Resolution of Generic Safety Issues: Task I.B: Support Personnel (Rev. 4) (Rev. 1) ( NUREG-0933, Main Report with Supplements 1–35 )

The objectives of this task were to:

(1) Improve licensee safety performance and ability to respond to accidents by upgrading the licensee groups responsible for radiation protection and plant operation in such areas as staff size; education and experience of staff members; plant operating and emergency procedures; management awareness of, and attention to, safety matters; and numbers and types of personnel available to respond to accidents.

(2) Improve licensee safety performance by establishing a full-time, dedicated, onsite safety engineering staff and providing, along with the concurrent dissemination of information to plant personnel, an integrated program for the systematic review of operating experience.

ITEM I.B.1.1: ORGANIZATION AND MANAGEMENT LONG-TERM IMPROVEMENTS

DESCRIPTION

Historical Background

This issue⁴⁸ dealt with implementation of long-term organization and management improvements, the overall objective of which was to improve licensee safety performance and ability to respond to accidents by upgrading licensee groups responsible for radiation protection and plant operation. The areas to be upgraded included: (1) staff size; (2) education and experience of staff members; (3) plant operating and emergency procedures; (4) management awareness of, and attention to, safety matters; and (5) numbers and types of personnel available to respond to accidents. The evaluation of this issue included consideration of Item II.J.3.1.

Safety Significance

The potential for accidents resulting from some measure of human error in operating a nuclear plant may be avoidable by the resolution of this issue.

Possible Solutions

Proper management and organization will improve administration, control, prevention, and coordination both within and among all key organizational components of a plant, including those located offsite. The management involved and their staff will be better qualified and trained and the staff will be increased. Thus, the management and organization will be better-prepared for both normal operations and emergency situations. Resolution of this safety issue was assumed to encompass the following:

(1) Each utility (licensee/applicant) would be required to submit a new proposed organization and management plan for review by the NRC, including a site review. No additional management staff would be required, but the qualifications and training of the management staff and the organization effectiveness would be improved substantially at most plants.

(2) Depending on the plant, up to 14 additional personnel would be required: maintenance (~9); health physics and chemistry (~3); and training (~2). Not included were staff to man a plant-specific simulator, if required by the NRC (this was considered under Item I.A.4.1). It was anticipated that 25% of the plants would require no staff additions, 50% would require only 8 people, and 25% would require all 14 people. Thus, on the average, a plant would require 7 additional staff members.

(3) OIE staff would perform annual assessments to ensure each utility satisfactorily met NRC management and organization requirements, as identified in the initial plant review.

(4) Regulatory Guides 1.33²²⁵ and 1.8²²⁶ would be revised and issued, along with other appropriate regulatory guidance, to define requirements in this area.

(5) Implementation of this issue was assumed to begin in FY 1984 at all operating plants and at those plants applying for an operating license, with all plants to be covered by mid-FY 1985; this included annual followup assessments underway in FY 1985.

PRIORITY DETERMINATION

To assess this issue, SPEB/NRR consulted with PNL as well as with NRR and RES personnel working on developing the management, organization, and staffing regulatory positions. The PNL personnel had expertise in general management, utility and nuclear plant management, reactor operations, reactor operation licensing, and general reactor safety areas. The technical analysis for this issue was provided by PNL.⁶⁴

Assumptions

The major benefit from resolution of this issue would be a reduction in human errors (operators and maintenance personnel) resulting in lower public risk. This applied to the remaining operating life of all plants (142) operating and under construction, subsequent to implementation of the solution in 1985, which was approximately 26 years.

The PNL staff estimated that the proper actions could potentially result in a 20% reduction in human errors at a nuclear plant. However, many of the plants (assumed to be 25%) were already well-managed and organized; these would see no further improvement. Another 50% would obtain only half the benefit and the remaining 25% would obtain the full benefit. An average value of 10% for reduction of human errors was anticipated for the nuclear industry at large.

Frequency Estimate

All accident sequences, except an interfacing system LOCA, would be affected. Reducing the human error rate by 10% was calculated to decrease the frequency of core-melt in Oconee-3 by 5 x 10^-6/RY. The frequency of core-melt in Grand Gulf-1 was assumed to be reduced by the same ratio, or 2 x 10^-6/RY.

Consequence Estimate

All release categories were affected and the reduction in public risk was estimated to be 13 man-rem/RY for PWRs and 15 man-rem/RY for BWRs, based on the WASH-1600¹⁶ release estimates and assuming a typical midwest-type meteorology and an average population density of 340 people per square-mile at U.S. reactor sites. Assuming 94 PWRs and 48 BWRs with an average remaining life of 26 years after implementation of the resolution in 1985, the total public risk reduction was 50,400 man-rem.

