ML20196F258

Requests CRGR Review & Approval of Encl Review Package for Line Item Tech Spec Improvement to Allow Organization Charts to Be Removed from Tech Specs

ML20196F258
Person / Time
Issue date:	02/22/1988
From:	Murley T Office of Nuclear Reactor Regulation
To:	Jordan E Committee To Review Generic Requirements
Shared Package
ML20151D709	List: ML20196E074 ML20196F258 NUREG/CR-4991, Notification of CRGR Meeting 130 on 880309 to Review Proposed Draft Resolution for USI A-40 Seismic Design, & Discuss NUREG/CR-4991 Evaluation & Proposed Improvements to Effectiveness of NRC Generic Communications
References
RTR-NUREG-CR-4991 NUDOCS 8803020137
Download: ML20196F258 (17)

Text

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4/ UedlTED STATES

. 8 e NUCLEAR REGULA.TOPY COMMISSION g NASHifeGTON, D. C. 30004

\..... FEB 2 21968 l

MEl10RACUM FOR: Edward L. Jordan, Chairman Consnittee for the Review of Generic Requirements FROM: Thomas E. Murley, Director .

Office of Nuclear Reactor Regulation

SUBJECT:

LINE ITEM TECHNICAL SPECIFICATION IMPROVEMENTS -

REMOYAL OF ORGANIZATION CHARTS ,

The staff prepared the enclosed CRGR review package for a line item technical srecification improvement to allow organization charts to be removad from

'echnicalSpecifications(TS). CRGR review and approval of this action is requested.

The Crxnmission's Interim Policy Stateinent on Technical Specification Improve-ments recognized the advantages of improved TS and endorsed the recomendatir.ns l of the nuclear industry and the NRC staff for such an improvement program. An important part of that program is the implementation of line item improvements in TS. Line iten isprovements are changes that can be isolemented in the short term. This line item improvement was proposed by $1earon Harris on a lead-plant basis and was endorsed by the Westinghouse Owners Group. For the longer term, a major industry effort is under way to develop a new set of Standard Technical Specifications based on criteria for deterinining which requirements are to be included in TS as established by the Commission's [

Interim Policy Statement.  !

Guidance letter to allfor this line power itemlicensees reactor improvement and applicants. to TS will be A p(rovided by a letter

.iraft generic generic isincludedintheCRGRpackage.) The generic letter provides an alternative I by which organization charts may be removed from TS and replaced by additional l l general requirements. This change will ensure that the essential aspects of

, organization charts, which are needed to ensure safe operation of the plant, ,

will remain in 15; hence, there would be no reduction in safety. The generic i

letter encourages licensees to propose license amendments to is.i.lement a change to TS for their plants to remove the organization charts.. This will allow licensees to make changes to the onsite and offsito organizational structure i without the need for NRC approval via the license amendment process, i

! The offsite and onsite organizational structure and responsibilities will l

! continue to be maintained in a document, such as the Final Safety Analysis 4

Report or Quality Assurance Plan, as currently exists or through updates t of such documents.

i !st g g ge se 13y MPr -

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FEB 2 21988 Edward L. Jordan This package has been reviewed by OGC ari they have concurred with the proposed action. Please schedule a meeting at the earliest opportunity for CAGR review of this ptoposal.

Original signed by James H. Snlezek Thomas E. Murley, Director Office of Nuclear Reactor Regulation r

Enclosure:

As stated Distribution:

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ATTACHMENT CRGR REVIEW PACKAGE 4

PROPOSED ACTION:*

ISSUE A GENERIC LETTER WITH GUIDANCE TO ALLOW ORGANIZATION CHARTS TO BE REMOVED FR0t! TECHNICAL SPECIFICATIONS CATEGORY: 2 RESPONSE TO REOUIREMENTS FOR CONTENT OF PACKAGE SUBHITTED FOR CRGR REVIDh (1) The proposed generic requirement or staff position as it is proposed to be sent out to licensees.

Enclosure A is a proposei generic letter to he sent to all power reactor licensees and applicants. It provides guidance on license amendment requests for c1anges to Technical Specifications (TS) that will allow the onsite and offsite organization charts to be removed from TS. These changes will include the addition of general require-ments to TS that capture the essential aspects of the existing organization charts. ,

(ii) Draft staff papers or other underlying staff documents supporting the requirements or staff position.

1 NUREG-1024 - TECHNICAL SPECIFICAT!0NS -- ENHANCING THE SAFETY IMPACT i

l Recomendation 5: "The preparation and organization of the Standard Technical Specification should be reviewed to assure that they are consistent with 10 CFR 50.36 and oniy contain requirements that have a

! sevnd basis."

52 FR 3788 - NTEklH C0ftfISS10N P01 ICY STATEMENT ON TECHNICAL LTCTTlCATIOP,' IPIFROYEMENT5 This policy statement acknowledges the recomendations of induttry arid the NRC staff as well as studies of TS prcblems and the role of short term (line item) iniprovements in the overall prugram to implement improvements in TS.

(iii) Each proposed re.;airerient or staff position shall contain the sponsor-ing office's pcsition as to whether the proposal wculd increase requirements or staff positions, implement existing requirements or staff positions, or would relax or reduce existing requirements or staff pcsitions.

The gereric letter presents an alternative to including organization charts as part of tie administrative centrol requirements of TS. The alternative would allow organization charts to be removed fron TS provided the change includes the addition of general reouirements that capture the essentiel aspects of organira. ion charts, which define requirenents necessary to ensure safe operation of the facility. This

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l CRGR PACKAGE alternative would neither increase nor reduce existing requirements or staff positions. However, it would relax the restriction on implement-ing changes to the organizational structure that exista. Currently, a licer.se amendment to change organization charts has to be pro-cessed before a licensee can implement a change.

(iv) The proposed metSod of implementation along with the concurrenco (and

, any coments) of OGC on the method pruposed.

Plant-specific applications for this change to its TS would be proposed by licensees on a voluntary basis and in accordance with regulatory requirements for license amendments. The guidance to licensees on the format of acceptable changes to TS is provideri in the encicsures to the generic letter. Shearon Harris was the lead-plant for this line item technical specification improvement and OGC concurred with the licer.tn amendment for Shearon Harris that implemented this change to its TS.

In addition, this package was provided to OGC for coment and con-currence. OGC coments on this package have been incurporated.

(v) Regulatory analysis generally conforming to the directives and guidance of NUREG/BR0058 and NUREG/CR3568.

A formal regulatory analysis is not applicable because the alternative being offered is voluntary and does not alter the regulatory require-ments for administrative controls to assure safe operation of the facility. The benefits to safety of improved TS are not readily quantifiable in terms of reduced exposure to the public from accidents, but they are recognized for their direct contribution to safety by their positive impact on plant operations. The alternative offered removr.s a restriction on timely innplementation of organizational chaPges that a licensee may make to improve unit operation and co'porate management.

(vi) .dentification of the category of reactor plants to which the generic .

requirement or staff position is to apply.

The alternative to the current requirements of plant TS -- including organization charts as part of the administrative control requirements -- i is applicable to all power reactors.  ;

(vii) For each category of reactor plants, the evaluation should also demon-strate how the action should be prioritized and seneduled in light of l other ongoing regulatory activities. The evaluation is to consider information available concerning any of the following factors as tray be appropriate and any other inform 4 tion relevant or material to the proposed action:

)

(a) Statement of the specific objectives that the proposed action is designed to achieve.

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CRGR PACKAGE ,

The objective of this action is that it would permit the licensee to make changes to the organizational structure '

without prior NRC approval and the issuance of a license amendment to update the organization charts currently in TS.

(b) General description of the activity that would be required  !

by the licensee or applicant in order to complete the action.

The generic letter encourages licensees and applicants to prerose changes to'their T5 that are consistent with the guidance provided. However, this W, tion wculd be voluntary  :'

l ard, if not undertaken in the short term, the change could j eventually find its way into a plant's TS through conversion

! to the new Standard Technical Specification (STS). This change would be accepteble for the new STS that are being developed by the vendor owners groups in response to the Commission's policy statenent on technical specification '

improvements.

(c) Potential change in risk to the public from the accidental  !

offsite release of radioactive material.  ;

i l As noted under regulatory analysis, Item (v) above, the  !

alternative to including organization charts in TS is con-  !

j sidered a technical specification improvement that does not ,

alter the essential aspects of the current requirements.

While there is a benefit to safety for this technical spec-

) ification improvement, it has a positive, yet unquantified.

impact on reducing public risk.

(d) Potential impact on radiological exposure of facility employees and other onsite workers. )

! The impact is the same as noted under (c) above.

I i (e) Installation and continuine costs associated with the action,

including the cost of facility downtime or cost of construc-tion delay.

1~ne cost irrect on the licensee is that associated with the a administrative burden to prcpese a change to TS. Since guidance is provided on an acceptable ferrat for the change,

)

it should not require extensive technical involvement and 1

should be handled with a minimum administrative effort and i

cest. On a continubg basis, there should be a net ecst 1

! savings for licensees and for the staff as noted in iten (g)  !

I below.

(f) "he potential safety impact of changes in plant or operation-al complexity, including the relationship to proposed and existing regulatory requirements and staff positions.

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l CRGR PACKAGE l The relocation of the organization charts would be accompanied with the addition of administrative control '

requirements that capture the essential aspects of the '

material removed from TS such that the associated regula-tory requirements will continue to be met. There is no impact on plant or operation complexity, however, because licensees would be a>1e to react more timely to situations that could be addressed through prompt implementation of changes in organizational structure, there is a positive impact on safety.  ;

(g) The estimated resource burden on the NRC associated with the propnsed action and the availability of such resources.

The NRC resource burden should be minimal since a license amendment request would be in response to matte ; for which an acceptable format for the changes has been established as noted in the enclosures to the gereric letter. Enclosure B to this package includes a model safety evaluation report for this change to TS. Thus, the project manager should be able to process the changes witicut input from a specialist and the staff resource burden should be much less than the average 0.1 man-) tar expenditure for a multiplant action that requires input from a staff specialist. The resource burden of this one-time change to TS is expected to more than compensate for all future resovrce burden by eliminating subsequent license anendments for changes to organization charts that would otherwise be encountered if they are retained in TS. Furthernere, such amendments would require specialist review each tire the licensee desired to iglement an improve-

. ment in organizational structure.

(h) The potential irpact of differences in facility type, design, or age on the relevancy and practicality of the proposed action.

Although the format of the changes follows the STS format, it would be adaptable to TS that follow a custom format with a minimum of effort, based on the guidance provided. Hence, the action is applicable to all plants with no significant impact because of the considerations not,ed.

(1) Whether the proposed action is interim or final, and if interim, the justificatien for imposing the action en an interim basis.

As previously noted, efforts are under way to develop new STS baned on the Connission's policy statenent for improve-ments in TS. However, at this time the staff has not reached any conclusions in its interaction with industry groups with regard to changes that might be rade to the

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]. I i CRGR PACKAGE ,

administrative control requirements in 75. However, there have l been no discussions or proposals on the need for any revision  ;

! of the requirements for administrative controls that are stipulat- 1 I ed in 10 CFR 50.36(c)(5). Therefore, it is anticipated that the J changes related to the relocation of the organization charts would i j be final rather than interim for any licensee that volunterfly l l proposes these changes to its TS. j (viii) For each evaluation conducted pursuant to 10 CFR 50.109, the proposint l i office directer's determination, together with the rationale for the ,

! determination based on the censiderations of paragraphs (1) through i i . (vii) above, that k (a) there is a substantial increase in the overall protection of 1 public health and safety or the copeon defense and security to be i l derived from the proposal, and  !

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!' (b) the direct and indirect costs of implementation, fer the l j facilities affected, are justified in view of this increased  ;

j protectien. j l Since the alternative to the current requirements of TS being offered l

is volontary, Mekfi+.cnsiderations are not applicable. l j (ix) For each evaluation cenducted for proposed relaxations or decreases in l 1 current requirements or staff positions, the proposing office l i director's determination, together with the rationale for the determin-  ;

j ation based on the censiderations of paragraphs (i) threugh (vii)  !

above, that: I I' I j -

(a) the public health and safety and the conson defense and security l would be adequately protected if the proposed reduction in -

requirements er positions were implemented, and l (b) the cc.. 2 4 attributed to the action would be substantial '

enough to o.t,dy taking the action.

i As noted in item (vii)(f) above, the alternative relaxes the current I limitaticns on implementing changes to the structure of the organt:#- i tien, yet retains in TS the essential aspects of organization charts  !

that would be relocated from TS. Therefore, there is no negative I effect or impact on public health and safety or the common defense and  !

security. Overall, there would be a cost savings as noted in item j (vii)(g) above; however, the justification for this change is related to its potential ter.efit to safety and furthering the process of 1 improvements in TS rather than cost alone.

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umTED sTATas Enclosure A

% NUCLEAR REGULATORY COMMISSION

[ p! wAsumaToN. o. c. som r,

\*..* (draft)

TO ALL POWER REACTOR LICENSEES AND APPLICANTS Gentlemen:

SUBJECT:

REMOVAL OF ORGAHlZATION CHARTS FROM TECHNICAL SPECIFICATION ADMINISTRATIVE CONTROL REQUIREMENTS (Generic Letter 88 _ )

Typically onsite and offsite organizations are defined by organization charts

- included under administrative control requirements of the Technical Specifi-cations (TS). Trits requires the processing of a license amendment to change an organization chart before implementiny . change in organizational structure.

