ML18016A101
| ML18016A101 | |
| Person / Time | |
|---|---|
| Issue date: | 12/20/1991 |
| From: | Taylor J NRC/EDO |
| To: | Chilk S NRC/SECY |
| Bavol, Rochelle | |
| References | |
| SECY-91-172, SRM-SECY-91-172 | |
| Download: ML18016A101 (3) | |
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~, -....:.;.I QF,ICE OF THI IICIIITAIIV MEMORANDUM FOR:
FROM:
SUBJECT:
RELEASED TO THE POR UNITED ITATH NUCLEAR REGULATORY COMM1;;.;10N:
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WAIHtNOTON, D.C. ZOHI (JjW
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December 20, 199!
Jues M. Taylor Executive Director Sa*u*l J. Chilk, secret SECY-91-172 - R!GULITOR QPORT - !'INAL Th* co.. iaaion recogni1eM the substantial work that has been undertaken by th* staff to evaluate the iapact of the NRC regulatory activities on 10 CFR Part 50 licen*****
NUREG-1395 and SECY-91-172 document the staffs finding* and *o** of the corrective actions that are being taken in response to this issue.
Additional activities, such as tha ataff'* review of the NRR inapection program and the Office of the Inapector General's (OIG) overall review of the NRC inspection program, will further review concern* identified in the survey.
The Conuntssion reque*t* that the ataff prepare annual update* on progress on implementing th* activitiea deacribed in thia paper, The program assessment should evaluate leaaon* learned from the success or failure of different efforts, and from licensee assessments of these efforts. This aasoaaaftnt should outline a staff proposal lor a continuing feedback proc****
such a proceas may incorporate tailored, **all *cope surveys which can be most effective if done on a progra.. *d, routin1a basis. Thereafter, the staff should provide the Colftfflisaion annual updates on the feedhack process.
(EDO)
(SECY Suapenao:
7/17/92)
The conmiaaion requeata that ataft puraue the following actiQna:
- 1)
In view of the *taffs ongoing effort to modify th*
Regulatory Analy*1* Guideline* ar.d the recent ~~:.aaentary on SECY NOTE:
SECY-91*172 WAS RELEASED 'l'O THE PUBLIC ON AUGUST 13, 1991. THIS SRM AND THE VOTE SHEETS OF THE CHAIRMAN AND COIOIISSIONERS ROGERS AND CURTISS WILL BE MADE PUBLICLY AVAILABLE 10 WORKING DAYS FROM
'l'HE DATE OF THIS SRM, Voting on this issue was completed before the start of Commissioner de Planque'a term.
- 2) 2 tho i**u* of averted on-sit* coat* (AAI. EPRI/NSAC Report NSAC-143, tranaaitted to th* CoaJ1iasion on March 27, 1991),
the staff should evaluate the various argwaent* for how averted on*aite coat* ahould be treated in coat-benefit analy**** Th* proposed ravi*iona to th* Regulatory Analyai*
Guideline*, including a thorough diacuaaion of the iaaue of averted on-aite coat*, ahould then be *ub*itted to the Commiaaion for review and approval.
(EDO)
(SECY suapenae:
8/14/92)
In the area of generic co.. unicationa in which a new staff poaition i* articulated or through which ataff seek*
additional iicen~ee co.. itaenta (~* oppoaed to *i*ply di****inating knowledge gained froa o~rational experience),
the Co11J1ission should be appriaed of auch co.. ur\\cationa prior to th*ir iaauance (Aa.51.a. via an 1ntoraatio~ paper),
unl*** it involv** an urgent aatter which auat be issued i.. ediately. Additionally, aince generic co.. unicationa do not provide fo:naal notice and comnant opportunities, effort should be **d* in such ca*** to aolicit th* views of interested groupa.
Th* ataff ahould propo** a **thodology to acco*plish thia.
In advising the Colllliaaion, th* staff ahould aumaariz* the safety iaaue to be addr****d, the baaia for th* new position, including a awmary of the views of interaated groups, and the rationale tor e~areaaing th* imaue via a ganeric communications rather th~n through rul***king or indivi~ual orders.
(EOO)
(SECY Su1penae:
~/24/92)
- 3)
The staff l1as indicated that n*w SALP procedures (Manual Chapter OS16) were implemented on Auguat 10, lttl. Thi* waa in reapon** to S!CY-90*119 and in accordance Yith the co.. iaaion'* directive. Th* revised procedur** did not include a aajor restructuring of the SALP Prograa, but did addr***, aaon9 other things, the definition* of th*
perforaanc* categori** and the criteria used for evaluations. Additionally, the staff baa infonaally di*cu***d what th* next step* for iaproving th* (ALP proc***
ahould be. Th* co.. iLaion believes that this i* the appropriate ti.. to cr/Rtalli1a th*** concept* and 1dentJ.fy specific area* of attentio~.
Th* ataff ahould undertake a coaprahenaive review of SALP results to detenain* whether appropriate QA control* are in place to enaura conaiatant and reliable evaluations. Th*
review should:
include an analyaia of both intra-And intar-ragional consistency of atandarda, procedure* and result*; address the **chanisms preaent to ensure th~t n national standard i* pr***nt and that tempora1 implications
("rising expectation*") are precluded, and av~luate whether
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3 sufficient controls are in place to enaure that individual inapector'* findings and opinion* cannot unduly influence the final evaluations. Suggestions for improving the process (e.g., requiring that SALP Boards have 2 out-of-
~,egion member*, in addition to the headquarters memberchip) should ba included as part of the review.
Additionally, and in light of the above reviews, the staff should reexa*ine the direct and indirect ramifications that categorical grade* have on licenaee actiono and whether the grades do help inprove plant safety. Suggestions for
!mproveaent ahould bo provided,** appropriate.
The atatf should present to the CoJ11JDission the results of their review* in order to reach agreement on the terms of reference, what action* require further analy*i* and work, and an appropriate timetable for completion of tha project.
The ataff should aubait the reaulta of the above reviews and analyse*, along with any reco... ndad corrective actiona, to the commiaaion for approval.
(EDO)
(SECY suspense:
3/6/9.2)
Additionally, Colllldisaioner curti9a requeats that the Policy Statement on Integrated Schedule* be raviewed by the commission before being publiahed in final for11.
(EOO)
(SECY Suspense:
3/6/92) cc:
Th* Chairman com2iaaioner Rogers commissioner curti**
coamisaioner Remick Commissioner de Planque OGC OCAA OIG ACRS I
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