Cost Estimate

Industry Cost: The major cost of resolving this issue was that associated with possible additional staffing required at a plant; both BWRs and PWRs would be affected equally. Specifically, industry costs associated with this issue were expected to be as follows:

(1) An average of 7 people/plant would be required for operation and maintenance.

(2) Approximately 2 man-years of effort for "intermediate case" plants would be required for preparing the initial management plan and reviewing it with the NRC. (Triple that for "worst case" plants and half that for "best case" plants). An average of 2.75 man-years/ plant was used for implementation.

(3) Approximately 1 man-month of utility effort would be required at each plant in supporting the annual NRC management assessment of the solution.

The industry costs calculated by PNL⁶⁴ were $33M for implementation and $2.27M for operation and maintenance, for a total of $35.27M.

NRC Cost: NRC costs associated with resolving this issue were expected to be as follows:

(1) Approximately 22 man-years of effort by NRR and RES to develop the long-term regulatory position on management and organization after FY-1982.

(2) Approximately 2 man-years to write, obtain, and issue comments on revised and new regulatory guides. The major development effort behind these guides was included in (1) above.

(3) Approximately 5 man-months to review the initial management and organization plan proposed for each plant. This included time for the site visit and assessment report.

(4) Approximately 0.5 man-month to perform an annual assessment of the solution at each plant.

The total NRC cost calculated⁶⁴ by PNL was approximately $30.8M.

Total Cost: The total industry and NRC cost associated with the possible solution was $(35.27 + 30.8)M or $66.07M.

Value/Impact Assessment

Based on an estimated public risk reduction of 50,400 man-rem and a cost of $66.07M for a possible solution, the value/impact score was given by:

Other Considerations

There would be some reduction in occupational risk primarily from lowering occupational exposure due to fewer unplanned outages caused by human error. Maintenance staffs would be primarily impacted; however, both operating and maintenance staffs would benefit from avoidance of major accidents.

The potential for exposure reduction was expected to be about 10% for the 25% "worst case" plants, 5% for the 50% "intermediate case" plants, and none for the 25% "best case" plants; an average value of 5% was used. It was estimated that 300 to 500 man-rem of occupational exposure occur annually at a typical facility. Assuming 400 man-rem as a best estimate, the 5% reduction resulted in an occupational dose reduction of 20 man-rem/RY. For 142 plants with an average remaining life of approximately 26 years, the total occupational risk reduction from this source was approximately 75,000 man-rem.

The industry accident avoidance cost was estimated by PNL⁶⁴ to be $26.2M.

CONCLUSION

The potential public risk reduction was relatively large (50,400 man-rem) and the potential for occupational risk reduction was also large (75,000 man-rem), if the estimate of the reduction in human error was correct. Since most of the costs were due to additional utility staff, this value/impact could be higher if a resolution were found that did not require added staff. Therefore, based on the large potential risk reduction, this issue was given a medium priority ranking (see Appendix C).

The NRC stated its movement toward performance-based rather than prescriptive regulation in its 1986 Policy and Planning Guidance (NUREG-0885, Issue 5).²¹⁰ The NRC was approaching Management and Organization by improving its responsiveness to licensee performance, e.g., systematic assessment of licensee performance (SALP) improvement. The Nuclear Utility Management and Resources Committee (NUMARC) was established by the industry in March 1984 with an objective of reviewing management and people-related issues in nuclear operations and developing industry-wide resolutions. The Commission responded to NUMARC initiatives in a positive manner. In a letter dated January 23, 1985, to J. H. Miller, Chairman of NUMARC, Chairman Palladino supported initiatives which include improvement in management and organization and stated, in part, "we strongly encourage industry efforts to enhance the performance of utility corporate management." Based upon industry initiatives and the Commission's policy guidance, work on Items I.B.1.1(1,2,3,4) was terminated.⁹⁵⁶

OIE routinely developed and issued inspection procedures which addressed new or revised regulations and requirements. Thus, Item I.B.1.1(5) was determined to be resolved.⁴⁴¹

In July 1984, OIE noted⁶⁵² that the proposed revision to Regulatory Guide 1.33²²⁵ was being addressed under Issue 75. This effort negated the need to pursue a separate resolution to those parts of Items I.B.1.1(6,7) that required a revision to Regulatory Guide 1.33.²²⁵ The parts of Items I.B.1.1(6,7) that require a revision to Regulatory Guide 1.8²²⁶ were addressed under Item I.A.2.6(1).⁹⁵⁶

ITEM I.B.1.1(1): PREPARE DRAFT CRITERIA

This item was evaluated in Item I.B.1.1 above and was determined to be RESOLVED⁹⁵⁶ with no new requirements.

