ML20059C146
| ML20059C146 | |
| Person / Time | |
|---|---|
| Issue date: | 09/22/1993 |
| From: | Jordan E NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD) |
| To: | Sholly S MHB TECHNICAL ASSOCIATES |
| References | |
| IEB-93-002, IEB-93-003, IEB-93-2, IEB-93-3, IEIN-93-035, IEIN-93-35, NUDOCS 9311010030 | |
| Download: ML20059C146 (3) | |
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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i September 22, 1993 Mr. Steven C. Sholly Senior Consultant MHB Technical Associates 1723 Haniiiton Avenue, Suite K San Jose, California 95125
Dear Mr. Sholly:
I am responding to your letter of May 20, 1993 to Dr. Moeller regarding Information Notice (IN) 93-35, Jnsights from Common-Cause failure Events.
In your letter, you expressed a concern about a three-month delay in issuing the IN af ter the relevant AE0D report on the subject was published.
This concern was forwarded to me by the Executive Director for Operations as indicated by Mr. Larkins (ACRS) in his letter to you on July 16, 1993. As you know, AEOD was created in 1980 in tne aftermath of the Threo Mile Island accident to provide an independent assessment of reactor operating experience.
Since that time, we have published several hundred reports on various aspects of plant operations. AE00 reports are categorized as Case Studies, Engineering Evaluations or Technical Reviews depending upon the significance of the finding.
The process is described in detail in the enclosed Annual Report for 1992.
The report you referred to was an Engineering Evaluation that contained suggestions for action and a draft Information Notice.
The Division of Operating Reactor Support in the Office of Nuclear Reactor Regulation that manages the NRC program of generic correspondence to reactor licensees received the AEOD report for action.
NRR responded to the AE00 suggested IN within a month and the text was agreed to by AE00 staff with minor modi fications, it normally takes from one to three months between the initial suggestion and the final publication of the notice. The total elapsed time of three mcnths is within the normal framework for these activities.
For urgent operational issues where subsequent issuance of a bulletin or generic letter requesting specific action is likely, the IN is issued within a few days.
Provisions also exist and are utilized for urgent issuance of new requirements or requests for action. Examples of urgent generic correspondence issued thus far in 1993 include NRC Bulletin No. 93-02, Debris Plugging of Emergency Core Cooling Suction Strainers, May ll,1993, and NRC Bulletin No. 93-03, Resolution of Issues Related to Reactor Water Level Instrumentation in BWR's, May 28, 1993.
The CRGR did not review the subject information notice since ins do not contain new or modified requirements or action requests.
The CRGR does review Bulletins, Generic Letters and new or revised regulations to assure the backfit provisions of 10 CFR 50.109 are being met and that any new g //? l p
requirements or positions are warranted. That review adds approximately two i
weeks to the review process for a proposed action unless major changes and a re-review are warranted. Such documents also receive ACRS, public comments and Commission review.
Urgent Bulletins and Generic Letters receive expedited.[kI pd/[:
CRGR review pr a rpost hspapc[p review for emergency actions.
Issues reviewed.
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O by the CRGR during 1992 are also summarized in the enclosed AE0D annual report.
As Director of AE00, I am keenly aware of the NRC responsibility to identify lessons of experience and assure they are learned.
Inherent in that process is the need to prioritize feedback to assure the proper level of response occurs commensurate with the safety significance of the lesson.
For example for the most safety significant issues, NRC expedites issuance of the generic correspondence, requires a written response regarding the requested actions, develops inspection guidance and conducts followup inspections to verify adequacy of those actions.
For issues that are unfolding, supplemental actions may be needed as further NRC and industry experience is obtained.
The boiling water reactor level indication problem is an example of intensive followup due to a significant safety issue.
On the other hand, Information Notices are provided for appropriate use by licensees and are not individually followed up by NRC inspectors.
I believe this range of feedback and followup mechanisms effectively uses NRC and industry resources.
The staffs of NRR and AEOD are continuing to seek ways of improving the feedback process to make it more timely and to improve effectiveness.
I appreciate your comments and would be glad to discuss the NRC processe.s for identification and feedback of generic lessons, the activities of the CRGR and AEOD's programs further if you desire.
Please feel free to contact me at 301-492-4848.
Sincerely, Original signed by:
E L Jordan Edward L. Jordan, Director Office for Analysis and Evaluation of Operational Data cc:
J. M. Taylor, NRC M. Taylor, NRC T. E. Murley, NRC B. K. Grimes, NRR H. N. Pastis, NRC Distribution:
See page 3 H:\\ED09232.VB
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I:A D VBenaroya GHolahan BGrimes JScinto DFRoss ELJordan 8/30/93 8/30/93 8/30/93 9/22/93 8/31/93 9/gn3 via fax
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JSniezek, EDO HThompson, EDO JBlaba, EDO JKnubel, EDO JScinto, OGC DWilliams, IG JLarkins, ACRS ELJordan, AE00 DFRoss, AE00 VBenaroya, AE0D JRosenthal, AE00-SIsrael, AE00 WJones, AE00 GMarcus, NRR JRaines/Rohrer, AECD 93-63 I
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