ML20196J547
| ML20196J547 | |
| Person / Time | |
|---|---|
| Issue date: | 12/07/1998 |
| From: | Zimmerman R NRC (Affiliation Not Assigned) |
| To: | |
| References | |
| NUDOCS 9812100123 | |
| Download: ML20196J547 (18) | |
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i i j j ANS EXECUTIVE CONFERENCE l "SELF-ASSESSMENT" Not a Program - A Way of Life l l December 7,1998 l
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SELF-ASSESSMENTS IN A CHANGING ;
! INDUSTRY / REGULATORY ENVIRONMENT i
ROY P. ZIMMERMAN DEPUTY DIRECTOR OFFICE OF NUCLEAR REACTOR REGULATION 98121UJ123 981207 PDR ORG NRRA
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2 SELF-ASSESSMENTS IN A CHANGING INDUSTRY / REGULATORY ENVIRONMENT by Roy Zimmerman INTRODUCTION Good morning. I am pleased to be here with you at this opening session on self assessment.
As many of you may be aware, during our Senate oversight hearing in July, a member of the financial community made a comment to the effect that there may be a perception and concem i among some senior utility executives that a nuclear power plant, at any given time, could be about ten minutes away from an unplanned extended plant shutdown triggered (either directly or indirectly) by NRC action. This perception is certainly disturbing because it highlights a i fundamental lack of confidence in the predictability and objectivity of our regulatory process.
Both the NRC and you in attendance here, have steps that we can take and should take, to
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minimize this potential. And those steps tie back to the theme of this conference. ]
l First, you should have confidence in your own operations as verified by your aggressive self-assessment efforts. You should be able to demonstrate and get credit for these efforts through NRC and other outside assessments of your program. At the same time, the NRC must continue to evaluate its own assessment methods to make them more predictable and objective, and to give you the confidence that your e&rts will be evaluated fairly within a performance-based and risked-informed framework.
Our joint challenge, related to self-assessment is to describe the expectations and provide the l necessary resources so we can continus to build on our successes - that is; from your strong self-assessment efforts and likewise, from our internal improvement initiatives.
l ELEMENTS OF SELF-ASSESSMENT .
As a first step in building on success, I would like to briefly review some attributes we see in successful utility, self-assessment programs.
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Senior Level Support:
It is most important that you, the senior nuclear executive, vice president nuclear, or plant manager, want your organization to be self critical, it is important that you and all your managers want to see things the way they really are, not only to confirm your strengths, but also any weaknesses. Your attitudes, intentions, and examples you set are critical to the effectiveness of your self assessment activities. If you are interested in performing objective and unbiased assessments, the process will work. Senior management should frequently l
assess the collective significance of problem reports and evaluations to assure they know about, and address areas, needing special attention before potentially serious problems result. 1 As we know, these problems can, and have resulted in long shutdowns.
1 involvement of Diverse Groups:
I Your self-assessment efforts should include all groups (and individuals) that play a role in identifying, assessing and following up on problems. This starts with top management. It l l
includes the line organizations, Quality Assurance organizations, and internal and external '
oversight groups. The Quality organization should be a competent and assertive internal oversight organization that, in addition to identifying problems through their own reviews, provides direct feedback to senior management on how the overall self-assessment process and efforts of other groups are working.
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Problem Identification and Resolution Process: !
l The starting point in the process is the reporting of problems. You and your supporting management should be receptive to " bad news". Some of you have established a zero threshold policy for the level at which a problem is reported. Others may have established specific criteria. Regardless, a key element is the general receptiveness to having problems reported.
While all problems should be evaluated at some level, selected problems should be scrutinized in-depth to ensure that root causes are understood. We recognize the need to be selective i
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4 l because attempting to treat every problem the same would only dilute your efforts and effectiveness - not to mention the resources involved. {
l Follow-up, Feedback and Continued Vigilance:
) l j Follow-up and feedback are vital to the resolution process. Assessment findings should not be ,
1 allowed to fall into a black hole. Staff should receive feedback that shows their concerns are ]
taken seriously. You and your managers should actively look for feedback that your l
expectations have reached the working level and that they are understood.
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Assessment efforts should be repeated with appropriate frequency to ensure that corrective actions ccet;nue to be effective. Risk insights, which I will discuss later, should certainly be a factor here.
