ML20010H009

A Survey by Senior NRC Management to Obtain Viewpoints on the Safety Impact of Regulatory Activities from Representative Utilities Operating and Constructing Nuclear Power Plants

ML20010H009
Person / Time
Issue date:	08/31/1981
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
References
NUREG-0839, NUREG-839, NUDOCS 8109220821
Download: ML20010H009 (55)

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t NUREG-0839 A Survey by Senior NRC Management to Obtain Viewpoints on the Safety Impact of Regulatory Activities from Representative Utilities Operating and Constructing Nuclear Power Plant ateYu shed August 1 1

. Nu lear egulatory o slon Washington, D.C. 20555 f ~,,,

1,

ABSTRACT A survey of licensee staff members representing the several organizational elements in different licensee corporate and plant staffs was conducted by senior NRC management to obtain licensee views on the potential safety conse-quences and impact of NRC regulatory activities. The_ comments received ad-dressed the full scope of NRC activities and the negative impact of agency actions on licensee resources, staff performance, planning and scheduling, and organizational effectiveness.

The findings of the survey is that the pace and nature of regulatory actions have created a potential safety prob-lem which deserves further evaluation by the agency.

t i

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TABLE OF CONTENTS

[

MGE ABSTRACT..........................

..-iii 1

1.0 BACKGROUND

1

2.0 INTRODUCTION

1 3.0 EXECUTIVE

SUMMARY

OF COMMENTS.................

2 l

3.1 Imposition of Requirements................

2

3. 2 Communications......................

3 3.3 Planning and Scheduling..................

3 3.4 Impact of Requirements..................

4 3.5 Training and Operator Qualifications...........

4 3.6 NRC Organization.....................

5 3.7 Licensee Organization...................

5 3.8 Enforcement.........................

6 3.9 On-Shi f t Operations....................

6 h

3.10 Surveillance.......................

6 I

3.11 Inspection........................

7 3.12 Fire Protection......................

7 3.13 Emergency Planning....................

7 3.14 Security.........................

7 k

3.15 Pub? ic Af f ai rs......................

7 3.16 Reporting Requirements..................

8 4.0 SURVEY FINDING.........................

8 5.0 CONCEPTUAL RECOMMENDATIONS...................

8 L

APPENDIX A:.........................

10

" Comments by Utility Representatives Made During the NRC Safety Impact Survey" 1.

Imposition of' Requirements.............

11 2.

Communications...................

18 3.

Planning and Scheduling..........,...

19 4.

Impact of Requirements...............

21 5.

Training and Operator Qualifications........

27 A

V

l I

i l

TABLE OF CONTENTS (Continued)

PAGE 6.

NRC Organization..........

29 7.

Licensee Organization...............

32 r

8.

Enforcement....................

34 9.

On-Shift Operations................

35 10.

Surveillance....................

36 l

11.

Inspecti on.....................

37 12.

Fire Protection..................

39 13.

imergency Planning.................

39 14.

Sec u r i ty......................

41 15.

Public Affairs...................

42 16.

Reporting Requirements...............

43 I

Exhibit 1 40 Appendix A:................

44

" Key to References Contained in Licensee Comments" APPENDIX B:.........................46

" Listing of Survey Meetings -

Utilities and NRC Representatives" l

APPENDIX C:.........................

48

" Representative Sche'dule of a Survey Visit" o

1 1

i.

1 I

1 I

1 vi.

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1.0 BACKGROUND

The Commission has clearly identified to the staff the necessity for evalu-ating the impact on licensees of proposed safety requirements.

For proposed actions that might impose a significant burden, a value-impact analysis is currently required and prepared by the staff for Commission consideration.

In the development of the NRC Action Plan as a result of the TMI-2 accident (NUREG-0660*), the Commission broadened this requirement to include the impact of a large number of proposed actions.

In this case, the NRC Steering Group for the Action Plan was requested to provide an operational safety assessment of the impact of 50 proposed actions on overall safety that apply to reactors approaching the operating licensing stage.

The report of that safety assessment, dated February 1, 1980, stated that no single proposed requirement produced a significant burden or a negative safety impact.

However, the imp d of the 50 proposed actions would divert utility engineering and technical support staffs from necessary ongoing routine safety-related tasks in order to properly respond to the large numbers of new requirements.

Accordingly, certain reductions and modifi-cations of proposed actions were recommended by the Steering Group and approved by the Commission.

In addition to the actions taken by the Commission following the accident at Three Mile Island, many other resource-intensive requirements have been issued by the Commis' ion.

Thus, the potential for a negative safety impact caused by the numbe'. and scope of requirements, has become very real to both NRC and the nuclear industry. The full significance of this issue may have been underestimated by T.he NRC staff.

2.0 INTRODUCTION

In order to directly ascertain the perspective of licensees on the depth and scope of this negative safety impact problem, the Office of Inspection and Enforcement coordinated a NRC survey of representative licensees.

The licensees selected for the survey were the following:

Florida Power and Light Company; Tennessee Valley Authority; Northeast Nuclear Energy Company; Yankee Atomic Electric Company; Boston Edison Company; Commonwealth Edison Company; Toledo Edison Company; Consolidated Edison Company; Philadelphia Electric Company; Arkansas Power and Light Company; Duke Power Company; and the Power Authority of the State of New York.

Appendix B to this report provides information on when and where each portion of the survey took place and the identity of NRC participants.

~

• For information on the availability o NRC Documents referenced in this report, please see Appendix A, Exhibit 1.

1

This survey was broader than the limited operational assessment conducted in early 1980 by the Steering Group for the NRC Action Plan (NUREG-0660).

The survey covered by this report addressed most of the areas relating to reactors regulated by the NRC.

The procedure used to conduct the survey was for a senior NRC manager to advise a senior manager of each selected utility of NRC's interest in discussing, without reservations or limitations, problems or issues essen-tial to upgrading NRC's effectiveness and responsiveness.

Licensee response to this proposal was well received, and very experienced licensee personnel were made available for the discussions, i

The NRC participants talked with groups of shift personnel, plant engineers, lower level plant supervisors, senior plant managers, corporate engineers, first level corporate supervisors, and senior corporate managers.

Each meeting was designed to be relatively small. to be unstructured, and to last for about one and one-half hours.

NRC q:.esttois were limited to clarifica-tions of comments.

Each group was informed by an NRC participant that the problems or issues identified would not be directly associated with the individuals personally or with their company.

All areas of reactor regulation were freely and openly discussed.

A repre-sentative schedule of a survey visit is provided in Appendix C.

NRC parti-cipants agreed that the groups at all utilities were frank and well informed.

The groups were serious and attempted to be constructive.

NRC participants who took part in more than one portion of the survey felt that J

comments and viewpoints expressed by different groups and by different utilities were strikingly similar.

This report contains a compilation of the identified problems that experi-enced licensee rep /esentatives stated they have with the NRC.

It was prepared to help NRC improve its effectiveness.

This report does not attempt to defend any NRC position or to explain any action taken by NRC in l

fulfilling its responsibilities to protect the health and safety of the public.

I NRC participants observed that there is a healthy respect for the Commission among the groups involved in the survey.

Furthermore, with few exceptions, no NRC requirement was viewed in itself as being' unsafe or unreasonable.

f Each group was complimentary of NRC for conducting the survey.

3.0 EXECUTIVE

SUMMARY

OF COMMENTS l

Hundreds of comments were made by licensee personnel directly involved in the survey.

The comments ranged from detailed technical issues to the basic j

causes of problems.

The number and types of comments received necessitate two summary presentations.

An executive summary of the comments is provided below A complete summary is provided as Appendix A to this report.

3.1 Imposition of Requirements A major issue identified is the imposition of requirements.

Licensees consider the_NRC system of imposing requirements to be "out of 2

l I

control" (generic letters, bulletins, circulars, notices, orders, rule c.hanges, NUREGs, Regulatory Guides).

A basic concern of the licensees is the number and scope of require-ments imposed by the NRC through its several organizational elements.

(

No one singular requirement is considered to be overwhelming.

A persistent comment was that NRC requirements, and pending require-ments, are poorly integrated as to their overall effect on plant operation and ut.ility resources.

A standard comment was that the impact of many changes on other safety-related activities has not been adequately evaluated.

Some additional specific licensee comments further characterize the nature of related concerns:

o NRC has underestimated the impact of Bulletins.

Changing requirements, provides a moving target which is wasteful o

l of finite capital and manpower resources.

I L

o The short turnaround times required for responses to many NRC i

communications are technically and administratively overwhelming.

t 3.2 Communications I

The licensees commented on communications problems with the NRC as well as their perception of communication problems within NRC.

Thcy expressed concern over their inability to obtain authoritative positions or interpretations from the staff on technical issues. They ascribe this to poor intra-NRC communications.

Moreover, licensees assert they are unable to identify those individuals or agency units which can provide definitive positions.

They also believe NRC is gen-erally unresponsive to their comments and proposed technical alterna-tives.

They perceive an inability by NRC to realistically apply acceptance criteria for a given requirement to plant specific circum-stances.

3.3 Planning and Scheduling The licensees consistently commented that they no longer manage their own resources or set their own priorities. They assert that NRC' functionally dictates their plans and schedules by virtue of work activities necessary to satisfy NRC-imposed requirements on NRC-required schedules.

It was the licensees' view that NRC does not live in the real world of planning and scheduling.

They urge that new requirements be integrated, from a resource stand-point, and imposed on the licersees on a schedule consistent with approved safety priorities.

Present work activities place large numbe 's of workmen into. operating plants.

This work force poses an additional negative safety impact on 3

plant activities due to an increased opportunity for error,and opera %

tional transients.

a.

• Impact of Requirements During the survey,.the licensees indicated that many mandateu94RC safety upgrades created to address specific technical concerns have not been effectively integrated to achieve efficiency in design, instal-lation and operation.

This has resulted, in their view, in duplication of effort and inefficiencies in the management of resources.

The assertion made by the licensees during the survey was that a more coordinated approach to the issuance of rec natory requirements, both in their technical content and in their schedule for completion, would have resulted in better safety-related modifications at less cost and without diversion of their finite technical talent from other safety tasks.

The licensees stated that the NRC fails to appreciate the magnitude of backfit activities.

The licensees asserted that, in some cases, crews performing this work onsite were as large as those used during the original construction of the facility, and the cost of the work has exceeded the original cost of the plant.

It is their perception that the cumulative effects of a " cut / weld /fix" series of priority opera-tions will ultimately end up hurting the plants.

Backfit activities are using available funds and technical manpower to the extent that desirable modifications and some major plant mainten-ance activities have been and are being deferred.

3. 5 Training and Operator Qualifications Licensee comments pertaining to training and operator qualifications identified a number of areas in which the licensees perceive a negative safety impact in both the short and long term.

For the short term, the licensees see current training requirements as impacting on current staff availability and overtime.

Experienced staff members are being recycled into new or upgraded training programs to increase their formal qualifications.

The remaining on-duty staff then experiences the adverse impacts of increand work schedules and responsibilities.

Moreover, the licensees indicate that_the lack of a definitive quali-fication " goal" for their staffs is producing uncertainty, instability and frustration.

They note increasing evidence that nonlicensed opera +, ors are no longer interested in moving into the licensed operator profession.

Strong concerns were expressed by the licensees relative to the negative impact they perceive would follow any finalization of an engineering degree requirement for all or portions of the operating staff.

The tentative nature of this requirement, according to the licensees, has already had an impact on staff stability.

Another immediate concern is that the frequency and number of plant modifications ultimately are reflected in operating procedure changes and a need for retraining of. operators.

This has produced a " cycling" of the operators for additional training that dees not upgrade their professional qualifications.

