ML20149D994
| ML20149D994 | |
| Person / Time | |
|---|---|
| Issue date: | 05/17/1994 |
| From: | Selin I, The Chairman NRC COMMISSION (OCM) |
| To: | Oleary H ENERGY, DEPT. OF |
| References | |
| NUDOCS 9405260103 | |
| Download: ML20149D994 (7) | |
Text
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.A jacteugjo UNITED STATES e
g' NUCLEAR REGULATORY COMMlf,SION n
WASHINGTON, D. C. 20555 3
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May 17, 1994 CHAIRMAN The Honorable Hazel R. O' Leary Secretary of Energy Washington, D.C.
20585
Dear Secretary O' Leary:
As the Vice President mentioned in his meeting on.May 3, we have all been asked to review our methods of measuring the success of our work. As part of our task in the Energy Committee, the NRC has identified the attached "results measures" to assess whether NRC efforts are actually leading to nuclear safety improvements. To achieve this improvement, many things are required, such as new sources of energy and stronger regulations. The Russian Federation must establish a vigorous safety culture based on institutional arrangements for a strong and independent regulatory authority and legal recognition of the need for adherence to agreed nuclear safety principles.
The early shutdown of Russia's least safe nuclear reactors is a very important measure of U.S.
success in enhancing Russia's nuclear safety regulatory regime.
The primary result expected from the NRC assistance program is to increase the effectiveness of the Russian nuclear safety' regulator, Gosatomnadzor (GAN).
Under the current Russian regulatory structure, GAN lacks true autonomy,.and its legal authority is derived from several decrees not clearly articulated.in Russian law.
Last year's decree (September 1993) increased GAN's responsibilities but did not give GAN adequate resources to exercise _its expanded duties.
One also_can expect increased safety and reduced accident risk at Russian reactors as a result of these efforts to strengthen GAN.
In addition, the quality of GAN's work should improve -- although this is more difficult to measure -- as a result of a significant amount of U.S.-supplied-training aimed at improving GAN's technical capability.
Distinguishing the safety impact of the NRC and other U.S. efforts from contributions being made by the assistance of other nations, and, to some extent, from Russian self-help efforts, will be difficult, as the results of 4
these efforts will tend to blend together. However, we hope the results for much of the NRC regulatory assistance to GAN will tend to be distinguishable.
The items identified as "results measures" are components of the institutional framework and programs that we believe contribute to a strong and independent nuclear safety regulator.
Essentially they codify results GAN should be striving to achieve to ensure the safety of Russian nuclear reactors. The measurement of success of the NRC assistance program is directly linked to-GAN's success.
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The Honorable Hazel R. O' Leary ;
As a result of the NRC program of cooperation and assistance, we are already seeing some positive changes towards increased GAN effectiveness as a nuclear safety regulator.
For example, GAN has prohibited reactor startup or restart based on safety considerations and is developing an emergency support center.
We hope to see more signs of growing effectiveness in the next year.
I will be happy to discuss these " measures" further at your convenience.
Sincerely, d
Ivan Selin
Enclosure:
Results Measures
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NRC'S PROGRAM TO ENHANCE NUCLEAR SAFETY REGULATION IN RUSSIA Description The United States Government, primarily through the United States Nuclear Regulatory Commission (NRC), assists the Russian Federal Nuclear and Radiation Safety Authority (Gosatomnadzor or GAN) in developing the infrastructure for an effective nuclear safety regulatory body. The assistance program concentrates on improving GAN's technical capability. However, we have also undertaken the more difficult task of encouraging Russia to enhance GAN's authority and independence through political-level exchanges conducted in the Energy Committee of the Gore-Chernomyrdin Commission.
The program concentrates on training in methods of nuclear inspection and technology. More than twenty two-week visits by Russian regulators to NRC and relevant U.S. facilities have occurred since the program's inception, utilizing both FY92 and FY93 funds.
Several forms of training have been employed, from classroom instruction to on-the-job-training, and from computer software development to site visits.
The training covers numerous facets of regulatory activity, including licensing and inspection of nuclear power plants, management and funding, and accident response practices..NRC's assistance also includes delivery and installation of computing and communications equipment which is virtually unavailable in Russia but readily obtainable in the U.S.
After a period of determining specifications and letting contracts, most of the approved equipment deliveries have been made.
Objectives Of particular significance are U.S. efforts to help GAN gain a position of authority and independence from the regulated industry similar to that of western regulators. We have achieved limited success in helping GAN to enhance its role; for example, by insisting that GAN take its proper place at the table in the Gore-Chernomyrdin Commission Energy Committee discussions of nuclear safety along with the powerful Ministry of Atomic Energy (HINATOM).
We have also arranged for GAN to serve as a full Co-Chairman of the Joint Coordinating Committee for Civilian Nuclear Reactor Safety, which oversees civilian nuclear activities between the U.S. and Russian Federations. We are directly encouraging GAN and the organization operating the Russian nuclear power plants to agree on a process for GAN's review and approval of procedures for maintaining a reactor in a safe condition during emergency situations.
The primary result NRC expects from this assistance is an increase in GAN's effectiveness as a nuclear safety regulator. Under the current Russian regulatory structure, GAN lacks true autonomy, and its legal authority is derived from several decrees not clearly articulated in Russian law.
