ML20056F931
| ML20056F931 | |
| Person / Time | |
|---|---|
| Issue date: | 08/24/1993 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| SECY-93-236, NUDOCS 9309010040 | |
| Download: ML20056F931 (14) | |
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August 24, 1993 POLICY ISSUE sEcY-93-236 (Information) l FOR:
The Commissioners EROJ:
James M. Taylor R
Executive Director for Operations
SUBJECT:
THE STAFF'S EVALUATION OF ONGOING LICENSEE FEEDBACK ON THE IMPACT OF NRC ACTIVITIES ON LICENSEE OPERATIONS PURPOSE:
To inform the Commissioners of the staff's esaluation of licensee feedback on the impact of NRC regulatory programs on licensee operations and to describe the staff's progress in implementing the activities described in SECY-91-172,
" Regulatory Impact Survey Report - Final," that were outstanding at the time l
of the last update.
SUMMARY
This paper provides a periodic update on results of activities initiated by the staff in October 1992 to solicit ongoing feedback from licensees on the impact of NRC activities on licensees' programs and operations. Overall, the feedback provided by representatives of 35 reactor sites indicates that previous improvement actions taken by the staff have improved the effectiveness of NRC programs and reduced unnecessary regulatory burden.
However, feedback also suggests that continued improvements are needed in the areas of scheduling and control of inspections, operator licensing, consistency and quality of the inspection program, licensing actions, and the systematic assessment of licensee performance (SALP) program.
The staff has implemented improvements to address these concerns and will continue to obtain feedback from the industry on the impact of NRC regulatory programs and activities.
NOTE:
TO BE MADE PUBLICLY AVAILABLE CONTACT:
IN 10 WORKING DAYS FROM THE Michael R. Johnson, NRR DATE OF THIS PAPER 504-1241 9 N f
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BACKGROUND:
On June 7, 1991, the staff forwarded SECY-91-172 to the Commission to describe l
final actions taken to address the concerns identified during the Regulatory Impact Survey. These actions provided improvements in four regulatory areas:
(1) consideration of the cumulative effect of the NRC's generic requirements and generic communications, (2) scheduling and control of inspections, (3) staff training and professionalism, and (4) control and involvement by senior NRC managers.
On December 20, 1991, the Commission issued a staff requirements memorandum (SRM) that requested annual updates on the staff's progress in implementing the activities described in SECY-91-172. The Commission also requested that the staff develop a process for continuing to obtain feedback from licensees and submit the results to the Commission annually. On August 18, 1992, the staff forwarded SECY-92-286, ' Staff's Progress On Implementing Activities Described In SECY-91-172, ' Regulatory Impact Survey Report - Final'," to the Commission in response to the SRM.
In October 1992 the staff began implementing the feedback process. The results of this effort for feedback i
obtained through June 1, 1993, are summarized below.
l DISCUSSION:
The feedback process developed and implemented by the staff gives licensees i
frequent opportunities to submit their input on regulatory impact. Assistant directors for projects in the Office of Nuclear Reactor Regulation (NRR) and regio al division directors solicit feedback from their licensee counterparts during routine visits to reactor sites.
In addition, during site visits conducted as part of NRC's periodic assessment of the effectiveness and implementation of the inspection program, assessment teams solicit input from l
licensee senior managers. The staff evaluates this feedback, the results of small scope surveys and any other feedback submitted to identify significant licensee concerns and to develop and implement necessary improvements.
From October 1992 to June 1993, the staff received 54 inputs from representatives of 35 reactor sites, ranging from single comments on site-specific concerns to detailed information on a broad spectrum of issues regarding regulatory programs and activities. The staff also received l
feedback in response to small scope surveys conducted as part of reviews of the SALP program, the operating reactor inspection program, and the operator licensing program.
Feedback provided, along with the staff's evaluation and improvement actions follow.
1.
Schedulina and Control of insoect4ons FEEDBACK Many licensees stated that the staff's efforts to improve the coordination of major NRC inspection activities with licensee activities have reduced their regulatory burden. Many licensees noted significant :mprovements in the scheduling of inspections and welcomed the change in the NRC's policy for i
announcing inspections.