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Proper scoping:
it is also important that your self-assessment efforts be of sufficient scope and depth to accomplish their intended purpose and produce meaningful results. Again, risk insights will be an important consideration. Also, the scope of your self-assessments will be a key consideration in NRC decisions to give you credit for such efforts in lieu of NRC inspection activities.
Staffing & Training: ,
The staffing and training of your personnel should be commensurate with the type of assessment effort involved. It is important to consider more than just technical competence. It is important that members of assessment teams have a critical eye. Some of you have seen that assigning individuals new to the assessment function along with experienced assessors is an important training tool.
I recognize that you have already considered and incorporated elements such as these in your own programs. I do not mention them here as some new philosophy, but rather to reinforce e
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good practices which seem to work. Now let me briefly address why it is important that the process work.
NRC VIEW OF IMPORTANCE OF INDUSTRY SELF-ASSESSMENT 4
Self-assessment is a key tool in assuring that surprises which challenge safety and result in l costly disruptions to plant operation are avoided. Over time, some safety problems which could have been avoided, have led to reduced confidence on the part of one or more ci the
, stakeholders imrolved -- whether it be government regulators and officials, the public, customers, or stockholders. These instances also have affected the self-confidence of the 4
power plant staff. On the other hand, an effective and pro-active self-assessment program in j which every one from line staff to senior company executives take part, will do much to achieve
] and maintain excellent performance and the confidence of all parties.
4 We, at the NRC, must continue to have confidence in your self-assessment programs. As you 3
know, we do not have the resources to perform our own assessments of all the activities which
- your own self-assessments can cover. Further, I think we can agree that NRC inspections would likely not be the most efficient method to conduct such assessments. The most experienced and knowledgeable individuals on your facilities are unquestionably your own staffs. They are the ones best situated to perform the most efficient and meaningful !
assessments when conducted in an environment that expects the tough questions will be asked. The more you can foster and demonstrate this ability, the more the NRC may be able to
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find ways to give you more credit for them. This already has, and will more so in the fuhre lead to less direct NRC inspection effort. Most importantly, aggressive and effective self- l assessment efforts by the best experts on your facilities, that being you and your own staff, should positively afTect your continued safe operations and everyone's confidence in it.
SELF-ASSESSMENT IN PRACTICE Up to this point I have discussed self-assessment in general terms of it's importance and key characteristics. I would now like to briefly discuss a few findings regarding the implementation of inoustry self-assessment programs in practice. I will first cover a couple of examples that i
6 indicate some work is still needed in this area, and then move on to some successes.
I'll begin by mentioning a May,1997,"GAO Report to Congress, entitled, Preventing Problem Plants Requires More Effective NRC Action," which makes some points related to the importance of your self-assessment and corrective action activities, and the NRC's evaluation of these activities. The report acknowledges, and we agree, that data supplied by licensees stuv that the overall safety pedormance of the nuclear industry, as a whole, is good and improving. However, the report also points out that there are some chronically weaker performers. At the time of this report there were 14 plants on the NRC's " Watch List," which are those plants whose declining safety performance triggers additional oversight attention by the NRC. This was the highest number of plants on the NRC's Watch list since 1988. l However, I must mention that as of this past July this number had dropped to five plants.
l A common element identified in such cases of weak or declining performance was lack of i
aggressive and effective action by the lice sees' to correct long-standing safety problems on a ;
timely basis. Key to this problem were in nt :c'ive self-assessments, weak corrective action l
programs, and ineffective management involvement. Also, the NRC was faulted for not having i a more aggressive inspection and enforcement effort in these areas to identify and help correct these performance problems earlier.
I As a more recent example, earlier this year an NRC team monitored and evaluated the effectiveness of a licensee Integrated Safety Assessment (ISA). This ISA was part of a response to declining performance followed by a shutdown event and subsequent extended unplanned outage. Some of the 3"' party findings germane to this self-assessment include:
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Ineffective independent oversight resulted in many missed opportunities to improve station performance.
. While the Nuclear Review and Au6roup was very effective in identifying technical issues, it was not effective in comn.. sicating its findings and ensuring that corrective actions were taken.
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7 Managers did not sufficiently oversee plant staff activities which contributed to staff not performing activities in accordance with management expectations.
The corrective action program did not effectively capture trends, was narrow in focus, and had no repetitive failure analysis, and had no application for common mode failures.