This training time enables them only to 4

keep pace with the physical changes that have occurred in the plant.

This is perceived by the licensees as having a further negative impact in that the operators do not develop a reliable base of experience on which they can rely during operational maneuvers or incidents.

A longer term negative impact identified by the licensees is the confinement of the Senior Reactor Operator to the control room.

Licensees expressed the concern that they are restricted from using a valuable resource to go into the plant, assist in trouble shooting, make decisions based on first-hand knowledge, and, in an overall capacity, improve the reliability and enhance the safety of the opera-tion.

3.6 NRC Organization During the survey, the licensees provided their perspective on NRC organization as well as their own organizations.

The strongest com-ments received on the NRC organization were that NRC presented the.

image of an uncontrolled organization.

The licensees sensed a lack of personal responsibility for individual actions on the part of the NRC are germane to the characterization of the licensee's perception of this agency include the following:

NRC involvement with industry committees at this critical time it o

less than during previous periods.

NRC does not appreciate or account for plant specific differences o

wher levying requirements. The philosphy of " good-for-one good-for-all" seems to prevail.

o The staff is seen as being unwilling (or unable) to consider reasonable alternative approaches to safety-related problems; e

conversely, identical solutions to a problem at different plants have received different receptions from the staff.

Many inspection, licensing and technical review activities, inclu-o ding the actual granting of a license, can be characterized as regulation by intimidation.

o Guidance and decisions on substantive technical matters are not forthcoming on schedules consistent with plant modification needs.

3.7 Licensee Organization Licensee concerns over the impact of regulatory requirements on their organizations focused on the lack of appreciation by ;4RC of the impact of requirements on their organizational effectiveness.

They feel that key managers in their 07ganizations are being detained on the " wrong problems." They find that many diverse NRC groups focus their attention for information and action on certain key managers.

This apparent inability or unwillingness of NRC to deal with lower 5

level managers in their organizations is perceived as a lack of appre -

ciation for the complexity of the operation of these facilities.

Consequently, these lanagers are no longer managing their plants or corpor-te ;;tl cities.

Their professional focus has been diverted from their primary areas of responsibilities.

The licensees n(ted some

.:oncern that the NRC has not recognized that new organizational units have been created just to coordinate actior.s on specific NRC require-ments.

3.8 Enforcement In those areas of the survey in which licensees addressed enforcement' issues, an underlying theme of their concerns is the development of a organizations.

These concerns are characterized by the following observations:

o Requirements for routine responses to NRC correspondence to be provided under oath or affirmation. reinforces the adversarial relationship.

o Formal documented responses on issues should not be required when NRC already knows the answer.

o Confirmatory orders should not be issued for matters that NRC knows are already being accomplished.

Isolated events should not receive the attention they currently o

receive.

The focus should be on breakdowns in their programs.

The licensees expressed their view that violations of regulatory o

requirements should be assessed in relationship to overall nuclear safety rather than being essentially.the same for both large and small events.

1 3.9 On-shift Operations The concern presented during the. survey regarding on-shift operations is that regulatory requirements have had a substantial negative impact on operator morale.

The licensees assert that operator types of jobs have become undesirable, and that operators perceive their every move to be subject to a large number of " Monday morning quarterbacks."

In this latter regard, the licensees made the observation that operators are not " replaceable" in the usual sense of that word.

They were concerned about the overall impact on the loss of dedicated long-term operator skills in the control rooms of their plants.

3.10 Surveillance Related to the subject of on-shift activities is the licensees' per-ception of surveillance testing.

The comments can 5-characterized as "too much--too often." The licensees assert that t" y are wearing out their equipment from surveillance testing alone.

A frequent example cited was that of the diesel generators.

They expressed concerns about 6

the many problems, including plant transients, that have been initiated during the conduct of surveillance testing.

Surveillance is the most hazardous part of shift work.

Their assertion is that by testing less frequently they would be able to reduce unnecessary challenges.

Some licensees, because of their technical specifications, noted a concern over the compounding of test requirements that occurs whenever redundant trains of equipment need to be tested immediately following an unsuccessful test.

3.11. Inspection Licensees commented that they consider NkC inspection activities to be heavily paper oriented, and that'NRC fails to appreciate that licensee preparation for and support of NRC inspection activities involve several manyears of licensee effort each year.

Comments were offered on the duplication of inspections performed by other elements within NRC and other organizations such as their'own audits'and those of the Institute for Nuclear Operations (INP0).

No credit appears to be given by NRC for non-NRC activities.

3.12 Fire Protection This area was singled out for particular licensee attention.

Fire protection was characterized by licensees as a. major area that has been poorly handled.

They are particularly concerned with Appendix R of 10 CFR 50.

They offered the view that industry feedback on this area has been ignored by NRC_and that the decisions reached have been wasteful of capital and manpower resources.

3.13 Emergency Planning Emergency planning is another area to which licensees addressed specific comments as being poorly handled.

They view present NRC activities as being unrealistic and uncoordinated.

They believe that NRC lacks a sense of appreciation for the problems involved in attempting to establish energency planning within multiple political jurisdictions and conducting annual exercises, particularly for multi-facility licensees.

NUREG-0696, and other related documents and changes in policy, received particular criticism during the survey as being poorly thought out.

3.14 Security Plant security matters were discussed during the survey. Surveyed licensees expressed the concern that security requirements are still producing problems between the operating and plant security staffs.

The problem of access to safety equipment remains an important issue.

3.15 Public Affairs The licensees often noted their perception that the correspondence between NRC and licensees has a con'sistent and unnecessary negative -

tone.

This tone pervades press re hases, enforcement correspondence, 7

orders, and requests for in nrmation.

The licensees assert that this tone has an adverse effect oi, morale not only of the corporate organ-ization and its public image a. a utility, but also at every level of the licensees organization, including the individual employee and his relationship with his neighbors.

3.16 Reporting Requirements The licensees regularly expressed their strong concerns over their view of a proliferation of uncoordinated and unnecessary reporting require-ments.

Apart from noting inconsistencies in reporting requirements applied to different functional areas, their largest concerns were the immediate reporting requirements of minor issues and the cascading effect of applying these requirements to.every state and local politi-cal subdivision.

To them this means the media.

The licensees offered a number of negative comments relative to their experience in using the Emergency Notification System, and their difficulties, including the time required, in transmitting information to NRC individuals that they felt were unfamiliar with plant operations and operational transients.

Such delays impact on their ability to make operational decisions and notifications to their own organizations.

4.0 SURVEY FINDING It is the finding, notwithstanding the competence and good intentions of the staff, that the pace and nature of regulatory actions have~ created a poten-tial safety problem of unknown dimensions.

5.0 CONCEPTUAL RECOMMENDATIONS Because of the seriousness of this matter and the nature of the comments-received, staff action may be necessary.

Accordingly, it is recommended that the staff evaluate this matter on a priority basis.

Conceptual recommendations were developed as natural reactions to reviewing the details of the survey. The recommendations are based not.only on the overall reaction to the comments obtained during the sur sey, but also on the knowledge and experience of participating NRC representatives.

These recommendations are intended to be informative and to indicate the shape and magnitude of the impact on regulatory policies and practices that could occur.

These conceptual recommendations, which are being considered in the staff evaluation of this survey, are provided below:

1.

The primary recommendation is that NRC take prompt action to bring the issuance of requirements "under better control." The word " require-ments" is used in the broadest sense.

2.

NRC safety priorities should be established at an early date.

Once NRC safety priorities have been established, the NRC should carefully consider, or reconsider, requirements in relationship to the time 8

required for implementation.

A greater degree of planning, flexi-bility, and stability in licensee organizations is needed.

3.

NRC should dedicate sufficient staff resources to assure the technical

~

adequacy and completeness of all requirements.

4.

NRC should expand and formalize the-various systems used to communicate with. licensees.

The system should be supplemented periodically by independent reviews conducted by senior NRC representatives.

5.

NRC should increase its sensitivity to people-related safety problems.

The negative safety impacts of many_ changes in designs,-procedures, and qualification requirements on all individuals and groups affected by regulatory actions shculd not be underestimated.

6.

NRC should establish a group, organizationally, to. provide official NRC interpretations of requirements that already exist, as well as those being proposed.

These interpretations should be disseminated period-ically to licensees so that licensees may depend on the interpretations for planning and resource expenditures.

A-system similar in purpose to the ASME Code case system is cited as an example.

t 7.

NRC should review its organizational structure and programs. This review should include consideration of changes that have taken place within the nuclear industry to avoid unnecessary duplication of effort between NRC, the nuclear industry, and other organizations.

9

,-e

APPENDIX A COMMENTS BY UTILITY REPRESENTATIVES MADE DURING THE NRC SAFETY IMPACT SURVEY 1.0

APPENDIX A COMMENTS BY UTILITY REPRESENTATIVES MADE DURING THE NRC SAFETY IMPACT SURVEY The following comments represent the comments provided by licensee represt.nta-tives.

No attempt has been made to rank comments by importance to safety or to evaluate the accuracy of the comments.

The comments are separated into sixteen general subject areas as a convenience to the reader and not as a means of iden-tifying importance levels.

An attempt was made to avoid repetition of comments; however, in cases where comments expressed other thoughts or were offered by the licensee in a different perspective, they were included in more than one subject area.

A key has been attached to this appendix to aid in identifying the NRC documents referred to in the comments.

1.

IMPOSITION OF REQUIREMENTS Licensees

• stated that, with regard to IE Bulletin 79-01B, there is'_a dead-line of June 30, 1982.

They believe the design criteria are not adequate and the guidance that exists is not sufficient to conduct a proper review in that time period.

Licensees reported that they have submitted responses-and comments three or four times with no response from NRC.

Licensees stated that NRC often requires " state-of-the-art" type of equip-ment that is not readily available or sufficiently tested for_use in the commercial area. An example given was main steam monitoring equipment.

NRC must not realize that licensees will have to calibrate such equipment-(main steam radiation monitoring) with 1000R sources.

To the licensees, it appeared that this requirement was not well thought out.

Some licensees felt that requiring an SRO to be in the control room full-time was overly restrictive and not fully thought out.

It was stated that it was beneficial to the plant to have an SR0 checking into things, helping other operators, and following major jobs going on.

The present situation with so much modification work going on was reported by licensees as being worse than the original construction period because work now interferes with reactor operations.

Construction workers are working around essential equipment.

T!wir work includes drilling and, in two recent cases, this caused a plant t.rio from full power.

These are between 200 and 300 workmen working full-time in the operating plant on NRC

• The word licensee (s) in this report can mean a licensed operator, a staff engineer, or a plant or corporate manager.

The term " licensees" is used for convenience.

11

Bulletins 79-14 and 79-02, fire protection and on the post accident sampling system.

In addition, the changes and modifications are being installed without plant personnel properly observing them.

A lot of work has to be done over.

There is too much work to be observed by a fixed number of qualified people.

Licensees stated that NUREGs-0700 and 0696, as well as Reg. Guide 1.97 are in conflict.

Primary system indications are required.. be safety grade in the control room whereas many other emergency-related indications are not safety grade in the technical support center (TSC) e d emergency operations facility (EOF).

Operators will not rely on nonsafety grade instrumentation while managers in the TSC will be making decisions on data less reliable than data in the control room.

Some licensees stated that there are cases in which different procedures and surveillance requirements occur at the same dual plant site for the same equipment because of different plant technical specifications.

The differ-ences are in administrative and surveillance requirements.

According to one group of managers, NRC has " lost sight of the forest because of the trees" in imposing new technical specifications.

The required amount of detail has approached the unreasonable level.

In a specific administrative example, it was stated that the format of the technical specifications changed six times in the last two years.

