ML20126D902
| ML20126D902 | |
| Person / Time | |
|---|---|
| Issue date: | 07/23/1981 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Jamarl Cummings NRC OFFICE OF INSPECTOR & AUDITOR (OIA) |
| Shared Package | |
| ML20126D877 | List: |
| References | |
| FOIA-85-55 NUDOCS 8506150239 | |
| Download: ML20126D902 (5) | |
Text
, o UNITED STATES App:ndix I
/ ,,o NUCLEAR REGULATORY COMMISSION P' 3 .E WASHINGTON. D. C. 20555
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\, * * * * * / jut. 2 31981 MEMORANDUM FOR: James J. Cummings, Director Office of Inspection and Auditor FROM: William J. Dircks Executive Director for Operations
SUBJECT:
DIA REPORT ON NRR'S OPERATING REACTORS LICENSING ACTION PROGRAM t
We have reviewed the subject report and are in general agreement that it fairly represents 4he operating reactors licensing situation as it existed in the period from May through December 1980.
e NRR has been aware of the problem areas identified by OIA and signifi-cant progress has been made in correcting these problems. In fact, corrective actions were being initiated before the OIA study was completed.
For example, substantial improvements have been made in the planning, assignment of work, and tracking of progress for those tasks assigned to the Franklin Research Center (FRC) contract. The second FRC contract is also being managed utilizing the Licensing Action Tracking System (LATS) which has proved to be so useful in bringing about the improvements with the first FRC contract. In addition, the third contract of this type, which is now before the Commission for approval, will also be managed utilizing a LATS-type system. The LATS system is also being used to successfully track the progress of other contracts with DOE laboratories which have been assigned multi-plant licensing actions.
Other areas addressed in the report have also received considerable attention and improvement, and further improvements are underway.
For example, in May 1981, NRR established a Technical Assistance Task Force whose charter is to review and assess the effectiveness of its technical assistance program and to recommend ways in which improvements can be made.
' Each of the, recommendations of the report is addressed in the enclosure.
A~
Willi J. Dircks Executive Director for Operations
Enclosures:
As stated 8506150239 850318 PDR FOIA -
ORABERBS-55 PDR
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'O Recomme1dations
- 1. DOL take a more active role in monitoring the backlog and managing its reduction. This should include the designation of a specific functional unit to have prime responsibility for reducing the backlog, including reviewing all tasks to detemine what action is necessary, teminating obsolete tasks, finishing "near-completed" tasks, developing acceptance criteria, and reassigning and developing revised schedules for the remaining tasks pending review,
Response
4 NRR supports this recommendation and has identified the Assistant Director for Operating Reactors, DOL, as the functional unit responsible for respontiing to items contained in the recommendation. Under the direction g
of this unit, major modifications are being made to the operating reactor i licensing action summary report, NUREG-0748, to pemit management review of the majority of items identified as shortcomings in the current process e of completed backlogged licensing actions.
i a) provides more definitive and realistic priority guidance in tems of the demands being placed on the staff; b) assigns priorities to the work currently in progress and ranks items with the same priority and schedule according to relative importance; and c) provides a mechanism for prioritizing and integrating new work into the existing workload, including detemining the cost and impact of ongoing work which is displaced when priority conflicts arise, and for periodically reviewing and revising established priorities.
Response
NRR recognizes the importance of a priority system similar to that
' described in the draft DIA report to manage its work in an environment of
' constrained resources. However, NRR does not believe the benefits derived from ranking items with the same priority and schedule according to relative
' importance (Recommendation 2(b)) would be commensurate with the effort involved. Decisions regarding items with the same priority should be made on a case-by-case basis, recognizing the uniqueness of each case. Such decisions may be to defer a task (s) within the priority group; reduce the scope of some of the tasks but do all the tasks; or do all the tasks on an expanded schedule. Furthemore, it may not be feasible for NRR to rank order tasks within a given priority group based on importance, since the
. tasks may be of equal importance from a Consnission perspective.
NRR plans to develop a system for prioritizing its work. The system envisioned will include criteria for prioritizing all NRR's work with specific priority groups for each of the major programs (e.g., operating reactors) and will be updated periodically. NRR had preliminary discussions
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- s A regarding such a system during its Management Conference in March 1981.
major input to completing the development of such a system is an NRR management study contract that is planned to be awarded in September 1981.