The guidance provided in this generic letter addresses amendments that may be proposed for removing organization charts from the administrative control requirements of TS.

The staff has determined that with appropriate changes to these admiristrative control requirements, the onsite and offsite organization charts may be removed.

The changes involve the addition of general requirements that capture the es-sential aspects of the organizational structure that are defined by existing onsite and offsite organization charts. Enclosure 1 provides guidance for license amendment requests to remove organization charts from TS.

Enclosure 2 provides an example of this change that was made to the administra-tive control requirements of the existing Westinghouse Standard Technical Speci-fications(STS). The staff has found that this change will not reduce plant safety and it is generically applicable to all power reactors.

The removal of organization charts is a line item improvement that was proposed on a lead-plant basis for the Shearon Harris plant and was endorsed by the Westinghouse Owners Group. This change was reviewed as part of the NRC's pro-gran for improvements in TS. The objectives of that program were established by the Connission's Interim Policy Statement on Technical Specification Improve-ments. The staff concludes that the renoval of organization charts frcm TS will provide greater flexibility for licensees to implement changes in both the onsite and offsite organizational structure, consistent with Comission policy.

Licensees and applicants are encouraged to propose changes to their TS that are consistent with the guidance provided in Enclosure 1. Proposed license amendments conforming to this guidance will be reviewed and approved quickly I

h O

l Gercric Letter 88 _

by the appropriate Project Manager while those that deviate from this guidance ,

will require a are detailed review. If you have any questions on this matter, please contact the Project Manager for your facility.

Sincerely, ,

P Trank J. Miraglia. Associate Director for Projects Office of Nuclear Reactor Regulation ,

Enclosures:

As stated r 1

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Enclosure 1 to Generic Letter 88 _

GUIDANCE FOR REMOVAL OF ORGANIZATION CHARTS FROM TECHNICAL SPECIFICATIONS INTRODUCTION This enclosure provides guidance for the preparation of license amendments for the removal of onsite and offsite organization charts from Technical Specifications (TS). It involves the addition of general requirements that capture the essential aspects of the organizational structure th9t are defined by existing organization charts.

This guidance was developed by the NRC staff based on its review of a lead- ,

plant proposal submitted on the Shedron Harris docket and endorsed by the Westinghouse Owners Group. The benefit of this proposal is that it would I permit a licensee to implenent changes to the structure of the offsite or onsite organizations without first having to obtain NRC approval through the issuance of a license amendment to update organization charts in TS.

DISCUS $10N The staff examined the regulatory requirements for administrative controls in TS provided in 10 CFR 50.36. This regulation states that administrative controls are the provisions relating to organization and management necessary to ensure o>eration of the facility in a safe manner. It has been the staff's experience tut organization charts by themselves have been of little help in ensuring that the objectives of administrative control requirements are met. Specific oper-ational requirements are required elsewhere in TS that bear more directly on operational safety than organization charts. As examples, the organizational  !

element responsible for the control rcom comand function is identified separately in TS, as are the requirements for minimum staffing under various operating  !

conditions. The organizational management functions for independent reviews and audits, unit review and independent safety engineering groups, and shift technical advisors are specified in other TS. ,

'l In sumary, many of the details shown on the onsite and offsite organization charts are not essential to the safe operation of the facility. Over the years, the staff experience with changes in tie details of operating organizations has  ;

shown that organization charts can be modified in many ways while maintaining adequate operational safety. This experience has enabled the staff to distill those organizational characteristics which are important to safety. The staff

finds that the only aspects of organization charts which are important to safety, are not covered by other specifications, and must renain in TS are those condi-l tions listed below.

(1) A requirement that lines of authority, responsibility, and comunication shall be established and defined from the highest management levois through intermediate levels to and including all operating organ 12ation positions. Those relationships shall be documented and updated, as appropriate, in the form of organization charts, functional des;riptions of departmental responsibilities and relationships, and job descriptions l for key personnel positions, or in equivalent forms of documenution.

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.'. Enclosure 1 to Generic Letter 88- l

% h;kh4,. (t. Cwew5 Y (2) Designation of an executive3 position3 in the offsite organization that has corporate responsibility for overall plant nuclear safety and authority to take such measures as may be needed to ensure acce) table performance of staff in plant operating, to ensure nuc lear safety. maintaining, and providing tecinical support to the (3) Designation of a management position in the onsite organization that is  !

responsible for overall unit operation and has control over those onsite

. activities necessary for safe operation and maintenance of the plant. '

(4) Designation of those positions in the onsite organization that require a seniorreactoroperator(SRO)orreactoroperator(RO) license. ,

(5) Provisions of sufficient organizational freedom to be independent of operational pressures to those indivicuals who perform the functions of i health physics, quality assurance, and training of the operating staff.

Since the above conditions will be maintained in the TS, removal of the organ-ization charts represents no reduction in current safety requirements. These t changes will simply allow licensees to implement changes in their organization l structure without obtaining NRC approval.

The licensee or applicant must ensure that the organizational information i described in (1) above is incorporated in a document (Final Safety Analysis j Report, Quality Assurance plan, or other appropriate document) to be referenced '

in the revised TS before the amendmer.t to remove the organization charts is proposed.

The qualifications for certain positions are currently designated by organiza-tion charts as requiring a SRO or R0 license. If these requirements 1.re not currently specified in TS outside of the organization charts (such as the minimum shift crew composition), they should be added to an appropirate specification.

I Finally, the plant TS should be examined for additional references to the  !

organization charts. Where such references are included in administrative control requirements, they must be replaced by an appropriate functional description of the requirement that was defined by tie organization charts.

As guidance on the format of the changes discussed above, an annotated copy of ,

the Standard Technical Specifications for Westinghouse plants is proviced as Enclosure 2 with (1) deleted material shown in strike out text and (2) additions to existing requirements shown underlined. On a plant-specific basis, the i form of proposed changes may differ from this guidance to the extent that differences may exist in the titles or names of various positions or the ,

enclosed example.  ;

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. Enclosure 1 to Generic Letter 88-

SUMMARY

The removal of the organization charts from TS will entail the addition or modification of existing requirements as noted above. If the FSAR or [

Quality Assurance Plan, or other approriate documentation does not currently contain organization charts to at least the level of detail as shown on those  ;

which are proposed to be removed from the TS, the licensee or applicant should t first complete tnat action which will ensure that organization information is included in appropriate documentation.

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Any question on this matter should be directed to the Project Manager for your facility.

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i-4 Enclosure 2 to Generic letter 88_

MARKUP OF WESTINGHOUSE STANDARD TECHNICAL SPECIFICATIONS 6.0 ADMINISTRATIVJ CONTROLS 6.1 RESPONSIBILITY ,

6.1.1 The(PlantSuperintendent]shallberesponsiblaforove-allunitopera-tion and shall delegate in writing the succession to this responsibility dur-ing his absence.

6.1.2 The Shif t Foreman (or, during his absence frora the control room, a designated individual) shall be responsible for the colitrol room connand func-tion. A management directhe to this effect, signed by the [ highest level ofccrporatemanagement]shallbereissuedtoallstationpersonnelonan annt.al basis.

6.2 ORGANIZATION GEFSITS.

6.2.1 0FFSITE AO ONSITE ORGANIZATIONS The-effs 44e-orgam4aa%4en-for-wn64 managemeit-and-tesha4sa4-support sha4 Ebe-as-shown-4m-F43vre 6,2-1, Onsite and offsite organizations shall tt established for unit operation ar.d f corporate managen+nt, respectively. The onsite and Offsite, organizations shall~

include the positions for activities affecting the safety of the nuclear power l plant.

! a.

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Lines of authority, responsibility, and comunication shall be  !

established and defined for the highest reagement levels through intermediate levels to and including all operating organization positions. These relationships shall be docuronted and updated, as

. Ja propriate, in the form of organization charts, functional descriptions of departmental responsibilities and relationships, and

! job descriptions for key p'ersonnel positions, or in equivalent forms of dor.umentation. These requirements shall be documented in [ plant document, e.g., F5AR~ur QA Plan.]

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b. The [ Plant Superintendent] shall tie responsible for overall unit safe operation and shall have control over those onsite tctivities l necessary for safe operation and r.aintenance of the plant.

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c. The [a specified executive* ao:ition individual -- corporate officer in '

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the offsite organization] sidll have corporate responsibility for l l

overall plant nuclear safety and shall take any neasures needeo to ensure acceptable performance of the staff in operating, p.aintaining, and providing technical support to the plant to ensure nuclear l safety.

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!!STS 6-1 l

W STS MARKUP (cont.) Enclosure 2 to Generic Letter 88 __

e.

ADMINISTRATIVE CONTROLS l

d. The individuals who train the operating staff and those who carry out ,

health physics and , quality assurance functions may report to the appropriate onsite manager; however, they shall have sufficient organizational freedem to ensure their independence from operating i pressures. l I

WHIT.STAEF 4 .

e.2.2 UNIT STAFF The-un44-ergam4aat4en-sha44-be-as-shown-4n-F4gwpe-6,2-3-and, l

i' a.throughf.(Nochange.)

21 The [pasitions as specified on current organization chartt.] shall ,

hold _a_ senior reactor operator license. The [ positions as specified on current organization charts] shall hold a reactor operator

. license.

(Nootherchangesforremainingspecifications.)

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I CRGR PACKAGE Enclosure B MODEL SER Underscored blank spaces are to be completed on the basis of the applicable facility information. The information indicated in brackets should be used as applicable on a plant-specific basis.

SAFETY EVALVATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDHENT N0. TO FACILITY OPERATING LICENSE NFP--

AND AMENDMENT NO. ~ TU FACILITY OPERAT!?;G LICENSE NFP-~

[UTILITYNAME)

DOCKET N05.~50- AND 50-

[ PLANT NAME), UNITS 1 AND T INTRODUCTION By letter dated [date), [ utility name] (the licensee) proposed changes to TechnicalSpecifications(TS)6.2.1,OffsiteOrganization,and6.2.2, Unit Staff. The proposed changes would remove Figure 6.2-1, Offsite Organization, and Figure 6.2-2, Unit Organization, and replace them with a narrative de-scription of the offsite and onsite organizations functional requirements in TS 6.2.1 [and unit staff qualifications in 6.2.2]. Guidance for these proposed changos to TS was provided to licensees and applicants by Generic Letter 88 _ , dated _ , 1988.

BACKGROUND Consistent with the guidance provided in the Standard Technical Specifications, Specifications 6.2.1 and 6.2.2 of the administrative control requirements have referenced offsite and unit (onsite) organization charts that are provided as figures to these sections. On a plant specific basis, these organization charts have been provided by applicants and included in TS issued with the operating license. Subsequent restructuring of either the offsite or unit organizatiens followingthei,suanceofanoperatinglicense,hasrequiredlicenseestosubmIt a license amendment for NRC approval to reflect the desired changes in these organizations. As a consequence, organizational changes have necessitated the -

. need to request an amendment of the operating license.

Because of these limitations on organizational structure, the nuclear industry has highlighted this as an area for improvement in the TS. The Shearon Harris licensee proposed changes to remove organization charts from its TS under the

- lead-plant concept that included the endorsement of the proposed changes isy the Westinghouse Owners Group. In its review of the Shearon Harris proposal, the staff concluded that nest of the essential elements of offsite and onsite organization charts are captured by other regulatory requirerents, notably, Appendix B to 10 (.FR 50. However, there were aspects of the organizational ,

ctructure that are important to ensure that the administrative control require-I rents of 10 CFR 50.36 would be tret and that would not be retained with the renovel of the organization charts. The applicable regulatory requirev.ents are those administrative controls that are necessary to ensure safe operation of the facility.. Therefore, those aspects of organization charts for

(MODEL SER Cont.) Shearon Harris that were essential for confortnance with regulatory requirements were added (1) to Specification 6.2.1 to define functional requirements for the offsite and onsite organizations and (2) to Specification 6.2.2 to define quali-fication requirements of the unit staff.

By letter dated January 27, 1988, the staff issued Amendment No. 3 to Facility Operating License NFP-63 for the Shearon Harris Nuclear Power Plant that incorporated these changes to their TS. Subsequently the staff developed guidance on an acceptable format for license amendment requests to remove the organization charts from TS. Generic Letter 88 ,,, provided this guidance to all power reactors.

EVALVATION The licensee's proposed changes to its TS are in accordance with the guidance provided by Generic Letter 88 _ and addressed the items Itsted below.

(1) Specifications 6.2.1 and 6.2.? were revised to delete the references to Figures 6.2-1 and 6.2-2 that were removed from the TS.

(2) Functional requirements of the offsite and onsite organizations were defined and added to Specification 6.2.1, and they are consistent with the guidance provided in Generic Letter 88- . The specification' notes that irrplementation of these requirements is~ documented in the [ plant document -- FSAR or QA Plan.)

(3) [The senior reactor operator and reactor operator license qualified position (s) of the unit staff was (were) added to Specification 6.2.2.