ITEM I.B.1.1(2): PREPARE COMMISSION PAPER

This item was evaluated in Item I.B.1.1 above and was determined to be RESOLVED⁹⁵⁶ with no new requirements.

ITEM I.B.1.1(3): ISSUE REQUIREMENTS FOR THE UPGRADING OF MANAGEMENT AND TECHNICAL RESOURCES

This item was evaluated in Item I.B.1.1 above and was determined to be RESOLVED⁹⁵⁶ with no new requirements.

ITEM I.B.1.1(4): REVIEW RESPONSES TO DETERMINE ACCEPTABILITY

This item was evaluated in Item I.B.1.1 above and was determined to be RESOLVED⁹⁵⁶ with no new requirements.

ITEM I.B.1.1(5): REVIEW IMPLEMENTATION OF THE UPGRADING ACTIVITIES

This item was evaluated in Item I.B.1.1 above and was determined to be RESOLVED^441,956 with no new requirements.

ITEM I.B.1.1(6): PREPARE REVISIONS TO REGULATORY GUIDES 1.33 AND 1.8

This item was evaluated in Item I.B.1.1 above. The revision of Regulatory Guide 1.33²²⁵ was covered in Issue 75^652,956 and the revision of Regulatory Guide 1.8²²⁶ was covered in Issue I.A.2.6(1).

ITEM I.B.1.1(7): ISSUE REGULATORY GUIDES 1.33 AND 1.8

This item was evaluated in Item I.B.1.1 above. The revision of Regulatory Guide 1.33²²⁵ was covered in Issue 75^652,956 and the revision of Regulatory Guide 1.8²²⁶ was covered in Issue I.A.2.6(1).

ITEM I.B.1.2: EVALUATION OF ORGANIZATION AND MANAGEMENT IMPROVEMENTS OF NEAR-TERM OPERATING LICENSE APPLICANTS

DESCRIPTION

This NUREG-0660⁴⁸ item required the staff to evaluate organization and management capabilities of NTOL applicants before license issuance. NRR was to provide draft criteria and OIE was to manage an inter-office review team. The findings of the team was to be factored into the SER for each NTOL facility.

CONCLUSION

Between January and July 1980, 6 NTOLs (Sequoyah, North Anna-2, Salem-2, Diablo Canyon, McGuire, and Farley-2) were evaluated; Zion, Indian Point, and TMI-1 were also evaluated later. As part of its overall review responsibility, NRR was to manage similar reviews for other NTOL applicants.

ITEM I.B.1.2(1): PREPARE DRAFT CRITERIA

This item was evaluated in Item I.B.1.2 above and was determined to be RESOLVED²³⁵ with no new requirements.

ITEM I.B.1.2(2): REVIEW NEAR-TERM OPERATING LICENSE FACILITIES

This item was evaluated in Item I.B.1.2 above and was determined to be RESOLVED with no new requirements.

ITEM I.B.1.2(3): INCLUDE FINDINGS IN THE SER FOR EACH NEAR-TERM OPERATING LICENSE FACILITY

This item was evaluated in Item I.B.1.2 above and was determined to be RESOLVED with no new requirements.

ITEM I.B.1.3: LOSS OF SAFETY FUNCTION

DESCRIPTION

This TMI Action Plan⁴⁸ item addressed regulatory action at an operating nuclear power plant in the event of human error leading to complete loss of a safety function required by the plant's TS. The following three options specified in the TMI Action Plan⁴⁸ were considered:

(1) Require licensees to immediately place the plant in the safest shutdown cooling condition following a total loss of a safety function due to personel error, if a total loss of a safety function had occurred within the previous year or two. Resumption of operation would require NRC approval based on a review of the licensee's program for corrective action.

(2) Use existing enforcement options (citations, fines, shutdowns).

(3) Use approaches such as a point system, licensee probations, and (in the extreme) license revocations.

Loss of a required safety function can lead to an increase in the probability that an event with an accident-initiating potential, should it occur, would lead to an actual major accident. This probability increase could be more or less substantial, depending on the specific function lost. The safety concern is heightened when the loss of safety function is caused by human error and this occurs more than once in a year or two. Such repeated personnel failures can bring into question whether the reliability of safety-related personnel actions at the plant involved are generally up to the standards expected and assumed in safety evaluations. This item was related to improving the NRC capability to make independent assessments of safety and, therefore, was considered a Licensing Issue.