According to licensees, the real problem goes beyond the establishment of a requirement.

Once a requirement is established, the acceptance criterion becomes the major issue.

It can change the impact of the requirement enormously.

As an example, a criterion established by the NRC might be a safety factor of four.

The criterion might permit, in some cases, a safety factor of two.

If the licensee agrees to meet the safety factor of four, but in one or two cases has a safety factor of 1.9 instead of the acceptable 2.0, do they have to undertake major plant modifications? The problem is getting a reasonable interpretation.

Licensees described the basic problem as the number of requirements--the sheer number.

In addition to the sheer number, the administrative systems that must be established within a utility to handle, schedule and plan are nearly unachievable.

Senior engineers within one company said they were very frustrated and that there was a serious strain on their capabilities.

In the health physics (HP) area, NRC was said to have imposed' requirements that, in one case, tripled the requirements for the purchase, storage and maintenance of equipment.

Specifically, equipment that was purchased to be physically interchangeable such c..; (Scott) air packs, hoses, and connections cannot be used as intended because NRC requires individual system connec-tions, such as hose A must be used with equipment A must be used with con-nection A.

When a new regulation comes out, licensees stated that they are beginning to assume that it will change.

The " technical support center" and " post accident sampling" issues are examples.

It appears that holding off on the response and resource expenditure is a necessity.

They must wait for final 12

requirements.

This is caused, licensees say, by the fact that licensees have finite resources and that the number of existing requiremants prohibit restructuring schedules every month.

A general group comment was that the entire area of imposing regulatory-requirements is out of control.

The absence of design criteria, poor communications with the nuclear industry, lack of priorities, establishment of unrealistic schedules, lack of technical expertise on the staff in some areas, and changing acceptance criteria were cited as examples.

Also, issues or problems that have been well known for " ten" years have become instant or 30-day requirements.

NRC appears to be unaware of existing requirements when reactive requirements are issued.

In one licensee's cpinion, the NRC staff must believe that the licensee can provide almost any information at any time.

Recently, according to this licensee, it took the licensee 15 man-days to compile information verbally requested of the entire industry.

This related to the service time for emergency core cooling systems (ECCS) equipment.

If this were thought through beforehand, perhaps different plants or groups of plants could have provided the information.

Such requirements could be rotated if they were necessary.

A utility reported that they felt NRC does not recognize the safety and cost significance of backfitting.

They feel that the staff does not follow its own backfit rule.

Backfitting has cost more than some original plants.-

Some shutdowns for backfitting involve crews as large as those during construction.

Some licensee concerns were in the following areas:

there are inadequate engineering reviews of modifications (their own and those of NRC); the simplicity of original designs (and operation) is compromised or lost; retraining and procedural changes are serious safety problems; there is limited room left in some plants for modifications and additions; design margins are being used up; there is more equipment in the back of control room panels than in the front; the cumulative effect oi cut, fix, and weld is hurting the plants and their operation, and there is a general feeling of overcommitment and frustration.

Problems of imposing requirements is not limited to NRC, according to one licensee.

Plant staff personnel feel that their corporate staff was guilty of many problems in the area of accepting NRC requirements so readily.

They said that they certainly could have done a better job of negotiating schedules, time, and actual equipment capability.

The following specific statements are included'to demonstrate the range and diversity of licensee comments on this general subject:

NRC safety priorities must be established before order can be brought-to the requirement problem.

In many creas NRC requirements have caused plants to be unsafe.

This applies to diesel testing, modifications conducted while plants are operating seismic requirements with regard to the problem of ;tif-fening sat 9ty-related piping systems, and large number of changes in important m erating and emergency procedures.

13

NRC must stop requiring implementation of requirements before the actual requirements are fixed.

It was recommended that, as much as possible, NRC set the requirements so that the utilities can plan and schedule within certain constraints.

It appears that NRC, to a large degree, is improperly responding to external stimuli when imposing requirements.

With regard to resource application, useful NRC interpretations or positions on technical issues are hard to come by.

The nuclear industry is a commercial industry.

They need a work horse, not a race horse.

We have not been able to perform many of our own initiated plant modifications to improve reliability or safety.

We have really been forced to postpone a good percentage of required balance of plant maintenance items.

Items such as personnel safety, cost benefit improvements, plant upgrades, and reliability improvements, take second place to every single NRC requirement.

The long-term cumulative effect will have a definite impact on nuclear safety.

We are really required to commit to NRC requirements, including sched-ules, prior to a full understanding of that requirement.

This is intimidation.

NRC is issuing descriptive requirements in narrow bands.

It is very difficult for utilities to integrate them.

NRC must do more integra-tion of requirements.

NUREGs appear to be generated as a result of an incident or an event.

i NRC seems to convert the event into a generic situation.

The problem and solutions then apply to everyone to the same degree.

Requirement criteria are often nebulous.

The hydrogen issue is a good example.

1 Almost all NRC requirements are, in themselves, honest safety upgrades.

Individual items are not the problem.

The problem is the volume of requirements and the lack of safety priorities.

There is a serious lack of integration of technical requirements.

This problem has a considerable amplification factor within each licensee organization.

The overall system is poorly managed.

The entire area of licensee commitments (versus requirements) will have to be resolved soon.

Some commitments are ten years old.

Also, please clarify the definition of a requirement.

Why isn't the tackfitting regulation fully complied with _by the NRC?

Flexibility for licensees must be built somehow into NRC requirements.

NRC is totally controlling our resources.

14

i I

Theoretically, new requirements should reduce or change some older requirements; however, we don't recall any requirements that were reduced.

NRC does a lot of referencing in their letters.

Some of the refer-encing is not applicable and some important references are not stated.

It makes one wonder whether NRC management is sufficiently familiar with NRC requirements.

Are bulletins and other reactive requirements being meticulously incorporated into construction permits and technical specifications as required?

NRC issued a requirement in a bulletin to test matrix relays every ten days.

One plant has been testing them and has had zero failures. Why must this testing continue?

Real operational and design reviews are being delayed because no other actions are possible due to getting NRC requirements completed.

We are too busy to really help ourselves.

As we see it, NRC better be right about the requirements.

The standard technical specifications require significantly more licensee reports.

The public. image of a plant that has standard technical specifications is much worse than the image of a plant with

" older technical specifications."

It seems that everything has to be new.

Specifically, two similar plants were ordered.

Notwithstanding, a new NRR review scheme was required for the second plant.

It is recognized that bulletins and orders appear to be subsiding in numbers somewhat; however, the impact of those issued, especially the recently issued, continues and will continue for years.

NUREG-0761 addresses the development of a radiation protection plan.

NRC is requiring a rearrangement of paper.

This entire effort will cost us over a year's worth of work for nothing.

The technical specifications, including referenced requirements, continually grow.

Technical specifications are looked upon more as a trap than as safety requirements.

We are making a plea for a more in-depth NRC review of requirements before they are issued.

It appears to us that they are not being effectively managed.

There continues to be a preoccupation by NRC with large breaks.

This is evidenced by the requirements of IEB 79-01B.

The practice of stuffing requirements into licenses penalizes everyone.

The proper system of imposing requirements is seriously compromised.

It is intimidation.

15

The numbers and extent of NRC requirements have necessitated going to architect-engineers (A/Es) for a large amount of work such as IEB 79-02 (anchor bolts and base plates) and IEB 79-14 (as built piping and supports), Appendix R analyses, and scram discharge piping concerns.

Licensees are competing within their own organization for A/Es finite and strained resources.

Their engineers have become coordinators.

They are losing touch and buying work, in some cases, of poorer quality.

Opportunities exist to combine related issues such a:, IEB 79-01B, Regulatory Guide 1.97, NUREG-0696 and -0700.

NRC grossly underesti-mates their inact.

If they do one job poorly, it shakes the entire industry. We want them to do a better job.

NRC requirements (e.g., NUREG-0737, bulletins, generic letters, Appendix R) frequently overlap and conflict.

NRC needs someone to provide interpretations of requirements and to provide resolution of conflicts.

Some licensees assign each new requirement to a different project engineer, perhaps like NRC, who then later finds a need to redesign as new requirements come in or as other project engineers resolve their conflicts.

It is our feeling that many technical specifications are issued merely i

for the administrative convenience of NRC.

Consideration of the impact on the licensee's training, procedural changes, and administrative systems and costs appears to be minor.

The requirement to update the FSARs is of no benefit to the plants.

It will take five staff years for one plant to effect this change.

This will require five of our best people.

The benefit seems to be primarily for NRC.

A good example of a bad requirement is ths Westinghouse rotor problem.

When cracks were observed in Westinghouse rotors, NRC moved too fast, and even required inspection of GE rotors.

This was unjustified and caused extetsive resources to be applied unnecessari!,,

The resources were not applied when they should have been.

NRC does not fully appreciate the fact that different issues affect different plants in different ways.

NRC forces all issues to be looked at the same way, at a?1 plants, and on the same time schedule.

The helter-skelter issuance of N'JREGs and bulletins (with their sup-plements) makes it difficult for any licensee to integrate related changes, to reduce costs and to set reasonable schedules.

The effect is magnified when one considers the industry as a whole.

The utility would prefer to use their engineering staff on high safety impact issues rather than tight schedule responses to NRC actions, i

We have found that if we put all NRC requirements into our specifi-s cations for purchasing equiptient (e.g., 10 CFR 21, EEQ), we receive no bids.

Licensees have been told by several major '/endors that they will not supply equipment to meet those specifications.

NRC knows and ignores this.

16

NRC is stuffing the technical specifications with NUREGs. 'The techni-cal specifications and the licensing process are being used as mecha-nisms for imposing " nice to have" requirements and commitments. We have no real choice.

Vendors are getting away with " murder."

It sometimes seems they work with the NRC to get requirements from the staff to benefit themselves.

NRC does not do a good job of evaluating the actually expected releases during accidents.

An identified subject area related to the form of iodine that may be released in an accident.

This requirement, unstable Grid Automatic Trip, is making plants less safe in that an automatic trip in an unstable grid condition may cause other nuclear plants on the grid to experience an even more unstable grid condition.

A cascading effect could result.

In the Browns Ferry scram problem, discussed in IE Bulletin 81-17, NRC insisted on state-of-the-art equipment (UT) to determine scram dis-charge volume water level.

No judgment was permitted by licensees, it was mandated.

There are many NRC technical specification amendments that have been sitting with NRC for years.

These, if issued, could help operations and technical evaluations by licensees.

Examples included core reload evaluations and inservice inspection (ISI).

Many of these pending amendments are correcting errors and, because they have not been issued, cause our technical manpower to be incfficiently applied.

NRC requires many anticipated trip settings at low power even though this creates transients.

NRC does not appear to 'isten to licensees regarding these types of problems. We have almost given up trying.

There are technical specifications on grid voltage.

The approach being taken by NRC seems to be a safety problem in itself.

It has not been thought through.

The answer to every problem is not to scram the plant.

The pace of licensing is such that NRR is no longer _ paying attention to reasonable approaches and, in some cases, safer approaches to problems.

A comment one licensee recently received from NRC seemed to have the tone of "we don't have time to review it, just send us what we need."

Ratcheting by NRC between utilities is prevalent, such as, "They do it, therefore you have to do it."

The NRC staff focuses on generic solutions for all problems.

' ey i.

ratchet a'l plants to one level--the level of requiring a standard "fix" for all.

The standard is the fix for the " biggest" problem plant on a sche 1ule fit for the." fattest" utility.

Total 19ss of power is an issue that has not been properly thought out by NRL 17

4 2.

COMMUNICATIONS Communications with NRC were reported to be poor.

Licensees feel the dialogue must improve since there is a growing degree of dircrust on both sides.