Therefore, this requirement that was identified on the organization chart for the unit staff will be retained.] OR operator and reactor operator license qualifie3 p[The olitions, senior reactor identified on the organization chart for the unit staff, were noted as being required by Specification . Therefore, this requirement will N retained as a requireeent following the removal of the organization snartfortheunitstaff.) OR The organization chart for the unit staff does not stipulate senTor [ reactor operator or reector operator license qualified positions. Hence, this is not an applicable consi-deration related to the removal of the organization charts from the TSfortheirplant.)

(4) Consistent with requirements to document the offsite and onsite organization relationships in the fonn of organization charts, the licensee has confirmed that this docurrentation [ currently exists in the (FSAR, QA Plan. or identify any other appropriate document that was identified.)) OR [has been designated for inclusion to the next updateofthe(FSAF,QAPlan,orotheridentifieddocument.)]

(5) [The licensee has confirred that no specifications, other than those noted in item (1) above, include references to the fioures of the organization charts that are being removed from TS for their plant. Hence, this is not an applicable consideration, with regard to the need to redefine referenced requirements as a result of the removal of these figures.) OR,

(MODELSERCont.)  :

[ Specification (s) referenced the figure for the (offsite and/orunit)organizationchart(s)beingremovedfromTSandhas (have) been revised to d fine the requirements that were identified by this (these) chart (s).

On the basis of its review of the above items, the staff concludes that the licensee has provided an acceptable response to those items as addressed in  :

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the NRC guidance on removing organization charts from the administrative control requirements of the TS. Accordir. gly, the staff finds the proposed changes to be acceptable.

EhVIRONMENTAL CONSIDERATION These amendments involve changes to the use of the facility components located I within the restricted area as defined in 10 CFR 20. The staff has deter:nin:d that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released off-site and that there is no significant increase in individual or cumulative occupational exposure. The NRC staff has made a determination that the amend- t ments involve no significant-hazards consideration, and there has been no public coment on such finding. Accordingly, the amendments meet the eli bility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9)gi- . l Pursuant to 10 CFR 51.22(b), no environmental impact staterent or environ. l mental assessment need be prepared in connection with the l$$uance of these amendments.

CONCLUSION The Comission made propcsed determinations that the amendments involve no significant-hazards consideration, which were published in the Federal Register (53 FR ) on The Comission consulted with the State of .

No public c b 1988.nts were received, and the State of did  !

not have any coments.  !

On the basis of the considerations discussed above, the staff concludes that (1) there is reasonable assurance that the health and safet  ;

not be endangered by operation in the proposed unner, (2) activities such y of the public will will be con acted in compliance with the Comission's regulations, and (3) the issuance of these amendments will r.ot be ininical to the comon defense and 1 security or to the health and safety of the public. l Principal Contributors: Thomas G. Dunning, OTSB/DOEA I

, PD_/DPR_

Dated: _ , 198, I

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l NUREG/CR-4991 PNL-6289 BHARC-700/87/016 Evaluation and Proposed Improvements to Effectiveness of U.S. Nuclear Regulatory Commission e,enenc c,ommunicat. ions

. /. Val at / N Battolle Human Affairs Research Contors 1

Pccific Northwest Laboratory i

Prcpered for U.S. Nuclear Regulatory Commission cn -- r- A .s i,

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1 NOTICE This report was prepared as an account of work sponsored by an agency of the United States l Government Neither the United States Government nor any agency thereof, or any of their employees, malies any warranty, espretted or imphed, or aslumes any legal habihty of re-Sponsibihty for any third party's Ule, of the results of such ule, of any information, apparatus, product or process disclosed in then report, or represents that all wie by such third party would not infringe privately owned rights l I NO11CE Availabihty of Reference Materials Cited in NRC Pubhcations Most documents cited in N R C pubhcations will be available from one of the following sources

1. The NRC Pubhc Oc.cuwnt Rcom,1717 H Street, N W.

Washington, DC 20555

2. The Superintendent of Documerts U S.Goiernment Printirs Othce. Post Of f ne Dos 37082, Washington, DC 20013-7082

3. The National Techn<al Information Sernce, Springfield. VA 22161  ?

Although the bsting th. ~ ilows rep'esents the majority of documents cited in NRC pubhcatic I it is not intended to be . avstive. f Referenced documents a tilable for inspettion and copying for a fee from the NRC Piolic Docu me t toom include NRC cerespondence and int trnal NRC memoranda, NRC Office of tru st en and Enforcement butletins. cireviars. information notices, inspection and invest +9ation notices.

Licensee E ent Reports vendor reports and correspondence. Commission papers, and appbcant and 1.censee documents and correspondence The following documents in the NUREG series are available for purchase from the GPO Sales Propam formal NRC staff and contracia reports NRC sponsorec' conference proceedtngs. and N RC booUets and brochures Also aradable are Regulatory Guides, N RC regulations in the Cc>de of feders' Fetatsbons, and Nacitar Regulatory Commission issuances DocurMnts aia.lable frein the National Technical informaten Seroce indude NUREG ser.es reports and tec% cal reports prepared by other federat agenoes and reports prepared by the Atomic E nergy Comn,ss.on, forerunnet agency to the Nuclear Regulatory Commission Documents ava' table from pubhc and special techNcal hbraries include all open hterature items.

Such at book s. Journal and periodical articlei, and transactions feveral Reg ster notices. f ederal and state leg. stat.on, and congressenal reports can usually be obtained f rorn these hbrar+es Documents Sach at theses, d.ssertatens, forep terorts and translations, and rv NRC cucference proceedings are avadable f or purchase from the organisation sNnsoring the pubhcation cited Sang's cop.es of NRC draft reports are avadable free, to the eatent of supply, upon wtitten request to the Dinsen of informat,on Support Seroces. Distribution Secten. U S Nuclear Regulatory Commission, Washington, DC N555.

Coes of industry codrs and standards used in a substantive manner in e e N RC tmtatory process are maintamed at the NRC L@ary, 7920 Norfoth Agenue, JetheMa WrCand, and a'e asa lable tht's for refe'eMe use by the P4hc. Codes ano standards are wSval, copyrignted and may te purchased from the originatiry cigan42ation or, if they are American Natonal Stancards, from the American N.tionat Standards institute.1430 Broadwiy, New York. NY 10018.

NUREG/CR 4991 PNL-6289 BHARC-700/87/016

= mo Evaluation anc Proposed Imarovements to Effectiveness of U.S. Nuclear Regulatory Commission Generic Communications

.w-Manuteript Completed: September 1987 Date Published: January 1988 .

I Preparsd by J. A. Thurber, B. D. Melber, C. L. Geisendorfer, Battelle Human Affairs Research Centers R. W. Vallario, Pacific Northwest Laboratory Batt;lla Human Affairs Research Centers 2030 M Street. N.W.

Washington, DC 20036 Pacific Northwest Laboratory Richland, WA 99352 Prea: red for Div sion of Operational Events Assessment Offico of Nuclear Reactor Regulation U,S. Nuclear Regulatory Commission W:shington, DC 20665 NRC FIN P2007 1

ABSTRACT This report describes an evaluation of NRC generic communications with industry concerning safety related issues of commercial nuclear power plants. The analysis builds on the findings presented in the 1986 Office of Analysis and Evaluation'of Operational Data (AE00) Special Study Report, "An Overview of Nuclear Power Plant Operating Experience Feedback programs" (AEOD/$602). The primary objective of the report is to present practical recomendations for improving NRC's documents and generic comunications system. The report is based upon a systematic review and evaluation of NRC and industry operating experience documents. It also includes an analysis of interviews with Itcensee personnel at five utilities and their nuclear power plants. NRC regional and headquarters managers and staf f were also interviewed for the study. NRC and licensee personnel interviewed are generally satisfied with the current NRC-industry coinmunications system; however, several problems and potential solutions to those problems are identified in this study. The report makes seven major recomendations for improvement in the ef fectiveness of NRC-industry generic comunications shout nuclear power plant operating experience, 111

t EXECUTIVE

SUMMARY

I The primary objective of this study is to present recomendations for the improvement of NRC cene*ic comunications with industry to help prevent the recurrence of sYgnificant safety problems in comercial nuclear power plants. To form the basis for these recommendations, Pacific Northwest Laboratory (PNL) and the Battelle Human Affairs Research Centers (HARC) have: (1) reviewed past inethods for comunicating safety significant operating experience to industry. (2) uncovered problems and described successes with the present system of NRC generic comunications, (3) identified and evaluated methods for improving NRC generic comunications, and (4) developed recomendations for improving the system of NRC generic comunications.

The PNL/HARC research team interviewed personnel, collected, rWwed, and analyzed information from five utilities and one nuclear power plant under each utility, and from NRC headquarters and regional personnel.

Interviews were administered between January and May 1987.

The report is organized into four sections: (1) section one introduces the background, objective, and scope of the analysis; (2) the project description section discusses the methodology of the study including sections on the evaluation of NRC documents, the sample of respondents questionnaire developme.it and administration, and analysis of data; (3$

the findings section describes respondent opinions about current problems and successes of NRC generic communications and sumarizes the generic comunication improvements suggested by NRC and licensee interviewers; and (4) the final section outlines the major recommendations for improving NRC generic comunication based on analysis of documents and reyonses f rom NRC and licensee personnel.

Generally NRC and licensee respondents are satisfied with the current communications system; however, several problems and potential solutions l to those problems are identified. After analysis of NRC documents and I interview dati, the following seven pri9cipal recomendaticns are made to improve NRC. industry generic communications about safety-related issues:

(1) Clarify NRC expectations of industry and of NRC regional staf f regarding use, tracking, and action o., information notices.

(2) Reduce the nunber of information aotices by raising the threshold of safety significance for them and by making them bulletins when warranted.

(3) provide more information on tb safety significance of the issues in NRC generic comunications and on approaches to resolve the issues.

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(4) Contact utilities eariter regarding issues to be addressed by bulletins and information notices, y

(5) Expand informal channels of communication among NRC headquarters, NRC regions, and litensees.

(6) Do not mate major revisions in tha existing NRC generic comunication documents; do not consolidate bulletins, information notices, and generic letters into one information documnt and continue publication of the Power Reactor Events Report and Licensee Events Report.

(7) Develop an electronic comunication network to send NRC documents to licensees and incor;orite the Generir. Comunications Index (GCI) into such a system.

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l TABLE OF CONTENTS Pagg ARSTRACT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii EXECUTIVE

SUMMARY

........................ v ACKNOWLEDGMENTS ......................... xi

1.0 INTRODUCTION

........................ 1 1.1 Background . . . . . . . . . . . . . . . . . . . . . . . 1 1,2 Objective ....................... 2 1.3 Liinitations of the Analysis .............. 2 14 Outline of Report ................... 3 2.0 PROJECT DESCRIPTION . . . . . . . . . . . . . . . . . . . . . 5 2.1 Review of Selected NRC and Industry Documents ..... 5 2.2 Survey of NRC Generic Communication .......... 6 2.2.1 Me thodo l o gy . . . . . . . . . . . . . . . . . . . 6 2.2.2 Protocol Development .............. 7 2.2.3 Interviews and Site Visits ........... 8 2.2.4 Cata Reduction and Analysis . . . . . . . . . . . 9 3.0 FINDINGS .......................... 11 i

3.1 NRC-Industry Generic Communications Process ...... 11 3.R NRC-Industry Generic Communications Problems end Successes ..................... 14 3.3 Suggesced Improvements to kRC-Industry Generic Communications . . . . . . . . . . . . . . . . . . . . . 22 3.3.1 Data Analysis . . . . . . . . . . . . . . . . . . 22 3.3.2 Conclusions . . . . . . . . . . . . . . . . . . . 35 4.0 RECOMMENDATIONS . . . . . . . . . . . . . . . . . . . . . . . 39 APPENDIX A. Protocol s ..................... A-1 I APPENDIX 8. Generic Communications Index .... ....... B-1  !

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LIST OF FIGURES Page Diagram 1 Sources of Operating Experience Feedback I n f o rma ti on . . . . . . . . . . . . . . . . . . . . 13 Figure 1. How Often do NRC Communications Cover Top r

Priori ty Safety Problems? . . . . . . . . . . . . . 15 Figure 2. How Of ten are Safety Issues Covered in a Timely Manner? . . ................ 16 Figure 3. How Often are There Tot, Many NRC Documents r Annually to Give Sufficient Attention? . . . . . . 17 Figure 4. How Often are Issues Covered Relevant to the Plant? . . . . . . . . . . . . . . . . . . . . . . . 18 Figure 5. How Often Can the Relevance to the Plant be Determined from Information Provided by the NRC?. . 19 Figure 6. How Often are Descriptions of Actions Taken by Other Plants Helpful in Determining Appropriate Action? . . . . . . . . . . . . . . . . . . . . 20 Figure 7. How Often are Issues Covered by NRC also Co A -

i by Other Sources? . . . . . . . . . . . . . . . . 21 '

Figure 8. Replace Bulletins, Notices, Generic Letters With One NRC Information Document . . . . . . . . . . . 24 Figure 9. Discontinue Power Reactor Events Report . . . . . . 25 Figure 10. Provide Additional Information Within Document on Level of Safety Significance . . . . . . . . . . 26 Figure 11. Specify Plants that Document Applies to Within Ducument . . . . . . . . . . . . . . . . . . 27 Figure 12. Expand Use of Figures and Diagrams . . . . . . . . 28 Figure 13. Reduce Narrative . ................ 29 Figure 14. Use Coded System for Characterizing and Summarizing Information . . . . . . . . . . . . . . 30 Figure 15. Eliminate Detailed Discussion of Actions at Other Plants ................... 31 viii

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. Figure 16. Hold Workshops with Utilitie: on Selected S a f e ty I s s u e s . . . . . . . . . . . . . . . . . . . 32 Figure 17. Provide a Generic Communications Index (GCI) of. PlRC Bulletins and Information Notices to Licensees . . . . . . . . . . . . . . . . . . . . . 33 Figure 18. Expand Automated Information Systems with GCI . . . . . . . . . . . . . . . . . ... . . . . . 34 4

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t ACKNOWLEDGMENTS The authors would like to express their appreciation to a number of people who contributed to this research project. We would like to thank Alan  !

