ML20029A658
| ML20029A658 | |
| Person / Time | |
|---|---|
| Issue date: | 02/19/1991 |
| From: | Carr K NRC COMMISSION (OCM) |
| To: | Bowsher C, Conyers J, Darman R, Glenn J, Graham B, Kostmayer P, Sharp P GENERAL ACCOUNTING OFFICE, HOUSE OF REP., ENERGY & COMMERCE, HOUSE OF REP., GOVERNMENT OPERATIONS, HOUSE OF REP., INTERIOR & INSULAR AFFAIRS, OFFICE OF MANAGEMENT & BUDGET, SENATE, ENVIRONMENT & PUBLIC WORKS, SENATE, GOVERNMENTAL AFFAIRS |
| Shared Package | |
| ML20029A659 | List: |
| References | |
| NUDOCS 9103010114 | |
| Download: ML20029A658 (9) | |
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UNITdD STATES -
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NUCLEAR REGULATORY COMMISSION n-i
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wAsHmoT oN, D. C. 20055
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February 19, 1991
- CHAIRMAN The Honorable J.ohn: Conyers, Jr., Chairman
. Committee on Government Operations linited States House of Representatives Washington, D.C.
20515
Dear Mr. Chairman:
'In--accordance with the statutory obligation. to respond to recommendations by the; General Accounting Of fice (GAO) within 60_ days of publicatter.,- I am submitting =the Nuclear Regulatory Commissio'n's:(NRC's) responses to the three recomn.endationc made by the GA0!in its report, " Nuclear Regulation:.NRC's Efforts to Ensure Effectivo Plant Heintenance Are Incomplete." -Our detailed comments are enclosed.
.The Commission believes that ongoing NRC efforts to-evaluate the-need-for:rulemaking in_the maintenance area are consistent with GA0's first recommendation.
The NRC also has initiated actions that: achieve the general objective of the second and-third GA0 recommendations.' We expect to complete action on these GAO-recommendations:in 1991.
Sincerely..-
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Kennnth M. Carr-
Enclosure:
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- Responses to GA0 Recommendations-cc:
Representative Frank Horton
-Representative Sam-Gejdenson
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- UNITED ST ATES NUCLEAR REGULATORY COMMISSION
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February 19, 1991-
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- CHAIRM AN l
The Honorable John.Glenn, Chairman
. Committee on-Governmental-Affairs
'IJnited States' Senate Washington,.D.C.
20510
Dear Mr. Chairman:
In.accordance with the statutory-obligation to. respond-to recommendationstby the General Accou'nting Office (GAO) within 60 days'. of publication,. I _ an submitting the Nuclear Regulatory Commiss. ion's-(NRC's) responses to the three recommendations made by.-the:GA0 in its repcrt, " Nuclear Regulation:
t!RC's Ef forts to Ensure Effective Plant--Maintenance Are Incomplete."
Our detailed c
--comments-are: enclosed.
-The Commission: believes.that ongoing ~HRC efforts _to evaluate the need f er rulema king, in -the maintenance area are consistent with-GA0's first recommendation.
The NRC-also has initiated actions
.that achieve;+ " general objective of the second and third GAO.-
recommendation _s.
We expect.to complete action on these GA0 recommendations in:1991..
Sincerely, sW.
Kenneth ti Carr
Enclosure:
Responsesuto GAO JRecommendations-cc:. = Senator-Wi1111am-V. Roth, Jr.
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l-Jo UNITLD STATES 8
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-The flonorable--Bob Graham, Chairman Subcommittee-on-Nuclear-Regulation Committee-on Environment and Public Works
. United States. Senate Washington,lD.C.
20510
Dear Mr. Chairman:
g 21n accordence with_the statutory obligation to respond to-
' recommendations' by the. General Accounting Office (GAO) within 60-. days of' publication, 1-am submitting the Nuclear Regulatory.
Commission's (NRC's) responses to the three recommendationt made.
~by'the GAO in;its report, " Nuclear.-Regulation:' NRC's Efforts to Ensure Effective Plant Maintenance Are~ Incomplete." 'Our detailed commentsfare enclosed.
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-The' Commission believes that ongoing NRC efforts to evaluate the-need=for rulemaking.in the meintenance area are consistent with
> GAG?s'first recommendation.
