ML20199L333
| ML20199L333 | |
| Person / Time | |
|---|---|
| Issue date: | 11/19/1997 |
| From: | Gamberoni NRC (Affiliation Not Assigned) |
| To: | NRC (Affiliation Not Assigned) |
| References | |
| PROJECT-689 NUDOCS 9712010379 | |
| Download: ML20199L333 (24) | |
Text
f sk'88809k UNITED 57ATES p*'
NUCLEAR REGULATORY COMMISSION g
l WASHINGTON, D.C. 30066 0001 p
November 19, 1997 i
g MEMORANDUM T0:
File G
'I 4 Q FROM:
David Louis Gamberoni Inspection Program Branc,
/
Division of Inspection and port Programs Office of Nuclear Reactor Regulation
SUBJECT:
PUBLIC MEETING ON INTEGRATED REVIEW 0F ASSESSMENT On Novemter 6. 1997, the NRC staff held a public meeting to discuss improvements to current NRC performance assessment processes and the Integrated Review of Assessment (IRA). Attachment 1 is a list of the meeting attendees. Attachment 2 is a copy of the NRC handout that was used in the meetirg. Attachment 3 is a copy of a Nuclear Energy Institute handout that was used in the meeting.
The staff made brief presentations that addressed:
(1) the information base for the senior management meeting (SMM)
(2) improvements to the SMM process, and (3) the Integrated Review of Assessment.
Following the staff presentations, the Los Alamos National Laboratory contractor facilitated a comment period. Comments from the public and industry included:
The trend models do nc. include scrams, significant events, and safety e
system actuations. These performance indicators are tied closely to safety. A trend model (if used) should be based on public health and safety.
Plants are unique and can not be graded on a single scale or against each other.
Eliminate the SALP program and Watch List because they provide no
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meaningful information.
I o
Alternatively, (if necessary) consider annual presentations, to the Commission that describe safety performance for each plant in a region N' g/m and the NRC's regulatory priorities.
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e Match SALP functional areas (if retained) to template categories.
e Economic indicators should not be used because they can not discriminate between a plant that is cutting corners and one that is improving productivity.
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The trend models are event driven and are not useful.
They are inconsisteQt with Commission staff requirements memoranda.
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g Develop performance expectations for each area that have a direct e
relationship to public health and safety. Objective indicators should be defined for determining the degree to W11ch performance expectations are being met, o
Assessments should be accurate, timely and objective.
e-Assessments should be tied to public health and safety and focus on specific safety issues.
e_
.SALP assessments are untimely. The Watch List is untimely, misleads the public, and is open to political pressures.
.o-The Watch List results in unfair treatment of licensees because there is no licensee response and no opportunity for hearing.
e Allegations should not be used for performance assessment because it could result in less allegations being raised, e
If a new assessment process is put in place it is very important to communicate the new process to the public.
The staff invited the attendees to provide written coments. The Integrated Review Team will consider the comments received at the meeting and any written comments that are received.
Attachments:
1.
List of Attendees
- 2. 'NRC Handout 3.
Nuclear Energy Institute HandoA cc w/att: See next page Distribution:
Central files PUBLIC
-Project?No,-689 PIPB R/F RBorchardt MMalloy DOCUMENT NAME:
P:\\ MEMO. IRA To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure "N" = No copy-OttICE PIPB: DISP tsi 16 PIPB: DISP lF l
l NAME DLGamberonim' MRJohnson YJ pd DATE 11//7 /97 11// 9/97 0FFICIAL REC]RD COPY
_____y l
Meetina Sumary on Intearated Review of Assessment dated November 19 1997-Mr. Ralph Beedle Ms. Lynnette Hendricks. Director.