Chockie, Walt Scott, Jim Huenfeld, Matt Bonham, and John Boyer who all

, assisted in the interviews of NRC and licensee respondents. John Boyer r was especially helpful in his thorough review of NRC and industry I

operating experience documents. At the outset Jon Olson contributed his

suggestions and insights to the research project. We also thank the l

! numerous respondents from NRC and the utilities for their observations and  :

willingness to participate in this research project. We thank all of the ,

anonymous reviewers of this manuscript for their helpful comments and  !

! suggestions for dmprovement.  !

I i We also appreciate the support and assistance of Vernon Hodge and William  !

] Anderson of the U.S. Nuclear Regulatory Commission. I r

l Thanks to Anita Freeze for her secretarial assistance to the project.  :

j Thanks also go to Frances Morris for typing the document. i I

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1.0 INTRODUCTION

1.1 Background l l

2 Comercial nuclear power plant (NPP) licensees and applicants currently receive a variety of generic comunications. Two types of generic comunication issued by the U.S. Nuclear Regulatory Comission (NRC) are information notices (ins) (about 100 per year) and bulletins (IBs) 3 (usually less than 10 a year and lately less than five). Information notices, although not requiring specific actions, are intended to bring the recipients' attention to a problem in order to enable them to determine its applicability to their facilities and operations. Bulletins do not constitute a continuing requirement but are designed to provide rapid interim solution to a serious safety problem. With a bulletin the recipient is required to perform specific actions and provide a written response to the NRC.

Nuclear power plant licensees also receive generic communications from other organizations both within and outside of the NRC. These include such items as the generic letters (GLs) from the NRC Office of Nuclear Reactnr Regulation (NRR), Power Reactor Events (PRE) reports from the NRC Office for Analysis and Evaluation of Operational Data (AE00), Institute of Nuclear Pows, Operations (INPO) Significant Event Reports (SERs), INP0 Significant Operating Experience Reports (SOERs) and INP0 operations and maintenance reminders and advisory letters and reports on equipment and design deficiencies from the equipment suppliers, nuclear steam supply system (NSSS) vendors and the architect-engineering (A-E) firms.

As a consequence of the lessons learned from the Three Mile Island (TMI) accident, the NRC issued requirements for NPP licensees to implement an operating exper ence (0E) function to improve overall safety performance.

The former NRC Office of Inspection and Enforcement (IE) determined in 1986 that there was a need to assess and improve the current methods for disseminating operating experience information to licensees on sijnificant safety problems and for following up on such communications. This determination was based on previous research and observations which showed that the effectiveness of current generic comunications is quite variable. Despite the post TMI OE requirements, there are incidents and accidents at nuclear plants which appear to be recurrences of similar problems previously addressed by NRC generic comunications. "An Overview of Nuclear Power Plant Operating Experience Feedback Programs,"

i the May 9,1986 report by the NRC (AE00/S602), identified comunications problems between NRC and various nuclear power plants. The extent and j type of interaction between the NRC staff and the licensees in attempting to assess the applicability of the generic comunication items to j particular plants also brought into question the effectiveness of these NRC comunications.

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1.2 Objective To address these problems the NRC identified four goals for the improvement of the generic communications. The first is to assure that the licensees can readily discern the relationship of previous events to their own plants. Second, the licensee should be provided with the information needed to adequately evaluate the problem and define appropriate corrective actions for their plant. Third, the communication system must also assure that adeqJate and proper information is supplied so that whatever and whenever corrective actions are undertaken they provide continuing solutions so that a recurrence is prevented. Finally, the comunications system should allow for tracking the effectiveness of licensee programs with minimal effort by NRC. -

The objective of this project is to assist in achieving these four goals by developing practical recomendations for the improvement in the generic comunications program to help prevent the recurrence of significant safety problems in comercial nuclear power plants.

To form the basis for these recomendations, Pacific Northwest Laboratory '

(PNL) and the Pattelle Human Affairs Research Centers (HARC) have: (1) reviewed past .nethods for comunicating safety significant information to ifcensees and applicants, (2) uncovered problems with the present system of NRC generic communications, (3) identified and evaluated methods for improving NRC generic communications, and (4) developed recomendations for improving the system of NRC generic comunications.

The PNL/HARC research team interviewed personnel, collected, reviewed, and analyzed information from five utilities and one associated nuclear power plant (NPP) site for each utility and from NRC headquarters and regional offices. Interview protocols for NRC regional perso'nel, key NRC '.

headquarters personnel, and for respondents at the five utility headquarters and five NPP sites were administered by two person research ,

teams between January and May 1987.

1.3 Limitations of the Analysis This study is limitet, to the review and evaluation of NRC and industry l generic comunications documents; interviewing NRC neadquarters j respondents; interviewing NRC regional staff and resident inspectors; and i visiting five licensee corporate headquarters and their NPP sites to discuss NRC and industry generic communications programs. Because of the limited number of sites and limited number of respondents this analysis should not be considered a statistically reliable representation of NRC or licensee views. A case study approach was considered most cost effective for eliciting practical solutions to the comunications problems. A consequence of this type of approach is that the survey size was necessarily small and in an effort to gain diversity in the sample, the 2

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J approach may have under-represented subgroups of the sample with greater responsibility for and knowledge of the generic communications process.

The quantitstive findings presented in thi; report and other conclutions should be read with these limitations in mind.

e 1.4 Outline of the Report I

The report is organized into three sections: (1) the project description l discusses the methodology of the study including sections on the evaluation of NRC documents, the sample of respondents, questionnaire development and administration, and analysis of data; (2) the findings section describes respondent opinions about current problems and successes of NRC generic communications and sunnarizes the generic communicattun ,

improvements suggested by NRC and licensee interviewers; and (3) the final .

section outlines the major recommendations for improving NRC generic  !

communication based on analysis of documents and responses from NRC and licensee personnel.

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4 2.0 PROJECT DESCRIPTION The researc.h consisted of a systematic review ae .d evaluation of NRC and industry documents and interviews with NRC r.1d investry respondents

regarding generic communications about NPP safety ;ssues. Both of these [

project elements led to the development of recotmendations to improve NRC  :

) generic communications discussed in Section 4.0.

2.1 Review of Sdected NRC and Induster Documer.ts The first task of the study was to systematically review and evaluate NRC and industry NPP safety issue documents. A. sample of NRC docurrents from such offices as the Office of Inspection ar,d Enforcement (IE) (on April

, 13, 1987 IE was incorporated inte other NR', offices), the Office of '

Nuclear Reactor Regulation (NRR), and the Office for Analysis and t

Evaluation of Operadonal Data (AF00) were reviewed to: (1) develop an  ;

understanorng of the types of technical probleras addressed by these i

' documents, (2) to review the present NRC manner of comunicating NPP '

safety issues to Itcensees, and (3) to identify comunications problems and potential improvements. Previous research on the topic was reviewed  ;

including NUREG-0839, "A Survey by Se)for NRC Management to Obtain .

Viewpoints on the Safety Impact of Regulatory Activities from  :

Representative Utilities Operating and Cona.tructing Nuclear Power Plants"  !

and AE00/S602 "An Overview of Nuclear Power Plac Operating Experience Feedback Programs." Statutory, regulatory, and IE manual requirements and  ;

restrictions on the NRC generic comunications were also reviewed to j

develop an awareness of restr31nts on proposed improvements and to set a framework for recomended changes, i The major types of generic comunications reviewed and evaluated were:

(1) Bulletins and Information Notices for 1985 and 1986 and selected previous years, (2) A sample of Generic. Letters from NPR for 1985 and 1986 and selected letters from previous years back to 1981, (3) AEOD Power Reactor Events reports for 1985 and 1986, l (4) Institute for Muclear Power Operations (INPO) Significant Events i Reports, i

(5) INP0 Significant Operating Experience Reports,

) (6) INPO Operations and Maintenance Reminders, and (7) Advisory letters and reports on equipment and design

) deficiencies from equipment suppliers, nuclear steam supply System (NSS) vendors and architect-engineering (A-E) firms.

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lhe non-NRC documents were reviewed with no reconimendation for their improvement in mind. These were reviewed as related documents whose f.ffcctiveness may interact with those issued by NRC and also serve as a basis for ::omparison of effectiveness of alternative cethods of generic comunications.

A list of problems, potential improvements, and good comunicathns practices were formulated from the review of NRC and industry documents.

These observations were used as a basis for several questions used in the interview protocols for NRC and industry respondents. Conclusions from the systematic review of documents als) contributed to the final recomendations for improvements in the NRC generic comunicouuns system.

2.2 Survey of NRC Generic Comunication In order to iden?,ify the general concerns with the surrent NRC-licansee comunication process (e.g. hulletins, information notices, generic letters and other NRC documents abo'it NPP srfety issues) and to develop recommendations for improvements to the system, interviews were conducted with a wide range of NRC and industry personnel. The process of carrying out this data colleccion effort and analyzing the information obtained is aescribed below.

C.E.1 Methodology inMrviews with personnel at NRC headquarters, all NRC regional offices, ano five licensee corporate and plant facilities was selected as the preferred survey strategy for this study. This approach allowed for in-depth discussion of issues, problems, and solutions regarding NRC generic comunications. The major focus of the study was to elicit observations from NRC and licensee personnel about current NRC generic comunication practices and how to improve them. The open-ended face-to-face interviews lasted from one to two hours per respondent. All interviews were Jone by trained intervi'. wing teams in a confidential setting during regular working hours.

The project was explained to each r'espondent and the following statement was read before each Interview:

A recent analysis by AE00 staff (AE00/S602) indicated that operating experience information provided by the NRC to ,

licensees is being used only to a limited extent at many plants. Based on issues raised in this report, I and E has ,

undertaken this project in order to identify specific ways to l improve the effectiveness of comunications from NRC to utilities and plants, focusing on I and E Bulletins and Notices. We will be conducting site visits to one utility and an associated plant in each region to determine how the NRC information is processed and used and to elicit suggestions for 6

improvement. We are also conducting interviews with key NRC staff, both in the regions and at headquarters. Thus, we are interested in your perspectives on areas that could be improved and mechanisms that potentially could be developed for such improvement.

No new regulatory requirements are anticipated for utilities as a result of this study. All responses are confidential; reporting of results will be in aggregate form only.

Definition of communication: a system for sending and receiving messages; the exchange of messages.

A special effort was made to explain that all responses were confidential and that no individual or organization would be explicitly associated with any quote or finding.

The five NPP sites and utilities were selected based on the following factors: NRC region, plant size, number of plants within the overall utility, plant age, reactor type, and different sites selected for the AEOD survey. Respondents within each of the five ifcensee organizations -

were selected by title and responsibility with the assistance of a key contact person at each utility headquarters. Utility headquarters staff responsible for NRC, INP0, and commercial communications on safety issues  :

and operating experience were selected from the five licensees. NPP l management and staff such as operations superintendent, shi/t supervisor, training manager, maintenance manager, lead maintenance engineer, technical services manager, and reactor engineer were selected for interviews. The selection of licensees was done in consultation with the NRC. After initial contact by the NRC and agreement to participate in the study, the PNL/HARC project team scheduled tb site visits. Five utilities and an associated plant of each utility comprised the industry sample. The NRC sample included headquarters management and staff across a wide range of divisions with special emphasis on departments with responsibilities for generic comunictti ms. It also includtd key l

personnel dealing with generic communications in all five regional NRC offices.

! 2.2.2 Protocol Development 1

Interview protocols or guides for NRC headquarters, regional personnel, i

licensee corporate and NPP managers and staff were draf ted and reviewed by NRC and licensee personnel. The draf t protocols were revised and formatted with a common core of questions asked all respondents and a special section designed for each group of interviewees. The commc1 core (see Appendix A, NRC and Industry Protocols) which 'ormed the basis of 1 *ach protocol included: (1) questions concerning the current process of (

l providing safety iaformation through bulletins, information notices, and '

q generic letters to identify their strengths and weaknesses, (2) questions [

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eliciting aggestions t r improvements to the current NRC comunications system, and (3) questions requesting reaction to proposals for changes in the system. This core of questions was used to obtain comparable information from all respondents. The special sections on the protocol included detailed questions on the proce' for responding to NRC generic comunications. Questions about irdivioual staff roles and experience with NRC communications were also incorporated in the utility and plant protocol s.

2.2.3 Interviews and Site Visits Two-person site-visit teams conducted interviews at NRC offices, utility headquarters, and NPP facilities. Generally both team members were present at each interview. However, interviews were conducted by only one team member when necessary to accomodate the scheduling needs of the respondents. In all but one instance the site visits to the NRC regional offices and to the licensee facilities in a given region were coordinated and conducted by the same site-visit team. In general, interviews with NRC regional staff were carried out the first day of the trip, followed by interviews at utility headquarters, and finally interviews at the plant site.