Examples provided included the issuance of unnecessc y confirmatory i

orders; investigations and subsequent enforcement actions ageinst individu-als; and the submittal of routine responsee under oath or af;irmation.

Licensees feel that NRC is not responsive to their comments, does not listen, and, if it does listen, it does not take the time to fully under-stand the comments.

This feeling, they stated, is amplified by the lack of acknowledgements or, if acknowledged, by the tone of responses.

Their view was that NRC is more responsive to individuals and groups who have little competence in the nuclear area.

1 i

Licensees say they need clear communication channels within the NRC organi-zation to get formal and reasonable NRC interpretations or positions that utilities can rely on before committing scarce resources.

Statements were made such as--we (licensees) cannot get an answer from the NRC; the authority within the NRC to really decide an issue is hard to find; we are often afraid to ask a question because all we will get is an unrealistic answer; and if we wait two years the answer may be reasonable but it may also be too late.

The problem they say is amplified because communications between technical groups withi'i NRC are poor.

Licensees at one facility said they receive at least one piece of paper a day from NRC requesting some action.

Many of these documents request j

information that is already available to the NRC staff.

Licensees view the or not understanding NRC staff as either never reading information provided, ieadily available.

the information provided, of not having the information The following specific statemeats are included to demonstrate the range and diversity of licensee comments on this general subject:

The use of certain phrases and definitions by the NRC has become very important.

A licensee stated they need a consultant tc interpret the rtquirement.

For example, a comment in NUREG-0737 was that " authorized individuals" should do certain things.

The connotation among some licensees is that a licensed operator is not good enough.

NRR obtains a lot of information that it does not even read.

One-half of what is submitted is not read.

l In addition to NRC's problems in communicating with licensees, licensee corporate offices do not have time to communicate with their plants.

The reverse is also true and-is also serious.

The architect-engineers are making a large amount of money on inter-preting the rules.

Is this really a role of the architect-engineers or i

should the rules be properly articulated by the NRC?

1 18

Our company is afraid to complain on safety issues.

They believe that NRC does not really understand and that its image of being " pro-safety" may be tarnished if they complain.

NRC needs more upfront communication with the licensees and a contin-uous reassessment process for establishing priorities.

One licensee reported that they submitted a letter to NRC relating to the requirements of Appendix J.

It took two and one-half years to get.

a response from NRC.

It would appear that before NRC starts a major study program at all utilities there should be some broad discussions with industry.

An example would be the recently completed HP appraisal program.

A large utility said they receive well over 1,000 documents per year from NRC requiring response or some type of action.

There is a significant and unnecessary negative tone in NRC letters and reports.

NRC's participation in industry committees has been cut back.

NRC participation means participation by individuals who have appropriate authority and could affect subsequent decisions.

It is very difficult, approaching the impossible, to get a reasonable answer from NRC--an answer that NRC will stand by.

3.

PLANNING AND SCHEDULING Experienced licensee managers report they do not remember when they last set-a due date.

They felt that they work full time for the NRC and that they can no longer plan or schedule.

They say they cannot remember when they last initiated a plant improvement or modification on their own.

By neces-sity, they report, they are driven by NRC requirements and NRC schedules.

Planned maintenance of important equipment suffers. The safety of their operation, due to their direct involvement, reportedly was neglected.

Such I

action is being left to other, less qualified people.

According to several licensee managers, NRC does not live in the real world of planning and scheduling.

They feel that the staff's basic assumptions are that a utility has infinite resources and no scheduling problems.

The staff does not realize that licensees are, in fact, intimidated.

They say they must react to, or commit to, drafts and unapproved guidance in order to "get a license" or to " minimize costly backfitting."

"What is an NRC requirement" has become, for many licensees, 'an academic.

discussion.

Licensees who move promptly on an NRC identified safety issue believe they often suffer from subsequent NRC requirements, with consider-able waste of important resources in technical talent and money.

Licensees are of the opinion that each NRC group believes its own area to be the most important. The more groups involved, the bigger the problem.

The utility is unable to set its own priorities.

Commitments to NRC due dates, 19

licensees say, put them at a disadvantage and normally result in a poorer, more costly product.

Several utility managers feel there is insufficient interaction between the utility and NRC on a plant basis.

They further feel that there is diffi-culty in getting a decision when a question arises.

It was suggested that IE field people should be more vocal in feedback to NRR on design changes.

Many operators addressed the anchor bolt, seismic, sampling system, fire protection, emergency planning, and, specifically, the technical support center modifications as examples of problems associated with the short time frame allowed to accomolish plant modifications.

They indicated that the massive amount of. work requires extensive contracting out, which results in untrained personnel working around essential equipment and substantial housekeeping problems throughout the plant.

They also identified the extensive modifications as making human engineering of the control boards virtually impossible.

Because of the time constraints on planning asso-ciated with modifications, many of the modifications have to be redone.

Licensees make a strong plea for NRC to establish a priority system.

They also plea for prioritization to complete NRC high safety impact items before final resolutions of NRC low safety impact issues.

One comment was that it must be recognized that licensees are running out or have run out of good people.

The licensees believe this is caused by many things, but high on the list would be the lack of priority and inability to permit reasonable scheduling and planning.

One licensee observed that there has been a major accumulation of technical specification change requests within NRR.

There would be more active complaints but they felt intimidated in that the processing of change requests could detract from licensing effort.

The vessel level measurement requirement was a subject of concern to one licensee.

The licensee stated that in September 1979 they received an order that this was to be accomplished by January 1, 1981.

Essentially this allowed for no advance planning.

The licensee went ahead and purchased the equipment and let a contract for installation.

Subsequent to the action, NRC changed the schedule, allowing an additional two years for completion of the modification.

This resulted in the licensee exptnding approximately

$1,000,000 on a relatively poor design, whereas the new design would cost about $100,000 per unit.

The loss of some of their key peoale on this project was costly to them during this period.

Utilities were concerned about environmental qualifications.

Environ-mentally qualified equipment is to be installed by June 30, 1982.

It was stated that the date can't possibly be met in that qu'alified equipment cannot be purchased by then.

It was suggested that NRC talk to industry personnel to establish a realistic schedule prior to imposition of schedule dates.

The need for prioritization of requirements and scheduling for specific plants was of concern !.o many licensees.

It was pointed out that, even

~

though a plant is not in a seismically active area, several actions by NRC have cost considerable resources both in dollars and manrem exposures.

20

The anchor bolt bulletin (IEB 79-02) at one plant reportedly required an expenditure of $4,500,000 and 365 manrem exposures.

Likewise, the seismic support bulletin (TEB 79-14) required an expenditure of $14,000,000 and 119 manrem exposures su fu.

Several licensees stated that the completion schedules for NRC requirenents are totally unrealistic to permit proper installation, testing, and training.

The frequently heard comment "come in for a change and you can receive an extension" was not, in their opinion, a proper mode of operation for the licensee or NRC.

The follow)ng specific statements are included to demonstrate the range and diversity of licensee comments on this general subject:

Utilities who drag their feet save money.

Utilities who jump in to fix a crisis problem generally apply excessive resources when such applica-tion was actually not required.

Security lighting at a cost of $1,000,000 per plant was double the cost if accomplished on a reasonable schedule.

It was pointed out that the same request, loss of all power, went to each power pla:1. without regard to the intertie differences between various plants.

It was requested that all imposed requirements be integrated from a resource standpoint and be imposed consistent with safety priorities.

NRC must stop providing a moving target and requiring implementation before the requirements are fixed.

A very high percentage of the engineering staff is performing NRC required modifications and related design work.

Little or no routine preventive or corporation planned work is being done.

Key supervisors are working full time to meet NRC schedules; known plant problems are not being corrected (pumps requiring maintenance at 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> versus pumps receiving maintenance at 2,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />).

Installation by forced schedule dates frequently results in less-than-desired design methods due to installation of available equipment which is frequently not tha desired equipment.

The block wall requirement is a " good" or " bad" example.

Our design fix interferes with operator access to equipment.

4.

IMPACT OF REQUIREMENTS A utility plant technical staff is reportedly now spending about 60% of their time, versus a normal expenditure of 40%, on regulatory issues.

It was noted, for example, in the administrative area that for the last two years three clerk-typists were used full-time just to type procedure changes for one site.

One licensee expressed serious concern that there are a large number of audits being conducted on licensed operations.

These include ANI, INPO, 21

Aiwi, the licensee's QA crganization, PAT, NER audits, NES audits, and the ncrual inspection and enforcerent tregrau. The substantial incact.cn tne licensee's cperations aust be reccqnized.

Scee organizaticns aust recogrize the tereficial ef'ects of other audits or revie.s. Optimizatica here wculd save rescurces for teth NiC ar4 licensees ard permit the acceeclistment of '

0;ter necessarj cbjectives.

A licensee nanager said that the sany MC crash prcgrass sericusly interfere witn a ry type of planning, there being very little integration of require-rents.

j

\\

Licensees stated that VJREG-0523 has been very ceranding en tne utilities.

One millica staff-hours were experded for one utility. Inis'invcived nany key licensee perscnnel and centractors.

Even thcugh this effort was exper4ad, licensees, in general, dc not telieve t5ey will be able to meet all the provisicas of MEG-0558 by June 1532.

Cne utility was especially concerred atcut the require:ent for determining

.ater levels in reactor vessels fcr pressurized water reacters. _ This was cascrited as an exaple of a crisis requirement.

In Septencer 1979, cper--

atir.g reactors were ordered to ccro~ett be installation by January 1,1531.

There was no nethcd availatle to ccelete this recuiresent. Millicas cf deliars anc considerable engineerirg and technical talent were applied to this project by all utilities.

A large percentage of this was vasted. MC recently exteried tre schedule by adding alzost ancther two years to the required cosoleticn tire.

This helps, of course, but it cannot excuse the

.i wasted effort ax failure to accceplish other things that were unnecessarily cancelled due to this

• crisis" requirezent.

With regard to envircrcental palifications, licensees were concerned that definitive design criteria have ret been provided ccamensurate with the June 30,1982 deadline.

They ctserved that SERs rcv contain screvgali--

fied ccopcrents tnan were criginally succitted by licensees, and deadlines are backing p cn these ccepcrents that shculd already be in the analysis /

procurenent cycle. One facility has two very different SERs because the t o units were revie-ed by different NiC crganizaticas.

Licensees state that there is a need to seet and resolve the differerces.- They are also' con-cerned over the nild eraircement require:ent and fear that MC dces ret

-I understand the scc;e T.,f the issue.

The conversion to the standard technical specificatica has serious ar4 cegative safety iglicaticns. Vnen the MC finally gets around to issuing -

standard technical specifications, they are effective insediately.

Licen-sees assa:e everycne kne.s that their docunents sit around for years in the MC. Because tre technical specification changes are substantive, the ircact on the plant is irneciate and encrzeus.

Also, in the preparatica of the standard technical specifications, the licensee's very test pecple zust work on that. These pecple are just not available for otner activities.

Tre sedificatico cf cid procecures, the develcpeent of new procedures, and the training of the entire plant staff to neet the stardard technical scecification are very rescurce-desanding tasks.

The incact on cperaters -

w c have vrked fcr years u-4er cne set of requirerents rest be grossly creerestinated !.ry NiC.

22

~ 2-

One licensee teported they felt that they were compromising safety as the result of NRC mandated requirements.

Some exhmples provided were: 'they have not put enough effort on improving our reliability; they have not paid adequate attention to the actual conduct and evaluTtion of surveillance testing to reduce down-time and to improve eff ciency; their emergenc, operating pro:edures are not as good as they should be; and they have not-been able to pay enough attention to real human factor considerations.