The NRC:also has-initia"tod'actinns that: achieve the general objective of the-second and third GAO
- recommendations, -.Werexpect to complete action on these GA0 Lrecommendations in 1991, Sincerely, h)th%,
I Kenneth M. Carr-F E n c l o s u re :--
' Response 2lto GAO Recommendations-cc: LSenator' Alan K. Simpson
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yi UNITE D STATES iVi S
NUCLEAR REGULATORY COMMISSION l
W ASHINGTON, D, C. 705%
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february 19, 1991 y
CHAIRMAN The Honorable Peter Kostmayer., Chairman Subconmittee on Energy and the Environment Committee on Interior and Insuler Affairs United States House of Representatives Washington, D.C.
20515
Dear Mr. Chairman:
In accordance with the statutory obligat'on to respond to recon.mendations by the Gencral Accounting Of fice (GAO) within 60 days of publication, I am submitting the fluclear Regulatory Cormission's (HRC's) responses to the three recor,mendations made by.the GA0 in its report, " Nuclear Regulation:
HRC's Efforts to Ensure Effective Plant Maintenance Are incomplete,"
Our detailed comments are enclosed.
The Cemnission believes that ongoing NRC efforts to evaluate the need for rulemaking in the maintenance area are consistent viith GA0's first recommendation.
The NRC also has initiated actions that achieve the general objective of the second and third GA0 recommendations.
We expect to complete action on these GA0 recommerdations in 1991.
Sincerely,
\\h <.k Kenneth M. Carr
Enclosure:
Responses to GA0 Recommendations cc:
Representative John J. Rhodes 1
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UNITED STATES 8
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+4 4 february 19, 1991 CHAIRMAN i
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-The Honorable-Philip R. Sharp, CheIrman Subcomnittee on Energy and Power Committce oniEnergy,and-Commerce United States House of Representatives Washington, D.C.
20515-Dea r lir.-- Cha irman:
In accordance-with'the statutory obligation tc respond to recommendations by_the General Accounting Office-(GAO) within
!60 days of pub-lication, 1:am-submitting the Nuclear Regulatory Commission's (NRC's). responses to the;three recomn.endations made by the GA0__in its report. " Nuclear Regulation:
NRC's Efforts to Ersure: Effective-Plant Meintenance>Are Incomplete."' Our detailed comments are enclosed.
The Commission believes-that-ongoing NRC effnrts to evcluate the
-need for rulemakingLin-the maintenance area are consistent with GA0's first-recommendation.
The NRC also -has initiated actions that achieve the genera-1 objective of the second and third GA0 recommendations.. We-expect-to-complete' action'on these-GA0 recommendations in~1991.
Sincerely, M%b Kenneth-M. Carr L
Enclosure:
Responses'to GA0 Recommendations
- c c : :- Representative Carlos J. Moorhead
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W AWING T ON, 0. C. 20666
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February 19, 1991-CHAIRMAN i
The; Honorable-Charles A. Bowsher
- Comptroller General ~of the United States LGeneral Accounting Office-
.h shington,-.D.C.
20548
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Dear Mr. Bowsher:
In:accordance with.the statutory obligation to respond to recommendations: by the General Accounting Of fice '(GAO) within
-60 days of publication, 1:am submitting the Nuclear Regulatory n
Commission.'s.~(rtRC's) responses:to the-three recommendations made
.by the-GA0 in -its-report, *Ituelear Regulation: - NRC's:-Efforts-te Ensure: Ef fective Plant Maintenance Are ' Incomplete."
Our detailed comments'are enclosea.
JThe Commission believes that ongoing NRC efforts to evaluate the
-need for _rulemaking in the maintenance'aree.are consistent with GAO.'s-first recommendation.
The NRC also has initirted actions thet: achieve-the general. objective of the.second and third GA0 recommendations.- i!e -expect to-complete action on the:;e GAO-crecommenda tions-lin-1991.-
S-incerely,-
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Kenneth M. Carr
Enclosure:
. Responses to GA0 l
Recommendations' l
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february 19, 1991 CHAIRMAN The Ponorable Richard G. Dartnan Director Office of Management and Budget W a s h i r.g t o n, D. C.
20503
Dear Mr. D a rira n :
In accordance with the statutory obligation to respond to recorrrendations t'y the General Accountirs Of fice (GAO) within 60 days of publication, I ara submittin; the Nuclear Regulatory i
Cominittion's (NRC't) respontes to the three recomrrerdotions made by the GA0 in its report. " Nuclear Regulation:
NRC's Efforts to Ensure Effective Plant Maintenente Are Incoraplete."