A total of 15 NRC headquarters staff and 23 NRC regional staff (approximately 5 from each region), were interviewed. Several staff witn director-level responsibilities for operational data assessment and comunication were included in the sample. The regional office personnel interviewed were primarily from the Reactor Projects and Reactor Safety divisions. Several NRC resident inspectors were also interviewed.

A total of 44 industry personnel were interviewed. Of these, 11 were utility headquarters personnel with direct responsibilities for NRC communications or operating experience feedback programs, 8 were nuclear power plant personnel involved in processing or reviewing all NRC comunications, and 25 were plant staff with a specific but liinited involvement in responding to NRC comunications. Licensee corporate headquarters staff were primarily locatea in the licensing and nutlear assurance departments; however, in a few instances they were in technical engineering sections. Most (about two-thirds) had h(en in their current position for one to two years; the remaining third had been in their current jobs for three to five years. The piant staff with central involvement in tracking comunications were located in the nuclear assurance or operating sections (over one-third), in technical services (over one-third), or in operations (one-fourth). Over a third had been in their been in position for less their current job than two years; for three the remaining to six years. Most(two-thirds had three-fourths) had been with their utility for over 10 years. The plant staff with more limited involvement were spread across a wide range of departments, primarily operations, training, and maintenance, with a few from nuclear assurance sections, from technical services or engineering, from health 8

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1 physics and from procedures. Approximately half had been in their current jobs for two years or less, with about one-quarter with three to five years and one-quarter with six to eight years experience in their positions. A majority of the HPP respondents had been with the utility for over 10 years.

2.2.4 Data Reduction and Analysis For analysis purposes the respondents were divided into five groups: NRC headquarters, NRC regions, utility headquarters, plant management (comprised af personnel with responsibilities for reviewing and distributing all NRC communications) and plant staf f (comprised of staff with limited involvement with NRC connunications). A content analysis of tne responses to the protocols was carried out within each group in order

, to categorize the information provided in the interviews. This is i discussed in Section 3.0, "Findings." For two sets of questions where a 1 structured response format was used, the data were coded and numerically analyzed (see Figures 1 through 19 in Section 3.0, "Findings."). The analysis focuses on comparing the responses of the five groups to identify the extent of similarities and differences in perceptions of 1 current problems with NRC generic communications and in identifying suggestions for improvements to the system.

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3 3.0 FINDINGS The findings section briefly describes the NRC-industry generic comunications process, reports perceived NRC-industry generic comunications problems and successes, and summarizes suggested improvements in NRC-industry generic comunications.

The extent and nature of problems with the NRC generic comunications system, categories of suggested improvement, and response to suggested changes in the current generic comunication system were analyzed to help develop recommendations for improvement in the NRC-licensee comunication system.

3.1 NRC. Industry Generic Comunications Process The process of handling NRC generic comunications varies among different utilities, but all have a systematic screening and distribution system.

Licensee corporate headquarters, often located away from the NPP, is generally responsible for coordinating the official bulletin responses to the NRC, but at most of the utilities visited the lead responsibility for determining the response to generic comunications is at the NPP level.

At three of the utilities, it was unusual to have corporate involvement with notices. Typically, corporate level resources are utilized when assistance is requested from the NPP. There was only one utility where overall responsibility for the response was at the corporate level. This also was the only utility with the operating experience program within the licensing and regulatory department.

All utilities screen comunications for relevance and assignment to an appropriate technical lead when actions are under consideration. This is generally an individual review process, but some of the utilities use a standing committee, sometimes the operating assessment review committee, for this function. Most plants have a standard distribution list for all comunications. After an initial logging and screening of documents, they are usually forwarded to the appropriate utility corporate staffs

, and NPP personnel. The documents are again screened and evaluated by corporate and by NPP staffs for relevance to their plant (s). Some utilities screen centrally with a small number of people reviewing the information to determine significance, relevance to plant, and priority.

At minimum, receipt of all comunications is documented. More typically a computerized tracking system for the screening and response decisions is utilized. Whenever actions are planned in response to a document, they are tracked on a regular basis at all plants.

This screening and response to generic comunication is highly selective at some utilities, with only a limited amount of the material circulated outside a small group that does the initial reviews. Consequently ' plant operators, radiation protoction personnel, trades personnel, and other staff of ten see only a relatively small portion of the documents 11

I l

. e available at the utility. These people will notice changes to their facilities that are initiated as a result of operating experiences, but may not be aware of the specifico of the experience or reason for the chhnges.

At three utilities there had been changes in the process in the past two years. In all cases the changes involved increased resources devoted to the screening, tracking, and action system. The most extensive revision was the centering of responsibility at the corporate rather than NPP level at one utility in order to assure greater availability of corporate level technical assistance. At another utility, where the operating assessment function had been added to an existing corporate position, there were plans to separate the role and expand plant-level involvement because of the time needed for carrying out the work. At a third plant the computerized tracking system for communications had been significantly improved.

Generally middle management at the NPP and utility headquarters determine the appropriate actions to be taken with regard to operating experience documents from NRC. Independent assessment groups are also utilized to broaden the perspective used in the assessment process. The research team was invited to observe one assessment group meeting at one utility to gain an understanding of how an independent assessment comittee functions. The quality of the screening and assessment of NRC documents seemed good in all of the sampled utilities but generally seemed highly dependent on the few people assessing the data to identify what is pertinent and important to the licensee's operations.

The primary sources of information (shown in Diagram 1) about operating experience and communications systems found in tne utilities were generally the same as reported in AE00's 1986 study, "An Overview of Nuclear Power Plant Operating Experience Feedback Programs" (see AE00, p.

14). ,

i According to the AE00 study, only a few operating experience documents ,

are determined to be relevant at each NPP, f

Ten to 20 percent of the industry-wide feedback from the NRC, INP0 and the vendor is determined to be significant and applicable, and generates some action at a specific plant. ,

Such actions generally include (a) changing the operating or maintenance procedures; (b) changing the plant design; (c) l incorporating the concepts of the problem into training programs; or (d) discussing the actual sequence of events, its consequences, and lessons learned directly with the plant operating staff. ( AEOD, p.14) .

The survey of industry respondents found thet around 20 percent of the operating experience douments were directly relevant to the plants but that all documents were studied for direct and indirect lessons that

, l l

12 l

l

Diagram 1. Sources of Operating Experience Feedback Information The following diagram shows potential sources of communications with nuclear power plants and utilities from industry and NRC.

lNPO NRC

• Site Evaluations 11/ yrs

• Ucens.ng Actens includsg

• NPROS Rooorts Genenc Letters (~2S/vtl

• NUCLEAR NETWORK

• IE Bulletins and information

• SEE IN Oscuments.1100/yr) Notices, (~ 12S/yfl

• Utdity Reoorts

• AE00 Penodec Reoorts (~20/yr)

• Information Quenes

• NUREGs and Sesected AE00

• NRC incident Resoonse Technscai Reports Center 150.72) Reoorts

• INPO O & MR's Licensee's On. Site Experience Vendo r's/ A.Es

• NSSS . SILs, Tils. TechnicJi

• Oemtion/0efcency Report:(~ 1oo/yr) V Sutletics. Event Notices. etc.

• t.ERs (~ 30/vri (~ 20/ve)

• ino Reports I-6/vtl

• Part 21 Rooorts

• Routine Ooerating Reports

• Equipenent and Component

• Special Studies Vendor Sonnes 8vitetins Licensee's Operating Experience Feedbac Program Owners Group ^

• Reports Commercial inf ormation Special Interest Groups Sources

. industry pubccations ir Data Banks

• PUC Stud es. State

• Soecial Subscrioten Servces Reports. Intememors. etc I AIF, Nuclear News, Irmde N AC, Nucleonecs Weem, etc.)

' - EPRI

• Techn.csa Studies

• NS AC Studies Source: An Overview of Nuclear Power Plant Operating Experience Feedback Programs (AE00/5602).

Prepared by John L. Crooks (Lead),

Program Technology Branch, Of fice for Analysis and Evaluation of Operational Data, U.S. Nuclear Regulatory Commission, ttay 9,1986.

13

would help improve UPP safety performance. Analysis of respondent att!tudes and the AE00 findings were consistent with respect to several observations about the NRC-industry generic communications process.

Each licensee visited in both studies had established a generic ,

communications system intended to meet NRC requirements and to conform to existing guidance. However, existing programs vary widely in their ,

characuristics and effectiveness. There is variability in who screens  ;

and assesses NRC docunents. Sonetimes upper management is involved and i other times not. The systems for collecting, controlling, screening, [

assessing and storing information about operating experience varied i considerably among the utilities in the sample. At some plants all NRC l documents are sent to a centralized staf f and in others the documents go to one person. The method of disseminating NRC generic communication to f NPP and corporate personnel varies considerably; however, most licensees  ;

use both a computer based and hard copy distribution system. There is i also variability in the distribution of documents. Some licensees make multiple copies of each incoming document and send it to a standard l distribution list of utility and NPP personnel for information as well as entering it into their review process. Others enter the document into ,

the assessment process and circulate only screened material to specific l distributions dependent on the topics of interest. The quantity and t depth of information from industry-wide operating experience sent to NPP personnel ranges from very little (only what seems to be directly '

relevant) to items of general interest. There seems to be a need for some additional guidance to help assure that licensee operating i experience documents from NRC and the industry reach the correct people in a timely fashion. i 3.2 NRC-Industry Generic Comunications Problems and Successes This sectio *: highlights industry and HRC respondent perceptions of the problems and successes with current NRC generic comunications. ~There )

ar? Statistical limitations inherent in this study (see Section 1.3) and ,

there are potential problems of overgeneralizing from case studies, but several conclusions are clear.

Figures 1-7 contain histograms of the mean responses to specific l questions about how well current NRC-industry generic comunications is j working. Major conclusions are listed below each figure. Descriptive j text is provided to clarify and supplement the quantitative presentation of the findings.

Analysis of interviews and data collected from the five licensees in this study confirm several important prot.lems found by AE00 about NPP operating experience feedback programs (see AE00, pp. 29-30).

The number of NPP safety communications received by licensees is large and of ten perceived to be overwhelming and unnecessary. Many documents 14 l

FIGURE 1. How Often do NRC Communications Cover Top Priority Safety Problems?

4.0 USUALLY 4.0 -

3.4 3.2 3.3 3.3 CrTU4 3.0 -- 2.8 2.62.6 O BULLETINS 2.5 2.5 2 2. ..s C NOTICES SOWTIMES 2.0 .

E GENERKLETTERS 1- 1 3 RAAELY 1.0 ~ i i t i ENrE Utility Plant Plant Staff POPULATION Hdqtra. Mgmt.

Note: The muns are listed above the bars for each category of respondent.

This figure shows that there is a high level of agreement among industry respondents that bulletins cover high priority safety problems. There also is a view that is consistent across the subgroups of respondents that the priority of notices and generic letters is not as high as that for bulletins.

15

FIGURE 2. How Often are Safety issues Covered in a Timely Manner?

USUAU.Y 4.0 '

TTEN 3.0, 2.9 2.9 2.8 2.8 29 p,y 2.7 2.6 O BULLETINS 2 2.52.5 E C NOTCES SOMETlMES 2.0 E GFNERKLETTERS RAAELY 1.0 -

16 ENTRE POPULATION i

Utility Hdqtrs.

i

v Plant Mgmt.

i Plant Staff i

Note: The means are listed above the bars for each category of respondent.

Figure 2 shows that the various forms of NRC generic communication are considered timely by the industry. Exceptions were noted by many '

respondents, but in general, the NRC and industry respondents feel that the issues are identified and brought to the attention of the industry in )

a timely way. Industry respondents find no major differences between I bulletins, information notices, and generic letters in the coverage of safety issues in a timely manner. Coments from industry expressed the desire to increase time for analysis and planning of necessary I modi fica tions.

l l

l l

16 i

i

b FIGURE 3. How Often are There too Many NRC Documents Annually to Give Sufficient Attention?

USUALLY 4.0 '

3.0 CFTEN 3.0 - 2.8 O BULLETINS 2.2 3

,3 SOMETIMES 2.0 - I'9

• 1.8 1.9 E GENERK1ETTERS i 1.5 l'd 7/1.3 1.S 1.3 RARELY 1.0 .

i S i i i ENTFE Utility Plant Plant Staff q POPULATION Hdqtrs. Mg mt.

Noto: The means are listed above the bars for each category of respondent.

Figure 3 shows satisfication with the number of bulletins and some concern

, with the increasing number of information notices. Because only a few bulletins are issued each year, they were viewed by the entire population of respondents to rarely be too many in number to give sufficient attention to any particular one. Utility headquarters respondents and plant management find there are often too nany information notices. This

] is complicated by the fact that some do not appear relevant to their plant

and that there is duplication with material received from INPO and other industry scarces. Respondents at utility headquarters and plant staff

! levels sorr.etimes find there are too many generic letters annually to give

! sufficient attention. Plant staff dif fer with the industry management i

view of notices in part because many of the staf f receive and review only notices that are relevant to their particular work function.

17

i

. . I I

FIGURE 4. How Often are ISSUES Covered Relevant to the Plant?