The licensee noted that, with regard to NRL Bulletin 79-14, they have already expended $20,000,000 and received 120 man-rems of exposures.

Some licensees feel that the high costs of ~ sone NRC require.nents must not be known to NRC, even by people who are obviously well experienced in construc-tion.

One licensee used the following as an example; our design finds that a fillet weld is totally acceptable.

In this case, they felt that NRC would probably not accept a fille' e'd and decided to specify a full penetration weld.

This program require-aen hold points.

Each held point costs resources.

According to ole licensee, there were 450 procedural changes at their plant in 1980.

So f6r in 1981, there have been 205 procedural changes.

The operators stated it was virtually impossible for people to keep _up with current requirements.

Therefore, whenever they are conducting an operation, they report that they have to read procedures line by line in order to make sure the operation is dote consistent with procedures.

Likewise, the procedures vere reportedly becoming much more complex.

As an example, they cited cn example in which they were injecting for 16 minutes with ECCS when it could have been terminated in 1 minute; it took that long to complete the procedure.

This, in turn, caused the usage of 2 thermal cycles on the reactor vessel nozzle, 50 life-time cycles are allowed, before the procedure and training were fully undarstood and completed.

One licensee stated that at one station 15 bulletins were received during 1980 that required $26,000,000 for modifications or changes, $16,000,000 of whu.n was for contractor engineering.

Likewise, notices and circulars have cost $3,000,000.

Ore study cost $2,000,000 for contractor engineering support.

In additicn, approximately 10 to 12 staff years of engineering from the corporate office was necessary.

Relative to the Three Mile Island 1teme about $18,000,000 was required through 1981.

The long-term expendi-tures were estimated to be about $74,000,000, not including the degraded ccre aspect.

For some licensees taere is a growing problem with the preparation and shioment of low-level radioactive waste.

They stated that they run into maay problems with acceptance criteria and there is little evidence of national solutions.

In fact, some licensees believe NRC 4 making the problem even more difficult in its interpretations of exbting rules and regulations. The industry feels that it needs several.,ptions, and that this is a major problem NRC should resolve.

The following specific statements are included to demonstrate the range and diversity of licensee comments on this general subject:

NUREG-0096 is considered to be the biggest bureaucratic boondoggle that ever occurred.

The costs are enormous and of limited value.

23

We are over-building because of the' lack'of.NRC criteria or the lack of time to permit more sophisticated analyses.

Because there are so many requirements, the practice or orientation of plant personnel is to key on requirements rather than on safety.

The large volume of requirements necessitate that approach.

There is a concern that IE Bulletin 79-14 is causing the piping systems to become too rigid.

Also, the changes that were implemented will have a major negative impact on ALARA.

The TMI event and the response by NRC to TMI created'a loss of confi-dence in their own plants by operators.

All our nuclear safety people are fully committed to NRC required activities.

IE Bulletin 79-01B has used up all of our electrical resources except for several power people.

The next " crisis request" is a disaster of priorities.

We have no one left who is not dedicated to meeting NRC requirements.

Because NRC focuses so heavily on the issuance of an operating license, they tie up all key nuclear safety people in utilities' organization.

We believe this focus adversely affects safety in that the nuclear safety people should be involved with the plant at this time.

NRC should focus on such issues much earlier in the licensing stage.

The entire subject of the retention of records is becoming a major resource problem.

Is it necessary to retain all these records?

The problems in backfitting were reported to be enormous.

For example, a licensee stated that in putting in new base plates for piping sup-ports, they had to drill ten holes for every good one because the rebar was so close together.

There is the general feeling of over-commitment in the broad area of instrumentation and cable separation.

There is a serious concern for the safety of piping systems.

The number of pipe supports may cause a serious accident--one we have designed into the plants.

l l

There is a negative impact, due to the totality of NRC activities, on j

the morale of licensed operators.

The negative impact on the morale of j

nuclear engineers, supervisors, and managers is less significant, but l

important.

A licensee stated that they have already spent 3,000 staff-hours on EEQ.

The lack of safety priorities is a serious and almost overpower-ing nuclear safety problem.

NRC should realize that there is very little room left in the plants.

Many plants are already too complex even to walk around in.

i 24 i

i l

NRC cannot appreciate what they are doing to construction.

The routine of stop, add, and subtract, is a serious problem. We are short on available space just to meet the needs for rewiring, reinforcing walls, ventilation, maintenance, air conditioning, seismic, supports, etc.

The list goes on.

We have initiated 300 engineering change notices caused by NRC commit-ments that must be implemented in fiscal year 1961 through fiscal year 1983.

This excludes all the impact from IEB 79-01B.

The caliber of our responses to NRC is down in that.we don't have suf-ficient resource's to properly review them.

We have no time to respond to the many requests for comments from NRC.

NRC assumes that we have few or no problems.

This is absolutely untrue.

NRC commitment modifications are projected to result in $115,000,000 in-implementing costs.

This represents 45% of the total budget for all modifications.

Maintenance-related improvements are cancelled or postponed.

Utility operating staffs.(mostly crews) are less permanent in their makeup because new requirements have been imposed on R0s and SR0s; e.g., staff upgrading, more training topics, degree requirements pending, increased grade standards on examinations, and new plant modifications.

Overtime is the only available solution of value.

Other solutions, using less qualified people, adversely affect-safety.

There is a strong feeling within the industry that the proliferation of ~

audits at all levels by all organizations must be controlled.

It is difficult for the industry to control this without help from NRC.

It is not an anti-safety feeling, but it appears to be hard to convince NRC.

Nuclear plant reliability data system (NPRDS) is a continuing concern.

We are bothered by this in that all plants because of their different ages have different pedigree data.

This could be a very resource-intensive problem when standard NPRDS requirements are imposed'on all plants.

The reactors are becoming very complex.

Also, many patch jobs are performed on them.

The complexity of the patch jobs coupled with the frustration of the operators is becoming a serious safety problem.

There has been a major diversion of resources toward details at the expense of the big picture.

The large number of requirements and the short times.llowed for implementation have resulted in designs that are not as good as they should be.

The caliber and enthusiasm of the professional staffs, technically and administratively, are down.

An example cited was that changes to one instruction entailed 30 engineering staff-hours.

The generation of more and more paper and forms resulting from requirements impacts safety.

25

It appears that the INP0 evaluations could somehow replace or reduce some of the PAT management reviews.

The post-accident sampling modification at one facility cost

$10,000,000.

It will take four years to fully complete.

During the last outage, 50% of the modifications made were regulatory requirements.

The modifications were made in 47 different areas.

Some of the requirements NRC has imposed or considered have come close to shutting down the industry without NRC appreciating the problem.

Examples in this category are the EEQ issue and the issue of loss of power.

The inability to effect changes in our technical specifications seri-ously and negatively affects our resources.

The amount of licensee time involved in,reparing responses to bulle-tins was grossly underestimated by NRC.

NRC has no idea of the impact this has on design, construction, and personnel.

The short turnaround time permitted for licensees to respond to NRC correspondence is administratively overwhelming.

Licensees are never out of the situation of "today being all the time allowed."

The criteria often come out after the work is done.

This creates the need for rework and backfitting.

The resulting costs and demands on resources are excessive.

This means, of course, that a lot of work that could have been done is not done.

Utilities are using 80% of engineering manpower responding to NRC-imposed requirements.

IE Bulletins 79-02, 79-07, and 79-14 have used up 80% of all our civil engineering resources.

The masonry wall problem used up the remainder.

IE Bulletin 79-14 may not be effectively accomplished during construc-tion because no qualified ceople remain, including architect-engineers and contractors.

Some of the information NRC is requiring in the TMI Action Plan is nice to know rather than necessary to know.

An example would be the reactor vessel water level.

We believe that measurenent of the actual level in a PWR is still very speculative.

Another example is the steam line radiation monitor.

We have made no modifications on our own initiative for a considerable period of time. We believe that many_of these modifications would enhance nuclear safety; however, our resources are limited to accom-plishing NRC requirements within prescribed times.

Design support is not adequately provided to the operating plants.

26

IEB 79-01B cannot be completed by the required time, June 30, 1982.

Mid-1983 would be our best estimate.

The problems at B&W plants to prevent TMI events have not been properly analyzed by NRC with regard to imposing requirements.

Specifically, the setting pressure for relief valves has a negative safety impact.

This is an example of a " cop-out" by the licensee,-the vendor, and NRC.

We have not put enough effort in improving reliability.

We have not paid adequate attention to the' actual conduct and evalua-tion of surveillance testing to reduce downtime and to improve eff_i-ciency.

Our emergency operating procedures are not as good as they should be.

We have not been able to pay enough ati,ention to them.

5.

TRAINING AND OPERATOR QUALIFICATIONS Some licensees feel that no human factors were applied to training require-ments.

There was a strong feeling of instability and frustration among licensed operators.

They are fully aware of the Commission papers, pro-posals, and feelings of where NRC wants the licensed operator to be aca-demically in the year 1986.

Many operators feel that NRC examiners have to fail a percentage of the applicants and that the grading is poor.

They doubt that an appeal of test results will be handled in a " fair manner."

It appears to operators that the appeal process only supports-the examiner who grades the tests.

Licensed operators say they are constantly studying for examinations.

Nonlicensed operators see this and many.of them do not want to have any part of such a career and, as a result,_the attrition rate is high.

Many operators consider NRC licensing examinations to have serious draw-backs.

Comments included the following:

there_is too much training on theory and not enough on systems; there is not enough tailoring of issues to specific plants; the actual conduct of examinations adversely affects the morale of operators, specifically, essay questions should be eliminated; the results of simulator examinations should be promptly provided to the opera-tor (not six months ~1ater); the results of plant walkthroughs should be provided promptly to the operator (not six months later); the results of oral examinations should be promptly provided to the operator (not six months later).

No reasons for delays were evidut in their opinions.

A serious comment made by one group of operators was the following:

The day a licensee receives an " unsatisfactory result" the operator must be immediately removed from shif t work, no matter how close he came or even if it is under appeal.

The delay in reporting the exam-ination results by NRC may have been six months.

The licensee has to take the now " unqualified" man off shift.

Do they appreciate this problem? Also, this results in overtime - 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per day for other people who are qualified to cover for him.

Of course, the now 27

" unqualified' man is eliminated from bonuses and premium pay for-being a licensed person.

One licensee stated that, in his opinion, the new kids coming into the training center cannot even change a tire.

None of the new trainees will stay on shift work.

They are replacing experienced personnel with mechan-ical and electrical abilities, with a "cegreed kid." Today's' graduates of the training school feel that they are coing to manage the utility.

That is their entire attitude.

To really learn to operate equipment is a minor and unimportant function, according to this licensee.

Operators all expressed strong feelings regarding training and qualifica-tions.

Operators feel NRC should eliminate the three-month observations for prospective SR0s in a nonproductive capacity in the control room. Moving from R0 to SR0 reflects an increase in a supervisory capacity.

The commit-ment should be in terms of supervisory training and management skill training.

School requirements no longer involve a brief time.

The total time required is three years for an SRO.

Requalification training and similar training counts for one year out of every ten years.

When a plant 2

staffing plan is generated, it must allow double the number normally required just to' account for lost rmoductive time. When current personnel losses are considered, the ratio is closer to triple.

The overall effect of increased educational requirements, in reality, has been a reduction of practical experience levels on shift in the plant.

This has created man-power shortages that have created frustration and job dissatisfaction.

There has been a very clear acceleration of losses of experienced personnel' from the industry.

There is a great need for overtime.

The resulting_

problems with overtime are amplified by NRC training requirements.

Licen-sees believe they are training at an unbelievable rate.

There appears to be no clear-cut qualification goal--there is no stability or understanding.

This is very frustrating.

