ML20006F501
| ML20006F501 | |
| Person / Time | |
|---|---|
| Issue date: | 11/27/1989 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| References | |
| ACRS-2679, NUDOCS 9002280096 | |
| Download: ML20006F501 (13) | |
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DATE ISSUED:
11/27/89 i'
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duh/3lfY1 ACRS REGULATORY POLICIES AND TRACTICES SUBCOMMITTEE MEETING MINUTES NOVEMBER 15, 1989 RETHESDA, MARYLAND i
PURPOSE The purpose of this meeting was to continue the process of developing an ACRS response to the Commission on how best to integrate the regulatory process. The Comission, at a meeting on May 3,1989, requested the ACRS to provide its thoughts on "how best to integrate the regulatory process."
PRINCIPAL ATTENDEES ACRS NRC H. Lewis, Chairman R. W. Houston, RES F. Remick, Member
- 0. Ward, Member W. Kerr, Member J. Carroll, Member C. Michelson, Member
- Part Time MEETING HIGHLIGHTS, AGREEMENTS, AND REQUESTS y
Dr. Harold Lewis, Subcommittee Chairman, discussed the purpose of the meeting, mentioning that the staff had responded to the Commission's request concerning how best to ensure integration of the regulatory process with an EDO letter dated October 10, 1989. Dr. Lewis suggested that their response did not properly address the issue.
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2-November 15, 1989 Practices Meeting Minutes Dr. Houston, Office of Research, discussed the staff's problems associ-ated with trying to integrate their work. He noted that the staff usually functions with scheduling restraints, such that the imposition of such restraints are not amenable to integration. There is a lot of emphasis on meeting schedules, both Commission and Congressional.
In response to a question from Dr. Lewis concerning who Dr. Houston was representing at this meeting, Houston said the October 18, 1989 letter l
was written by him with several NRC offices concurring.
It was signed out by the EDO.
Frank Gillespie, NRR, added that Dr. Houston, both through the October 18th letter and at this meeting, was also repre-senting hRR with regard to this matter.
Dr. Remick felt that in order for the Commission's safety phi.losophy to be consistent, the Executive Director for Operations (EDO) would have to be the one to ensure this was done.
He expressed his disappointment that the EDO was not in attendance at this meeting.
Dr. Remick discussed some examples of specific NRC offices not knowing what other NRC offices were doing, noting that possibly the CRGR may be the proper group to ensure integration.
Dr. Lewis suggested that setting of coherent policies in the NRC's regions is more frequently done by regional than by headquarters personnel. Mr. Gillespie said that any new requirements going to regions have to go through his program office and that inspection procedures would have to be written if there are any new requirements.
Gillespie noted that in addition, NRC management groups are going to the regions to see that policies are being implemented as intended.
Three visits have already been performed and the last of these visits will be conducted in December 1989. The group members have t,een coming back y
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Regulatory Policies and l
Practices Meeting Minutes November 15, 1989 i
to headquarters with many of the same complaints from the different i
plant managers, e.g., complaints about ratcheting and fear of retribution, along with criticism not only of inspectors by also of the NRC staff.
Mr. Gillespie stated that the staff's integration of regulatory matters i
has greatly improved in recent times. He felt there was less disparity among new requirements now as compared to previous times and that it is i
getting even better. He felt that there are not very many issues of any significant value that don't get thoroughly discussed among the various offices, such that all necessary offices and responsible individuals do know about them. Gillespie said he is the single sta,ff contact in the RES/ER interface, and the ouestions of "have we done it before, is the cost more than its worth, should it be forward fit or backfit " are always asked.
Dr. Lewis suggested that the budget process, fighting over money, is a way of integrating, but that the difference between coherence and j
integration should be a philosophical approach to safety at a high level.
The Subcommittee members noted that it appeared to be the general f(cling of the staff representatives that attended the meeting that there is no significant problem with regard to the lack of coherence in the regulatory process at this time, but that if and when they do see any problem, they will work on it.
Members of the Subcommittee suggested that the incoherence in the regulatory process really did not completely fall on the staff partici-pants to resolve, but generally fell in the ED0's domain. The EDO was not at the meeting, but should be invited to 3ttend a future meeting, at which time, this problem should be discussed.
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Regulatory Policies and Practices Meeting Minutes November 15, 1989 Mr. k'ard suggested that there appears to be some systematic failure in the system, such as the need to meet schedules in order to get employee bonuses which may over-ride the act of ensuring that requirements are
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coherent.
Dr. Beckjord said that as a whole, the approach to ensuring coherence is working reasonably well. He said that with regard to the USIs and Gis, there was a large backlog of issues from a few years ago that had to be taken care of in a timely manner. This number has now dropped from 735 I
to about 80 and in another year that number will be liquidated. The large backlog of these items, along with the schedule that had to be met, did not lend itself to ensuring that all personnel working on issues would be fully aware of others work in areas t' hat may have overlap.
Dr. Kerr noted that the NRC's regional offices are putting a large emphasis on the " problem plants " and asked whether the headquarters and regional offices have some sort of self assessment for themselves.
Gillespie said the NRC is doing a self assessment of the entire inspection program (including self assessment of the regional and headouartersoffices). This cuality assurance program will look at each office.
Drew Persinko is looking at NRR. All offices will be reporting to the EDO on November 27, 1989.
Dr. Kerr expressed his concern that it appeared the NRC's regional employees are trying to run power plants. Gillespie suggested that the Comission has the same concern, i.e., micro-management. The Comission is going back and looking at the basics for the Systematic Assessment of Licensing Performance (SALP). The SALP was the catalyst for the Public Utility Commission using NRC ratings at the Boston Edison Plant for setting electric rates.
