ML20033D941
| ML20033D941 | |
| Person / Time | |
|---|---|
| Issue date: | 04/27/1988 |
| From: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Connelly S NRC OFFICE OF INSPECTOR & AUDITOR (OIA) |
| Shared Package | |
| ML20033D942 | List: |
| References | |
| FOIA-92-402 NUDOCS 8805120137 | |
| Download: ML20033D941 (3) | |
Text
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April 27, 1988 MEMORANDUM FOR: Sharon R. Connelly, Director Office of Inspector and Auditor FROM:
Victor Stello, Jr.
Executive Director for Operations
SUBJECT:
REVIEW 0F THE IMPLEMENTATION OF THE PLANT-SPECIFIC BACKFIT PROCEDURES This responds to your March 24, 1988 memorandum transmitting the subject audit report.
I note your conclusion that I need to increase and improve the management oversight of the plant-specific backfit process to assure that backfits are being identified and handled in accordance with 10 CFR 50.109 and MC-0514. As a general connent, I note that in independent recognition of some of the deficiencies noted in the report, I had the Director of the Office for Analysis and Eva'iuation of Operational Data (AE0D) assure the duties in the PC-0514 (revised to respond to the then recent court decision). This action took place just af ter the audit period, i.e., on November 13, 1987 with the audit period being February to October 1967 and was therefore not evaluated by the audit. With respect to your specific reconnendations, I submit the following:
Recommendation 1.
Establish procedures to be used by the ED0's office to monitor implementation of plant-specific issues.
Response
We agree, the revised Manual Chapter paragraph 032 assigns AEOD the responsibility for developing oversight procedures for the agency.
Reconmendation 2.
Assure sufficient resources are assigned in the ED0's office to effectively monitor the implementation of MC-0514.
Response
We agree, however, AEOD will provide the resources to implement this oversight.
AEOD already provides appropriate oversight for generic backfits and, in view of the severe limitations on resources, is looking at cost effective ways of monitoring the plant-specific backfii: process. Since evidence of a problem with plant-specific backfits is a substantial increase in licensee complaints, AE00 is considering methods such as an annual questionnaire to licensees in addition to review of all backfit appeals from licensees.
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Reconmendation 3.
Assure that MC-0514 is finalized and included in the NRC Hanual.
Response
We agree, the MC-0514 has been submitted to the Commission with the proposed final rule on backfitting.
Recommendation 4.
Assure that the Office / Region procedures are revised as necessary to provide specific and consistent guidance for recording data on and tracking plant-specific backfits in accordance with MC-0514.
Response
We agree, this will be addres' sed as part of the implementation of the Manual Chapter.
Reconnendation 5.
Include in MC-0514 specific procedures for assessing plant-specific backfit issues for generic implicatiens.
Response
We agree MC-0514, paragraph 43 Regulatory Analysis was modified to include consideration of the plant-specific backfit as a possible generic backfit.
Recommendation 6.
Assure that the current status of active and closed issues is both timely and accurately recorded in the PSBS.
Response
We agree, this will be incorporated into Office and Regional procedures developed to c:anage the plant-specific process and will be monitored in the' oversight of the program.
Recommendation 7.
Establish and implement criteria to assure that plant-specific backfits imposed on licensees are closed only after NRC accepts licensee commitments and verifies that the actions have been taken.
Response
We agree, criteria are necessary to establish uniform reporting of the closeout of plant specific backfits. This will be addressed in Office / Region L
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procedures and coordinated by AEOD. Due to the plant-specific nature of backfits, close out verification could entail large expenditures of staff resources without conmensurate safety benefits. Thus, close out procedures may be developed which are short of verification by NRC on-site inspections.
Reconcendation 8.
Establish controls to eliminate unnecessary access into the PSBS.
Response
We agree, the Manual Chapter now includes a statement that acces? tr; ev.ke charges will be limited to designated personnel.
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,d/ DG Vff tor Stello,ftor Jr.
Executive Dire for Operations cc:
J. Taylor 6
T. Re'hm E. Jordan l
J. Murray i
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