ML20195G153
| ML20195G153 | |
| Person / Time | |
|---|---|
| Issue date: | 05/07/1987 |
| From: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| TASK-PINV, TASK-SE SECY-87-117, NUDOCS 8706030080 | |
| Download: ML20195G153 (7) | |
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POLICY ISSUE May 7,1987 S ECY 117 (Notation Vote)
Fy:
The Cemissioners Fron:
Victor Stello, Jr.
Executive Director 'or Operations Sub,iect:
COORDINATION PLAN FOR NRC/INPO USE OF PERF0PMANCE INDICATORS
Purpose:
To obtain appreval of the NRC/INP0 coordination plan.
Suma ry:
The performance indicator program for operating nuclear power plants, as approved by the Comission, is being implemented by the staff in accordance with Comission guidance. The program provides an objective view of operational perfomance and anhances the staff's ability to recognize changes in the safety performance of plants.
It is only a tool.
In conjunction with other information, it provides an input to management decisions regarding the need to adjust regulatory programs. The staff recognizes that performance indicators have limitations ard could be subject to misinterpretation and misuse with the potential for an adverse impact on safety. Accordingly, the staff and INFO have developed a coordination plan as a joint venture to help assure that the performance indicators are properly used. The plan also provides for sharing of the performance indicator data and coordination of develnp-mental activities that will reduce duplication of efforts.
The coordination plan is consistent with the Comission directive provided in the Secretary's memorandum of Decerber 30, 1986 in response to SECY-86-317, Perfonance Indicators, which cautioned the staff on the proper use of performance indicators.
The staff believes that the ccordination plan establishes the necessary principles for the proper use of performance i
indicators, and thus it is mutually ben *ficid to the NRC and INPO. The plan does not affect other existing regulatory programs.
Backoround:
The staff has been interacting on an ongoing basis with the industry and industry groups, particularly with INPO. in the development and implementation of the NPC performance indica-l ter program. These interactions were summarized in SECY-86-317 and in a subsequent briefing to the Comission on November 7, 1986.
Eoth the staf' and INPO have had concerns about the misuse cf performarce indicators that
Contact:
R. Singh, AECD 492-4361 q 9 O(cCISC5 ~b]5~}~
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. could be counter to the objective of enhancing operational safety.
INP0 provided their concerns in a letter to the Chairman dated November 5,'1986.
In the Secretary's memo-randum of December 30, 1986, the Comission directed.the staff to take into account the cautions listed in the INPO letter.
The staff and INP0 have developed a coordination plan, provided in Enclosure 1, for ensuring the proper use of performance indicators censistent with the Comission directives.
Discussion:
The primary objectives of the coordination plan are:
1.
To clarify the purposes of the NPC and INPO performance indicator programs; 2.
To recognize the limitations of performance indicators and estab'ish principles for their use in order to prevent their misuse or misapplication that could have an adverse impact on safety; and 3.
To provide a framework in which the staff and INP0 will work to meet the objectives outlined in 1 and 2, above, and to reduce the duplication of efforts by sharing data and coordinating developmental activities.
The coordination plan will affect the data collection activities and the proprietary treatment of some of the data as sumarized below.
The Comission has ooroved the use of six perfornance indicators; three o these are by design identical to INP0's performance indicators (automatic scrams while critical, safety systems actuations, and forced outage rate). The Comission also has directed the staff to develop addi-tional indicators in several areas, including personnel radiation exposure. Personnel radiation exposure has beer, added to the NPC program as the seventh indicator. As provided in the coordination plan, INP0 will provide quarterly data to the staff on these comon indicators.
This data sharing obviates the need for the staff to inde-pendently collect and/or reocess some data such as personnel radiation exposure.
Furtner, for comon indicators the use of shared data ensures that industry and the NRC will receive consistent quantitative information. As a result, while the NPC and INP0 nay attach different meaning to the data, the focus of management will be on the overall assessment of performance rather than reconcilia' tion,of small differences in data.
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, Data for indicators not comon with IMPO will continue to be collected and processed by the NPC staff. The staff plans to spot check the INPO data to verify its general consistency with~NPC information sources.
The plar-does not preclude collecting or processing data needed but not provided by INPO, for the performance indicator program.
It also does not affect data activities in supoort of other procrams or those in accordance with existing reporting recuirements.
The data obtained from INP0 will be treated as proprietary within the framework of previous legal decisions with respect to the exchange of information between the NRC and INPO. The NRC will control distribution of INP0's perfom-ance indicator data, and hence the NRC quarterly performance indicator reports which contain that data, within the agency and will exert best efforts to protect INPO proprietary documents and data. Controlled copies of reports will be distributed to the seniu NRC management and the Comission for their use.
When appropriate, senior NRC managers will review individual plant performance indicator data with senior utility management.
In sumary, the coordination plan should help ensure the proper use of performance indicators in the interest of improving operational safety. OGC has assisted in the development of this coordination clan and concurs in its implementation.
Following the approval of the coordination plan, the EDO will issue a policy statement to the staff, as directed by the Comission in the Secretary's memorandum of December 30, 1986, that will include the principles and approaches described in the coordination plan. Also, licensees will be notified of the NRC policy with respect to the use of performance indicators.
