ML19280B524
| ML19280B524 | |
| Person / Time | |
|---|---|
| Issue date: | 11/02/1981 |
| From: | Bassett H NRC OFFICE OF MANAGEMENT AND PROGRAM ANALYSIS (MPA) |
| To: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| References | |
| NUDOCS 8112070590 | |
| Download: ML19280B524 (6) | |
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HOV 0 7.133I PEMORANDUM FOR:
Victor Stello, Jr., Deputy Executive Director for Regional Operations and Generic Requirements
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Harold S. Bassett, Acting Director fx '
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SUBJECT:
SURVEY OF MECHANISMS USED TO C0fEUlilCATE WITH LICENSEES N OV 2 0 1981 -
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sc Sumary VXy s
y In response to your request, MPA has completed a survey to identiff-the s. /.
formal and informal mechanisms used to communicate with licensees.
Cori ~
mission personnel and several outside groups were er tacted.
Licensees were not contacted directly. A list based on the survey results is attached. This meno discusses l'PA's approach to the survey, notes some salient points identified by respondents, and makes a suggestion regarding any direct survey of licensees.
Approach o
Restricted survey to nuclear power plants. Assumed these are of more immediate interest.
o Included comunications which may be non-generic in nature.
o for the most part, restricted survey to "one-way" comunications (NRC to licensee), omitting licensee-generated comunications (such as correspondence resulting from reporting requt ements).
o Talked to the principal individuals who were (1) On the now-dissolved
" Licensee Communication Task Force," or (2) Who supported the preparation of NUREG-0339, " Survey [of Licensees] by Senior NRC Management... " to benefit from their extensive work.
o Talked with headquarters staff from IE, HRR, HMSS. ELD, and ADM.
(We understand that additional ELD views have been provided to you directly. )
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Talked with resident inspector program staff and regional inspection gJ staff from Region I.
,nf l-fVhy CONTACT:
John A. Sullivan,!:PA 49-29859 on.cn S U" * >
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Victor Stello, Jr.
2 NOV 0 21931 o
Contacted the Atomic Ir,' ' rial Forum and Institute for Nuclear Power ther industry had recently conducted Operations to determir-o similar surveys (answei
..cne had").
Salient Points Identified There are no widely accepted definitions of the tems " formal or " informal" cormunications with licensees. Some individuals restrict the use of the tem "fomal" to comunication documents that could be used as a basis for legal actions or sanctions. Other individuals include under that term any comunication that is written and addressed directly to a licensee.
The most inclusive definition of "fomal" would include any " official" contact (e.g., all it.spections--other than day-to-day contact by resident inspectors--would be included).
11 ore important than NRC-staff perceptions or distinctions between documents that are " legally enforceable" vs. "non-enforceable," and " formal" vs.
"non-fomal" nay te the possibility that many licensees may not perceive that there are such distinctions. That is, some licensees may view most cocmunications from NRC as legally binding.
Closely related to the foregoing point is that documents or mechanisms not nomally tl.ought of as communications to licensees may be considered by some licensees as interpretations of policy or changes in requirements.
Examples are SECY papcrs obtained by licensees, Architect and Engineering fims, etc. Speeches (such as the Chairman's recent Florida speech),
and even interviews or articles appearing in newsletters (e.g., Inside NRC) or periodicals may also be candidates for this category.
Survey of 1.icensees We strongly recommend that any future " survey" of reactor licensees involve very careful planning (in the selections of survey questions and potential respondents), not only to minimize " trips to the well," but also to maxi-mize the payoffs of these fomal contacts.
Nevertheless, there do seem to be some important questions, best answered by licensees, as follows:
1.
Do the licensees perceive any distinction between " formal" and " informal" and " enforceable" and " unenforceable" comunications?
2.
What is the relative extent and resource impact (including disruption of operations, maintenance schedules, etc.) of non-generic (e.g),
possibly emanating from project managers or resident inspectors conpared to generic requirements?
3.
What is an exhaustive list of recently imposed requirements that may actually be counterproductive to safety (some were cited in NUREG-0839)?
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Victor Stello, Jr.
3 NOV 0 21961 As just one example of the survey complexities involved, probably each question would have to be addressed to a different organization at a particular facility.
Conclusion In view of the salient points noted above, even c cursory review of the attached list leads one to conclude that the !;RC has an imense conmunica-tion problen.
We would like to support your effort to develop a system for controlling liRC's corounications with licensees.
I would like to discuss with you (1) how existino management infomation systems could be used to meet your needs and (2) how we raight assist in any value-impact or regulatory analysis that you might undertake.
