ML20196A946
| ML20196A946 | |
| Person / Time | |
|---|---|
| Issue date: | 01/29/1999 |
| From: | Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM) |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20196A940 | List: |
| References | |
| SECY-99-007-C, SECY-99-7-C, NUDOCS 9906230043 | |
| Download: ML20196A946 (3) | |
Text
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NOTATION VOTE RESPONSE SHEET TO:
John C. Hoyle, Secretary FROM:
CHAIRMAN JACKSON
SUBJECT:
SECY-90-007 - RECOMMENDATIONS FOR REACTOR OVERSIGHT PROCESS IMPROVEMENTS x
Approved w/commentsDisapproved Abstain Not Participating COMMENTS:
See attached comments.
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Shirley nn Jackson SIGNATURE January 29, 1999 DATE Entered on "AS" Yes x No lM' ne Un'"
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CORRESPONDENC6 PDR 46603 Jb Y#t
Chairman Jackson's Comments on SECY-99-007 I acknowledge and approve of the staff concepts and scope of the changes presented in the subject
. paper. The staff, along with our internal and external stakeholders,are to be congraallated for an outstanding cooperative effort, which has resulted in proposed changes to the power reactor oversight process of very real significance in a relatively short period of time. I believe the level of stakeholder /NRC interaction on this issue represents the very best of what we can hope to achieve in terms of openness (one of our principles of good regulation).
It is clear to me that the staff has organized its program logically and has provided improvid clarity of purpose over the existing NRC programs for assessment and inspection. The establishment of a system of risk-informed performance thresholds and cornerstones of safety to tie operational concerna to the NRC mission are features which, in my estimation, significantly aid in properly focusing our attention.
Taken in conjunction with risk-informed inspection and assessment guidance (including the approaches to defining informational needs and integrating performance indicators with inspection findings as
- defined in the subject paper), we stand to gain a much stronger footing as we attempt to maximize the efficient use of our resources. I similarly approve of the development of an assessment matrix which i
predefines the level of agency response as a function of licensee performance. In approving this concept, I would caution the staff that, while some flexibility in the application of such a matrix will be required, such flexibility should be very carefully managed to prevent a loss of predictability and scrutability. I approve of the staff proposal for the transition from the current inspection and assessment process to the new process, including the approach to pilot applications, and to the staff position on continuing the suspension of the SALP process.
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_With respect to specific aspects of the paper, I would encourage the staff to consider the following.
With respect to Risk-Informed Matrix Number 1, the staff should continue to enhance
' individual inspection activity descriptions to include not just the number of hours required to
' perform an individual inspection, but the number of samples, observations, c other activities which result in the documented number of l'ours. The staff should also ensure that the program i
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is capable of accepting inspector feedback on the time required to perform a particular activity, l
to ensure that realistic resource estimates result from inspection planning.
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With respect to the proposed concept of an Action Matrix, the staff should consider adjusting
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e-the elements of the matrix to include Commission involvement earlier in the NRC response.
scheme. The goal of doing so would be to ensure that the agency has exhausted all possible l
q avenues of regulator / licensee communication prior to licensee performance falling to an i
4 unacceptable level and to ensure that the C( canission is raade aware of significantly declining I
licensee performance and proposed and ongoing staff act}vities in a timely manner The staff should consider employing language in performance thresholds that will accurately j
e describe the gradations oflicensee performance in a given area (as opposed to using the term
" acceptable" until performance becomes " unacceptable").
The scheduling of the Agency Action Review meeting (annually) appears to presuppose that no I
plant will require agency-level action at any other time. This seems analogous to the placement of a plant on the Watch List - by the time the plant is on the list, the level of NRC activity has already escalated to the point that the Watch List designator adds little to the overall agency response. Since this meeting is described as being for plants with severely degraded performance (indicating that only a few plants, if any, would be considered), the staff should consider an approach which would convene such a meeting whenever needed to affirm an intended agency-level action.
The enforcement portion of this paper is not integrated well with the balance of the paper. It does not discuss the advisability of pursuing enforcement actions as a result of the assessment process, and the separate portion dealing with enforcement does not discuss a proposal made in the assessment portion of the paper, which proposes an entirely new approach to violations of regulatory requirements. The staff should ensure that fullintegration is achieved in its final proposal to the Commission, a