9ecomendation:
That the Comission Approve the coordination plan for NRC/ IMP 0 use of performance indicators provided in Enclosure 1.
Schedulina:
Timely action by the Comission will:
(1) facilitate finalization of the policy statement and coordination with INPO,(2) provide a reduction in duplication of NRC/INP0
4 efforts, and (3) define corrunications within the industry-and betweeen the NRC and industry and hence irrprove program effectiveness. : Ccordination Plan for NRC/INP0 Use of Performance Indicators
, 7 c ' ' 's..
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i,eto Victor Stello, Jr. '
Executive Director for Operations Commissioners' comments or consent should be provided directly to the Office of the Secretary by c.o.b. Tuesday, May 26, 1987.
Commission Staff Office comments, if any, should be submitted to the Commissioners NLT Monday, May 18, 1987, with an infor-mation copy to the Office of the Secretary.
If the paper is of such a nature that it requires additional time for analytical review and comment, the Commissioners and the Secretariat should be apprised of when comments may be expected.
DISTRIBUTION:
Commissioners OGC (H Street)
OI OIA GPA REGIONAL OFFICES EDO OGC (MNBB)
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ENCLOSURE 1 APPENDIX NUMBER FIVE C0 ORDINATION PLAN
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FCR NRC/INPO USE OF PERFORMANCE INDICATORS A.
NRC and INPO agree that the Plant Performance Indicator and Long Term Goals Programs established by.the industry have three purposes as.
follows:
1.
Providing a means by which utility managers can monitor and track the j
overall safety and reliability performance of nuclear units. The performance indicators are a management tool for utility executives.
2.
The performance indicators can be helpful to senior NRC management and senior INPO management in assessing overall safety and reliability performance patterns and, on a limited basis, corroborating other indications of problems (or impending problems) in a plant's performance.
3.
Providing a basis for healthy _ competition between nuclear stations and between utilities in the industrywide quest for excellence.
8.
In support of the above approach, NRC and INPO agree on the following principles:
1.
The recognition that pressure to achieve certain levels of performance, as measured by performance indicators, by persons or organizations outside the line management organization in a utility can lead to non-conservative safety decisions by middle level utility managers, operators, technicians, or craftsmen.
2.
The recognition that excessive focus on one or a small set of indicators by a utility can lead to undesirable actions, such as efforts to "tranage the indicator" instead of managing the pliat.
Such a focus could have an adverse impact on the overall margin of safety.
3.
The recognition that the use of certain indicators, such as numbers of scrams and forced outage rate is particularly sensitive with respect to principles (1) and (2) above.
4.
NRC and INPO application of performance indicators are for somewhat different purposes, with the prie:1 pal focus of each organization being as follows:
o NRC uses the indicator: as one tool for assessing and trending plant safety performance, as an input to adjust NRC programs.
NRC/INP0 Coordination Plan Appendix Five Page 2 o INP0 promotes utility line management use of the performance indicators as a goal-setting and performance-trending tool for the utilities.
C.
In view of these considerations, NRC and INP0 agree on the following:
1.
NRC has identified seven overall performance indicators which will be used in its trending program.
Four are in common with the INP0 effort and three are unique to NRC's program.
INP0 collects data for certain performance indicators from each nuclear station on a quarterly basis.
INPO will provide data for the four that are in common (unplanned automatic scrams, forced outage rate, personnel radiation exposure, and unplanned safety system actuations) to the NRC on a quarterly basis.
NRC will obtain the data unique to its program from existing data sources and will obtain the data for the common performance j
indicators from INPO, thereby precluding the need for additional requests of utilities.
It is recognized that NRC may desire to spot check the data received from time to time.
It is also recognized that NRC or INPO may expand or otherwise modify its present performance indicators program from time to time, 2.
INP0 and NRC will coordinate performance indicator development in order to reduce duplication or parallel efforts.
3.
NRC and INPO interactions with utilities con'cerning performance indicators will be conducted at the senior management level (of NRC, INPO, and the utility) to avoid perceived or real pressure at the working level that could cause a misuse of performance indicators which 'ould detract from safety.
4.
IMP 0 will not write evaluation findings based specifically on a nuclear plant's performance indicators.
NRC will not write deviations or violations or SALP findings based specifically on performance indicators.
It is recognized that both organizations will write findings covering shortfalls that may contribute to poor perf ormance.
5.
Cons' stent with previous legal decisions sanctioning the exchange of proprietary information between INP0 and NRC in the interest of improving nuclear plant safety, NRC will control distribution of INP0's performance indicator data within the agency and will exert best efforts to protect INPO proprietary documents and data.
NRC/INPO Coordination Plan Appendix Fise Page 3 NRC will develop a policy statement that sets forth cautions that 6.
must be applied in the-use of performance indicators, and that describes the rationale for the approach described above.
Victor Stello, Jr.
[ Zack T. Pate Executive Director for Operations President U. S. Nuclear Regulatory Commission.
Institute of Nuclear Power Operations Effective Date:
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