They assert that NRC's role should be to establish criteria and objectives and to utilize its examination program as the final determinant.

They believe that the approach described in Commission Paper 81-84 will reduce rather than improve the quality of licensed operators.

The following specific statements are included to demonstrate the range and diversity of licensee comments on this general subject:

Human factors, with regard to NRC actions in the areas of training and l

operator qualifications, are not being practiced.

i The use of simulators is highly recommended.

Simulators must represent the actual plant and must behave the same as the artual plant during transients as well as during the maximum credible accident.

NRC should be well aware cf the fact that the level of training does, in fact, affect the caliber of talent on specific ~ shifts.

Job stability and career progression are of serious concern to all operators.

In their minds, their futures are unpredictable and, if they listen to rumors, not bright.

28

4 I don't believe that anyone would ever become or try to become an R0 if he thought he could not move up.

Fire brigade traini_ng occurs too frequently and is not practical.

Frequent plant modifications make it difficult to remember what is correct.

Doubt is now in the control room.

New plant recruiting standards impact on safety.

One plant is hiring only degreed people.

Who provides the dedicated hardware knowledgeable people? Soiiie licensees are recruiting current R0s and SR0s from other licensees by offering two years of college before being licensed on the new facility.

The requirement for R0s and SR0s to continuously be retrained in HP when the plant has an entire HP department to handl.e these problems is incorrect and poorly thought out.

At one plant, it was stated that "we train for the license exam," and then they say "now we're going to teach you how to operate the plant."

The 60 credit hours of technical training is too burdensome for the benefit it gives.

One Shift Supervisor said he is on a three-month cycle, three months in the plant and three months in' college. When j

they come back, they feel like a recruit.

Plant changes that require procedural changes do not allow enough time-to " unlearn" the old and " learn" the new before they are faced with using the new.

More time should be given to unlearn the old.

Step-by-step following of procedures is too restrictive.

There is no allowance for on-the-spot temporary changes of little significance.

Educational requirements (permanent STAS) of people on shift have overextended our operational staff by taking away some of the people who had performed very important safety functions.

Important' work was left for the rest of an already overtaxed staff.

There apparently was no evaluation of this impact.

The operations examinations are awesome to nonlicensed personnel.

Some qualified individuals will just not suLmit to the examination.

The feeling among the operators in our plant is that NRC has to fail some, no matter how well they are trained.

The operators indicated that it would be very difficult to attract graduate engineers to serve in a shift work capacity. They indicated that the exam material is too theoretical and requires a knowledge not

.aquired for plant operations.

An example used was the six factor formula.

6.

NRC ORGANIZATION NRC offices and branches were judged by the licensees to be competitive among themselves.

Poor communications were thought to exist betwaen and 29

I within the branches. Other comments were that all branches consider them-selves most important to safety.

Security branch personnel, radiation protection personnel, and quality assurance personnel all consider them-selves most important.

Together they have the industry on a treadmill.

Each branch seems to have a blank check and each gets "its own piece of flesh."_ For example, on the BWR scram proble.n, NRC issued 15 letters, seven from M ad eight from NRR.

Licensees believe NRC'is technically overwhelmed with coordination between groups and within groups.

An example related was one in which a utility submitted a request to amend its license to modify spent fuel racks.

The request was approved.

Shortly thernfter, another utility submitted the identical request that was dissapp oved.

Licensees all stated that NRC has to clear up many unreviewed items.

Many items in NRC's hands are safety upgrades, that cannot be implemented by licensees until NRC approves them.

Several licensees felt that IE resident inspectors and NRR project managers were not as familiar with requirements as the Regional Office and NRR specialty staffs.

This causes problems in that their guidance on important issues is not adequate.

Licensees believe the SALP program should be more constructive rather than negative with regard to licensees.

They feel that SALP reports can create serious morale problems within a utility and unnecessary public anxiety.

The following specific statements are included to demonstrate the range and 4

diversity of licensee comments on this general subject:

NRC staff effort and resources appear inadequate to present technical issues to the Commission on specific cases.

NRC has a casual attitude toward industry problems.

There is a lot of regulation by intimidation.

This is particularly evident when the utility has a facility approaching the operating licensing stage.

Licensees are afraid to disagree because of possible consequences.

The SALP program, although there appear to be positive benefits to both the licensee and NRC, is a subjective way of intiridating licensees.

Comments made by various staff members, although tney cannot be justi-fied, may readily appear in reports that receive national attention.

The image we have on some technical issues is that NRC technical staff does not make the decisions.

Nontechnical managers and politicians are-making important technical decisions.

An individual with real authority, oiie who can decide an issue, is hard to find in NRC.

Over the last decade, licensees have observed significant changes in NRC.

In the first b;1f of the seventies, NRC engineerir.g staff 30

appeared to be quite good.

In the latter part of the seventies, the quality of engineering was quite bad.

The perfor: nance of the engi-neering staff, although better at present, still has a way to.30.

6 The Mcensing project managers appear to have lost control of the licensing process.

A project manager needs authority.

The NRC staff appears to be unduly " afraid" of any dissenter with an overly conservative point.

They seem unable to face up and rcly on their engineering backgrounds and experiences.

NRC appears to overreact to every problem.

This is evident when one compares information pertaining to NRC's immediate reaction, with the final action taken.

There is distrust between NRC and the industry.

For example, it appears that comments AIF makes are taken with a grain of salt.

Under the NRC organization, the special discipline branches are uncoor-dinated.

It becomes a major problem for licensees when one NRC man is promoted, retires, or is transferred.

In some cases, the reviews start all over again.

It appears that NRC workers, their supervisors and their managers are not held fully responsible for their actions.

NRC organizational units create problems.

They do not appear to be managerially controlled.

As a result, a priority system is not estab-lished and safety requirements are apparently all treated the same.

Regional " clarification of NRC requirements" meetings conducted by NRC are good and worth aile, but most other meetings are not.

The various studies made of NRC following the TMI accident seemed to focus on the fact that NRC should look closely at itself.

It is obvious that NRC has not come to grips with this most important_ issue.

Licensees are afraid to ask questions because they are afraid of the answers they will get.

Everyone in NRC seems to accept the findings of the most conservative member of an NRC group; therefore, the incompeter.t and conservatively articulate NRC employees are in charge.

There appears to be a prostitution of common sense engineering within HRC.

NRC.is not consistent in its emphasis on issues.

We receive many calls from the NRC to the same person, on the same issue, from different NRC offices and groups.

31

NRC has started to use coi,sultants even in the area of technical specification development.

In one case this appears to be out of order based on the poor questions from consultants directed to our engi-neering staff.

Everyone appears to have good ideas.

These good ideas have to be controlled, coordinated, and integrated to achieve some overall benefit rather than confusion and frustration.

NRC still has not come to grips with the major issue--the dire need to sit back and do some managing.

In that NRC plans, schedules, and engineers almost all safety-related activities--how does the NRC apply the necessary QA to its own acti-vities?

It is not obvious to industry that t' sis is done.

NRC has focused on numbers and eliminated engineering judgment.

NRC supervisors and managers back away from reasonable _ positions because of the "more is better" safety philosophy.

NRC must take more time to discuss and decide technical issues on a site-specific basis rather than a generic basis.

1 NRC operator licensing is understaffed.

Licensees expressed concerns about scheduling operator licensing exams and have low regard for NRC consultant examiners.

There should be a central authority for the imposition of requirements in NRC At the present time, each group appears to impose its own requirements with little regard to interrelationship with other groups.

NRC's value/ impact analyses are extremely shallow and rarely adequate.

NRC has two monuments to failure.

These are (1) the inability-to solve the waste problem, and (2) the inability to solve the TMI cleanup problem.

These must be addressed.

i 7.

LICENSEE ORGANIZATION Licensees stated that overall they appear to be losing sight of the big problems.

The STA program was described as being basically unstable with uncertainty of objective, inadequate criteria, and the appearance of being divorced from-day-to-day operation.

The approaches to solve this problem were recognized as not being consistent between utilities.

In most cases (some noteworthy exceptions,) the STA was considered to be of no practical value in the control rooms.

One licensee manager said NRC should realize that there are a number of new areas and functions established within licensee organizations just to administer NRC requirement.s.

These included emergency planning, security, 32

l STAS, Bulletins and Circulars Administrator, human factors engineers, fire protection engineers, EEQ engineers, SEP engineers, PRA engineers, and FSAR updating engineers.

A plant manager felt that NRC had not fully recognized, in its approaches toward licensees, the changes that have taken place over the last decade.

Specifically, he pointed out that a two-unit site now has between 600 and 800 full-time employees.

This group is routinely supplemented by con-struction and maintenance personnel.

The operation of the site is very complex.

Notwithstanding, the manager of this complex feels he is required to personally approve and participate in every identified NRC activity.

For example, he aid he must attend all exit interviews, he must approve all procedures, he must participate in safety committee meetings, and that he is called personally by various groups within NRC to obtain additional informa-tion or to receive complaints.

The size and technical strength of the licensee's organization, he feels, must be recognized.

He further stated that it must be recognized that the plant manager is indirectly forced to talk to NRC employees by NRC policies and precedents.

Because of all the requirements directly assigned by NRC to plant managers, the managers say they have no time for running their plaats or their departments.

One comment was to the effect that NRC should realize that there is-a lot of real pressure to return plants to power which, of course, means the dropping of " nice to do" items but never the NRC-required items.

In the utility's viev, some of the " nice to do" items are of much more significance to plant reliability and safety than NRC items.

The following specific statements are included to demonstrate the range and diversity of licensee. comments on this general subject:

Key managers are all tied up on issues of relatively minor safety significance, most likely involving the rearrangement of paper.

NRC's focus on the Resident Inspector Program and the STAS have caused the market for operations-oriented nuclear engineers to dry up even further.

This is a significant problem.

How much resources do we have to expend to prove to NRC that we are performing responsibly?

We feel we are managing to explain and defend rather than to anticipate and correct safety problems.

The making of a report is not a simple task within any licensee's organization.

I; this fully recognized?

The only way

• can obtain people who are qualified is to steal them from the Navy or from othr.r utilities.

We are forced into that role because of the unrealist#c schedules and demands by NRC.

It must be recognized chat we are running out of good people to meet all requirements.

I'.n sure that some utilities have already run out of people.

We belicv.e that this is caused by many things, but high on the list would be the ;ack of safety priorities and NRC's inability to 33

permit reasonable scheduling and planning.

Also, the entire industry, including NRC, is overly preoccupied with paper production.

The safety of operations, due to direct licensee involvement, is not better but worse than it.used to be.

This.is caused by involvement in things not relatina directly to operational safety.

8.

ENFORCEMENT One licensee expressed concern that NRC enforcement has concentrated on licensee adherence to procedures. What NRC has actually accomplished is that licensee lawyers are now reviewiq all procedures to ensure that they do not' contain matters that can be considered NRC requirements.

This is certainly not what NRC desires, but what NRC certainly should expect over the long run.

Another concern.was that there should be a statement in the enforcement policy on how commitments can be terminated.

Commitments made in response to routine enforcement correspondence are numerous and very difficult to track.

Specifically, how do licensees get rid of old commitments since time, modifications, training, and equipment changes are always going on?

Many old commitments really make little sense today.

The following specific statements are in:luded to demonstrate the range and diversity of licensee comments on this general subject:

Requirements for signatures under oath or affirmation on responses to NRC correspondence reflects the adversary role of NRC.

NRC focuses on details and loses the big picture.

Enforcement docu -

mentation and correspondence are " ultra-negative".

The operators are concerned about the impact of NRC enforcement policy on them personally, civil penalties in particular.

Licensees are losing the incentive to find and identify problems on their own.

