ML20154A386
| ML20154A386 | |
| Person / Time | |
|---|---|
| Issue date: | 02/05/1986 |
| From: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| Shared Package | |
| ML20154A384 | List: |
| References | |
| NUDOCS 8603040008 | |
| Download: ML20154A386 (4) | |
Text
l FEB 0 5195 For: The Commissioners .
From: Victor Stello, Jr.
Acting Executive Director for Operations !
Subject:
FINAL GAO REPORT ENTITLED "fiUCLEAR REGULATION - PROCESS FOR BACKFITTING CHANGES IN NUCLEAR PLANTS HAS IPPROVE0"
Purpose:
Approval of a response to Congress on actions taken on GA0 recomendations (pursuant to Section 236 of the Legislative Reorganization Act of 1973).
Discussion: The GA0 report includes two specific recomendations (Chapter 3, pp. 70-71 of the report). Both these recom- '
mendations pertain to the agency's plant-specific back-fitting procedures as described in the NRC Hanual Chapter 0514.
The first recomends that the Chairman, NRC, revise the agency's plant-specific backfitting procedures to explicitly state that the NRC staff is responsible for identifying and processing, in accordance with the plant-specific backfitting procedures, all new or amended plant-specific positions taken by the staff.
The second recomends that the procedures be revised to explicitly state that to cualify as a plant-specific back-fit, the technical basis for a new or revised staff position taken rust be unique to a specific plant or plant location.
The staff agrees with the substance of the first recom-mendation. A chance responsive to the first recomenda-tion was incorporated in the Panual Chapter (Section 042, page 11, Final Version) submitted for Comission approval by renorandum from the E00 to the Comission dated November ;
13, 1985. We differ with GAO with respect to the second 0603040000 060224 ,
PDR COMMO NRCC CORRCSPDtTOENCC YDR
Contact:
Thomas H. Cox, ROGR Staff 492-4357
9 g-eeconrenda tion. Our definition of plant-specific, already included in the Manual Chapter in Section 01, Purpose, says in effect that a position applied to two or more plants at the same site would be a generic position.
This definition is clear and has caused no problems in application. The GAO definition could cause a position unique to a plant location to be interpreted as plant-specific even though that position may be applicable to more than two essentially different plants at that location. Therefore, we choose to not include the phrase
"... or plant location" in the definition. However, for additional clarity, I propose to include our current definition in the first paragraph of Section 052 (definition of plant-specific backfit) of the Manual Chapter, as follows:
"Backfitting is plant-specific when it is limited to the imposition of a position that is unique to a specific plant."
Both these proposed responses to the Gt0 recomendations are presented in Enclosure I which would Le enclosed with the proposed letter to Congress in fulfillment of the reporting requirement.
Recomr.endation: That the Comission approve the proposed response to Congress.
Orisinal n
- hctor gg 7 Victor Stello, Jr.
Acting Deputy Executive Director for Operations
Enclosures:
- 1. Response to GA0 Reconrendations
- 2. Proposed Letter to Congress OFC :ROGR : ROGR' -
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ENCLOSURE 1 Response to GA0 Recommendations Contained in
" Nuclear Regulation - Process for Backfitting Changes in Nuclear Plant Has Improved" GA0/RCED-86-27 December 1985 Chapter 3 - Recommendations to the Chairman, Nuclear Regulatory Commission.
GA0 recognized that the NRC has a comprehensive backfitting management system in place that relies on its backfitting regulation (10 CFR 50.109) as its foundation. GA0 recomended two revisions to the system's plant-specific backfit management procedures to provide additional assurance that the system is operating effectively:
- 1. A revision to explicitly state that the NRC staff is responsible for identifying and processing, in accordance with the plant-specific backfitting procedures, all new or amended plant-specific positions taken by the staff.
NRC Response:
The NRC agrees with the substance of this recommendation. Statements conveying this direction are introduced at the beginning of Section 042 of the NRC Manual Chapter 0514. " Identifying Plant-Specific Backfits."
- 2. A revision to explicitly state that to qualify as a plant-specific backfit, the technical basis for a new or revised staff position taken must be unique to a specific plant or plant location.
NRC Response:
The NRC differs with the substance of this recommendation. The NRC definition of plant-specific, already-included in the Manual Chapter in Section 01, Purpose, says in effect that a position applied to two or more plants at the same site would be a generic position. This definition is clear and has caused no problems in application. The GA0 definition could cause a position unique to a plant location to be interpreted as plant-specific even though that position may be applicable to two or more essentially different plants at that location. Therefore, the NRC chooses to not include the phrase "... or plant location" in the definition. However, for additional clarity, the NRC will include its preferred definition in the first paragraph of Section 052 (definition of plant-specific backfit) of the Manual Chapter, as follows:
"Backfitting is plant-specific when it is limited to tne imposition of a position that is unique to a specific plant."
The Honorable William V. Roth, Jr.
Chairman, Committee on Governmental Affairs United States Senate Washington, DC 20510
Dear Mr. Chairman:
In accordance with the statutory obligation to respond to reconmendations by the General Accounting Office (GAO) within 60 days of publication, we hereby submit our responses to the recommendations made by GA0 in their report entitled, " Nuclear Regulation - Process for Backfitting Changes in Nuclear Plants Has Improved."
The Commission has responded to the two specific recommendations made by GA0.
These recommendations pertained to statements in the NRC agency-level written procedures directing the program for management of plant-specific backfitting of nuclear power plants. The Commission issued a formal regulation governing NRC management of backfitting (10 CFR 50.109 and other conforming amendments),
effective on October 21, 1985. The procedures reviewed by GA0 have recently been revised to conform with the new regulation and those procedures also include most of the substance of the revisions recommended by GA0. The new regulation and agency internal procedures for both plant-specific and generic backfitting form a strong foundation for continued NRC improvement in the management of backfitting.
As recognized by GAO, these and several other important new initiatives in backfit management are at most only a year old. The NRC is looking forward to integrating and effectively applying the various initiatives as rapidly as possible to yield measurable improvements in the overall bact' fit management program.
Specific responses to the GA0 recommendations are presented in the Enclosure.
Sincerely, Nunzio J. Palladino Chairman
Enclosure:
Responses to GA0 Recommendations cc: Sen. Thomas F. Eagleton Identical Letters to Those on the Enclosed List n
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