Senior Vice President Plant Su) port and Chief Nuclear Officer Nuclear Energy In'stitute Nuclear Energy-Institute Suite 400 Suite 400 1776 I Street. NW i
1776 1 Street. NW Washington..DC 20006 3708 i'
Washington. DC 20006-3708 Mr. Alex Harion. Director-Programs Nuclear Energy Institute f
Suite 400 l
1776 i Street. NW-l Washington. DC 20006-3708-Mr. David Modeen. Director-Engineering -
Nuclear Energy Institute-Suite 400 1776 I Street. NW Washington. DC 20006 3708-Mr. Anthony Pietrangelo. Director Licensing Nuclear Energy Institute-Suite 400 1776 1 Street. NW Washington, DC 20006 3708 Mr. Nicholas J. Liparulo. Manager i
Nuclear Safety and Regulatory Activities Nuclear and Advanced Technology Division Westinghouse Electric Corporation P.O. Box.355-Pittsburgh Pennsylvania 15230 Mr. Jim Davis. Director:
Operations Nuclear Energy Institute Suite 400 1776 ILStreet. NW Washington, DC 20006-3708 i
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Integrated Review of Assessment Public Heeting November 6, 1997-q HEDe Oraanization-Bill Borchardt NRC/NRR/PIPB Mike Johnson NRC/NRR/PIPB David Gamberoni NRC/NRR/PIPB Tim Frye NRC/NRR/PIPB Bill Dean NRC/0E00 Glenn Tracy NRC/0E00-Gail Marcus NRC/NRR/ORPW Bi'l Reckley NRC/NRR/ORPW Helinda Malloy-NRC/0 RPM /PGEB 1
Larry Nicholson NRC/ Region I Mark Lesser NRC/ Region 11 Michael Parker NRC/ Region-III Bill Johnson NRC/ Region IV Ernie Rossi NRC/AEOD Alan Madison NRC/AE0D Peter Prescott NRC/AE00
-Jose Ibarra NRC/AE00 Joel Kramer NRC/RES Heidi Hahn Los Alamos National Laboratory Pamela U11barri Los Alamos National Laboratory Steve Floyd Nuclear Energy Institute Herb Fontecilla Virginia Power David Lochbaum Union of Concerned Scientists John Matthews Morgan, Lewis, and Bockius LLP Deann Raleigh SERCH David Ste11 fox McGraw Hill M. Straka NUS Info Services t
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j PUBLIC MEETING. PRESENTATION ON IMPROVEMENTS TO N1tC PERFORMANCE ASSESSMENT PROCESSES i
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i NOVEMBER 6, 1997 I
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l o Information base for the senior managemwint neeeting I
o Imiprovennents to the SMK process i
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I o Integrated Review of Assessment Processes l
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OSJECTIVE - CONSISTENT - LEADING - SCRUTABLE i
THE COMMISSION HAS INITIATED A COMPREHENSIVE REVIEW OF THE SENIOR MANAGEMENT MEETING PROCESS i
l A SERIES OF STAFF REQUIREMENTS MEMORANDA HAVE CALLED FOR INDICATORS.
THAT:
i "CAN PROVIDE A BASIS FOR JUDGING WHETHER A PLANT SHOULD BE PLACED ON OR REMOVED FROM THE WATCH LIST,"
ARE " OBJECTIVE, MEANINGFUL AND LEADING,"
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" REDUCE RELIAMCE ON EVENT-DRIVEN ASSESSMENTS,"
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" ESTABLISH (ES) AN UNDERSTANDABLE LEVEL OF PERFORMANCE EXPECTATION,"
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" IDENTIFY FACILITIES IN A CONSISTENT MANNER."
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1 1
IMPLEMENTATION PLAN
- o Template
- Indicators and measures 1
- Criteria for watch list planto i
o Trending Methodology
- Criteria for discussion plants
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' o Economic Indicators l
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L PERFORMANCE ASSESSMENT INFORMATION Information Objective Assessment Sources Data M
Perforriance Performance 188m TWde Event Reports l
Allegations l
Investigations Performance Performance i
Enforcement Indicators Trends i'
Actions Reliability Data Monthly Operating Economic Economic Reports Indicators Trends i
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PLANT PERFORMANCE TEMPLATE i
1 Operational Performance (Frequency of Transients) lA' Normal Operations 1B Operations During Transients lc Programs & Processes 2 Material Condition (Safety System Reliability / Availability)
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2A Equipstent Condition 2B Programs & Processes 3 Human Performance i
3A Work Performance 4B Knowledges/ Skills / Abilities 3C Work Environment 4 Engineering and Design i
4A Design 4B Engineering Support 4C Programs & Processes l
l 5 Problem Identification & Resolution l
f 5A Identification 5B Analysis 5C Resolution l
l 6 Organizational Effectiveness
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TEMPLATE INPUT MEASURES i
l o Multiple sources of " issues"
- Start with regional Plant Issues Matrix (PIM) i
- Safety significant LERs, Significant events, AGPs
- Escalated enforcement and civil penalties F
- Substantiated allegations and investigation findings I
o Issues evaluated by appropriate staff based on guidance from_HQ.
- Merge redundant issues
- Assign risk significance (high/ medium / low)'
- Map issues to template subcategories i
o Headquarters audit of implementation
l PLANT 103 PERFORMANCE TREND MODEL (6-QTR) e 6-7tweehokt l
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192 292 392 492 193 293 393 493 194 294 394 494 195 295 395 495 196 296 396 496 Forced Outage Rote (percent)
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ECONOMIC VARIABLE TRENDS: MULTI. UNIT FACILITY -
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80 40 20-0 1991 1982 1993 1964 1996 1996 1997 coermMmm covsmos a0 7
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ASSESSMENT PROCESS DECISION PROCESS i
Template Issues Cats.
Integrated hision Remedial Subcats.