NRC's response to little iten ; and big items is nearly the same.

In defense of security guards at our plants, we believe that NRC enforcement actions have guards scared to death for their jobs.

As a result, the guards (they have to " eat" too) really take it out on plant employees.

On items of minor importance, NRC should not require responses.

All responses take time and cost money.

If NRC knows the answer, what are we writing for?

NRC enforcement should not focus on isolated events.

A better program would be to focus on breakdowns in important programs.

34

The ready admission of errors by operating personnel was nearly auto-matic; however, NRC is wearing everyone down.

After a couple of incidents and reactions, one can see why an operator would not readily-admit personal inadequacies.

NRC is issuing orders to confirm agreements that they know the licen-sees are already conforming with.

This " tactic" creates an attitude of hostility, particularly when NRC knows it has sufficient monitoring and enforcement authority to U.;ure that such work is accomplished.

Noncompliance should be assessed in totality, including documentation, in relationship to overall nuclear safety.

9.

ON-SHIFT OPERATIONS The following specific comments were made by operators regarding onshift operations:

The number of surveillances is overpowering.

It is the most difficult and !.azardous responsibility the SRO has.

A large percentage of incidents occur as the direct result of surveillances. When one piece of equipment fails, we test others even if they were just tested. We are wearing out equipment.

This whole area should be reviewed.

The reporting requirements are excessive and unsafe. When an incident occurs, we have to notify seven to tan individuals and organizations.

All this must be done while an event is taking place in the plant.

Since no one wants to talk to a perstn who does not understand the incident, key people on shift must be involved.

the majority of people we talk to are totally incompetent on the problems being discussed.

This problem must be corrected for safety reasons, or we are going to create an incident.

Security requirements remain a serious concern.

This could cause, and has become in several instances, a safety problem by curtailing access to vital plant areas and equipment.

The installation of many fire doors, the large number of surveillance activities, and the masonry wall modifications have substantially increased the difficulty in proceeding about the plant.

This detracts from safe operations, because it takes three times as long to tour the plant as it did a few years ago.

One licensee stated that it was detrimental to the operation of the power plant to require the SR0 to be in the control room continuously.

They believed the SRO should be able to spend a portion of the time in-other parts of the plant whereby they could detect actual problems, interface with the operators and crafts, and assure they are performing their functions satisfactorily.

We feel gun shy, and we have a sense of inadequacy. We believe we have more tunnel vision now than we did before TMI.

35

4 Operators should be handled with intelligence and discretion.

NRC has done very poorly in this area.

It must be renembered that the opera-tors are not replaceable.

Operators' jobs are no longer desirable because of the (1) shortage of people to permit required training, (2) high operator overtime, and (3) shift work.

There is a safety impact in double operator verification of. valve positions.

The verification of important valve positions requires double radiation exposure.

Does NRC consider this negative safety implication?

The control room operator is at the bottom of the ladder in every way.

No matter what happens, there are one hundred Monday morning quarter-backs.

The operators feel that NRC requires everything to be done with procedures in hand.

This is the way they train people.

There remains absoutely no room for judgment.

?.e control room operators are responsible for handling all administra-t~ve matters on backshifts and weekends.

Everybody dumps everything on the control room operators.

The operators take messages, answer phones, and do tasks left over from the dayshift or from the. plant's normal work week.

The effectiveness of each crew is reduced.

Digital readouts are not liked by control room operators.'. They cannot sense range, limits, or trends.

The designers and engineers have over-reacted in regard to control rooms because of their own deficiencies.

The control rooms are over-loaded.

Examples provided include:

TMI; the Browns Ferry Fire; the Browns Ferry scram volume problem; reactor coolant pumps--the starting and stopping issue; automatic start of auxiliary feedwater pumps; operator training requirements; and surveillances.

The numbers and types of surveillance tests are wearing equipment down.

They also detract from operators being available for other operational needs.

The major surveillance problem is testing of the diesel genera-tors.

We are taking samples and analyzing them to death.

A problem even exists during emergencies.

People must realize that overemphasis on sampling detracts from the accomplishments of other necessary opera-tions.

10.

SURVEILLANCE The number of surveillances is overpowering according to licensees.

A *.p ;e percentage of incidents occur as the direct result of surveillances. A frequent comment was that equipment is wearing out.

One group of licensees observed that some of the requirements for testing do not make sense when compared with others.

36

When the out-of-service time is shortened, it must be realized that mainten-ance operations suffer.

L henwcs say that if they cannot fix it properly before the entire plant i; i eauired to come down, the tendency, no matter how honest their motives, is tc. put it together the best they can until they have another opportunity to fix.it.

Licensees said that if they took the time to fix it, bringing the plant down, there would be an additional transient on the unit.

Does the NRC consider these type matters? Some of the problem areas cited included the following:

shut down the plant within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> on snubber problems; shut down the plant within an hour for problems with boron systems; and shut down the plant immediately when there are problems with control rods even though the ability to scram is not affected.

Another comment was that there is a compounding of testing requirements when a system is taken out of service.

For example, when the RHR system is taken out of service, a large number of components must be tested, including the diesels.

In this particular case, practical and effective maintenance on the RHR system is nearly impossible.

The follow ng specific statements are included to demonstrate the range and i

diversity of licensee comments on this general subject:

Surveillances are overdone.

NRC seems to have a philosophy that, if something does not work, recheck everything else.

This occurs even if tests have just been completed on the other items.

One third of all relief valve actuations occurred for surveillance purposes.

This certainly appears to be counterproductive.

The overemphasis on surveillance testing is particularly evident on the backshifts.

There is one surveillance done every hour.

NRC should not forget that many major events appear to be surveillance related.

Examples cited were the Browns Ferry fire and the TM1 accident.

When one diesel is out of service, the other units are required by technical specifications to be tested daily.

This is counter-productive to diesel design and manufacturer recommendations.

Diesels are intended to be run for long periods of time and not for short periods of operation.

When performing surveillance tests, we have started the diesels 1,500 times in the last 2 years.

11.

INSPECTION One plant manager pointed out that inspections are conducted by various groups in the NRC, in addition to the red ine NRC inspections. Far example, they had four special teams inspecting units in a recent two-week period.

NRC must think licensees have an unlimited number of qualified people.

37

~

q i

i One licensee commented that more reliance should be placed on the licensee's audit program and the resident inspector.

This could reduce the number of special inspections by NRC. -The inspections should occur primarily in those areas in which the results of the licensee's audit program and the resident indicate there is a problem.

Certain specialist inspectors, in the opinion of one group, are improperly judging licensee's interpretations of NRC requirements.

It was stated that the utilities tend to comply instead of fighting.

NRC needs a system for controlling what appears to be ratcheting.

One utility estimated that about 8,500 staff-hours will be expended in preparation for and support of NRC inspections.

It was stated that the inspectors' reports should not indicate only negative aspects of findings but should also indicate positive aspects.

It was felt that NRC.should take more credit for the resident inspector findings and only use the teams of specialists when the resident inspector indicates a need in a specific area.

The following specific statements are included to_ demonstrate the range and diversity of licensee comments on this general subject:

Some resident inspectors appear intimidating.

Their attitudes consti--

tute a continuing threat.

Specifically, constant questioning within a functional area combined with an occasional item of~ noncompliance, implies "we better do it his way or someday we will get it."

A licensee reported that there were 43 Federal inspectors (not all NRC) on their property in one day.

NRC inspections and audits key on paper.

They set a paper tone to operations--this has a direct effect on the operators.

Operators are concerned about the motives of the resident inspector i

based on various questions and comments he makes while in the control room.

Resident inspectors provide a good sounding board on regulatory issues.

Operators find that the residents are more attuned to plant happenings and are primarily concerned with ensuring that things are done right versus the legalistic aspects of ins'pection.

They help us get things done.

The resident inspectors do not know the details of many regulatory requirements, yet they imply they do.

Their advice has hurt us in several cases.

The resident inspector's credibility has been challenged by.a number of special inspection teams.

The special teams have had findings that differed from comments received from the resident inspectors.

4 38

12.

FIRE PROTECTION One licensee pointed out that in the fire protection area the Commi sion has ely one or two qualified fire inspectors.

Accordingly, when one looks at die number of ' qualified people and the detail contained in Appendix R, one wonders whether or not Appendix R was properly and effectively prepared.

~

According to this licensee, the development of Appendix R is an example of deteriorating communications between the Commission and.the industry.

Another utility-reported submitting information on fire protection in September 1979.

They received no response until April 1981.

Concern was expressed by one licensee that industry feedback.was not accom-modated and the implementation schedule was shortened at the last moment.

It was further stated that previous licensee responses were ignored or.NRC required several submittals of the same information.

The cost of the pro-gram was said to be $20,000,000.

Insufficient time was allowed to examine alternate methads, e.g., where it was impractical to install three-hour fire barriers.

Tha following specific statements are included to demonstrate the range and diversity of licensee comments on this general subject:

Appendix R and safe shutdown requirements are in conflict with regard to redundancy requirements.

One utility reports expenditures to date of 40,000 to 50,000 staff-hours as a result of Appendix R.

A specific question by one licensee was,'"Is the. fire hazard analysis part of the license?"

With regard to resource utilization, fire protection requirements have been very poorly handled by the NRC from the beginning.

In the area of fire protection, we have never received an SER.

It appears that no priorities have been set in the area of fire pro-tection. We have wasted many millions of dollars because of changed schedules.

Four separate groups looked at some aspects of fire protection in a two-week period at our plant.

13.

EMERGENCY PLANNING Licensees find the NRC definition of " emergency" to be unrealistic in that almost everything that goes on in the plant is now defined as an emergency.

Once something is defined as an emergency, according to licensees, the avalanche of notifications and reports is started.

This, they report, has serious implications for the image and morale of the industry.

It also creates unnecessary public anxiety.

This, of course, is picked up by the media by proviriing them with interesting " emergency" material.

39

Approximately 50 people were reported by one licensee as being used in emergency planning and coordination.

This licensee pointed out that it is necessary to coordinate three states and multiple local jurisdictions.

It was recommended by this licensee that full utility participation in some exercises be reduced since they are exercising with several different states and many different localities and for several different plants.

Emergency planning is really a can of worms, according to one utility.

Licensees say they are caught up in political considerations and the ina-bility of NRC and FEMA to agrae in areas such as changing requirements and interactions with counties, states, and other local officials.

A particular problem, reportedly, is that the one exercise per year, of the magnitude currently required, has negative safety implications due to the amount of talent being drawn away from other necessary activities.

This utility finds that it takes six staff-months' to develop an appropriate scenario.

The EOF was described as a zoo during the drill--and would probably be worse in reality.

The following specific statements are included to demonstrate the range and diversity of licensee comments on this general subject:

The red phones should be taken out of the control room because they interfere with the orderly conduct of operations during incidents and unusual occurrences.

The caliber of employees on the NRC end of the red phones ~is unaccept-able and interferes with the orderly transmission of information.

NUREG-0696 is cosmetic and is only a bureaucratic solution to the problem.

=

NUREG-0610, -0654, and -0696 are ex;.T.plas of developing complexity.

It appears that no one will stop and look where we are going and where we will end up.

It appears it would be appropriate to stop and put things all together.

Emergency planning documents have not been reviewed by NRC management prior to conducting meetings covering the topics.

The red phone threshholds are too low, thereby diverting resocrces and attention from real problems.

There should be a definition of NRC's role in emergencies.

The resi-dent inspectors should be on the red phone in the control room during an emergency.

Dates and requirements imposed by NUREG-0696, " Functional-Criteria for Emergency Response Facilities," is an example of regulation by NUREG.

The transition process from " issued for comment" to a " requirement" is unfair.