However, while the scheduling of major NRC site
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visits has significantly improved, several licensees cited isolated cases in which inadequate coordination of team inspections and other major NRC site visits with licensees significantly impacted licensee resources.
Several licensees also stated that they often receive little advance notice of routine inspections.
The Nuclear Utility Backfitting and Reform Group (NUBARG) provided feedback to the staff on the effectiveness of the staff's policy to limit the number of inspections conducted at each site during a SALP cycle. During the 1993 Regulatory Information Conference on May 4 and 5,1993, participants suggested that the staff appeart o be circumventing the policy of having only four major NRC activities e site during a SALP cycle.
The policy defines a major NRC activity as consisting of four or more staff on site for a period of five or more days. NUBARG expressed concern that in some cases the staff intentionally conducts group inspections consisting of less than the four inspectors or consisting of four or more inspectors but lasting less than the five days. NUBARG suggested that the staff revise the policy to define NRC
" Major Activities" in person-days of effort.
EVALUATION AND ACTIONS Improvements in the scheduling and control of inspections resulted directly from actions taken by the staff to resolve concerns identified during the Regulatory Impact Survey. The NRR inspection program assessment conducted in fiscal year 1993 identified the need for improved implementation of the policy i
for announcing inspections. Regional Administrators were advised of this finding during assessment exit meetings. NRC management will continue to focus attention on ensuring the consistent implementation of the policy to announce inspection. NRR will evaluate this area in future inspection program assessments to verify policy guidelines are achieved. The staff plans on studying the major activity limitation of four or more persons for five or more days on site.
2.
Operator Licensino FEEDBACK Licensees noted improvements in the operator licensing program and described revision 7 to the Operator Licensing Examiners
- Standard (NUREG 1021) as clear and concise. However, several licensees suggested that the staff be more flexible in scheduling and conducting licensing examinations based on consideration of the operating staff size of a reactor site.
This feedback reflected the licensees' concern with the frequency of requalification 1
examinations that operators must take at sites with small operating crews because of the requirement to examine two operating and one staif crew during
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requalification examinations. Some licensees also stated that a few NRC examiners have adopted the licensee's performance standards for operators
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during NRC administered examinations.
Licensees suggested this might create ever increasing operator performance expectations by the NRC.
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EVALUATION AND ACTIONS The staff has continually obtained feedback on the effectiveness and implementation of the operator licensing program from the nuclear industry through a variety of methods. These include working and managerial meetings with licensees and industry organizations, including the Nuclear Management and Resources Council and the Professional Reactor Operator Society, and the solicitation of comments about proposed changes to the NRC's initial and requalification examination programs for licensed operators.
Revision 7 of the Operator Licensing Examiner Standards (NUREG-1021) addresses specific industry concerns with the conduct of individual operator evaluations during NRC requalification examinations and implements feedback forms to assess undue operator stress during those examinations. The NRC also recently published a proposed rule change for public comment to significantly change the requalification examination requirements by focusing NRC resources on inspecting licensee requalification programs, with the provision.to perform requalification examinations for cause only.
By focusing NRC efforts on the inspection of licensee requalification programs, these program changes should i
address the concerns with increasing performance expectations for licensed operators and the burden on reactor sites with small operating staffs.
The staff contracted for a study from June through September 1993, to obtain feedback from licensed operators, licensee managers, industry groups, and members of the NRC staff participating in operator licensing. The results of this study will be used to evaluate the methods to improve licensed operator examination consistency.
3.
Inspection Proaram Ouality and Consistency FEfDBACK Many licensees indicated that inspector professionalism and the quality of inspections have improved. Most licensees stated that the communications with resident and regional inspectors were good and that inspections focus on substantive issues rather than on issues with little safety significance.
However, many licensees noted that the amount of inspection effort and the treatment of findings were inconsistent from site to site.
Some licensees expressed concern that although most inspections were performance-based, some inspectors continue to be program and compliance oriented.
Licensees described isolated instances in which the inspector (s) assigned to perform inspection: lacked the requisite expertise.
Licensees also stated that the i
NRC did not acquire the needed expertise to conduct the motor-operated valve and commercial grade dedication program inspections.
Licensees stated that a lack of inspector expertise increased the burden on licensee operations.