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The inability to identify, evaluate, and correct problems was a major impediment to '
l improvement. Failure to monitor and ensure implementation of corrective action plans contributed to recurring problems. I As another example, as recently as a week ago, at a commission meeting, the Commission had an opportunity to hear from senior executives of a different utility where problems were identified that resulted in an outage that has already lasted over a year. These problems were largely unexpected to both the NRC and the licensee because they had been considered a relatively good performer. Without going into specific details of the problems, I'd like to :
1 mention that it's executives pointed out that one of the factors that lead to thic situation was that they had become insular and somewhat overconfident due to many past years of success.
They also pointed out that although their organization was effective at identifying and l performing initial assessments of issues, they were lacking in the rigor and discipline to ;
uhimately resolve the issues. !
However, as I mentioned before, such findings should not be viewed as the norm. We ,
consistently observe many strengths in industry self-assessment and corrective action )
programs. For e.xample, while conducting Maintenance Rule baseline inspections, the NRC teams reviewed licensee quality assurance audits or self-assessments of Maintenance Rule i l
programs, procedures and implementation practices. The teams found that limnsee self- l assessments identified several weaknesses in these programs and implementation practices.
l While we recognize that the industry has raised some issues regarding the Maintenance Rule I
and its ongoing implementation which we must work on (such as defining risk-significant systems), the point I want to make here is the noted strength and effectiveness of your self- )
- assessment processes in identifying and correcting issues under the implementation of the l
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8 current Maintenance Rule. In this regard, we can say that industry self-assessments consistently identified as a strength of the Maintenance Rule program implementation Accordingly, the staff recommended that licensees continue self-assessment act periodic basis to verify that the Maintenance Rule programs do not lapse, and continue to demonstrate the effectiveness of maintenance in improving overall plant performance.
You rightfully should take pride in the overall successes we can see in your self efforts. However, I think that when we do see exceptions, they re-emphasizes for senior managers to look beyond perceptions and examine activit.'es w all the elements of successful self-assessment programs. This should be done t surprises.
_SELF-ASSESSMENT: RISK INSIGHTS As I mentioned in my discussion of key elements of a self-assessment prog should cenainly play a role in how the program is implemented. The NRC has re relevance of risk insights with respect to adjusting the application of licensee O controls. The regulations require that the QA controls be applied in a manner consis the importance to safety of the equipment. A method to determine o the relative im safety is to include a risk-informed process. The staff believes that in this manner, b licensee and NRC resources can be focused on equipment and activities which ha greatest safety significance. In this regard, we recently issued Regulatory Guide 1.17 Approach for Plant-Specific, Risk-Informed Decisionmaking: Graded Quality Ass August 1998.
With regard to audits and other self-assessment processes, those activities sho safety-significance could be assessed less rigorously and less frequently th significant population of equipment. In this manner, finite self-assessment resourc preferentially allocated based on risk-informed decision making.
In a similar vein, once a risk-informed process has identified less safety-signif
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8 current Maintenance Rule. In this regard, we can say that industry self-assessments were !
consistently identified as a strength of the Maintenance Rule program implementation.
Accordingly, the staff recommended that licensees continue self-assessment activities on a l periodic basis to verify that the Maintenance Rule programs do not lapse, and that they continue to demonstrate the effectiveness of maintenance in improving overall plant
- performance.
, You rightfully should take pride in the overall successes we can see in your self-assessment efforts. However, I think that when we do see exceptions, they re-ernphasizes the importance
! for senior managers to look beyond perceptions and examine activities with a critical eye using ,
all the elements of successful self-assessment programs. This should be done to prevent a
surprises, k
SELF-ASSESSMENT: RISK INSIGHTS As I mentioned in my discussion of key elements of a self-assessment program, risk insights i
should certainly play a role in how the program is implemented. The NRC has recognized the
! relevance of risk insights with respect to adjusting the application of licensee QA program controls. The regulations require that the OA controls be applied in a manner consistent with the importance to safety of the equipment. A method to determine the relative importance to safety is to include a risk-informed process. The staff believes that in this manner, both foonsee and NRC resources can be focused on equipment and activities which have the greatest safety significance. In this regard, we recently issuea Regulatory Guide 1.176; "An f Approach for Plant-Specific, Risk-Informed Decisionmaking: Graded Quality Assurance;"in l
August 1998.
With regard to audits and other self-assessment processes, those activities shown to be of less safety-significance could be assessed less rigorously and less frequently than the more safety significant population of equipment. In this manner, finite self-assessment resources can be preferentially allocated based on risk-informed decision making.
