ML20035G591
| ML20035G591 | |
| Person / Time | |
|---|---|
| Issue date: | 09/20/1991 |
| From: | Jordan E NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD) |
| To: | Blaha J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20033D942 | List: |
| References | |
| FOIA-92-402 NUDOCS 9304280132 | |
| Download: ML20035G591 (7) | |
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'o, UNITED STATES NUCLEAR REGULATORY COMMISSION
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September 20, 1991 Uc Q A dp /gg d'dt w._
N MEMORANDUM FOR:
James L. Blaha Assistant for Operations Office of the Executive Director for Operations FROM:
Edward L. Jordan, Director Office for Analysis and Evaluation of Operational Data
SUBJECT:
STATUS OF STAFF IMPLEMENTATION OF OIA RECOMMENDATIONS REGARDING NRC BACKFIT PROCEDURES This is in response to your memorandum of August 29, 1991 on the same subject.
Your review indicated that Recommendations 1, 7, and 8 were not implemented and that further improvement was possible for Recommendation 6.
You requested a description of the actions AE00 will take regarding these items.
AEOD will take actions to implement Recommendations I, 7, and 8 as described in the enclosure.
It is expected that these actions will be completed by December 30, 1991. AE0D will also take action to effect improvement regarding Recommendation 6 as described in the enclosure.
It is expected that the improvement will be apparent by December 30, 1991.
f/00pg7 We will provide a followup report on these actions by December 30, 1991. p/g gg 7 dwa d, Jordan, Director Office or Analysis and Evaluation of Operational Data
Enclosure:
As stated cc/w enclosure:
J. Taylor, EDO T. Murley, NRR t
Regional Administrators 1
19304200132 930204 PDR FOIA LEN92-402 PDR t
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.I September 20, 1991 t
MEMORANDUM FOR:
L Blaha Office of the Executive Director for Operations FROM:
Edward L. Jordan Director Office for Analysis and Evaluation of Operational Data
SUBJECT:
STATUS OF STAFF IMPLEMENTATION OF OIA RECOMMENDATIONS i
REGARDING NRC BACKFIT PROCEDURES This is in response to your memorandum of August 29, 1991 on the same subject.
Your review indicated that Reccmmendations 1, 7, and 8 were not implemented and that further improvement was possible for Recommendation 6.
You requested a description of the actions AE0D will take regarding these items.
AEOD will take actions to implement Reccmmendations 1, 7, and 8'as described I
in the enclosure.
It is expected that these actions will be completed by l
December 30, 1991.
AEOD will also take action to effect improvement regarding Recommendation 6 as described in the enclosure.
It is expected that the improvement will be apparent by December 30, 1991.
We will prov1 followup report on these actions by December 30, 1991.
e Original Signed by:
E. L. Jordan Edward L. Jordan, Director Office for Analysis and Evaluation j
of Operational Data
Enclosure:
As stated j
cc/w enclosure:
J. Taylor, ED0 i
T. Murley, NRR Regional Administrators Distribution AEOD R/F DChamberlain, EDO LJCallan, RIV ELJordan PCota, NRR AJohnson, RV J
DFRoss DHolody, RI AE00 91-106 i
JSniezek LWatson, RII DPAllison i
RDovovan, DIG CPederson, RIII JConran CRGR:AEOD
- AE0D t
DPAllison
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DF, ss ELJordan 9/q/91:jr 9/
1 9p/91
i Enclosure AE0D Actions RECOMMENDATION 1:
Establish procedures to be used by the ED0's office to monitor implementation.
of plant-specific backfit issues.
OEDO DISCUSSION (8/29/91) i On April 27, 1988, the EDO commented on a draft DIA report on plant-specific backfitting procedures.
In addressing this recommendation the EDO stated that Manual Chapter 0514 paragraph 032 assigns responsibility for developing oversight procedures for the agency to AE00.
Although AE0D is exercising oversight responsibility, there are no formal (or
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informal) AEOD procedures for this task.
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The need for a procedure was discussed with the AE0D contact who stated that.
i it would be relatively straightforward to prepare such a procedure.
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This recommendation is therefore not yet implemented.