While communications between inspectors and licensees generally improved, examples of poor communication continued to occur.
For example, a licensee stated that inspectors retained inspection findings until the end of their inspection or added new information in their report cover letters without i
including supporting information in the body of their inspection reports.
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EVALUATION AND ACTIONS The NRR inspection program assessment conducted in fiscal year 1993 also found l
inconsistencies in implementing the inspection program. The staff is preparing changes to the inspection program to improve the consistency of inspection effort.
Although the staff found that the quality of communications with the licensees is generally not a problem, NRC managers will continually monitor inspector performance during oversight visits and senior NRC managers will continue to emphasize the importance of effective communication during inspector refresher training and at inspector counterpart meetings. Senior regional managers will continue investigating and resolving specific licensee concerns in a timely and effective manner. These efforts should help reduce inspector performance inconsistencies and improve communication between the NRC and the nuclear industry.
Based on the results of initial motor-operated valve (MOV) inspections, the staff recognized the need for increased inspector expertise in the area of M0V diagnostic evaluation. Selected inspectors have received in-depth MOV diagnostic training as well as training on the requirements of Generic Letter 89-10, " Safety-Related Motor-0perated Valve Testing and Maintenance," and inspection procedure guidance.
These inspectors participate in the MOV inspections currently being performed.
In addition, NRR has provided contract personnel with extensive MOV diagnostic training to supplement inspection team expertise.
i The staff conducted five pilot commercial grade dedication inspections.
An inspection procedure is being developed to establish requirements for inspection of licensee commercial grade dedication programs. This procedure will incorporate the lessons learned from pilot inspections and subsequent staff interactions with the industry. NRR will train the regional staff on implementation of the inspection procedure and will provide any necessary support.
4.
Licensina Issues FEEDBACK Most licensees expressed concerns with the processes for requesting license amendments and changes to technical specifications. These processes are viewed as slow and tedious, requiring significant licensee resources.
Several licensees stated this resulted partly from the way that the NRC sets priorities for reviewing and approving change requests.
Licensees stated that the NRC assigns priority to change requests based on their age and not on the importance of the change to the licensee. They suggested that the needs of the licensee submitting the change should significantly contribute to NRC's prioritization of change requests.
Licensees suggested that delays in NRC rulemaking could lead to regulatory uncertainty.
Examples cited were the approval of drycask storage requirements and the issuance of license renewal guidelines. One licensee suggested that
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l the imposition of design changes on older plants could force plants off line due to rising costs and that design changes at older plants should be required to pass tighter controls to justify the changes, i
EVALUATION AND ACTIONS The NRC has reduced the backlog of requests for license amendments and technical specification changes. The average monthly inventory of licensing actions for all of fiscal year (FY) 92 was 1282, while the monthly average in FY 93, through May 1993, was 1158.
On June 6, 1993, the Director, NRR, issued to the staff the revised process for assigning priority to NRR licensing actions according to safety significance, risk considerations, and the effect on licensee operations. NRR established four levels of priority to clearly define the level of staff response to review license actions and other effo.'ts.
In addition, a recent review of plant-specific licensing tasks indicates that there are a significant number of current reviews for which there are no immediate safety benefits or detriments associated with their approval; however, there may be significant economic benefits.
In the past, these reviews have been assigned a low priority on a resource-available basis. As a result, possible economic benefits may not be made available to some licensees on a timely basis.
In April 1993, NRR formed a task force to evaluate this policy and provide a systematic, logical approach for scheduling these reviews and assigning staff resources. The task force will complete its evaluation by September 30, 1993 and prepare conclusions and any recommended improvements.
5.
Systematic Assessment of Licensee Performance FEEDBACK Many licensees expressed concern with the SALP program.
Licensees felt that the minimal amount of inspection effort by regional inspectors hinders the NRC's ability to make an unbiased assessment of licensee performance.
Licensees also considered inconsistent SALP implementation within regions a Several licensees expressed the concern that proposed changes to the concern.
SALP program would exclude those people most familiar with plant performance from voting on SALP scores.