In a similar vein, once a risk-informed process has identified less safety-significant equipment, i
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9 the corrective action process should account for those differences. For low safety-significant items, the timeliness can be given less priority, and extent of corrective actions could be reduced accordingly, based on the low safety significance of the activity (this is consistent with Generic Letter 91-18, "Information to Licensees regarding NRC Inspection Manual Section on Resolution of Degraded and Nonconforming Conditions;" revision 1). So,in a similar manner to self-assessments, the staff promotes the adjustment of licensee corrective actions based on risk insights.
As a cautionary note, it may be necessary to make a formal change in docketed information (such as a OA program) and receive NRC approval to provide the enabling mechanism to proceed with these changes.
NRC EVALUATION OF ' lCENSEE PROGRAM & INTERNAL SELF-ASSESSMENT I would now like to talk for a few minutes about how the NRC evaluates the effectiveness of licensee self-assessment efforts. Along with this I would also like to discuss some of our efforts to evaluate and adapt our own program to better accomplish this.
As licensees look at their programs, including those for self-assessment, more and more from a performance-based and risk-informed approach, so must the NRC also look at it's approaches for evaluating licensee effectiveness and ultimately safety. We are taking action to modify our
, reactor oversight functions accordingly. Some current and ongoing effort include:
IP 40501 - Licensee Self-Assessments Related to Team inspection This inspection procedure provides guidance on evaluating a licensee's self-assessment effort as an alternative to an NRC team inspection in consideration of a licensee's past performance.
In evaluating this, we look at: a) the capability of your organization to manage the self-assessment, b) the knowledge and experience of your assessment team to perform a technically creditable self-assessment, c) that the scope and depth of your program to ensure that they are at least equivalent to those requirements specified in the NRC's inspection procedure for the issue involved, c~ :.at you have provided an acceptable basis for reducing the t .
10 scope or depth, and d) that the timing of your proposal and assessment is such that we can adequately adjust our planning so that we have sufficient time to evaluate the proposal and align our resources to be able to monitor the in-process conduct of your self-assessment effort.
Licensee's have given us estimates that 4-5 of their staff are needed for each NRC inspector on site to locate documents, respond to questions, etc.. Thus when efforts such as this can rasult in sending half or one fourth of the usual number of inspectors, you should be able to save considerable resources, even when offset to some extent by the time it takes to do the self-assessment. The NRC also benefits here. Initial data has shown that the agency is saving 50% to 75% of the staff time previously devoted to such inspections.
IP 40500 - Effectiveness of Licensee Process to identify, Resolve, and Prevent Problems (including NCV positions)
Areas covered by this inspection procedure include corrective action programs, root cause analysis, self-assessments, safety review committee actions, and corrective a7tions relative to operating experience feedback.
Over the last year a review and update of IP 40500 was conducted in an effort to address implementation of lessons learned, many dealing with making the procedure more performance based. Efforts were made to tailor the inspection focus, in both time and areas reviewed, based on evaluation of the licensee's observed performance. Although such decisions remain subjective to a large extent, the revision is v5wed as a posi'.ive first step in allowing a more effective and directed inspection effort. This revision is expected to be issued in the near future.
Ongoing Enforcement Policy Efforts:
A frequently asked question is: How does NRC handle enforcement with respect to self identified problems? Recognizing that our response can strongly influence industry attitudes and willingness to be self critical, our enforcement policy does provide for discretion. Our ability and willingness to exercise discretion is dependent, however, on the timeliness and
11 effectiveness of licensee corrective actions for problems uncovered.
Licensee corrective action program records are not to be " mined" by inspectors for the purpose of identifying violations. However, challenges to corrective action program resolutions are l appropriate. Since licensee corrective action programs may arrive at incorrect or incomplete resolutions, inspectors will continue to review and question licensee conclusions.
It is anticipated that the NRC Enforcement Policy will be revised in the near future. With limited exceptions, Severity Level IV v olations will be identified as non-cited violations (NCVs) and not i require a response by the licensee or a formal closure by the NRC. This policy change, if implemented, would be based on the conclusion that corrective action programs developed by licensees have attained a level of proficiency sufficient to reliably evaluate and correct issues of this type. Confirmation of the integrity of licensee processes would be achieved through NRC inspections. Individual NCVs would be closed out based on evidence that the issue has been placed into the licensee's corrective action program. The corrective actions for each individual NCV will not be inspected. Instead, the focus would be on the overall effectiveness of the license A corrective action program. To this end, a sample of NCVs would be reviewed alongside similar licensee-identified problems to ensure that the licensee's disposition of these issues is adequate.