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i Dr. Beckjord stated that "the staff is doing the best they can with regard to ensuring coherence of its regulatory policies considering the large number of clocks running." He felt this was the significant l
source any incoherence in the regulatory process.
In response to questions from Dr. Siess concerning why industry has shown so little interest in the Integrated Safety Assessment Program (ISAP),Gillespiesaidthatmostplantsdonothaveenoughbacklogitems on their plants to want to get the NRC involved with their scheduling.
Gillespie said ISAP was good for plants that have a lot of things backed up, but there were only a few plants in this situation.
EXECUTIVE SESSION The members discussed the information obtained during the meeting noting that some of the problems seen by the ACRS were not seen by the office representatives in attendance at the meeting.
The members discussed some possible strategies that the Subcomittee could recommend to the Committee with regard to coherence in the regu-latory process. The possible approaches discussed included the follow-ing:
a.
The Comittee could pick an item and follow it through the Commission to see how it is shown to be coherent, b.
An outside " blue ribbon" panel, could be set-up to take an outside look at whether the Comission is acting in a coherent manner with regard to establishing policies and new regulatory requirements.
c.
The Comittee could talk to the ED0 with regard to this matter and make its recomendations following that meeting.
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L Regulatory Policies and Practices Meeting Minutes November 15, 1989 Mr. Ward suggested that the ACRS should better define the problem, e.g.,
does incoherence in the regulatory process make electricity more expen-sive or nuclear plants less safe, etc.
Dr. Remick indicated he was not in favor of establishing an outside panel, but suggested that the ACRS was a more likely group to do a review of this matter for the Comission.
Dr. Kerr suggested that based on recent discussions, the Commission did not appear to be interested in the ACRS thoughts on management.
Dr. Lewis questioned where in the NRC the expertise for reviewing increased reliability.of plants through the use of ad,vanced technology is assigned. He noted that the new EPRI requirements are supposed to be pushing for better and safer plants using advanced technology, but that the NRC appears to be looking down on this matter.
The Subcommittee suggested that the ACRS should write a letter to the Commission on coherence in the regulatory process. The letter should contain a list of examp1es the Committee has stated in its previous reports that mentioned the need for coherence and iiitegration in the regulatory process, along with a statement that there is no mechanism in place in the NRC to ensure that things stay up with the state of the art, with regard to increasing reliability of reactor plants.
The members discusseo the suggestion that a " blue ribbon" panel be used to review the NRC's organization for coherence in its requirements.
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was suggested that members of the Committee should draft a charter for such a panel if the Committee suggests that such a panel be used.
James Taylor, Acting EDO, was contacted during the Subcommittee meeting and indicated that he would not attend the 355th ACRS meeting, but will attend the 356th ACRS meeting to discuss this matter.
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Fegulatory Policies and Practices Meeting Minutes 7
November 15, 1989 NOTE:
Additional meeting details can be obtained from a transcript of this meeting available in the NRC Public Document Room.
2120 L Street, NW, Washington, DC 20006.(202)634-3273,or can be purchased from Ann Riley and Associates. Ltd., 1612 K Street, NW, Suite 300, Washington, DC 20006 (202) 293-3950.
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4 INTEGRATED APPROACH ON REGULATORY MATTERS R. W. HOUSTON, RES NOVEMBER 15, 1989 ACRS SUBCOPPIITTEE ON REGULATORY POLICIES AND PRACTICES 4
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BACKGROUND
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/7615 15, 1989 '~
ACRS LETTER DATED MARCH,
--NEED FOR GREATER C0HERENCE AMONG NEW REGULATORY POLICIES" SECY-89-178 DATED JUNE 9, 1989
" POLICY STATEMENT INTEGRATION" ACRS LETTER DATED APRIL 17, 1989
" INTEGRATED APPROACH ON REGULATORY MATTEP.S" 3
MEMORANDUM TO CHAIRMAN CARR DATED OCTOBER 18, 1989
" INTEGRATED APPROACH ON REGULATORY MATTERS" e
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- 4 ALLOCATION OF NRC PRIORITIES AND RESOURCES FIVE YEAR PLAN AND BUDGET PROCESS STRATEGIC PLANNING POLICY AND PROGRAM GUIDANCE RESOLUTION OF SAFETY ISSUES i
PROCESS FOR GENERIC ISSUE RESOLUTION SECY-89-138 DATED APRIL 27, 1989,
" WITHDRAWAL OF 1978 NRC POLICY STATEMENT..."
SECY-89-328 DATED OCTOBER 24, 1989, "USE OF PROBABILISTIC RISK ASSESSMENT IN RESOLVING SAFETY ISSUES" i
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P RESOLVING "0THER" GENERIC ISSUES REGULATIONS DEVELOPMENT-SEVERE' ACCIDENT ISSUES SECY-88-IIs7 DATED MAY 25, 1988,
" INTEGRATION PLAN FOR CLOSURE OF SEVERE ACCIDENT ISSUES"
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SECY-89-31 DATED OCTOBER 10, 1989,
" RESOLUTION PROCESS FOR SEVERE ACCIDENT ISSUES FOR EVOLUTIONARY LIGHT WATER REACTORS" PLANT SPECIFIC SAFETY ISSUES t
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i CONSIDERATION OF INDUSTRY RESO_ _URC _ES
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INTEGRATED SCHEDULES (ISAP)
INTEGRATION OF IMPOSED WORK LOAD ON LICENSEES ROLE OF CRGR f
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a OBSERVATIONS SAFETY GOAL POLICY AS AN INTEGRATING VEHICLE ROLE OF REGULATORY ANALYSIS GUIDANCE BACKFIT OF NEW REQUIP.EMENTS FORWARD FIT OF NEW REQUIREMENTS CHANGING INEFFECTIVE OR UNNECESSARY REQUIREMENTS i
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