EVALUATION AND ACTIONS Upon considering similar comments from a SALP workshop on September 29, 1992, the staff recommended changes to the SALP program proposed to the Commission in SECY-92-290, " Systematic Assessment of Licensee Performance." On April 6, 1993, the staff recommended these changes to the Commission in SECY-93-90
" Systematic Assessment of Licensee (SALP) Performance." On May 19, 1993, the Commission approved for use the staff's proposed SALP program described in SECY-93-90. The NRC will continue to assess the new SALP program.
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Small Scope Surveys In addition to routine feedback, the staff conducted several small scope surveys to solicit industry feedback on specific regulatory programs. During the comprehensive review of the SALP program, the staff conducted a workshop on September 29, 1992, to obtain feedback from the industry on SECY-92-290,
" Systematic Assessment of Licensee Performance." On April 6, the staff recommended changes to the SALP program to the Commission in SECY-93-90
" Systematic Assessment of Licensee Performance (SALP)." On May 19, 1993, the Commission approved the proposed SALP program described in SECY-93-90.
In another small scope survey, the Office of Policy Planning (OPP) obtained feedback from the nuclear industry while evaluating the effect of the inspection program on the safety performance of nuclear facilities. On November 16, 1992, the staff provided the Commission the results of this effort in OPP-92-01.
The enclosure provides an update on the status of actions taken to address the concerns that were found during the Regulatory Impact Survey and were in progress when the last update was issued in SECY-92-286 in August 1992.
In the near future, papers on two related topics will be forwarded to the Commission.
These are the FY 93 Assessment of the Effectiveness and Implementation of the Operating Reactor Inspection Program and the Regulatory Review Group final report that includes a review of the assessment. The inspection program assessment considered the information in this paper and will identify specific problems and the staffs' corrective actions. Overall, the staff has had some success in reducing the unnecessary burden of regulatory activities and programs on licensee operations.
The staff will continue to implement changes which address licensee concerns to achieve further improvement in the NRC's regulatory programs.
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Enclosure:
Status of Activities Described in the Regulatory Impact Survey Report DISTRIBUTION:
Cormnissioners OGC OCAA OIG OPA OCA OPP EEGIONAL OFFICES EDO SECY
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a ENCLOSURE STATUS OF ACTIVITIES DESCRIBED IN THE REGULATORY IMPACT SURVEY REPORT This update provides the status of those activities undertaken by the NRC in response to concerns identified during the Regulatory Impact Survey that were not completed as of the last update issued as enclosure one to SECY-92-286.
A.
Managing the cumulative Effect of NRC's Generic Requirements and Generic Communications Issue - The industry expressed concerns regarding the number of NRC requirements.
Specifically, the major area for improvement was management of the cumulative impact of NRC's generic requirements and generic communications. Underlying the major issue was, (1) deficiencies in communication between the NRC and the regulated industry, (2) unauthorized imposition of informal requirements, and (3) insufficient participation on the part of industry in such staff initiatives as integrated schedules or the integrated safety assessment program.
Action / Description Status / lessons learned 1.
Revise and publish the Regulatory Analysis 1.
Completed. The Staff provided the Commission Guidelines for public comment.
The guidelines with the revisions to the Regulatory Analysis provide direction to ensure that (i) NRC generic Guidelines on February 22, 1993 in SECY-93-043.
regulatory decisions are based on adequate SECY-93-043 sought the Commission's approval to information concerning the need for and publish a Federal Reaister notice announcing the consequences of a proposed regulatory action and availability of proposed Regulatory Analysis (ii) cost-effective regulatory actions are Guidelines for public comment.
identified that are consistent with providing the necessary protection of the public health and Staff guidance on implementation of the safety safety and common defense and security. Once the goals in regulatory analysis is based on the use of public comments are resolved, the revised a change in core damage probability rather than an guidelines will go to the Commission for approval.
absolute number and involves certain criteria for staff action.
This is consistent with the approach described in SECY-91-270.
Guidance on the factors to use in the estimation of the value of person-rem averted is to continue using the $1000/ person-rem-factor (1993 dollars) while continuing the review and analysis of this issue.
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Action / Description Status / Lessons Learned 2.
Incorporate an additional statement into 2.
Partially Completed.