Additional Reactor Oversight Tasking: The Cornerstone Approach There is an ongoing effort to redefine what is called the NRC's Core Inspection Program. The program is being revised to what will be called the Baseline inspection Program and is intended to be more perf6/mance-based and risk-informed. The program is based on what are called cornerstones condsting of Initiating Events, Mitigating Systems, Barriers, Emergency Preparedness, Health Physics, and Security. Each cornerstone is assigned key attributes, or things that impact the comerstone. Each attribute is in turn evaluated by a combination of Performance Indicators (Pis) and Risk-Informed inspections (Rlls).
Where Pls are appropriate, licensee's would supply the data and would be expected to perform verification and validation to ensure thct it is accurate and meaningful. The NRC would also i
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12 perform verification of PI's on a sampling basis as past of its inspection effort. However, as is the case now, there would be additional NRC inspection effort outside of Pls and Riis. These would occur as Reactive Inspections if a threshold is " exceeded" or for certain events of such importance they would automatically get an inspection.
How does self-assessment fit in here? In addition to the inspection areas I just mentioned, there are certain " cross-cutting issues" which could be expected to require some special inspection effort, such as the corrective action program and licensee self-assessment effort.
Defining and implementing an effective problem identification and resolution (Pl&R) program is a key element underlying licensee pedormance in each and every cornerstone area.
The scope of Pl&R programs includes processes for self-assessment, root cause analysis, i
safety committees, operating experience feedback, and corrective action. Effective self-assessment directly affects the confidence that the NRC has in all of these elements.
Consequently self-assessment effectiveness, in part, will have an affect on the nature and depth of NRC inspections in the areas assessed.
As mentioned before, the NRC also has limited resources to accomplish it's inspection goals. It is hoped that efforts, such as these mentioned above, will help give us the flexibility to give credit for your self-assessment efforts where appropriate, reduce unnecessary burden or redundant efforts, and direct our inspection efforts where they can produce the most l meaningful results.
NRC Self Assessment and improvement initiatives I have covered several aspects and NRC insights of licensee self-assessment programs and now I would like to look at the NRC and discuss NRC internal self-assessment and l imptovement initiatives.
1 I In the broadest sense, the mission of the NRC remains the same today as when the Congress I created the NRC with the Energy Reorganization Act of 1974: that is, to ensure the protection of the public health and safety, the common defense and security, and the environment in the
13 civilian use of source, byproduct, and special nuclear materials. Periodically, however, the NRC has engaged in self-examination and reassessment of its regulatory functions-both as a stimulus for continued improvement and in response to changes in the industries we regulate.
The three years since the initiation of the NRC Strategic Assessment and Rebaselining effort in 1995 have been a time of self-evaluation, as we have prepared to realign our regulatory policies and programs in order to improve our own effectiveness and efficiency, as well as position the agency for changes in the regulated environment, such as those resulting from electric utility deregulation and restructuring.
With regard to the NRC's internal improvement initiatives, I will center on the plan we have developed for change, on the expected outcomes, and on questions yet before us to help minimize unnecessary iegulatory burden. I hope that you will be encouraged by the self I
assessment activities and resulting changes the NRC is undertaking.
1 Background '
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I As I previously mentioned and you all know, the NRC has been and continues to be the subject of a number of external reviews, some of them sharply critical, from the nuclear power industry, public interest groups, and the Congress. From the beginning, we have been open to these critiques as providing healthy feedback to us and to our processes. In synthesizing these j sometimes disparate forms of feedback and coupling them with our own self assessment activities, we felt it important to communicate clearly with our stakeholders to define and refine I the issues. Accordingly, on July 17, the Commission held what has been called our first "stakeholders" meeting. At that meeting, we heard from representatives of the nuclear power reactor community and the concerned public about issues important to them. A subsequent "stakeholders" meeting was held on November 13. It had an expanded number of participants to allow State participation and a larger representation of public interest groups. I believe both meetings were constructive and were useful to all in attendance. Industry participation remains vital. The Commission's intention is that these "stakeholders" meetings be held on a regular basis.
