ML20138R600
| ML20138R600 | |
| Person / Time | |
|---|---|
| Issue date: | 11/06/1985 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Pate Z INSTITUTE OF NUCLEAR POWER OPERATIONS |
| References | |
| NUDOCS 8511180692 | |
| Download: ML20138R600 (4) | |
Text
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ocS 6
o NOV 061985 l
1 Dr. Zack T. Pate, President Institute of Nuclear Power Operations 1100 Circle 75 Parkway Suite 1500 Atlanta, GA 30339
Dear Dr. Pate:
SUBJECT:
STATUS OF THE NUCLEAR PLANT RELIABILITY DATA SYSTEM i
This is in response to your October 22 letter commenting on the NRC's seventh Semiannual Evaluation of the Status of the Nuclear Plant Reliability Data Systen (NPRDS). As you suggested, I have provided your letter to the appro-4 l
priate NRC staff, and I would like to share with you their reaction and comments.
When INi0 took over the management and direction of the NPRD System in mid-1981, it was recognized by INP0 to be a test of the industry's ability to self-regulate. That is, through industry's efforts, including plant evalua-j tions, discussions with utility management, and peer pressure, all plants would strive to reach a standard of excellence and in so doing would at least reach the level of performance of component failure reporting that would be present through government regulation.
Now you indicate that the NPRD System has achieved its objectives, that the point has been reached which "... represents virtually full utility partici-pation...", and that, as a result, all INP0 needs to do is
"...to keep track of and act on occasional lapses."
NRC staff members familiar with individual plant performance in the NPRD System believe your assessment is not correct.
Neither the data provided in your letter nor the information available to the NRC support such a conclusion.
Despite intensive and aggressive action by INP0 management, data available to the NRC indicates that as of the first quarter of CY 1985, the NPRD System had not yet reached the point where all plants are participating in accordance with NPRDS procedures. Thus, it is our view that the NPRDS objectives have not been i
achieved, and substantial numbers of reportable component failures are not being entered into the system.
Thus,.Zack, as I see it, the issue is not whether significant improvements 1
have been made in the NPRD System over the past several years. Everyone agrees that this has occurred, and this fact has been repeatedly stated in the NPRDS evaluation reports to the Commission. The issues are whether all plants are(Dj/
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fully participating in the NPRD System and, accordingly, whether the industry has demonstrated the capability for self-regulation in this area. The data available to us does not yet allow us to share the conclusion that all plants are satisfactorily participating in the NPRD System.
I am hopeful, however, that this goal will be reached, and if it is, I will be pleased to report this milestone in a future semiannual evaluation report.
With regard to our most recent evaluation report itself, evidently you are not aware that the report was not developed by a contractor. We did use a contrac-tor to extract and process the raw data, but the evaluation was performed by senior NRC staff members. This process is the same as that discussed with INP0 personnel in the past and is fully consistent with our past agreements and understandings.
Additionally, evidently you are also not aware that the evaluation report to the Commission included your July 25, 1985 letter for information and perspec-tive. Our analysis, however, was based on the specified report period, and thus we committed to evaluate the "more current" data in our next report.
Finally, we are not aware of any deficiencies in our methodology which would cause these evaluation reports to be " uninformed" or " misleading." I am told that in past discussions with your staff, no deficiencies in methodology were identified that required changes. However, I agree that additional discussions between our respective staffs would be helpful, particularly to review the INP0 data which supports your conclusion that the NPRD System objectives have been achieved, i.e., all plants are now satisfactorily participating in NPRDS.
In the meantime, I believe the NPRDS evaluation reports continue to be needed since they serve a useful function for both of us in focusing our attention on the status of the NPRD System and on the areas warranting further improvement.
Sincerely, (SigneG William 1.Dhcd William J. Dircks Executive Director for Operations Distribution:
AE0D CF H. Denton R. Martin R. Dennig AE0D SF J. Taylor J. Martin
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NOV 061985 Dr. Zack T. Pate, President Institute of Nuclear Power Operations 1100 Circle 75 Parkway Suite 1500 l
Atlanta, GA 30339
Dear Dr. Pate:
STATUS OF THE NUCLEAR PLANT RELIABILITY DATA SYSTEM
SUBJECT:
This is in response to your October 22 letter commenting on the NRC's seventh Semiannual Evaluation of the Status of the Nuclear Plant Reliability Data As you suggested, I have provided your letter to the appro-System (NPRDS).
priate NRC staff, and I would like to share with you their reaction and comments.
When INP0 took over the management and direction of the NPRD System in mid-1981, it was recognized by INPO to be a test of the industry's ability to That is, through industry's efforts, including plant evalua-self-regulate.
tions, discussions with utility management, and peer pressure, all plants would strive to reach a standard of excellence and in so doing would at least reach the level of performance of component failure reporting that would be present through government regulation.
Now you indicate that the NPRD System has achieved its objectives, that the point has been reached which "... represents virtually full utility partici-pation...", and that, as a result, all INP0 needs to do is "...to keep track of and act on occasional lapses."
l NRC staff members familiar with individual plant performance in the NPRD System Neither the data provided in your believe your assessment is not correct.
letter nor the information available to the NRC support such a conclusion.
Despite intensive and aggressive action by INP0 management, data availabic to the NRC indicates that as of the first quarter of CY 1985, the NPRD System had not yet reached the point where all plants are participating in accordance with Thus, it is our view that the NPRDS obiectives have not been NPRDS procedures.
achieved, and substantial numbers of reportable component failures are not being entered into the system.
Thus, Zack, as I see it, the issue is not whether significan* improvements have been made in the NPRD System over the past several years. Everyone agrees that this has occurred, and this fact has been repeatedly state 1 in the NPRDS The issues are whether all plants are evaluation reports to the Commission.
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Zack T. Pate fully participating in the NPRD System and, accordingly, whether the industry The data has demonstrated the capability for self-regulation in this area.
available to us does not yet allow us to share the conclusion that all plants are satisfactorily participating in the NPRD System.
I am hopeful, however, that this goal will be reached, and if it is, I will be pleased to report this milestone in a future semiannual evaluation report.
With regard to our most recent evaluation report itself, evidently you are not aware that the report was not developed by a contractor. We did ure a contrac-tor to extract and process the raw data, but the evaluation was performed by This process is the same as that discussed with INP0 senior NRC staff members.
personnel in the past and is fully consistent with our past agreements and understandings.
Additionally, evidently you are also not aware that the evaluatinn report to the Commission included your July 25, 1985 letter for information and perspec-Our analysis, however, was based on the specified report period, and tive.
thus we committed to evaluate the "more current" data in our next report.
Finally, we are not aware of any deficiencies in our methodology which wnuld I am told cause these evaluation reports to be " uninformed" or " misleading."
that in past discussions with your staff, no deficiencies in methodology were identified that required changes. However, I agree that additional discussions between our respective staffs would be helpful, particularly to review the INPO data which supports your conclusion that the NPRD System objectives have been In achieved, i.e., all plants are now satisfactorily participating in NPRDS.
the meantime, I believe the NPRDS evaluation reports continue to be needed since they serve a useful function for both of us in focusing our attention on the status of the NPRD System and on the areas warranting further improvement.
Sincerely, (Staed)Wdliam L Dircks William J. Dircks Executive Director for Operations i
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