ML20196A951
| ML20196A951 | |
| Person / Time | |
|---|---|
| Issue date: | 02/16/1999 |
| From: | Dicus G NRC COMMISSION (OCM) |
| To: | Vietticook A NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20196A940 | List: |
| References | |
| SECY-99-007-C, SECY-99-7-C, NUDOCS 9906230045 | |
| Download: ML20196A951 (3) | |
Text
-
NOT ATIO N VOTE RESPONSE SHEET TO:
Annette Vietti-Cook Secretary of the Commission FROM:
COMMISSIONER DICUS
SUBJECT:
SECY-99-007, RECOMMENDATIONS FOR REACTOR j
OVERSIGHT PROCESS IMPROVEMENTS Approved X Disapproved Abstain Not Participating Request Discussion COMMENTS:
l See Attached bh 6a
\\oQO
*"^)L9
\\
l Release Vote / X /
(qk'bmau /C
/ 9D
}
~~
DAT
/
~
Withhold Vote /
/
Entered on "AS" Yas X No 9906230045 990618 PDR COMMS NRCC CURRESPONDENCE PDR
)
Q?oba3aDt-]5 3 ey i
Commissioner Dicus Comments to SECY-09-007
' The staff has done an excellent job in developing the revised reactor oversight j
assessment program. This paper represents a significant expenditure of staff j
resources on an process that is paramount to ensuring protection of the environment and adequate public health and safety. The proposals have been well thought out, and
{
are consistent with the development of a process that integrates the use of risk-insights, performance indicators and inspecuon. I agree with the staffs approaches as discussed in the paper.
Nevertheless, recognizing that the details of various aspects of this new process need to be aired for public comment and refined, I offer the following comments:
1.
I am concerned that the threshhold for unacceptable performance in any
)
particular cornerstone is not necessarily well defined or realistic. As an example, unacceptable performance relative to unplanned scrams per 7000 hours0.081 days <br />1.944 hours <br />0.0116 weeks <br />0.00266 months <br /> is set at
>25. Yet staff notes in Appendix H that such a high value is realistically unachievable. Irrespective of whether declines in performance in other areas are expected to be observed prior to this threshold being reached, the yellow-red threshold for this cornerstone, as well as others like it, should be able to stand alone. I urge staff to establish meaningful performance thresholds which define unacceptable performance.
2.
Many performance indicators state that the threshold for unacceptable performance is 'NA." Examples of such indicators include physical protection, public radiation safety and emergency preparedness. The lack of stated thresholds appear to imply that deficient performance, no matter how extreme, whether determined by performance indicatora or inspection, will not be considered unacceptable. For areas where performance is to be derived from inspection results (such as those performed for physical security Access Control and response to Contingency Events (i.e., deQ;r. Msis threat assessments] as described in Appendix G), staff should develop clear meaningful thresholds and criteria which constitute unacceptable performance.
3.
The commercial nuclear power industry reminds us that over the past ten years, the industry has matured considerably as evidenced by the significant improvements in plant operations and industry performance indicators. Yet, even though in most cases, plant performance as mcasured by indicator data ten years ago was considered acceptable, we do not consider those performance standards to be appropriate in all cases, in today's environment.
By the same token, the performance standards and thresholds that are being established in this new reactor oversight assessment process may not be appropriate ten years hence for a nuclear industry that has gained that additional
o 2-maturity. Staff should periodically evaluate the appropriateness of the performance band thresholds for the various cornerstones as future risk insights
- s.
are developed.
4.
As the agency moves towards imple. mentation of a more performance-oriented assessment framework, the success of the process is dependent upon the licensees' implementation ofits programs, and the staffs verification of the licensees' performance it is imperative that staff utilize appropriate inspection and evaluation resources and expertise to properly verify and assess by independent means, the effectiveness.of licensee performance.
l 1