ML20035G597
| ML20035G597 | |
| Person / Time | |
|---|---|
| Issue date: | 12/31/1991 |
| 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 9304280137 | |
| Download: ML20035G597 (7) | |
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jj k.6 December 31, 1991 HEMORANDUM FOR:
James L. Blaha Assista:.t 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 As promised in my memorandum of September 20, 1991 on the same subject, a status report on our actions to complete the implementation of the OIA recommendations is enclosed.
We will provide another followup report on these actions by March 30, 1992.
C e
s r w Edward L. Jordan, irecto /
Office for Analysis and aluation of Operational Data
Enclosure:
As stated cc/w enclosure:
J. Taylor, EDO T. Murley, NRR Regional Administrators cdI 9304280137 930204 PDR FOIA PDR LEN92-402 l
Decemoer 31, 1991 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 As promised in my memorancum of September 20, 1991 on the same subject, a status report on our actions to complete the implementation of the OIA recommendations is enclosed.
We will provide another followup report on these actions by March 30, 1992.
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Edward L. Jo, dan, Director Office for Analysis and Evaluation of Operatior.al Data
Enclosure:
As stated cc/w enclosure:
J. Taylor, E00 T. Murley, NRR Regional Administrators Distribution:
AEOD R/F ELJordan DFRoss JSniezek RDovovan, OIG DChamberlain, EDO PCota, NRR DHolody, RI LWatson, RII CPederson, RIII LJCallan, RIV AJohnson, RV AE00 91-106 DPAllison JConran 2 2 2 n / ]I
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Enclosure Status Report on 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)
On April 27, 1988, the EDO commented on a draft DIA report on plant specific backfititng 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 AE00 is exercising oversight responsibility, there are no formal (or informal) AEOD procedures for this task.
The need for a procedure was discussed with the AEOD contact who stated that it would be relatively straightforward to prepare such a procedure.
This recommendation is therefore not yet implemented.
AEOD RESPONSE (9/20/91)
AE00 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.
STATUS Complete.
The procedure was issued on October 9, 1991.
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RECOMMENDATION 6:
The EDO should assure that the current status of active and closed issues is both timely and accurately recorded in the PSBS.
l OEDODISCUSSION(8/29/911 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.
Review of the PSBS found that the data base was generally up to date.
- 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 shif t overtime at Farley Unit 1.
This recommendation was implemented and the PSBS accuracy has improved.
However, there remains room for additional improvement.
AEOD RESPONSE (9/20/91) i The procedure discussed in response to Recommendation 1 will specify frequent 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 j
tracking system entries.
It is expected that the improvement will be evident by December 30, 1991.
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STATUS AE00 conducted a review and provided comments on selected items to office / regional backfit coordinators in December 1991.
It is expected that the entries for these items will be improved as a result of addressing the i
comments.
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Ii RECOMMENDATION 7:
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The EDO should establish and implement criteria to assure that plant-specific l
backfits imposed on licensees are closed only after NRC accepts licensee commitments and verifies that actions have been taken.
F OEDO DISCUSSION (8/29/91)
Manual Chapter 0514 does not acdress this concern nor did the Region III backfit procedure.
Some discussion has taken place between OIG and AE00, and a draft proposal to satisfy this recommendation was prepared; however, no procedure 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.
}c AE00 has previously made a recommendation, which has been ciscussed with and informally agreed to by the OIG staff, to accept a written commitment from the
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licensee that the action will be performed.
The action would then be listed t!
as closed in the PSBS.
Subsecuently, 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).
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.
AE00 RESPONSE (9/20/91)
We will request each office _ add a provision, similar to the following, to its plant-specific backfit procedure.
"With regard to closure:
1 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).
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 i
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."
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The current status of the office procedures is as follows:
Region I Procedure recently revised.
Does not require a change meet this provision.
Region II Draft procedure revision recently submitted for AEOD review.
Will be requested to add this provision in the final procedure.
Region III Draft procedure revision recently submitted for AE00 review.
Will be requested to add this provision in the final procedure.
Region IV Draft procedure revision recently reviewed by AE00. Will include this procedure in the final procedure.
Region V Draft procedure revision being prept red.
Will include this provision.
NRR Draft procedure revisio, ceing prepared.
Will include this provision.
It is expected that all of these revisions can be accomplished and issued in final form by December 30, 1991.
STATUS The regional office procedure revisions have been issued.
The NRR procedure was submitted for AEOD review and concurrence on Decemoer 5,1991.
This review will be completed in the near future, after which it is expected that the NRR procedure will be issued.
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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 NIH computer and the PSBS program could make changes.
The IRM contact stated that it would be relatively easy to put in such a control feature.
This recommendation is not yet implemented.
L AE00 RESPONSE (9/20/91)
IRM has been requested to establish password protection with regard to making l
changes.
It is expected that this will be implemented by November 30, 1991.
STATUS
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AEOD provided the names of people needing passwords to IRM in December 1991.
IRM will complete the establishment of password protection in the near future.
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