CONCLUSION

Option 2 was selected as the best option that would provide the latitude needed by NRC for determination whether a particular event falls under the definition of a "loss of safety function," the role of human error in causing the event, the acuteness of the risk, the urgency and nature of appropriate remedial action, conditions for resumption of operation, and such considerations as the public health-and-safety need for power at the time (see References ²³⁴, ²⁶⁵, ²⁶⁶, ²⁶⁷, ²⁸⁷). With the selection of Option 2, Item I.B.1.3 was terminated, having become part of the Enforcement Policy issue (Item IV.A.2) which was completed.²⁸⁸ Thus, this Licensing Issue was resolved.

ITEM I.B.1.3(1): REQUIRE LICENSEES TO PLACE PLANT IN SAFEST SHUTDOWN COOLING FOLLOWING A LOSS OF SAFETY FUNCTION DUE TO PERSONNEL ERROR

This Licensing Issue was evaluated in Item I.B.1.3 above and was determined to be resolved.

ITEM I.B.1.3(2): USE EXISTING ENFORCEMENT OPTIONS TO ACCOMPLISH SAFEST SHUTDOWN COOLING

This Licensing Issue evaluated in Item I.B.1.3 above and was determined to be resolved.

ITEM I.B.1.3(3): USE NON-FISCAL APPROACHES TO ACCOMPLISH SAFEST SHUTDOWN COOLING

This Licensing Issue was evaluated in Item I.B.1.3 above and was determined to be resolved.

REFERENCES

0016. WASH-1400 (NUREG-75/014), "Reactor Safety Study: An Assessment of Accident Risks in U.S. Commercial Nuclear Power Plants," U.S. Atomic Energy Commission, October 1975. 0048. NUREG-0660, "NRC Action Plan Developed as a Result of the TMI-2 Accident," U.S. Nuclear Regulatory Commission, May 1980, (Rev. 1) August 1980. 0064. NUREG/CR-2800, "Guidelines for Nuclear Power Plant Safety Issue Prioritization Information Development," U.S. Nuclear Regulatory Commission, February 1983, (Supplement 1) May 1983, (Supplement 2) December 1983, (Supplement 3) September 1985, (Supplement 4) July 1986, (Supplement 5) July 1996. 0210. NUREG-0885, "U.S. Nuclear Regulatory Commission Policy and Planning Guidance," U.S. Nuclear Regulatory Commission, (Issue 1) January 1982, (Issue 2) January 1983, (Issue 3) January 1984, (Issue 4) February 1985, (Issue 5) February 1986, (Issue 6) September 1987. 0225. Regulatory Guide 1.33, "Quality Assurance Program Requirements (Operation)," U.S. Nuclear Regulatory Commission, November 1972, (Rev. 1) February 1977, (Rev. 2) February 1978. [7907100144] 0226. Regulatory Guide 1.8, "Qualification and Training of Personnel for Nuclear Power Plants," U.S. Nuclear Regulatory Commission, March 1971, (Rev. 1) September 1975 [8801130111], (Rev. 1-R) May 1977 [7907100073], (Rev. 2) April 1987. [8907180147] 0234. Federal Register Notice 47 FR 9987, "10 CFR Part 2, General Statement of Policy and Procedure for Enforcement Actions," March 9, 1982. 0235. Memorandum for H. Denton from R. DeYoung, "TMI Action Plan Items Still Pending," June 10, 1982. [8401170101] 0265. Memorandum for the Commissioners from W. Dircks, "Enforcement Policy," March 18, 1980. [8005160508] 0266. SECY-80-139A, "NRC Enforcement Program," U.S. Nuclear Regulatory Commission, August 27, 1980. [8009180277] 0267. Memorandum for R. Purple from R. Minogue, "TMI Action Plan," October 24, 1980. [8011120511] 0287. SECY-81-600A, "Revised General Statement of Policy and Procedure for Enforcement Actions," U.S. Nuclear Regulatory Commission, December 14, 1981. [8201190600] 0288. NEDO-10174, "Consequences of a Postulated Flow Blockage Incident in a Boiling Water Reactor," General Electric Company, October 1977, (Rev. 1) May 1980. 0441. Memorandum for H. Denton from R. DeYoung, "Commission Paper on the Prioritization of Generic Safety Issues," April 20, 1983. [9705190224] 0652. Memorandum for W. Dircks from R. DeYoung, "Elimination of Duplicative Tracking Requirements for Revision of Regulatory Guide 1.33," July 26, 1984. [9705190264] 0956. Memorandum for V. Stello from H. Denton, "Close-out of the Division of Human Factors Technology TMI Action Plan Items," January 6, 1987. [8701140115]