AE00 RESPONSE AE0D will issue a procedure to document its activities in monitoring plant-specific backfitting.
It is expected that this will be done by October 30, 1991.
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i RECOMMENDATION 6:
The EDO should assure that the current status of active and closed issues is
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both timely and accurately recorded in the PSBS.
OEDO DISCUSSION (8/29/91)
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The AEOD contact stated that this was done on an audit basis.
Problems identified are discussed with the appropriate office or region _ and are usually corrected in a reasonable time.
i Review of the PSBS found that the data base was generally up to date.
i However, there were some items for which predicted closing dates were not given and the current status was not clear: for example, issue RRFARL190001, which is a backfit concerning operating shift overtime at Farley Unit 1.
l This recommendation was implemented and the PSBS accuracy has improved.
However, there remains room for acditional improvement.
AEOD RESPONSE The procedure discussed in response to Recommendation I will specify frecuent reviews of the tracking system and we will place more emphasis on conducting j
the reviews as scheduled. When combined with appropriate feedback and followup, this should further improve the timeliness and accuracy of the i
tracking system entries.
It is expected that the improvement will be evident by December 30, 1991.
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RECOMMENDATION 7:
The EDO should establish and implement criteria to assure that plant-specific backfits imposed on licensees are closed only after NRC accepts licensee commitments and verifies that actions have been taken, i
OEDO DISCUSSION (8/29/911 Manual Chapter 0514 does not address this concern nor did the Region III i
backfit procedure. Some discussion has taken place between OIG and AE00, and a draft proposal to satisfy this recommendation was prepared; however, no proceoure is now in place to handle this.
The ED0's response to this item stated that close out procedures may be developed which are short of verification by NRC onsite inspections.
The draft proposal did not require that every item be inspected for final closure.
AE00 has previously made a recommendation, which has been discussed with and informally agreed to by the OIG staff, to accept a written commitment from the licensee that the action will be performed.
The action would then be listed as closed in the PSBS.
Subseauently, rather than continuing to track the item with the PSBS until the action has been completed, the item would be tracked by another appropriate NRC tracking system, such as SIMS, until complete.
In this way the PSBS is kept more concise and the item is carried along with all other open licensee commitments in one unified tracking system (e.g., SIMS).
i This approach, or another which is acceptable to both the OIG and the staff, should be agreed to and implemented to satisfy the OIG recommendation.
i AE00 RESPONSE We will request each office add a provision, similar to the following, to its plant-specific backfit procedure.
"With regard to closure:
For backfits being imposed on a licensee, the closure information should include a reference to a written licensee commitment to implement the backfit (or an order to implement the backfit).
1 It should also include one of the following:
(1)
Reference to a specific item in another tracking system which will track licensee implementation and/or any NRC verification of implementation determined to be appropriate, or (2)
Reference to a written licensee statement that the backfit has been implemented and/or any NRC verification of implementation determined to be appropriate."
The current status of the office procedures is as follows:
Region I Procedure recently revised. Does not require a change meet this provision.
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Region 11 Draft grocedure revision-recently submitted for AEOD review.
Will i
be requ=sted to add this provision _in the final procedure.
Region III Draft procedure revision recently submitted for AEOD review. Will be requested to add this provision in the final procedure.
Region IV Draft procedure revision recently reviewed by AEOD.
Will include this provision in the final procedure.
Region V Draft procedure revision being prepared. Will include this provision.
NRR Draft procedure revision being prepared. Will include this provision.
It is expected that all of these revisions can be accomplished and issued in finai form by December 30, 1991.
l RECOMMENDATION 8:
The EDO should establish controls to eliminate unnecessary access into the PSBS (Plant Specific Backfit System).
OEDO DISCUSSION (8/29/91)
Manual Chapter 0514 states:
" Access to make changes to the system will be limited to those designated within each Office and Region."
The IRM contact responsible for this system stated that there was no special control, such as a " read-only" provision, and that anyone who could access the i
NIH computer and the PSBS program could make changes. The IRM contact stated l
that it would be relatively easy to put in such a control feature.
This recommendation is not yet implemented.
l AEOD RESPONSE IRM has been requested to establish password protection with regard to making changes.
It is expected that this will be implemented by November 30. 1991.
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