USUALLY 4.0 '

3.2 3.0 3.0 M 3.0 ' 2.7 2.8 2.7 O BULLETINS 2.6 2.7 2.4 2.3 C NOTCES  :

SOPETIMES 2.0 - E GENERKl.ETTERS RARELY 1. o <

ENTFE r"DPULATON i 12.

Utility Hdqtrs.

i -

.is Plant Mgmt.

t Plant Staff i

]

l Note: The rneans are listed above the bars for each category of respondent.

According to the mean responses shown in Figure 4, NRC generic comunications are considered important and relevant. For the industry subgroups, bulletins, notices, and generic letters are judged to be of ten relevant to the plant. Generic letters are judged to be slightly more relevant than' bulletins, which in turn are more relevant than notices.

18

FIGURE 5. How Often can the Relevance to the Plant be Determined from Information Provided by the NRC7 USUALLY 4.0 -

3.3 3.3 3.1 30 3.1 3.1 o CFTEN 3.0 - 2*9 '

2.7 2.7 0 BULLETINS

/. 2.4 C NOTICES SOAETIMES 2.0 ~ '

E GENERICLETTERS RAAELY 1.0 - i e i i EtmRE Utility Plant Plant Staff POPULATION Hdqtrs. Mgmt.

Note: The means are listed above the bars for each category of respondent.

Industry respondents of ten find that the relevance of bulletins, informatioit notices, and generic letters can be determined from the information provided by the NRC. Figure 5 shows that this view is consistently shared by the industry subgroups although the plant management has a somewhat more skeptical view of notices than other forms of communication. Although plant relevance can of ten be established, it is not clear to industry respondents and many HRC respondents what the NRC headquarters' expectations are with regard to licensee actions in response to notices.

19

l FIGURE 6. How Often are Descriptions of Actions Taken by Other ants Helpful in Determining Appropriate Action?

USUALLY 4.0-3.3 N 3.0 3.0 ' 2.7 2.8 2.7 O BULLETINS 2.5 26 2.52.5 2.3 2.4 g SOPETIMES

• E GENERKLETTERS

2. 0 --

FMRELY 1.o<- 4 EtmRE Utility Plant Plant Staff PCPULATION Hdqtts. Mgmt. l l

l Note: The means are listed above the bars for each category of respondent.

l l

Figure 6 shows that utility headquarters and the plant management find that bulletins, notices and generic letters which describe actions taken by other plants are helpful in determining appropriate actions for their own plants. During the interviews, it was of ten noted that not only does the information provide useful insight into innovative ways of dealing l with problems, but the information also provides insight into what is considered an acceptable solution / action by the imC.

l l

20 l

l FIGURE 7. How Often are issues Covered by the NRC also Covered by Other Sources?

USUALLY 4.0 -

3.3 3.2 3.2 3.03.03.0 2.9 CFTEN 3. 0 - 2.9 O BULLETINS O toittS

.l2.9 l3.1 SOPETIP.ES 2.o . E GENERKLETTERS FMRELY 1.0 -

i i i i ENTRE Utility Plant Plant Staff POPULATKW Hdqtrs. Mgmt.

Note: The means are listed above the bars for each category of respondent.

Respondents find a high level of duplication among sources of information as shown in Figure 7. The*e is widespread agreement that issues addressed in nulletins, notices, and generic letters are of ten covered by other sources, most notably INP0. However, the view was also expressed by both industry and NRC respondents that the interests and objectives of the various sources do not always coincide and that dif ferent perspectives and i information are sometimes contained in the treatment of the same issue.

Because dif ferent objectives and interests may need to be served, most respondents did not indicate that eliminating all duplication would be desirable.

21

I t

are produced by many sources (see Diagram 1). Many of the documente contein little or no indication of priority of importance. Other documents contain information that overlaps with that from other sources. Licensees indicate that they must cope with vast quantities of ,

paper, some redundant, and most of varying importance and usefulness. l Many respondents feel that their review of the large number of documents  !

from NRC, INPO, and the NSSS vendor, is overwhelming and subtracts i resources from more effectively solving safety significant problems  !

relevant to their plants, j Overlapping and redundant documents from NRC, INP0 and commercial sources I' were cited by respondents as wasteful of resources and at times a problem. The principal overlap is between NRC and INP0 documents that  :

attempt to bring significarct events and generic concerns to the attention  ;

of licensees (e.g. ins, SER3, and SOERs). Other redundant documents were i found from NSSS vendors but respondents felt that some overlap was good.  !

It gave them more information and a dif ferent perspective on safety  !

problems and solutions. If the timing were better coordinated, the l duplication would be less problematic some respondents indicated. l l Howeve", licensee respondent report that conflicting information is occasionally communicated by one or more sources. Thus, licensees have  !

to carefully read and compare information from all sources in order to identify dif ferences and conflicts. Licensees generally have procedures i for resolving the conflict, if identified, prior to acting on the information within their organization, but this causes delay and at times j unnecessary expense.

1 Significant time and resources of licensees are spent screening and assessing documents for which a record of review is required or is l perceived to he necessary (such as NRC bulletins, information notices, and generic letters). Other NRC and industry documents that contain l relevant information but no explicit requirement for action of ten receive little attention, (e.g. PRES and NUREGs). ,

3.3 Suggested Improvements to NRC-Industry Generic Comunications i This section highlights industry and NRC suggestions for and reactions to suggested improvements to NRC-industry generic communications. Section 3.3.1, Data Analysis, sumarizes the major suggestions for improvements in generic communications from NRC and industry respondents. Section 3.3.2 sumarizes the major conclusions about improvements from the study.

3. 3.1 Data Analysis NRC and industry respondents were asked to react and comment on specific suggestions for changing the current NRC generic comunications system.

Figures 8 through 18 show the mean responses f rom interviewees to several suggestions for improving NRC documents and comunications. Respondents 22 i

i I

. ~ . - - - - _ , _ . . - . _ , - , .

---

m_- -- - - - . - , - - - - - - - - , ~ . - - - - - - - -

- - -_J

I were asked to react to the suggested reforms through a closed-ended scale (i.e. the change would be: much better, somewhat better, not make a difference, somewhat worse or much worse). These reponses were scaled statistically and transformed for the histograms (Figures 8 through 19) showing means with a range of +1 to -1 for subpopulations. Conclusions about the proposed improvements to NRC communications _are elaborated below each figure.

NRC and industry personnel were also asked to make suggestions for the most important changes that could be made by NRC to improve connunications' with licensees. The five most of ten made suggestions for improvements in in open-ended discussion with respondents are summarized by each sample subpopulation below.

NRC Headquarters e Improve identification of level of safety significance in NRC documents.

e Reduce number of NRC documents to licensees.

e Improve explanation of purpose of information notices to licensees.

e Hold workshops and meetings with ifcensees after issuing bulletins.

e Centralize responsibility and authority for all NRC generic communications.

NRC Regions e Reduce number of NRC documents to iicensees.

e Establish single NRC organization to communicate n 'th licensees about safety significant problems.

e Establish clear guidelines for NRC inspectors regarding information notices.

e Rank information notices for safety significance.

e Establish clear boundaries between information to encourage safe practices and information to require action. -

Utility Headquarters e Provide more safety significant problem experience from other nuclear power plants.

23

l l

l 1 <

1 i

l FIGURE 8. Replace Bulletins, Notices, Generic Letters With One NRC Information Document ,

l BETTER 1.00 "

l 0.29 I

l NDFTERENT 0.00

[/ 0.00 0.00 ^

I 0.05 fff) Wlb - ,

0.30  !

l YCTEE 1.00 " l ENTFE NRC Hdqtts. NPC Region Utility Plant Mgmt. Plant Staff (

POPULATION Hdqtts. '

t Note: The means are listed above the bars for each category of respondent.

Figure 8 shows that respondents at NRC headquarters tend to favor replacing bulletins, information notices, and generic lotters with one NRC information document, but industry respondents at the corporate ,

headquarters and plant staff members are opposed. Utility headquarters staf f of ten expressed the concern that such a change could result in costs  :

to the utility. NRC regional staff and plant managers are indifferent to  !

I the suggested improvement, neither supporting or opposing the idea. l l

l \

l I

l i

t i

i l

24 l t

l

, . . _ _ - . - . _ . , _ . . . . . - . - . - . . - , . . _ . ~

1 I

t FIGURE 9. Discontinue Power Reactor Events Report

BETTER 1.00 " l 1

1 0.64 l I o.So i

[ 0,14 i IPO!FFERENT 0.00  : .- --- ,

t 6

! VCREE 1.00 "  ;

ENTTE NRc Hdqtts. NRC Region Utility Plant Mgmt. Plant Staff I 1

POPULATM Hdqtts.

t i  !

I J Note: The means are listed above the bars fcf each category of respondent. l 4

I

} Respondents at NRC headquarters and plant managers prefer to see the f i publication of Power Reactor Events Reports (PRES) discontinued, wnile ,

other groups of respondents are largely indifferent as shown by the i histograms in Figure 9. However, most plant training staf f felt strongly l that PRES were cost helpful for their training prograns and would like the  :

l j flRC to continue publishing the reports, r

, I i

l

! l k

1

! 25 l-1 i  ;

) i a

l t

FIGURE 10. Provide Addi+.lonal Information Within  !

Document on Leval of Safety Significance ,

1.00 DETTER 1.00 ' -

l 0.70 0.38 / 0.43 00; 0.18 r

' ' ^

NDFFEFENT 0.o0 -

t ENTTE NRC Hdqtrs. NRC Region Utility Plant Mgrnt. Plant Staff PC9tAATON Hdqtrs.

i Note: The means are listed above the bars for each category of respondent.

j Industry respondents at all three levels prefer documents that provide j additional information on level of safety significance. Plant management l felt informatien about the level of safety significance would greatly improve the usefulness of NRC documents. NRC respondents have no strong preference about publishing more information about the level of safety significar,ce within NRC d)cuments. Some concern was expressed by NRC regional staf f, that introducing a formal priority rating system would be cumbersome, lead to delays in getting the dccuments out, and he difficult to administer.

26

FIGURE 11. Specify Plants that Document Applies to Within Document EETTER 1.00 "  !

0.67 0.70 0.67 0.65 i

0.60 F0FFERENT 0.00 ~

4 "

l VERE 1.00 "

D(TFE NRC Hdqtts. NRC Region Utility Plant Mgmt. Plant Staff POPULATION Hdqtts.

,, Note: The means are ".ated above the bars for each category of respondant.

l 1

l

' [

Figure 11 reveals that all respondents would like to see documents screened for the NPPs to which they apply. This is somewhat inconsistent I with licensee plant management that expressed a preference for controlling the screening and codification of documents themselves. Figure 11 shows that all respondents feel that it would be easier to screen NRC documents i if the documents contained more plant specific information.

l 27 h

-m, -

, , ~ , , - g . . --

I FIGURE 12. Expand Use of Figures and Diagrams

• 0.95 1M BETTER 1.00 " 0.86 j

\ ,

.. ./

y g .: /

NDlFFERENT 0.00 1

i  !

1 I WCHE 1.00-

! ENTFE Utility Hdqtrs. Plant Mgmt. Plant Staff l i POPULATK)N i  ;

P Note: The means are listed above the bars for each category of respondent.

'This was not a specific protoco! question for NRC staff, i I

Figure 12 clearly shows that industry respondents strongly favor the 1 expanded use of figures and diagrams in NRC information documents. This l I would make it easier for licensee personnel to quickly understand the problem being discussed. More diagrams and figures are perceived to be significant improvements over the current system.

i

! t I

28 I i i

1 I

i

i FIGURE 13. Reduce Narrative

• l e

BETTER 1.00 "

t i

FDFFERErn 0.00  ;

(..

,g 0.33

/

, +t4

/

0.59 0. '.,7 l 0.71

,' VDE 1.00 "

DEFE Ittinty Hdqtts. Plant Mgmt. Plant Staff i P N Ut.AT O N ,

1  ;

)

u

) Note: The means are listed above the bars for each category of respondent.

1 *This was not a specific protocol question for f1RC staff. 7 i '

i  !

I i Figure 13 clearly shows that industry respondents, especially plant staff, ,

i are opposed to reducing the narrative in NRC information documents. They want more data on the problem and solutions to the problem. Industry

. respondents feel it would he cruch worse if the narrative was cut bcck in

) NRC documents, t j

t 1

I 4

29 i

'I d

I 4

4

, FIGURE 14. Uso Coded System for Characterizing and Summarizing Information' i BETTER 1.00 '

I 0.30 l NDfTERENT 0.c0 0.03

1. (([J

[ o,co V////A  ;

0.33

! i WTE 1.00 "

ENmE Utility Hdqtts. Plant Mgmt. Plant Staff  ;

, POPULATON i'

i

! Note: The means are IIsted above the bars for each category of respondent. i

) 'This was not a specific protocol question for NRC staff. l i ,

)

i

] i

. I Figure 14 shows that respondents at utility headquartets favor a coded i system for characterizing and summarizing information, but plant j j management opposes this change and plant staff is indifferent. Plant i

~

staff are indifferent probably because they already receive pre-screened 1

NRC documents.

E I

30 l

1

• O i I i  !

I r

a  !

l FIGURE 15. Eliminate Detalled Discussion of Actions at i j Other Plants

• l 4-N 1.00 "

i i  !