The most recent of these decrees was issued in September 1993. The decree expanded GAN's responsibilities, but failed to give it adequate resources to carry them out.
We also expect to see signs of increased safety and reduced accident risk at Russian reactors as a result of our efforts to strengthen GAN. However, such
2 improvements cannot be assigned solely to regulatory enhancement, given other U.S.-efforts to improve the safety of operating nuclear power. plants (for which the Department of Energy has the lead role).
Evaluation Plan NRC has structured its assistance program to permit the best possible evaluation of whether the objectives of the program have been effectively-achieved and whether relevant resources have been properly expended. The method for evaluating progress against the objectives parallels the approval mechanism and reporting requirements of USAID.
It involves:
jointly developing projects with the recipient; obtaining approval of the program from USAID; jointly developing explicit annual implementation plans in concert with aid recipients; documenting the results of activities called for in the plans; preparing quarterly reports to USAID as required by interagency agreements; reviewing the results of activities with the recipients during annual meetings; reviewing plans and programs periodically with other involved USG agencies such as the Departments of State and Energy.
This approach assures that the program is responsive to the needs of the recipients and that the program remains within the bounds of the NRC agreements with USAID.
To determine whether these activities are actually leading to improvements in nuclear safety regulation, NRC has developed "results measures" as a way to assess (however imperfectly) the results of our continuing efforts'to increase GAN's effectiveness as a nuclear safety regulator and reduce risks at Russian reactors.
Development of such measures is difficult because a number of the desired outcomes are hard to quantify and are expected to occur. over a long period.
For example, effective regulation must include legal authority to assure enforcement as well as government financial and moral support.
These conditions in the recipient countries are subject to unsettled political circumstances which are difficult to influence.
3 Results Measures for NRC Procrams Goal: Through appropriate channels such as the Gore-Chernomyrdin Commission, influence the Russian government to increase GAN's authority and stature.
Measurable Results:
1.
Enactment of a law granting GAN legal and fiscal autonomy frcm MINATOM and providing strong authority to regulate nuclear safety 2.
Stabilization of GAN staff measured by reduction in attrition rates.
3.
Authorized increases in the size of GAN's staff as a result of Russian Government policy.
4.
Increase in the number of GAN resident inspectors to at least one at each nuclear power plant, with adequate support staff.
5.
Increase in GAN's resources to allow funding of safety projects, research, training, travel, and equipment procurement.
6.
Increase in number of inspections conducted.
Goal:
Increase the effectiveness of GAN's pro Jures and processes.
Measurable Results:
1.
Improved documentation of significant effects of inspectinn efforts.
2.
Full GAN participation in joint SSD activities in material control and accounting.
3.
Increase in skill levels of GAN staff in nuclear safety-related technical areas.
4.
Establishment and operation of a new Emergency Support Center.
5.
Establishment of a proper legal framework of nuclear safety regulation.
6.
Training for GAN personnel in all aspects of nuclear safety regulation based on U.S. methods and experience.
G0AL:
Reduce risks at Russian reactors (in addition to above, which will also contribute).
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4 Measurable Results:
1.
Improved reporting of significant Russian nuclear reactor events.
2.
Reduction in the number of significant events (Level 3 or higher per International Nuclear Event Scale).
3.
Externally documented evidence of improved safety culture at Russian-reactors through ASSET or OSART missions of IAEA.
4.
Improvements in the amount and quality of nuclear power plant operator training.
L 5.
Closure and decommissioning of plutonium production, early RBMK, and VVER 440/230 reactors.
6.
Reduction in numbers of automatic scrams while plant is critical.
Using these measures, it is evident that NRC's program is beginning to produce the desired results associated with the goal of increasing the effectiveness of GAN's procedures and processes.
(It is also evident that this is a very difficult job.)
For example, GAN:
prohibited startup of a reactor at Zaporozhye (now in Ukraine) until GAN's safety requirements were met; prohibited the Kola plant from restarting after an event until GAN was satisfied with corrective actions; developed a standard plan, using the NRC model, for reviewing new and modified reactor designs; obtained permits for installing incident );;ponse equipment at two plants (Kalininskaya and Sosnovy Bor);
modified a U.S. analytical code for application to Russian reactors; committed to a regulatory training center modelled on that of the NRC; committed to write a " Concept of Operations" for emergency response which calls for detailed planning; is developing _ an emergency support center which will improve regulatory.
enforcement and perform analysis on serious accidents; and, has come to recognize the importance of educating its licensees and the public on the role and responsibilities of the regulator.
5 Potential Difficulties in Achievina Ob.iectives The ability of NRC and its client agencies in the recipient countries to achieve the objectives of the assistance program depends on political.and economic conditions in the recipient countries. The concept of a strong, independent regulator is a novel one in the countries of the FSU.
Politically, GAN in Russia is considered a threat to the existing nuclear establishment, which has developed over many decades without effective oversight.
In addition, GAN is small and its personnel poorly compensated.
Without support for a comprehensive nuclear regulatory law and adequate funding from the Russian Government, which we are pursuing vigorously through the Gore-Chernomyrdin process, GAN cannot be expected to meet its responsibilities effectively.
On the other hand, the NRC has established extremely close working relationships with regulatory authorities in recipient nations, which have enabled us to overcome most administrative and bureaucratic impediments to program delivery. We have demonstrated the ability to deliver the assistance we have agreed upon with our recipient counterparts.
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