The objective of this contract is to examine NRR programs, the workload, the resources allocated, and the existing NRR tools and systems to manage those resources. The contractor will provide recommendations Since the that will full improve allocation and utilization of NRR resources.
benefits of this contract will not be forthcoming until the spring of 1982, other efforts to develop and improve procedures for identifying and prioritizing existing work items, as well as new work received, have been initiated. It is expected that these efforts will substantially improve NRR's ability to identify, prioritize and track its work.
It should be recognized, however, that any workable NRR priority system will depend on general approved priority guidance from the Commission from which NRR's more detailed guidance would flow; and a recognition by the Consnission that all new programs directed by it will not necessarily be
- given the highest priority unless they so direct.
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- 3. NRR management develop a better definition of technical branch roles to eliminate the prevailing confusion among the D0L staff and the resulting delay in detennining where OR tasks should be assigned for review.
Response
The " prevailing confusion" in detennining where OR tasks should be assigned for review is not believed to be as severe a problem as described in the draft report. However, a more in-depth assessment of the technical branch roles will be conducted in conjunction with the effort discussed in No.1 above. This part of that effort should be completed by about September 1, 1981.
- 4. NRR management assign a high priority to completion of proposed changes to 10 CFR 50.36 and 50.59 to reduce the number of incoming
' routine OR licensing actions and enable the staff to devote more effort to matters directly related to safety.
Response
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A proposed rule will be submitted to the Commission in August 1981, which will recomend revisions to 10 CFR 50.36 and 50.54 (not 50.59) that would include a redefinition of a Limited Condition for Operation (LCO) and remove certain administrative and surveillance requirements from the technical specifications of future licensed facilities. These changes t would be optional for those plants which are presently licensed. The effects of these changes would be expected to reduce the number of incoming routine, non-safety related licensing actions.
- 5. Develop general guidance to the staff on the handling of contractor work: a) stressing the importance of timely review of the contractor's products and prompt completion of the corresponding licensing actions.
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, .* and b) instructing the staff to ascertain that adequate criteria and supporting documentation are available to the contractor when licensing actions are assigned.
Response
On May 15, 1981, the Director of NRR appointed an NRR Technical Assistance Task Force whose objective is to conduct a review of program assistance resources available and to analyze the effectiveness of the use of those resources. Preliminary recomendations from the Task Force include a number of improvements that would require better accountability on the part of individual contract managers and NRR line management, improve overall planning of technical assistance needs and require training of staff and management in contract administration requirements. A final report is expected in August 1981.
I In addition, DL has instituted the use of a tracking system for locating bottlenecks in the review and implementation of contractor evaluation.
- Management oversight of the tracking system has resulted in a significant improvement in product utilization.
- 6. Dedicate the assigned project managers to the two contracts discussed in this report on a full time basis, to enable them to more effectively monitor contract perfomance and ensure adequate NRR support is being provided.
Response
The project managers for the two contracts referred to in the OIA draft report have been assigned on a full-time basis.
- 7. Detemine the review approach to be used on multi-plant issues--i.e.,
individual or generic reviews--before the work is assigned to the contractor. This will minimize waste of contractor effort and NRC resources resulting from changes in review approaches after work has been initiated.
Response
l NRR agrees that in the case of multi-plant issues, the review approach should be and is now very clearly detemined before the work is assigned to a contractor. This policy is in effect for all contracts that include multi-plant reviews for NRR. Those few instances at the start of the Franklin Research Center contract where the type of review to be conducted was initially not clear are being resolved and subsequent assignments under this contract have been made only after the type of review was detemined.
- 8. NRR and MPA jointly study the capabilities of RAMS to detemine how the system can be better utilized to produce reports that are more useful to the staff, and to detemine how NRR's reporting procedures can be improved to maintain the quality of the source data.
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Response
The Management Study contract and the Technical Assistance Task Force will i result in a number of recomendations regarding NRR's computer and data needs. Once these are received NRR and MPA will review the existing systems and reports to determine how best to implement the recomendations.
Although the Management Study will not be completed until about March of 1982, improvements based on the Technical Assistance Task Force recomen-dations in the program assistance area will be considered after that report is completed in August 1981. In the interim, a LATS/ Tracking system, the RAMS output on manpower spent on OL activities, and individual technical branch manpower assignments and tracking systems are being used
. to manage the review and implementation of contractor work.
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