ML20151Y719

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Submits Comments Re COMSECY-98-024, Response to Issues Raised within Senate Authorization Context & 980717 Stakeholder Meeting
ML20151Y719
Person / Time
Issue date: 09/04/1998
From: Mcgaffigan E
NRC COMMISSION (OCM)
To: Hoyle J
NRC OFFICE OF THE SECRETARY (SECY)
References
NUDOCS 9809210004
Download: ML20151Y719 (2)


Text

j UNITED STATES RELEASED TO THE PDR l

y NUCLEAR RECULATCRY COMMISSION

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September 4. 1998 MEMORANDUM T0:

John C. Hoyle. Secretary FROM:

Edward McGaffigan, Jr.

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SUBJECT:

COMSECY-98-024 - RESPONSE TO ISSUES RAISED WITHIN THE SENATE AUTHORIZATION CONTEXT AND JULY 17. 1998 STAKEHOLDER MEETING I have reviewed the subject memorandum and offer the following comments:

I would note that the House Commerce Comittee and both Senate and House Appropriations Comittees have also raised issues in their reports on FY 1999 authorization and appropriation bilis. Many of the issues raised, but not all, are covered by the tasking memo and response.

I am concerned that there are some other issues that were raised by stakeholders that are also not yet

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being tracked in the COMSECY.

These issues raised by other Comittees or stakeholders include stricter application of the backfit rule, issues relating to uranium recovery facilities. possible changes in our hearing process, etc.

We are. in fact, already acting in many of these areas.

I recognize that this is a living document and I would hope that future versions would capture these activities so that we have a single comprehensive tracking document for these initiatives.

Second. I am concerned that topic area VI.D on Decomissioning Decisions does not provide the level of detail on licensing reviews, which for example, is provided in topic area I.C. on risk-informed plant-specific licensing actions.

I would hope we could get dates for completion of all pending licensing actions for shutdown plants. Maine Yankee. Haddam Neck, Big Rock Point. Zion, etc.

Third. I do not support suspension of the systematic assessment of licensee performance (SALP) process as proposed by the staff.

I could support suspension of SALP if plant progress reports (PPRs) score licensee performance in each of the four SALP categories compared to the baseline SALP score and if I g a public meeting is still held at no more than a two-year interval compared to the last SALP meeting to convey the latest PPR assessment.

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2 PPRs already all but provide an updated score in the four categories. The extra step of scoring should not be burdensome unless we make it so.

Let's empower our Regional branch chiefs project managers and resident inspectors

-(as the original Integrated Review of Assessment Programs (IRAP) proposed to i

do). The Regional Directors of the Division of Reactor Projects can resolve i

any differences and ensure adequate consistency. Their scoring judgments i

should not require further review by SES-level regional and headquarters managers.

I would also note that scoring in the PPRs during the interim period is consistent with previous Commission guidance to maintain scoring.

including of superior performance, in the new assessment process.

Finally, I

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believe that without summary scores in the four current assessment categories the public will not be able to wade through the often dense technocrauc prose of our PPRs and plant issues matrices and understand how well we believe a plar.c is performing.

My caveat on the need for at least a biannual public meeting comes from the public reaction at the recent St. Lucie SALP meeting to the notion that SALP would be terminated.

Members of the public were genuinely concerned that a valuable mechanism for staying abreast of St. Lucie's performance was potentially going to be lost to them.

The IRAP as originally proposed envisioned annual local meetings.

It is not too much to expect at least a biannual meeting during the transition to a new assessment process.

i If my recommendations for PPR scoring and biannual public_ assessment meetings i

reduce the savings of the SALP suspension. I suggest that the Commission i

revisit some of the just 'made FY 1999 budget decisions and find the necessary resources by reconsidering some of the options for reductions presented to the Commission.

1 cc:

Chairman Jackson i

Commissioner Diaz EDO OGC l

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