/Sl Harold S. Cassett, Acting Director Office of 1:anagement and Program Analysis
Attachment:
As stated cc w/ attachments:
W. Circks, ED0 K. Cornell, D/EDO T. P. chm, A/ED0 J. Davis,!! MSS H. Denton,iRR R. DeYoung, IE D. Donoghue, TCM J. O'Peilly, Region II H. Shapar, ELD J. Craig, IE bcc:
J. Durst K. Perkins RETYPED - See next page for additional concurrences.
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9 Victor Stello, Jr.
3 As just one exemple of the survey complexities involved, probably each question would have to be addressed to a different organization at a particular facility.
Conclusion In view of the salient points noted above, even a cursory review of the attached list leads one to conlude that the liRC has an imer.se communica-tion problem.
We would like te support your effort to develop a system for controlling fiRC's comunications with licensees.
I would like to discuss with you (1) how existing management information systems could be used to meet your needs and (2) how we might assist in any value-impact or regulatory analysis that you might undertake.
Harold S. Bassett, Acting Director Office of Management and Program Analysis Attachner.t:
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cc w/ attachments:
W. Dircks, ED0 K. Cornell, D/EDO T. Rehm, A/EDO J. Davis, NMSS H. Denton,liRR R. DeYoung, IE D. Donoghue, ADM J. O'Reilly, Region II H. Shapar, ELD Distribution:
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MPA Reading MPA/APB Reading JASullivan, MPA h0 M
MPA MPA/APB
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11/?/81 11/ 4 /81 11/ /81 omp we enu deawa m_u ma OFFICIAL RECORD COPY use.r.a m i-m m
COMMUNICATION MECHANISMS Formal
_ Regulations and Related Issuances Regulations Acceptance Criteria (e.g., Branch Technical Positions, Regulatory Guides)
Federal Register Notices (e.g., Rulemaking, Petitions for Action)
Code Conaittee Documents (e.g., ASME, IEEE)
Licensing and Amendment Process PSAR, FSAR, DES, FES Technical Sper.ifications Reactor Licensing Amendments Operator / Senior Operator Licenses (Issuance and Amendments)
Public Hearing Records ACRS Meeting and Letters Formal Correspondence C?neric Letters TMI action Plan Letters Orderc (including Confirmatory Orders)
Bulletins Immediate Action Letters Denial t etters to Applicants for Operator and Senior Operator Licenses Reports NUREG Reports Ci rcula rs Information Notices Special Reports Operator Examination Result Reports Inspection and Enforcement Activities Inspection Reports Enforcement Notices Performance Appraisal Team Reports Investigation Reports Entry, Exit, and Management Meetings SALP Reports Mi_scellaneous Activities Public Meetings Preliminary Notifications Lists of Personnel to Provide Access to ATTACHMENT
~
2 Informal Telephone Reports of Occurrences Licensee Event Report 1
Sent to Other Licensees Construction Deficiency Reports J Conferences Licensee Requested NRC Requested Matters of Current Interest NRC Participation in and Comment on Licensee Drills Meetings Between NRC/ Licensee Public Affairs People Press Releases Public Meetings (Held Quarterly)
Resident Inspector Day-to-Day Contact NRC Operator Licerising People Contact Licensees on a Continuing Basis Periodic Visits to Some Licensees by HQ Staff Such as ELD or Other Offices' Staff NRC Discussions with Local Officials on Matters Affecting Licensees Speeches to Local Groups or Industry Associations Safety Evaluation Report Review for Licensing Code Committee Working Group Phone Calls or Site Visits by NRC Staff or Commission to:
Interpret formal Requirements Obtain Information (i.e., Corrective Actions, Schedules, Conduct Surveys, Etc.)
Precede a Formal Action (i.e., Immediate Action Letter, Notice of Civil Penalty, Etc.)
Discuss Proposed Requirements (i.e., New Security Plans, Proposed Tech Specs,Etc.)
Meetings with Owners' Groups (i.e., Unresolved Safety Issues, and Generic Matters)
Other Information Exchange (i.e., Workshops, Public Meetings, Technical Discussions)
SECY Papers (Some utilities apparently sent operators to college based on recent SECY paper on operator qualifications.)
Contractors (National Labs) - Obtaining information from utilities for specific projects (i.e., plant-specific risk assessment, human factors, etc.)
Meetings with Industry Representatives (i.e., AIF, INP0) on Matters Affecting Licensees Discussions between NRC and Utility Legal Representatives during Hearing Process Media Coverage (TV, Newsletters, Periodie's)