As i mentioned at the outset, on July 30, the Commission testified before the Senate
14 Subcommittee on Clean Air, Wetlands, Private Property, and Nuclear Safety to discuss NRC programs, and criticisms which had been made of the NRC by the nuclear power industry, the financial community, public interest groups, the Government Accounting Office, and the Senate.
The Senators probed wide-ranging areas of NRC involvement, and their questions and concerns were thought-provoking and reflective of nuclear power industry and public concerns.
Tasking Memo The stakeholder and Congressional perceptions can be aggregated into a number of areas:
predictabiliiy, objectivity, and timeliness of NRC decisions; the focuc of NRC activities; the quality of NRC-licensee interactions; the implementation of NRC programs; and the size of the NRC staff. On August 7, Chairman Jackson tasked the NRC Executive Director for Operations (EDO) with assembling, defining, and prioritizing items in these areas that support our long-term performance improvement goals and those that would receive near-term attention.
This " tasking memorandum" led to the development of the NRC plan and schedule for addressing areas of stakeholder concern, which we refer to as the " tasking memorandum" response. I hope that you have had an opportunity to review this document. I think you will find that it is broad in its scope, and that it covers individual items ranging from ensuring the efficiency and timeliness of processing license renewal and license transfer applications, and decommissioning decisions, to the development of risk-informed reactor regulations and a ncw performance assessment process for operating reactors. While the plan is broad in scope, we are emphasizing the importance of an integrated approach to improving our processes.
Changes to one process cannot be allowed to adversely impact dependent processes. An )
example of where we have taken a holistic approach and sought out the issues which crosscut programs is in the performance assessment, inspection and enforcement program changes currently being aeveloped. Each of these programs are clearly dependent on one another.
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In responding to stakeholder input, we found that a great deal of activity that addressed stakeholder concerns already was underway. In the course of developing our response to Chairman Jackson's tasking memorandum, we were able to prioritize existing tasks and to accelerate schedules in certain key areas. While stakeholder input definitely opened our eyes
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to a number of concerns (for example, the unnecessary burden associated with Severity Level i
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15 IV violations and inappropriate requests for additional information), it also allowed us to prioritize certain activities in ways that provided the best mutual benefits to ourselves, licensees, and the pubic. This highlights the importance of frequent and candid communications across every level of our respective organizations. I am confident that, as a result of our scif-assessment activities and our interactions with our stakeholders, we have developed a series of actions which will result in efficiencies for both the NRC, and its licensees, in a way that should enhance the level of safety afforded the public. We now are in the process of executing our plan and, through effective management attention to its milestones and the continued participation of all those affected by our actions, we will produce meaningful, tangible, perceptible results in the field.
In the area of reactor licensing and oversight, we are taking several actions to self examine our processes and address concerns expressed. Regarding regulatory process controls, we have adopted measures that internally challenge the need for each generic communication, to ensure that the licensee actions requested and responses required are commensurate with the safety significance of the issues involved. In addition, we have increased NRC management oversight of Confirmatory Action Letters, to ensure that proper controls are exercised in NRC staff confirmation and documentation of licensee commitments, and that licensees are not pressured into actions in excess of regulatory requirements. Regarding our focus on design basis information, the Commission has issued revised guidance to clarify the evaluation process for resolving degraded and nonconforming conditions, and we are committed to providing more flexibility for you to make facility changes without NRC approval (i.e., using 10 CFR 50.59). We will continue to work with you to bring clarity and a risk-informed approach to this and many other areas.
1 OUTCOMES Our focus in all of this is on outcomes, not outputs.
For the past three years, the NRC has been assessing systematically its programs and improving and streamlining its processes. From our Strategic Assessrnent and Rebaselining efforts beginning in 1995, in which we defined what the NRC does and how those activities are
4 16 aligned to our mission, to our current Program, Budgeting, and Performance Management
. (PBPM) process, which builds in accountability and self-assessment, we have rsSned the planning and execution of activities. Part of this improvement and streamlining has included the j development and revision of Standard Review Plans (SRPs) for many aspects of NRC review activities. These documents are " procedures" that direct NRC staff efforts in reviewing licensing submittals. The development of SRPs help improve and streamline NRC procest ?s by ensuring the proper review focus, establishing clear regulatory expectations that W h <!e to the public, and providing estimates of resource demands based on the level of regua.ory activity s described in the SRP. For example, SRPs play a pivotal role in keeping license renewal reviews focused, on track, and in-scope, and in the application of risk-informed methodologies in regulatory decision-making.
