ML19309C055

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Comments on Gao Rept, Nrc:More Aggressive Leadership Needed. Steps Are Being Taken to Improve Commission Leadership in Gao Recommended Areas
ML19309C055
Person / Time
Issue date: 03/14/1980
From: Ahearne J
NRC COMMISSION (OCM)
To: Mondale W
SENATE, PRESIDENT OF THE SENATE
References
NUDOCS 8004080091
Download: ML19309C055 (3)


Text

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UNITED STATES

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j NUCLEAR REGULATORY COMMISSION

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CORA March-14, 1980 OFFICE OF THE

' CHAIRMAN The Honorable Walter Mondale The President of the Senate Washington, D.C.

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Dear Mr. President:

In accordance with the statutory obligation to respond to recommendations by the General Accounting Office within 60 days of publication, we hereby submit our comments on the GA0 report entitled "The Nuclear Regulatory Comission:

More Aggressive Leadership Needed." The GA0 report is required by Section 306(b) of the Energy Reorganization Act (ERA) which directs the Comptroller General to evaluate the implementation of Title II of the ERA 60 months after the effective date of the Act.

We found the report to be particularly relevant to NRC at this time, dealing

.as it does with the history, the full scope, and the fundamental nature and responsibilities of the agency.

As evidenced by individual Commissioner comments on the draft version of the GA0 report (Appendices III-VII of the final report), individual Commissioners differ somewhat on GA0's ' findings with respect to the Commission's past performance and the implications of those findings.

Nevertheless we agree with the GA0's broad recommendation that the Commissioners must exercise increased leadership and direction ir.

nuclear regulation.

In general (with the important exceptions noted in the enclosures), the Com-mission believes that the report provides a reasonable overview of the nature of NRC's organizational and regulatory problems and their status at the time of the GA0 audits and interviews.

It should be noted that the NRC's structure, policies and practices have been, and continue to be, revised to reflect the evolving nature of NRC's regulatory responsibilities.

In addition, in the last six months the NRC has largely implemented or begun to implement many of the recommendations made by the GA0.

We have already taken a number of steps and are planning to intensify our efforts to improve Commission leadership in the specific areas recommended by GA0:

The Commissioners are examining existing NRC policies and formulating new policies to reemphasize safety's paramount importance in all NRC activities.

The renewed emphasis on NRC's primary mission of protecting the public health and safety is being codified by the Commissioners in a new docu-ment, the Policy, Planning, and Program Guidance (PPPG), which will be the primary mechanism for disseminating basic policy throughout the agency.

Over.the last year, the Commission has worked to develop the PPPG in order t6 improve NRC's previous methods of setting goals and measuring progress.

In the future, we expect,this effort to coincide r see4080 09/

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The Honorable Walter Mondale

  • with the development of our annual budget.

The final PPPG for the current budget cycle will be considered by the Commission in late March and is expected to be issued in April.

The PPPG process described above will be instrumental in identifying areas in which new Commission policy is needed or in which existing policy requires clarification.

The staff has in place a system for tracking progress on all tasks of policy significance identified as decision units in the budget.

The staff's decision unit' tra'cking system (DUTS) and the Commission's PPPG are the key elements of the Commission's new integrated system for establishing agency goals and measuring agency progress.

The Commission has taken several steps that will increase the Commission's control over the agency's policy-making.

The Commission intends to make greater use of Commission-level offices in policy development, in part by having the staff coordinate more closely with Commission offices at an earlier stage of policy development than has heretofore been the case.

Examples of increased use of Commission-level offices include the recent study of delegations of authority by the Offices of General Counsel and Pol. icy Evaluation and studies by OGC of the Commission's ex parte rules and' practices and of the role of the NRC appeal board.

RWresentatives of OPE and 0GC have served on agency-wide task forces such as those which studied construction during adjudication, the use of part-time members on the licensing panel, and cleanup of the Three Mile Island plant.

To meet these needs as well as maintain its other statutory responsibilities, the OGC staff has been increased.

The Office of Policy Evaluation has been directed to give increased emphasis to longer-range matters.

The net result of these efforts will be a substantial increase in Commission leadership in and control over agency policy development.

The Commission has also addressed the urgent matter of clarifying its roles and those of key staff.

Although the Commissioners differ on the dagree of authority the Chairman should have relative to other Commissioners and the best means of providing it, we do agree that the Chairman should exercise supervision of the staff, at least in matters on which the Comission policy is established.

With respect to the role ~of the Executive Direct.or, we have made it clear to the Office Directors that, notwithstanding their rights t6 communicate with the Commission directly, the ED0 is the agent of the Commission in supervising the staff's implementation of Commission policy.

As you know, the President is developing _a reorganization plan for the NRC.

Copies of our comments on elements of that plan relevant to these points are attached in Enclosure 1.

In sum, we agree with the GA0's report that the Commission must exercise in-creased leadership in nuclear regulation.

Our principal focus is'the agency's present performance and the need to continue to identify and implement the improvements consistent with the agency's primary mission of protecting the public health and safety in the future.

We believe-the. record of the recent past and our plans for the future provide a strong basis for confidence that we can and will meet that need.

F. ihe Honorabl

. Responses to the recommendations of the report are in Enclosure 1 and coments on the findings are in Enclosure 2.

Sincerely,

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i v'. /f John F. Ahearne Chairman

Enclosures:

As stated 1

cc:

Elmer 8. Staats Comptroller General of the United States i

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