40

Operators are concerned about what takes place on the other end of the red phone.

They appear to be totall' " unimpressed" with the questions, delays and feelings of " lack of knowledge" on the other end of the red phone.

The red phone situation is a plague.

There is no threshold on releases.

NRC in Washington does not understand the issues, and key staff members are unnecessarily tied up at an important time.

The requirement for sirens gets the population excited over a problem that is not real.

The requirement to have certain people available at the site and functioning % thirty minutes is unrealistic (NUREG-0654).

The whole area of emetgeacy planning has mushroomed beyond belief. The emergency planning experts have created a situation like a major war game.

NRC should define its role in emergency planning very clearly.

Apparently, this has been very difficult to do.

Please recognize the impact of a large number of drills on the corporate structure of a multisite utility.

This has to be looked at carefully.

The regional offices must have the same problems.

14.

SECURITY A licensee observed that operators have h torically been very negative toward all aspects of security.

It was pc nted out that this licensee was well aware the guards "have to eat" and, si.1ce NRC has so vigorously enforced security requirements, the security guards were scared to death.

They really have no choice.

As a result,.according to this licensee, the strict enforcement of all security requirements is reflected in antagonism toward plant personnel.

The security requirements reportedly remain a serious concern, which has become a safety problem in several instances by curtailing access to vital-plant areas and equipment.

The installation of many' fire doors, the large number of surveillance activities, and the masonry wall modifications were said to have substantially decreased effectiveness in proceeding about the plant.

Licensees feel this detracts from safe operations, because it takes three times as long to tour the plant as it did a'few years ago.

One licensee made the statement tnat lighting requirements for security are inappropriate.

They believe there is no justification for the criteria and feel that lighting promotes a false sense of security.

The lighting was described as being so intense that nuclear power plants can be located in the evening by air from immense distances.

The following specific statements are included to demonstrate the range and diversity of licensee comments on this general subject:

41

Security guards work in their chain of commands, have a fear of being fired, and, therefore, complete all administrative forms' carefully.

This delays operator access to areas when needed.

Security reporting requirements should be integrated with 10 CFR 50.72 and be made consistent with all reporting requirements.

Security lighting at a cost of $1,000,000 per. plant was double the cast if installed on a reasonable schedule.

Changing security requirements forced the development of two systems in series--the first at $1,000,000 and the replacement at $12,000,000.

4 Some security requirements still appear to be excessive. 'One exampl.e given was that all locks must be changed whenever someone is termi-nated.

It appearr, that NRC has not uniformly established requirements for security at all plants.

15.

PUBLIC AFFAIRS Most licensees believe NRC's tone is overly negative in every' area, which includes emergency classifications, inspection reports, confirmatory orders, and " secret" types of releases that receive national attention.

In local areas, licensees feel there is humiliation of the operators and the opera-ting staff.

The public view of them is that they are totally incompetent.

Many licensees feel the problem of reporting requirements is broad and The problem goes well beyond reporting to the NRC in.that other severe.

agencies and organizations also use NRC reporting criteria.

The resources applied by key people on most reported issues, combined with public anxiety created by the press, have enormous negathe impacts on licensee organi-zations.

Local officials who receive pron., *. reports and enforcement corri-spondence consider the managers and operators of nuclear facilities to be totally incompetent.

The following specific statements are included to demonstrate the range and diversity of licensee comments on this general subject:

When a commitment or action date is missed for whatever reason, the public sees this as the licensee being nonresponsive.

t Positive strokes as well as negative strokes should be given to utili-ties when warranted.

Press releases have a negative impact on the employee's interrelation-ship with his neighbors.

It was suggested that, whenever possible, i

positive statements as well as negative statements be included in press releases.

42

e 1

16.

REPORTING REQUIREMENTS Many licensees, as stated previously, feel that the reporting requirements in accordance with 10 CFR 50.72 are excessive.

The problem is amplified because many states and local governments now require reporting in accord-ance with NRC criteria.

Licensees said that reports required in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> by 10 CFR 50.72 frequently do not permit determination of whether there is a real problem or an instrument failure--many potenti:1 issues are reported that are later determined not to be issues at all.

One licensee indicated that_two major areas troubled him regarding red. phone calls:

the threshold on rad releases is much too low, and personnel in NRC do not understand their plant sufficiently.

The licensee pointed out that of 102 red phone calls made since February 1980, 32 were related to spikes from rad monitors and only 8 of the 32 were actual releases to the environs, and they were within technical specifications limits.

Several licensees stated that reporting requirements should be better coordi ated.

Similar times should be specified for similar safety-related n

matters.

Reporting requirements are out of perspective, too scattered, and too conflicting.

Exhibit 1:

Key to References Contained in Licensees Comments 43

o i

EXHIBIT 1 TO APPENDIX A i

KEY TO REFERENCES CONTAINED IN LICENSEE COMMENTS NUREG*

0588 -

Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment 0610 Draft Emergency Action Level Guidelines for Nuclear Power Plants 0654 Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants 0696 Functional Criteria for Emergency Response Facilities 0700 -

Preliminary Analysis of First Crop of Plants Grown in Seven Soils Uniformly Contaminated With Four Transuranic Elements Simultaneously 0737 Clarification of TMI Action Plan Requirements 0761 Radiation Protection Program Development 1

REGULATORY GUIDES

• 1.68 -

Preoperational and Initial Startup Test Programs for Water-Cooled Power Reactor 1.97 -

Instrumentation for Light Water-Cooled Nuclear Power Plants to Access Plant and Environs Conditions During and Following Accident 10 CFR PART 50 APPENDICES

• J Primary Containment Leakage Testing R

Fire Protection System Requirements

^Available for purchase from the NRC/GP0 Sales Program, U.S. Nuclear Regulatory Commission, Washington, DC 20555.

44

IE BULLETINS

• 79-018 - Environmental Qualification of Class IE Equipment 79 Pipe Supports Base Plates Using Expansion Type Anchor Bolts 79 Seismic Stress Analysis ofLSafety-Related Piping 79 Seismic Analyses of Safety-Related Piping Systems Pipe Cracks in Stagnant Borated Water Systems at PWR Plants 79-17 "Available for inspection and copying for a fee from the NRC Public Document Room, 1717 H Street, NW, Washington, DC 20555.

4 f

45

~.

APPENDIX B LISTING 0F SURVEY MEETINGS - UTILITIES AND NRC REPRESENTATIVES I

MEETING UTILITY DATES LOCATION NRC REPRESENTATIVES-Florida Power &

April 7, 1981 Miami, FL

_R. DeYoung, Deputy Director, Light Company Office of Inspection and Enforcement (IE)

J. P. O'Reilly, Director Region II (RII)

R. Lewis, Acting Director, Division of Resident and Reactor Inspection (RRPI), RII Northeast Nuclear May 6, 1981 Hartford, CT V. Stello, Director, Energy Company Office of Inspection and Enforcement (IE)

J. P. O'Reilly E. Brunner, Acting Director, Resident and Reactor Project Inspection (RRPI),-Region I (RI)

Yankee Atomic May 7 (a.m.)

Boston, MA-J. P. O'Reilly Electric Ccapany~

E. Brunner-

'E. Jordan, Deputy Director, Division of Resident and Regional Reactor Inspection (DRRRI):IE Boston Edison May 7 (p.m.)

Boston, MA J. P. O'Reilly-Company E. Brunner E. Jordan Peach Bottom, May 8 Washirgton, V. Stello Tennessee DC R. DeYoung Valley Authority, B. Grimes, Director i

Arkansas Nuclear, Division of Emergency Duke Power, Power Preparedness (DEP)

Authority of the State of New York, Inc.,

i Commonwealth Edison (Meeting of Operational Representatives) 46 a

MEETING UTILITY DATES LOCATION NRC REPRESENTATIVES' Tennessee Valley May 12 Knoxville, TN J. P. O'Reilly Authority D. Eisenhut, Director of Licensing (Office of Design and Office of Nuclear Reactor Construction)

Regulation (NRR)

S. Hanauer, Director of Human Factors Safety, NRR Tennessee Valley May 13

. Chattanooga, TN V. Stello Authority J. P. O'Reilly-(Office of Power)

5. Hanauer Toledo Edison May 26 Detroit, MI J. P. O'Reilly Company J. Keppler, Director, Region III (RIII)

J. Partlow, Chief, Programs Appraisal Branch (PAB)

Commonwealth May 27 Chicago, IL K. Cornell, Deputy Executive Edison Director for Operations (0PNS)

E. Cas?, Deputy Director, Office of Nuclear Reactor Regulation (NRR)

J. P. O'Reilly J. Keppler J. Sniezek, Director, Division of Resident and Regional Reactor-Inspection (DRRRI):IE o

47

APPENDIX C REPRESENTATIVE SCHEDULE OF A SURVEY VISIT TIME DISCUSSION GROUP 8:30 a.m. - 10:00 a.m.

Senior Reactor Operators, Reactor Operators, Shift Technical Advisors, Shift Foremen, and Operational Supervisors 10:00 a.m. - 11:30 a.m.~

Plant-QA Engineers, Maintenance Engineers, Nuclear Engineers, and Electrical Engineerd 11:30 a.m. - 12:30 p.m.

Lunch.

12:30 p.m. - 2:00 p.m.

Corporate' Licensing Engineer, Corporate QA Manager, Manager of Planning and Scheduling, Project Engineer, and Corporate Training' Officer 2:00 p.m. - 3:30 p.m.

Managers of_0peration, Managers of Construction, and Managers of Engineering

~

and Design 3:30 p.m. - 5:00 p.m.

Executive Vice President, Senior Vice President, and other corporate-personnel 48'

'U U.S. NUCLE AR REGULATORY COMMISSION CIBLIOGRAPHIC DA1 A SHEET NUREG-0839 4 TITLE AND SUBTITLE (Add Volume No.. if epropriere).A Survey by Senior NRC

2. ite e erm*/

Management to Obtain Viewpoints on the Safety Impact of Reg-ulatory Activities from Representative Utilities Operating

3. RECtPIENT"S ACCESSION NO.

and Constructing Nuclear Power Plants.

7. AUTHORIS)

5. DATE REPORT COMPLETED NRC Steering Committee uOuTs l YEAR July 1981

9. PERFORMING ORGANIZATION NAME Ar 0 MAILING ADDRESS (Include 2,p Codel DATE REPORT ISSUED Office of Inspectior. & Enforcement fug~u's t I%81 U.S. Nuclear Regulatory Commission g ft,,,,,,,,,,

Washington, DC 20555

8. (Leave blank)

12. SPONSORING ORGANIZATION NAME AND MAILING ADDRESS (Include Esp Codel p

11. CO:JTR ACT NO.

d

13. TYPE OF REPORT PE RIOD COVE RE D (/dctuove dates)

Ragulatory

15. SUPPLEMENTARY NOTES 14 iteeve (Weal 16 ARSTR ACT (200 words or less)

A survey of licensee staff members representing the several organizational elements in different licensee corporate and plant staffs was conducted by senior NRC management to obtain licensee views on the potential safety conse-quences and impact of NRC regulatory activities. The comments received ad-dressed the full scope of NRC activities and the negative impact of agency actions on licensee resources, staff performance, planning and scheduling, and organizational effectiveness. The findings of the survey is that the pace and nature of regulatory actions have created a potential safety prob-lem which deserves further evaluation by the agency.

i

17. KE Y WORDS AND DOCUME N T AN ALYSIS 1 74 DESC RIP TORS 17ts IDENTIFIE RS OPEN ENDE D TERMS ECURITY CLASS (Tn.s reporr/

21 NO OF PAGES 19 fnciassified 18 AVAILABILITY ST ATEMENT I

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