E Utility Hdqtrs. Plant Staff  !

POPUL.ATION Plant .Wmt.

FDFTERENT l

); /

. ;ce ;;;t a

&j?

f )

HA ME 0.70 0.70 l /

0.62 l

l j 1.00 -

1 1.00 .

! l l f i

) '

q Note: The means a a listed above the bars for each category of respondent.

'This was not r. specific protocol question for NRC staff.

i

i Figure 15 shows tha'. industry respondants strongly oppose eliminating i i detailed discussion of action taken to resolve problems at other plants. [

l The open ended remarks froa licensed personnel also call for more detail l

] in NRC documents rather than less. Industr.y especially wint more detail  ;

j about what the problems und solutions are to other NPPs.  ;

i >

i' ,

, +

) I i i

i I

31 i i  ;

I J

FIGURE 16. Hold Workshops with Utilities on Selected Safety issues 1.00 BETTl.R 1.00 ' 0.88

0. 7 0.79 NDETERENT 0.00

& '?

f ,

V YDE 1.00 "

ENTFE NRC Hdqtts. NRC Region Utility Plant Mgmt. Plant Staff POPUt.ATON Hdetts. j 1

l '

1 Note: The means are listed abova the bars for each category of respondent.  !

NRC and industry respondents Strongly favor holding workshops with utilities or selected safety issues to improve comunications and safety performance, as shown la Figure 16. All respondents want to improve j

informal, non-adversarial comunications between NRC and licensees and advocate periodic workshops to achieve that goal.

32

• O FIGURE 17. Provide a Generic Communications Index (GCl) of NRC Bulletins and Information Notices to Licensees BETTER 1.00 " 0.86 0.74 0.50 f4DFFERENT 0.00 3 y y, 3 3 -

YOYE 1.00 "

ENTFE NRc Hdqtrs. NRc Reg'on Utility Plant Mgmt. Plant Staff POPULATION Hdqtts.

Note: The rneans are listed above the bars for each category of respondent.

All respondents strongly prefer providing a Generic Comunications Index of NRC bulletins and information notices to licensees, as shown by the high mean scores in Figure 17. The GCI was also strongly supported by open-ended cocments in the interviews. Plant management feels it would make their search for relevant documents much easier when they are attempting to assess the applicability of bulletins and information notices to their NPPs.

33

. . i i

i FIGURE 18. Expand Automated Information Systems with GCI i BCTTER 1.00 " 0.90 0.75 0.80 i POFFERENT 0.00 .

l l

YOFE 1.00 "

ENTTn NRC Hdqtts. NRC Regs Utility Plant Mgmt. Plant Siatt NTION Hdqtts.

1 i

Note: The rneans are listed above the bars for each category of respoMent.

All respondents strongly support the idea of expanding an autom" .J information system for NRC documents with an automated Gem.ri; Comunications Index, as shown by the data analysis in Figure 18. Most reapondents would like to see automated distribution of NRC documents to the industry with the GCI on line for euy retrieval and analysis.

I i

I 34 l

I i . o I

o Establish an early informal warning system so that licensees can think about a problem before a formal comunication is i received.

e Prioritize and categorize documents for safety significance.

j e Hold workshops and improve informal communications with HRC.

e Reduce nurcer of NRC documents.

Plant Management l

j e Establish prioritization/classtfication of NRC documents by safety significance.

j I e Improve timeliness by getting information (issue rathcr than j requirements) to licensees as soon as possible.

1 j e Provide util'.ty with rationale for NRC decisions.

i

e Hold workshops that focus on management anf human factors I, associated with safety significant problena.

o Put NRC documents on line with the Generit Comunications Index.

, Plant Staff t e Improve time',iness of all NRC documents.

)'

e Hold no.e workshops in a non-adversarial environment and improve communication between industry and NRC.

! e Improve categorization of notices and bulletins regarding j safety significance.

l e Reduce the number of NRC documents.

j e Improve guidelines for industry action in information notices.

3.3.2 conclusions l Several conclusions can be drawn from the interviews with NRC and l licensee personnel. Many utility and NRC respondents felt that there are i

too few NRC bulletins. Generally bulletins are considered to be of high quality with good level of technical detail. Respondents had mixed

, feeling abo 1t the timeliness of bulletins. Some industry respondents

{ said there should be a preliminary issues document on the safety issues in forthcoming bulletins (or bulletins under consideration) mailed to the l licensees to give them an idea about what may come from NRC.

35

l t I

A majority of respondents said that there are too many NRC information notices. According to industry respondents, information notices seem to ,

be used as "backdoor regulation" through the inspection process. [

Industry respondents felt that if NRC inspects for information notice safety issues, they become de facto regulations. The status of ,

i information notices is confusing to many respondents. Some information notices are of such importance to safety that they should be published as i bulletins according to many industry and NRC regional respondents. l Although clearly stated in NRC policy, many respondents felt that ,

information notices have an ambiguous status: what are the actions to be  !

taken by licensees and what are NRC's expectations of the licensees? i Respondents felt there should be a better way of classifying and '

screening information notices. The non-comercial nuclear power plant information notices should be screened out by NRC. Most respondents felt that information notices could include better discussions of NRC i expectations and of what action could be taken. NRC could improve its '

system of classification of safety significant problems for the information notices. One idea that was offered was to color code safety significant problems in a manner similar to the coding done by INPO.

Industry respondents generally said that there should be no change in NRC l generic letters. They felt that the current system is working well. The  !

Power Reactor Events (PRE) Report doet not have wide support or use, but i the publication is often employed in training exercises. .

l l Lic?nsees appear to have good distribution, tracking and follow-up  !

l systems from bulletins, information notices, and generic letters although the system characteristics va"y widely. Many respondents said that NRC l

could improve its system of dissemination of documents. Many respondents '

complained of not getting bulletins and information notices until one or  !

two weeks after they were officially published. Some NRC Resident ,

Inspectors (RIs) complaineu of not getting the bulletins and information  !

notices at all. When RIs are asked questions by the licensees about what  !

they mean and they do not have a copy, it presents problems. Some -

j respondents recomended expansion of the number of figures and drawings  ;

in bulletins and information notices, and most suggested not cutting back i on the narrative in the documents. Many reported that if anything, the l documents need more detail; they do not need to be shorter. Licensee I respondents appeared to like the examples in the documents, and in general, they find that the description of problems and solutions used by others most useful, f

Most respondents felt that the best and most desired NRC communication is l prompt, detailed, and comprehensive descriptions of signifiednt events or j safety concerns. Trends and patterns analyses and other sunmary  ;

information that address the operating experience ollectively are also l desired. These are most useful for information, training, and other l purposes. Descriptions which are brief and which contain no assessments j 36 l I

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J of >fgnificance are not widely used. Documents that require extensive analysis are also not widely used.

Utilities and plants do not want the bulletins, information notices, and ganeric letters replaced by one document. They genert11y reported that they like the system the way it is right now. Licensee retpondents and NRC personnel want improved informal communication with each other. For j the most part, licensees would also like to see more two-way communication through workshops on selected safety issues.

i The majority of respondents advocated development of the Generic

]

Communications Index (GCI) (see Appendix B for discussion of the GCl).

They felt that the GCI should be expanded and automated (but not with INP0's Nuclear Network). Industry respondents felt that it could be on INP0's system but should not be integrated because it might limit the free exchange of information if NRC nad access. The informal

! cormunication network would be significantly hindered. Respondents were generally impressed with INP0's communications systens, especially Nuclear Network. Many called for better coordination between NRC and j INPO. Finally, NRC and INPO communications are of ten seen as duplicative causing confusion and waste of resources.

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! 4.0 RECOMMENDATIONS

The analysis of NRC documents and responses from NRC ;nd licensee personnel provided the basis for the following recommendations to improve i NRC generic communication of NPP operating experience:

b

(1) Clarify NRC expectations of licensee and of NRC regional staf f

regarding use, tracking, and action on information notices.

Industry respondents, particularly at the corporate level, are concerned with the inconsistent message regarding information l

j notices; of ficially there are no requirements connected with them, but in fact NRC follows up on industry programs. The AE00 Report i recommended development of a new Inspection Module for follow up of j licensee operating experience feedback programs. Regional NRC staff find the mandate of resident inspectors (R!s) with regard to notices unclear. The responsibilities of RIs in follow-up of ins need to be i specified; a new Inspection Mcdule could serve that purpose; in addition, improving the timeliness of Temporary Instructions (T!s) to Resident inspectors would facilitate their follow-up role.

(2) Reduce the number of informaticn notices by raising the threshold of safety significance for thea and by making them bulletins when i warranted.

There is general agreement that the volume of notices is very high i

and a reduction would be desirable. This is consistent with AE00 l findings. The regional staf f as well as industry find coping with i the volume difficult. Some NRC staff as well as industry respondents indicated some notices really should be bulletins.

While there was considerable support for raising the safety I threshold of notices as a way to reduce volume, there was concern among regional staff that not disseminating information on any potential problem could lead to later criticism if incidents were to

{ occur.

Notices have been increasing at both ends of the safety impact

continuum. Since very hign volume can be counterproductive in i achieving concerted industry attention and action to each issue, a

{ process for setting the threshold for bulletins and information notices or identifying safety priority is needed to avoid dilution j of resources and to focus atteation on the most pressing issues.

(3) Provide more information on the safety significance of the issues and on approaches to resolving them in NRC generic communications.

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• Industry respondents indicated that more specific advice on acceptable ways to respond to specific issues would be very helpful.

This is consistent with AEOD's recommendation which calls for more NRC guidance to industry on the process of operating experience assessment. While a more explicit safety prioritization system was -

considered desirable by many respondents, there was concern, particularly among regional NRC staff, that any formal process would be time consuming and very dif ficult to implement. Industry is very positive about the current use of examples from other plants and the detailed narrative in the documents. They find the NRC, at times, does not provide a technical contact who can provide assistance ,

beyond what is written in the document. While a formal safety '

priority system is not recomended, some indication of relative significance in the narrative would be useful. In additinn, an indication of the appropriateness of the approaches of other plants discussed would indicate directions acceptable to the NRC while '

still allowing individual licensee discretion in determining their own course of action.

(4) Contact utilities earlier regarding issues to be addressed by bulletins and information notices Utilities and plants suggested that some type of informal "early warning system" of issues in progress would help them begin to think about their approaches in advance of the afficial document. An  ;

informal contact alerting utilities to an upcoming issue can t initiate industry attention to the safety concern.

(5) Expand informal channels of communication among NRC headquarters, NRC regions, and licensees. -

l The AE00 analysis recomended expanded discussions with industry on ways to improve operating experience review activities. There was general support for this idea through increased use of workshops on ,

l selected issues. Many industry respondents found informal contacts I i

as most useful, particularly with regional staff and Resident Inspectors. Workshops provide a channel for discussing approaches and providing advice in a less official forum than the written document mechanism. Because regional staff are a major contact source for licensees. NRC headquarters needs to focus more attention {

on keeping regional staff informed of issues in the document development process.

(6) Do not make major revisions in existing NRC generic comunication formats; do not consolidate bulletins, information notices, and generic letters into one information document and continue to '

publish Power Reactor Events Report and Licensee E. vents Report.  !

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The AE00 Report recommended consolidation of all operating experience information into one document and termination of the separate PRE and LER compilation publications. The maiority of I industry and regional NRC respondents disagree with this recommendation. They find the three distinct information documents useful and serving specific purposes. These information documents are identifiable and meaningful to industry. There is limited use

, and limited knowledge of PRE at the utility and plant level, however those using the document, primarily training managers, find it of high quality and effective for their programs. Very few respondents recommended eliminating the LER publication. Although the PRE Report has a narrow use, it is an important one because of the role 1 of the training manager in communicating new safety information at the plant operations level. Also, there is widespread support for d

improving the. documents by increasing the use of visual aids (e.g.,

j figures and diagrams) where appropriate.

(7) Develop an electronic communication network for NRC information documents and incorporate the Generic Comunications Index (GCI) (

)

into such a system.

4 There was strong industry support for an easy access computer based

. on-line system to receive documents and to obtain related information through the categorized index of GCI. The AEOD report i also recomended consideration of an electronic communication system. NRC staff was also generally favorable to the use of such a ,

i system. Expansion of the system to include other documents (such as  ;

I a NUREG index) was also supported by most respondents. A i computerized on-line system would improve access to documents and j could assist in coordination of related materials when coupled with )

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an e vanded GCI.

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APPEN0!X A 1

i NRC AND INDUSTRY PROTOCOLS 1

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INTERVIEW PROTOCOL 5 NRC STAFF  !

! A recent analysis by AE00 staff (AEOD/S602) indicated that operating experience f i information provided by the NRC to licensees is being used only to a limited ,

i extent at many plants. Based on issues raised in this report, I and E has i

undertaken this project in order to identify specific ways to improve the  !

effectiveness of communications from NRC to utilities and plants, focusing on !

I and E Bulletins and Notices. We will be conducting site visits to one utility j and an associated plant in each region to determine how the NRC information is j processed and used and to elicit suggestions for improvement. We are also  !

] conducting interviews with key NRC staff, both in the regions and at l l headquarters. Thus, we are interested in your perspectives on areas that could i

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be improved and mechanisms that potentially could be developed for such i 3

improvement. i

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i No new regulatory requirements are anticipated for utilities as a result of this i

study. All responses are confidential; reporting of results will be in j i aggregate form only.