The staff had revised IMC generic communications that requests licensees 720, "NRC. Bulletins and Information Notices," to provide voluntary feedback on the short-term and incorporate a statement in bulletins that solicits long-term impact of responding to and implementing licensee feedback on the time and cost of the requested actions delineated in specific responding to and implementing recommendations made generic communications.
This information will on a voluntary basis. Currently the staff is permit an effective comparison of NRC staff revising IMC 720 to. include instructions on the estimates for future generic communications.
process for~ developing generic letters that will include a similar statement for inclusion into generic letters.
The revision to IMC 720 should be issued near the end of FY 93. As an interim measure the NRR Generic Communications Branch is including this statement in all Generic Letters during their review.
3.
Incorporate a flexible ranking system for 3.
In progress.
Completion date to be determined.
generic communications into the generic
. A flexible ranking system for generic communications process.
This system will entail communications requiring a backfit cost-benefit prioritizing, on the basis of safety significance, analysis is still under development. Generic past, present, and proposed generic communications.
communications issued since the commitment was made It will provide both licensees and the NRC staff to develop the ranking system have been compliance with a clearer understanding of which issues the oriented and have not included any generic staff believes to be the most safety significant.
requirements based on a backfit cost-benefit The system will be updated periodically, analysis.
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3 Action / Description Status / lessons learned 4.
Incorporate consideration of the cumulative 4.
Completed.
In response to the staff impact of NRC generic communications on a typical requirements memorandum on SECY-91-172, the staff Babcock and Wilcox, Combustion Engineering, developed an implementing procedure for the Westinghouse, and General Electric plant into the issuance of generic communications that allows for generic communications process before a new generic the evaluation of the scope and schedular concerns communication is issued.
This will permit the for proposed generic communications. -The evaluation of the impact of a proposed NRC generic Commission approved the staff's proposed procedure communication against the existing regulatory as provided to the Commission in SECY-92-224.
burden placed on these representative facilities.
Information obtained from industry concerning the In this approach, the staff develops the generic plant-specific, short-term and long-term impact of communication aud its regulatory analysis, and generic communications will be incorporated into publishes this information via the Federal Reaister this activity.
This approach, when combined with so the public and industry may comment directly on the flexible priority ranking system, will aid the the proposed scope and schedule. After analysis of staff in establishing appropriate scope and the comments received, the staff can adjust the schedule for implementing the action requested in scope and schedule of the document for appropriate the proposed generic communication.
generic concerns if apprupriate.
For Bulletins the guidance using the approach contained in SECY-92-224 was incorporated in IMC 720, "NRC Bulletins and Information Notices." A revision to IMC 720 to incorporate instructions for the development of Generic letters is under development.
This revision to IMC 720 will include provisions for public comment on Generic letters.
The revision to IMC 720 incorporating instructions on Generic letters is scheduled to be issued near the end of FY 93.
In the interim, Generic Letters have been published in the Federal Reaister l
following the guidance of SECY-92-224.
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4 Action / Description Status / Lessons learned 5.
Revise and publish in final form the Integrated 5.
Completed.
The Final Policy Statement on Schedules for Implementation of Plant Hodifications Integrated Schedules was published in the Federal program to incorporate the more favorable aspects Reaister on September 23, 1992. This policy of the program and desirable additions from the statement describes the policy to promote voluntary IRRIS concept. The Integrated Schedule for Flant implementation of licensee integrated schedules for Modifications Policy provides licensees, on a regulatory requirements and other activities of-voluntary basis, with a simple scheduling mechanism nuclear power plants. The policy focuses on the to encourage early -implementation of plant way licensees may establish realistic integrated modifications.
This shculd result in the most schedules and how the NRC intends to interact with safety for resources expended, should set balanced these licensees.
Based on the operational priorities, and avoid duplication of effort.
experience obtained from seven (7) licensees that have implemented integrated schedules, the process has generally benefitted both the NRC and the licensees involved.
Since the policy was published, one additional licensee has expressed interest in using an Integrated Schedule. This licensee is coordinating the development of their program with the staff.
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5 B.
Scheduling and Control of Inspections, Especially Team Inspections Issue - Concerns were raised on the number of NRC onsite activities.
Specific concerns focused on the scheduling and control of NRC onsite activities, especially team inspections.
