ML20140A419
| ML20140A419 | |
| Person / Time | |
|---|---|
| Issue date: | 03/17/1986 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20140A422 | List: |
| References | |
| NUDOCS 8603190436 | |
| Download: ML20140A419 (2) | |
Text
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% ..... l Mkn 17 1986 MEMORANDUM FOR: James M. Taylor, Director Office of Inspection and Enforcement FROM: Harold R. Denton, Director Office of Nuclear Reactor Regulation
SUBJECT:
MANUAL CHAPTER 0516 " SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE" This is in response to your November 5,1985 memorandum (forwarding the revised SALP Manual Chapter for review), and your memorandum of December 12, 1985 (requesting comments on your. proposed staff actions based on Category Three SALP Evaluations)._ Ue do not endorse the use of the SALP report as an enforcement tool. We believe the SALP process should continue to be a periodic and syste-matic evaluation of licensee performance. We recall that the stated objective of SALP is to provide a rational basis for allocation of resources and to provide a basis for NRC to encourage or require licensee improvements. If, at any time, NRC's review of a licensee's activities indicates the need for enforcement action, the action should be taken at that time, and not be deferred until the SALP -
process is underway or the SALP report is finalized.
NRR has reviewed the proposed revisions to the Manual Chapter and agrees that they constitute improvenents which should be incorporated. However, the changes do not go very far towards addressing our fundamental concern with the program.
Therefore, NRR's concurrence in the Manual Chapter is based on the understanding that a broad re-evaluation of the program is needed and will be undertaken.
The following ccmments are being provided as discussion topics aimed at improving the existing SALP program. The re-evaluation should address the following thoughts:
I. Making the assessment an assessment of plant safety
- 1. including the use of performance indicators;
- 2. including an assessment of the design and design changes;
- 3. including combining rainor categories such as " Fire Protection" and " Refueling" into larger categories;
- 4. including provisions for directly addressing operational events (rather than simply addressing the reporting of those events).
II. Improving our ability to modify the performance of problem plants
- 1. use of Regulatory Improvement Programs"; ,
- 2. including enforcement policies on poor performance; )<
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- 3. including provisions for rapid action outside the normal /,f , L/ /
SALP schedule, when necessary.
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EAR 17 g James M. Taylor As you know, efforts have been initiated to develop a set of performance indicators that more clearly correlate licensee performance to safety. The principal objective of these efforts is to implement an NRC program for prompt identification and timely correction of the problems. This objective is consistent with the goals outlined by Mr. Dircks in his November 26, 1985 memo on the lessons learned from Davis-Besse. We are aware that IE and the Regional Offices have considerable interest in the area of performance indicators and we will be coordinating our efforts in this area with other NRC actions on performance indicators. If the SALP process is determined to be the most appropriate vehicle for assessing plant safety based upon the performance irdicators developed, additional modifications to the SALP Manual Chapter will be prpposed.
Regarding using SALP as an indicator for tne allocation of our NRC resources and attention, we agree in concept with the recent decision to decrease inspection resources at selected reactors in Region III. We believe the concept can be expanded to other Regions.and in the future NRR would very much like *~ oe involved in the selection of such plants, since we must move forward in our efforts of better integration of the inspection and regulatory efforts.
Detailed comments on the Draf t Manual Chapter, including suggested editorial changes, have been provided to your staff. If you have any questions on this subject, please contact G. Holahan (24410) of my staff.
CrifMISIPfTi it it 0m Harold R. Denton, Director Office of fiuclear Reactor Regulation DISTRIBUTION YELLOW TICKET 859344 & 859334 Central File w/ incoming NRC POR w/ incoming NSIC w/ incoming HDenton/DEisenhut PPAS DMossburg (w/ yellow folder)
ORAS Rdg GHolahan MVirgilio FBrenneman RScroggins
- PREVIOUSLY CONCURRED ORAS* BC:0 RAS
- D:0 RAS
- DD D/fg FBrenneman:dm MVirgilio GHolahan D eIIut HDd/ ton 12/30/85 12/30/85 12/30/85 p /86 (re-concurred O g /86 2/14/86)