Our detailed corme nt s a re encloted.
The Commission believes that ongoing NRC efforts to evaluate the need fer rulemakirg in the maintenance area are consistent with G AO 's fi rs t recor:rrenda tion.
The NRC also has initiated actions thet achieve the general objective of the second and third GA0 r e c omm e rid a t i o n s.
We expect to complete action on these GA0 rernemendations in 1991.
Sincerely, O
i...t h, %
Kenneth M. Carr Enclosurs:
Response', to GAO Recormendations i
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J Responses to GA0 Pecommendations Chapter 2 The GA0 responded u the question, " Maintenance Regulations: Are They Needtd?"
with the following recommendation:
"To previde the foundation for ensuring utilities' future commitment to effective plant r.aintenance, we reconnend that the Chairman, NRC, base the decision on the need for additional rtgulations, in large measure, on HRC's ability to enforce cor.ective action in all plant areas, including balance-of-plant."
NRC Response:
The NRC agrees that enforceability is an important factor to consider in evaluating the appresch to be taken on the maintenance issue.
On April 13,1990, the staff recommended to the Comission proposed criteria to be used for determining the need for additierel raaintenance rulemaking.
On May 25, 1990, the Commission, in approving the staff's proposed criteria, indicated that the staff should consider, among other factors, the ability to enforce mainter,ance programs or standards.
This factor will bt considered by the Commission in its final determination on the need for additional rulcmaning in the maintenance area. The NRC staff is preparing its recomendation or the need for additional rulemaking on maintenance and will provide its recommenda-tion to the Commission in April 1991.
Chapterj As a result of a review of performance indicators, t% GA0 made the follning two recomrrendtions to the Chairman; NRC, to help the hPC ensure compliance with the maintenance requirements eventually established:
1.
" Ensure that NRC continually examines utilities' commitment to maintenance either through its regular inspection progran or by periodically conducting special teen inspections af ter April 1991,"
NRC Response: The NRC agrees with the GAO recommendation. The NRC examines utilities' cornitment to maintenance continually through the regular inspection program and periodically through special team inspections. We intend to upgrade our regular inspection proge:m to include additional attention to maintenance issues. As pret of the current hRC inspection program for comercial power react es, inspection procedure 62703, " Monthly Maintenance Inspection," dire.1s the NRC resident inspector staff to evaluate a utility's mainte' ance program, including the quality of maintenance, by direct observation of ongoing maintenance activities. The HRC is developing a major revision to this inspection procedure to include the major elements and guidance of the Maintenance Team Inspection Program, which is currently being implemented by team inspections conducted for all plants to assess the status of naintenance in preparation for a decision on the need for a maintenance rule. The revised procedure will ensure that the utilitics' comitment to their maintenance programs, as well as maintenance performance, are appropriately examined by NRC resident and egional personnel as part of reatine inspections.
In addition, in 19', the NRC plans to incor> orate the Maintenance Team Inspection process es a new procedure into tie NRC's inspection manual, This new procedure would be used by a special team as ne;essary when conditions at an individual plant require an extensive review of the maintenance process.
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2.
- Integrate perfornance indicators into the inspection process."
imC Response: The NRC agrees in principle with the GA0 recorrendation.
Performance indicators do provide valuable input into the inspection process, and from limited applications in octual plant circumstances using utility-supplied failure data (NPRDS), were shown to identify $_ome, of the specific structures, systems, and coh.ponents warranting review.
However, based on these satae trials with the utility-supplied data, the agency's Maintspance Effectiveness Indicator was shown to be not sufficiently developed for purposes of identifying all of the specific systems, structures, and components which should he reviewed. The NRC believes that the existing NRC Performance Indicator Program provides an additional view of operational performance and enhances the NRC's ability to recognize general areas of poor and/or dec1%1ng safety performance at operating plants.
However, it is only a tool ata it, used in conjunction with other tocis such as the rereits of routine and s etial inspections and the SystenatIc Assesstnent of Licensee Performance fSALP) program, to provide input to NRC management decisions regarding the need to adjust plant-specific regulatory prograris.
It is important to note that the performence indicators have limitations and can be misinterpreted.
Because of these limitations, performance indicators are net over-emphasized in relation to other rneasures of safety performance, for this reason, the llRC does not take regulatory action, including directing inspection resources, tolely on the basis of Performance Indic6 tor Program results.
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