Performance Indicators Factors Actions Model 5
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. INTEGRATED REVIEW OF THE NRC ASSESSMENT PROCESS FOR OPERATING i
COMMERCIAL NUCLEAR REACTORS i
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1 la OVERVIEW OF CURRENT ASSESSMENT l
PROCESSES SYSTEMATIC ASSESSMENT OF LICENSEE l
PERFORMANCE (SALP) l
- Implemented in 1980 following TMI event l
- Allowed for a systematic, long-term, integrated evaluation of overalllicensee performance SENIOR MANAGEMENT MEETING (SMM)
- First implemented in April 1986 following the 1985
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Davis-Besse loss-of-feedwater event
- SMM developed to bring to the attention of the highest l
levels of NRC management those plants whose performance was of most concern
- Process developed so that the primary focus of the SMM l
Is on operational safety
- Allowed senior NRC managers to plan a coordinated
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course of action l
4
i OVERVIEW OF CURRENT ASSESSMENT PROCESSES (Continued)
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o PLANT PERFORMANCE REVIEW (PPR)
- Initial process implemented in October 1990 as a t
quarterly activity i
- Developed to provide mid-course adjustments in inspection focus in response to changes in licensee performance &
emerging plant issues
- A major emphasis to improve the PPR process occurred following the South Texas Lessons Learned Task Force o
PLANT ISSUES MATRIX (PIM)
)
- Implemented across the regions in Spring 1996 l
- Developed as part of the effort to improve the integration of inspection findings following the South Texas Lessons Learned Task Force
- Provides an index of the primary issues that are evaluated during the PPR, SALP and SMM processes.
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(+) STRENGTHS /(-) WEAKNESSES OF CURRENT ASSESSMENT PROCESSES i
i PPR
- (+)PPR piviides short term, integrated assessments and is effective at identifying leading indicators of ci enge in performance
- (-)PPR is not as effective at identifying long term
- rends and recurring issues e
- (+) Periodic, integrated reviews of licensee performance over an extended time period are effective at identifying long term trends
- (-)Due to a lomj assessment period, the SALP process is backward looking and provides lagging indicators of licensee performance l
l
- (+)SALP process cotesviizes licensee performance so that relative f
performance between plants can be measured j
- (-)SALP scores are not clearty defined, not well understood by the public, and often misused by the public, financial institutions and industry i
i j
i
(+) STRENGTHS /(-) WEAKNESSES OF CURRENT i
ASSESSMENT PROCESSES (Continued) j SMM
-- (+)SMM provides for a coordinated agency position for both declining and superior performance
- (-)Significant administrative requirements placed on staff and
)
senior managers in preparing for and participating in SMMs l
- (+)SMM process effective at highlighting agency concern to l
licensees. Plant performance often increases follouring Watchlist l
designation and issuance of trending letters i
GENERAL l
- (-)Many assessment processes are redundant and have similar end products
- (-) Assessment criteria differs between processes such as the SALP and SMM l
- (-)Piucesses have potential for inconsistent impt.i.e itmi;cn
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among the regions j
- (-) Processes have gone through many changes and require more i
resources for implementation than originally intended
4 SUCCESS CRITERIA FOR INTEGRATED REVIEW 4
ATTRIBUTES TO MAXIiWIIZE
- Single assessment process. Early identification of dactining i
licensee performance. Ability to detect long term trends and recurring events
- Staff job assignments for critical assessment activities well defined
- Open dialogue of assessment results with the industry and public ATTRIBUTES TO MINIMIZE
- Inconsistent assessment criteria between different steps of the process
(
- Overlapping responsibilities among staff. Excessive administrative requirements to implement the process
- Latitude among regions /HQ in impt.T.;i.ii.g the process
-- Opportunities for conflicting messages on performance
BOUNDARY CONDITIONS FOR INTEGRATED REVIEW
- Not tied to the " Status Quo" of any existing processes i
e The inspection program and enforcement policy are j
not included in this review e Performance of all plants categorized e Public interaction and opportunity for licensees j
i to respond j
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INTEGRATED REVIEW ASSESSMENT 1
e PROCESS
- A series of meetings will be held with active participation from all regions and several program offices SCHEDULE i
- March 1998-integrated Review and Assessment Results
~
Finalized
- May 1998-PublicAndustry Comments Received and Reviewed
- June 1998-Implementation Plan Developed l
l
- June 1998-Commission Briefing For Approval of Process and Implementation
- July 1998-Commission Approval For Process implementation j
- December 1998-Implementation of New Aasessment Process i
J s
l SCHEDULE /. MILESTONES o PUBLIC COMMENT PERIOD AND WORKSHOP FOR BOTH PROJECTS:
SPRING, 1998 i
o RECOMMENDATION FOR COMMISSION DECISION:
SUMMER, 1998 o IMPLEMENTATION:
END OF CALENDAR YEAR 1998
- REVISION TO MANAGEMENT DIEECTIVE 8.14 2 -
i i
-DRAFT Guidina Princiales for Performine Safety Assessments
- 1. The objectives of the assessment activity should be clearly defined.
- 2. = Performance expectations should be well de6ned and be clear and undarstandable for each assessment area.
- 3. Performance expectations should have a direct relationship to public health and safety.
- 4. Objective indicators should be defined for determining the degree to which performance expectations are being met. Attributes of appropriate indicators are:
direct relationship between the indicator and safety e
necessary data should be available or capable of being generated e
able to be expressed in quantitative terms e
unambiguous e
meaningful e
significance should be understood j
e not susceptible to manipulation e
able to be validated e
- 5. Assessment findings should be supported by the direct measurement of the performance indicators.
- 6. Assessment findings should be scrutable and repeatable.
8 Attadmmt 3
.