Action / Description Status / Lesson Learned 6.
Reevaluate the limits established in IMC 0301 6.
Completed. Guidelines established in IMC 0301 as part of regular inspection program reviews and appear appropriate. Much of the feedback from the modify them as necessary to ensure they are industry shows that coordination of major NRC site appropriate. This action addresses concerns visits with licensees has improved the ability of expressed by the industry that the number of major the licensees to manage their resource commitment NRC visits to sites permitted without management in support of NRC activities more effectively.
review and approval should be further reduced.
Generally, coordination with licensee has improved the ability of the NRC to effectively and efficiently conduct major site visits.
7.
Revise IMC 0300,
" Announced and Unannounced 7.
Completed.
The staff revised IMC 0300 to inspections," to establish the general policy that establish the policy to announce inspections.
The all inspections be announced except if advance manual chapter provides exceptions to this policy.
notification cauld reasonably compromise the This policy change has enabled improved ability of the staff to obtain an accurate coordination with licensees and greater efficiency assessment of licensee programs, practices, or without adversely impacting inspection activities.
effectiveness.
The presence of NRC resident inspectors to observe and verify ongoing licensee activities, including those conducted during weekend, late evening, and early morning hours continues to make it unlikely that advance notification of planned inspections prevents the NRC from achieving its objectives.
Feedback from licensees suggests that when inspections are announced the impact of major site visits is reduced by providing them the opportunity to prepare documentation and personnel to support the NRC's activities.
Continued improvements in this area can be achieved by consistently implementing the policy to announce inspections.
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6 C.
Training and Professionalism Issue - The industry raised concerns related to the training and preparation of the NRC professional staff.
Specific concerns raised were the need for increased training for the staff and for a clear understanding of expectations for staff professionalism.
Action /Descri.ption Status / Lessons learned 8.
Schedule additional team leader workshops.
8.
Completed / ongoing.
The Office of Personnel These workshops provide valuable team leader continues to conduct courses targeted at team insight into the issues and problems of managing a leaders. A curriculum has been established that team on site.
includes a Team Leader Workshop and communication techniques for inspectors. A pilot course in-problem analysis has been given in Region I.
Team Leader training has been provided at all of the regional offices.
Inspection Manual Chapter (IMC) 1245 was changed in September 1991 to include specific training and qualification requirements for Team Leaders.
An issues oriented Team Leader counterpart meeting was held in April 1993 to discuss current issues (service water was the primary focus of this counterpart meeting). Annual Team Leader counterpart meetings are planned.
9.
Conduct periodic industry workshops on 9.
Completed / ongoing. AEOD procedure 11 provides backfitting.
provisions for periodic industry workshops on backfitting. Workshops on backfitting requirements are planned for late 1993 or early 1994.
- 10. Modify the existing " Fundamentals of 10 Completed.
The revisions to the fundamentals Inspection" course which is given to new inspectors of inspection manual chapter were issued to and NRR employees to provide additional guidance in Headquarters and Regional Management for review and those areas dealing with methods and processes for approval on May 5, 1993.
The schedule for the planning and documenting inspection results, initial use of the revised manual chapter and guidelines for inspector's conduct, and insights on lesson plan is for June 28 through July 2,1993 in professionalism.
Region 1.
Monitoring of this training session by selected working group members will assess the need for improvements to the manual chapter and lesson plan.
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7 D.
Management Control and Involvement by NRC Senior Managers issue - Concerns expressed in this area were related to the staff's lack of a clear understanding of management's standards and expectations and a lack of management oversight and involvement in regulatory-activities and actions.
Action / Description Status / Lessons learned 11.
Review performance elements and standards and 11.
Completed. An August 26, 1992, memorandum revise them as appropriate to reflect management addressed to each of the Regional Administrators expectations.
from James H.-Sniezek, Deputy Executive Director for Nuclear Reactor Regulation, Regional Operations and Research, provided guidance on uniform performance elements and standards for Inspector / Examiner, Senior Allegations Coordinator, Senior Enforcement Specialist, State liaison Officer, State Agreement Officer, and GG-15 Team Leader positions.
Each region was responsible for incorporating the new guidance on performance elements and standards for the performance period starting in October 1992 (FY 93).
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