Other improvement and streamlining efforts under way by NRC include the use of outside j expertise (Arthur Andersen) to strengthen NRC skills in mapping certain key processes and I
identifying opportunities for efficiency, and effectiveness improvements. The agency started i
with the functions within the Office of Nuclear Reactor Regulation. Additionally, we have looked i into the organizational structure of the NRC and determined that certain changes are necessary. As a result, NRC has extended buyout offers to managers and supervisors with the intent to achieve an overall manager-to-employee ratio of 1:8.
i As our plan for change indicates, we have a great deal of work to do. While we have established controlled change as the order of the day, the NRC is, first and foremost, a health and safety regulator. Our desire to be responsive to our stakeholders cannot override our responsibility to ensure that public health and safety is maintained. As we pursue change, we remain mindful of the limited resources we have available to coordinate and to develop changes while simultaneously executing our public health and safety mandate. There still are inspections to perform, events to analyze, licensing actions to review, and, yes, enforcement cases to address.
One goal of changing our processes, programs, and regulations is to remove unnecessary burden from both NRC licensees and ourselves. We will achieve this goal through the application of risk-informed thinking and performance-based approaches. It is important to '
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understand that these concepts offer the possibilities of both relief and burden. Risk-informed approaches frequently identify situations in which safety can be enhanced, while producing
- regulatory relief, or in which relief can be allowed without a significant increase in risk. One such example of this is the recent approval of risk-informed emergency diesel generator extended allowed outage times. We are also pursuing other appropriate burden relief opportunities.
As we become more risk-informed, we may identify areas in which risk information dictates that
- additional regulatory controls be applied due to pre-existing, but as yet unidentified, risk contributors. If our regulatory structure is to be risk-informed to the extent allowable by the state of the art, you must accept this possibility. It is also the goal of the NRC to "let go" of that 2
which is not risk significant as we review licensing actions, assess licensee performance, conduct inspections, and take enforcement actions. We intend to reduce, to the extent possible, but certainly to clarify, the use of " regulatory significance" tactors in our decision-making, and to focus our attention on those areas which offer the greatest demonstrable safety payback.
As we, the NRC and our stakeholders, work through change, it is important for us to establish the standards by which we will measure our success. While timeliness is directly measurable, it 4
is not the only performance goal or area in which we intend to make progress. Funhor, focusing on the line items of our plan and ensuring we meet completion milestones is not I
enough. That will not show us the worth of what we have done, nor will it monitor our performance for signs of trouble. We must consider how to measure performance attributes such as clarity of expectations, objectivity, predictability, quality of product, quality of interface, and safety focus. These areas, while being central to recent criticisms of NRC, are not the only areas we intend to measure. We also need to consider other areas, such as streamlining NRC work processes, financial management, the use of information technology, and training.
SUMMARY
AND CONCLUSION in summary, both we at the NRC and you abug with your staffs should be striving to reach a goal of minimizing performance surprises at your plants. There is a strong nexus that exist ,
18 between your self-assessment activities and achieving this goal.
Whether we are talking about the nuclear industry's own self-assessment efforts or the NRC's efforts to see that they are effective, we are not just trying to count numbers of assessments.
We are looking for creativity - looking for areas where benefits can be greatest from a real safety / risk perspective. We are looking for the means of preventing problems - not just fixing existing ones. We are looking for an integrated pro-active approach that will make effective use of resources based on risk-informed and safety significance consideration to produce the best positive effect on safety.
Positive signs, certainly owing in part to your effective self-assessment efforts, can be seen. It is generally recognized that overall safety performance of the nuclear industry, as a whole, is good and improving. The challenge for the industry will be to maintain effective implementation where it has been achieved, and to continue to work to improve implementation where it has not. So while you should always celebrate your successes, your organizations still need to seek out weaknesses before they manifest themselves in erosion of safety margins.
For our part, we will continue to work to make our efforts more predictable and objective, and to give you the confidence that your efforts will be evaluated fairly in a performance-based and risk-informed environment. In closing, I would reiterate that this is a time of fundamental change for the NRC. I believe that change is a necessary and healthy endeavor for any organization and, to the extent the regulated community has helped us identify areas for NRC improvement, it has our gratitude. There is still much work to be done, but I hope we will be able to continue to work together, learning from our mutual experiences, to achieve these goals.
Thank you for your kind attention and I would be happy to address any questions you may have at the appropriate time.