! Definition of communication a system for sending and receiving messages; the l l exchange of messages.  !

1. From your experience, what are some of the best types of communications (

(e.g., Bulletins, Notices, Generic letters)" E th'e utilities?

2. From your experience, what are some of the worst types of communications to the utilities? l' I, 3. Based on your experience, how serious a problem do you think inadequate l I licensee attention to NRC information documents 157 I l (PROBE) 1 5

{ Very serious, somewhat serious, minor problem, not a problem at all. [

4. From your experience, what are the greatest difficulties you think i licensees face in effectively responding to each of these three types of t i NRC documents?

, (PROBES) 1 l a. Licensees receive too many to give sufficient attention to each one.

l l b. The information is not detailcd enough to assess relevence and L appropriate action.

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c. Licensees do not get the information to the right people at the plant level,

d. Plarits are not provided with enough resources from parent utility to act on information.

e. Documents are poorly written and consequently, lack clarity.

Other:

5. What areas need the greatest attention by NRC to improve the effectiveness of these documents?

(PROBES)

a. The importance of the safety issues addressed in the documents?

b. Type of information provided (specify e.g., accuracy, level of detail, priority, applicability)

c. Integration of information from NRC, INPO, Vendors, etc.? (overlap across sources)

d. Timeliness of notification?

e. Formatting / writing of the documents?

f. Monitoring and assessment of actions taken by plants in response to informat'on documents?

g. Coordination and cooperation between NRC headquarters and regional staff in:

e preparing documents?

e monitoring licensee activities?

i Other:

i 6. What mechanisms would you suggest for more effective monitoring and l l assessment of utility programs for review of and response to safety informat ion?

! (PROBES)

Changes to current inspection system? (e.g., formulation of more detailed ,

routine inspection guidance, determining plant specific applicability of I notices, use of special inspection teams, more emphasis in SALP l assessments?) i A-2

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7. We are interested in your ideas on ways to make the information provided by [

the NRC more useful. We'd like your reaction to some specific suggestions i

for changing the current system.

a. Consolidate the types of documents provided to utilities to reduce the different kinds of documents sent to utilit:es.

- Replace bulletins, notices, generic letters with one NRC information document.  !

l - Discontinue Power Reactor Events Report.

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- Other ways to consolidate 7 i J

] b. The NRC is currently developing a Generic Communications Index (GCI) l (to be published as NUREG/CR-4690) to be able to access bulletins and

notices more easily (show categorization plan). Would this be useful  !'

i to you at the regional office?

i

c. Expand NRC Generic Communications Index (GCI) (to be published as  !

NUREG/CR-4690) to include Generic Letters in same data base, j

d. Provide additional NRC screening of information within document to ease I efficient use by utilities. Screen for: l

- Level of safety significance j

- Specify plants to which applies j l

- Listing of licensee personnel categories for whom information is  :

most relevant j s

- Listing of applicable categories in GCI

! Other:  !

1 l e. Expand automated information systems (e.g., electronic mail) for i earlier dissemination of information and improved integration of

]t information sources, i

j - Make GCI available on line ,

- Add indexed NUREG data base to GCI  :

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- Add GCl to INPO Nuclear Network?  :

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] f. Change writing /fornatting (specify hon) ,

g. Hold workshops with utilities

! - On selected safety issues  !

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- C maintaining effective review and response process.

Other:

8. Do you have any specific suggestions for actiens that NRC might take in cooroination with others (such as INP0, ver. dors to improve the communication system?

9. What do you think are the characteristics of a good utility communications programs? (Mention ccmmunication process stages as a probe.)

(PROBES)

Who is involved in program, extent of automation, management oversight, etc.

10. What are the two or three most important things the NRC could do that you think would lead to ucilities making more effective use of NRC information documents?

Thank you for your time and thoughts on how NRC can improve its communications to the industry.

I wish to reaffirm that all your responses tre confidential and the reporting of  ;

them will be in aggregate form only, i i

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INTERVIEN PROTOCOL INDUSTRY The purpose of this project is to identify specific ways to improve the effectiveness of communications from NRC to utilities and plants, focusing on '

1 I and E Bulletins and Notices and NRR Generic Letters. We will be conductinD site visits to one utility and an associated plant in each region to determine

how the NRC information is processed and used and to elicit suggestions for l improvement. We are interested in your perspectives on areas that could be improved and mechanisms that potentia'ly could be developed for such ,

improvement. We will be discussing with you l

(1) your assessment of NRC communications on safety issues, covering the content, format and process used; i

(2) potential methods to improve communications; and (3) how these communications ara used at your utility and plant.

i PART I. GENERAL ASSESSMENT OF NRC COMMUNICATION EXPERIENCE ,

1. What would you say are the best types of NRC communications to the utilities?

]

(PROBE)

For example, Bulletins, Notices, Generic Letters, AEOD reports. ,

i l Why? f I

2. What are the worst types? Why? j i de'd like you to briefly look over this list of bulletins, notices, and l

! generic letters to remind you of the issues covered in the past 2 years.

l (Hand list of bulletins, notices and generic letters for past two years to intervienee. Ask each question about bulletins, notices, generic letters.)

(!!and intervienee card)

. t l 3. Looking over the recent bulletins, how often do they cover top priority safety problems?

Notices?

l Generic letters?

)I 4. To what extent are the issues covered relevant to your plant?

( i Notices?

i Generic letters?  !

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5. Can the relevance of bulletins to your plant be determined by the information provided by the NRC?

Notices?

Generic letters?

6. Are the descriptions in bulletins of actions teken by other plants helpful in your determination of whether and what kind of action is appropriate for your plant?

Notices?

Generic letters?

7. Do bulletins cover issues in a timely manner?

Notices?

Generic letters?

8. Are there too many bulletins annually for a plant to give sufficient attention to each one?

Notices?

Generic letters?

9. How frequently are the issues covered by NRC bulletins also covered by other sources? I Notices?

Generic letters?  ;

Here is a figure shoning several potential sources of information (hand Figure 1).  ;

10. From your experience, which are the 3 to 4 mo',t useful types of infonnation for the safe operation of your plant?  !

What makes this source effective? i l

(Probes, confidentiality, ease of access, time available, quality of technical l content, direct relevance to plant)  !

11a. Considering the full range of types of information potentially available (see 1 Figure 1), are thre any, in your opinion, that could be eliminated without a l loss of important safety information? l 1

Yes No l I

lib. If yes, which ones?

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12a. Are you aware of any generic issues important to plant safety that have not j been addressed by tfie NRC7 I

Yes No i 12b. If yes, what are they?

13. If a specific occurrence (e.g., continued early wearing out of an equipment part) at one of your plants might have generic relevance, how would you get ,

this information to others in the industry? I

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14. In your experience, what are the major strengths of the NRC information  ;

system?  !

(Probes: issues covered, timeliness, thoroughness of information, etc.) .

I 15. In your experience, what are the major weaknesses of the NRC infonnation i system?

l a  ;

4 (Probest classification system.-some bulletins should be notices, vice versa, i lack of confidentialit 1 of information, etc.) y of responses, issues covered, timeliness. -thoroughness  ;

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PART II. METHODS TO IMPROVE COMMUNICATIONS  !

1 j We are interested in your ideas on ways to make the information provided by NRC i i

more useful. We'd like your reaction to some specific suggestions for changing  !

l the current system. (

f (Hand interviewee response card #2)  ;

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1. Consolidate the types of documents provided to utilities.

, (a) Replace bulletins, notices, generic letters with one NRC information j document i

What would be gained (lost) from this change?

{ (b) Discontinue Poner Reactor Events Report f

{ What would be gained (lost) fro'n this change?

I 2.

' NRC is currently developing a Generic Comunications Index (GCI) (to be  !

published as NUREG/CR-4690) to be able to access bulletins and notices more '

! easily. (Showcategorizationplan) 1

] (a) What is your reaction to the proposed categorizat;on scheme?  ;

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l (Probe: appropriateness of categories, usefulness of indexed l information) j i

(b) Expand to include generic letters in same data base

)

4 What would be gained (lost) from this change? (

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3. Provide additional NRC screening of information within document. (

(a) Level of safety significance What would be gained (lost) from this change?

(b) Generic concern vs. manufacturer dependent i What would be gained (lost) from this change?  !

(c) Listing of personnel information is most relevant for l What would be gained (lost) from this change?  !

(d) Listing of categories applies to on GCI l What would be gained (lost) from this change? r

4. Expand automated infonnation systems.

(a) Make GCI available on line  !

What would be gained (lost) from this change?  ;

i (b) Add indexed NUREG data base to GCI . j What would be gained (lost) from this change? l l (c) Add GCI to INP0 Nuclear Network?

What would be gained (lost) from this change?

5. Change writing / formatting. f (a) Expand use of figures, diagrams l

What would be gained (lost) from this change? l l

(b) Reduce narrative j What would be gained (lost) from this change?

(c) Use coded system for characterizing and sumarizing information (i.e., l style similar to NUREG-0020 (Greybook]) l What would be gained (lost) from this change? l (d) Replace standard explanation paragraph of notice / bulletin with short actien phrases: e.g., "no response to NRC required"  ;

What would be gained (lost) from this change? )

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(e) Replace narrative with outline fomat regarding issue, presentation of past experience and actions at other plants What would be gained (lost) from this change?

(f) Eliminate detailed discussion of actions at other plants  :

What would be gained (lost) from this change?

i

6. Hold workshops with utilities.

(a) On selected safety issues What would be gained (lost) from this change?

(b) On maintaining effective revie.v and response process

What would be gained (lost) from this change? I (c) Other topics? (specify)

7. Are there any specific suggestions you have for improving NRC informatic1 documents?

8. Are there any specific sugaestions you have for improving the process NRC uses for providing you with safety information?

l 9. Are there additional ways in which NRC could coordinate activities with INP0 to improve the communication system?

j 10. Are there techniques used by other industry information sources such as INP0 or comercial inforteation services that the NRC could use to improve comunications?

i (Probe how other sources are evaluated - whether better, and if so, what makes

them more useful?)

1 11. What would be the most effective way for NRC to be kept informed of your use j of information in bulletins, notices, and generic letters and actions your i

utility has undertaken based on this information?

l l 12. What, in your opinion, are the two or three most important things the NRC i i

could do to help utilities:

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N APPENDIX B d

P l GENERIC COMMUNICATIONS INDEX

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APPENDIX B GENERIC COMMUNICATIONS INDEX The NRC Generic Comunications Index (GCI) contains the printed index of all bulletins, information notices, and circulars from 1971, whi.n such documentation started, to 1986. The NRC plans to update this document periodically. The GCI consists of records, which are single line or row entries, or twenty fields, or columns. A particular field contains the same type of information for all documents. Included are fields for the document identity type (IEB, !EC, or IEIN), year, serial number, revision or supplement number, title, and NRC technical contact, plus two fields each for general system or topic, specific component or topic, cause or defect, potential effect, and remarks. There are three fields to list vendors involved. The list of the categories used for each field is presented on the following page. A list of vendor names that are included in the index also follows. An example of the list of vendors included in Generic Comunications Index for 1971 thru 1986 Comunications and the categorization subject list for Generic Comunications Index (GCI) is included.

B-1

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• a ost C T T AS tierOa s, v%i t N o Division cf Operational Events Assessment Office of Nuclear Reactor Regulation " "

U.S. Nuclear Regulatory Comission FIN P2007 Washington, DC 20555 (is rvec or as oar n a.c o c e v i s o ,,ac ., u- i I August 1986 - September 1987 i t 5,s p P L E V E N T A n v N O T E 5 14 i t , *, * **

• l I se instaa:t ex..,,,,,w,, inis report describes an evaluation of NRC generic communications I with induttry about nuclear power plant operating experience. The analysis builds on l the findings presentqd in the 1986 AE0D Special Study Report, "An Overview of Nuclear l Power Plant Operating Exterience F'edback Programs" (AE0D/S602). The primary objec-l tive of the report is to oresent practical recommendations for improving NRC's docu-l ments and generic comunications systen. The report is based uoon a systematic re-view and evaluation of NRC and industrj operating experience documents and an analysis of interviews with licensee oersonnel at five utilities and their nuclear power plants l and NRC regional and headouarters ranagers and staff. NRC and licensee pc"Sonnel l interviewed are generally satisfied with the current NRC-industry comunications ,

system; however, several problems a d solutions to those problems were discovered. l The report makes seven recom~endations for improvement ir, tne effectiveness of NRC-l industry generic comunications about nuclear power plant operating experience. 1 o c , .ea es .N: :ocwtNt. m vsis n :t s: a.> t e a: NRC generic comunications Nuclear power plants Operatina experience t ?> iO! N tisit a s C#t N E N:( ? Yg a vs it av a:L Asitif v Statt ut NT j 'i M sa t* C 455tra.s .. , 12 i N O C f P & l,( $ Unclassified I Unlinited p: 0Ec1MM ffdd '~' P ' s* * ' " N . c . e - m . . . .. NUCLEAR REGULATORY OMMISSION IEINt EliY59IY" WASHINGTON, D.C. 20555 l ,,,[ # ,, PENAL F R PRI TE (1 E, 4300 C N n m E E 5 5 5 8 i 8 5 2 C 2