we have been presented on several entrances 18 that the results of their own self-assessment and they track 19 very well.
20 DR. REMICK:
Gentlemen, I'm told that lunch is 21 here so in a minute I think we should break and take a half 22 hour2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> for lunch rather than the scheduled hour since lunch is 23 coming in.
But before we break I wonder if you would look 24 at the agenda and see if there are any objections either 25 from members or from the region staff on dropping for the
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144 fgL) 1 moment in-situ valve testing and service water systems.
Is 2
there any specific request by members or staff?
3 MR. CARROLL:
I was only going to comment on 4
valve testing, but had forgotten until I rode in from the 5
airport, Philadelphia Gear Limit Torque is just down the 6
road from these guys and I don't understand why we still
. 7:
have these problems.
Why don't you go over there and 8
straighten them out.
9 DR. REMICK:
How about fire protection programs, 10 is that something that --
11 DR. KERR:
Mr. Chairman.
12 DR. REMICK:
Yes, sir.
13 DR. KERR:
Are you proposing to eliminate valve
(}
14 testing, service water systems, and fire protection?
15 DR. REMICK:
Yes, sir, since you're not objecting 16 we are.
17 DR. KERR:
I applaud.
18 DR. REMICK:
How about fire protection programs?
19 DR. KERR:
Are we making somebody here feel bad?
20 DR. REMICK:
That's why I'm asking for the 21 region -- do you have handouts?
22 MR. RUSSELL:
We have handouts, so we can provide 23 you and that way you can review the handouts and if you have 24 questions on them we can respond to them.
25 DR. REMICK:
I think that will help get us back l
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$ /D on'alreasonable schedule.-
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1 3 --
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- All;right.:,Let's break for a half-hour and'
-. 3 creturning'at'lio' clock.. QA progrars.s. then~.'I guess would be 4-.
next on'theilist-.
5-
.(Whereupons at712:32 p.m. the meeting was!
6
... recessed to reconvene at 1:00 p.m.)
'8 g.
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CERTIFICATE 2
3 This is to certify that the attached proceedings before the 4-United States Nuclear Regulatory Commission in the matter 5
of:
.Subor.mtittee on Regional Frograms, Region 1 Office 6
Name:
7 8
Docket Number:
9 Place: King of Prussia, PA 10 Date: ' August 29, 1989 11 were held as herein appears, and that this is the original 12 transcript thereof for the file of the United States Nuclear 13 Regulatory Commission taken stenographic'lly by me and, 14.
thereafter reduced to typewriting by me or under the.
15 direction of the court reporting company, anel that the 16 transcript is.a true and accurate. record of tne foregoing
'17 proceedings.
18
/s/n nN APH a
19 (Signature typed) :
Irwin L. Coffenbe 20 official Reporter 21 Heritage Reporting Corporation 22 23 I
24 25
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