ML20202H855
| ML20202H855 | |
| Person / Time | |
|---|---|
| Issue date: | 03/27/1986 |
| From: | Palladino N Office of Nuclear Reactor Regulation |
| To: | Bowsher C, Brooks J, Markey E, John Miller, Roth W, Simpson A, Udall M GENERAL ACCOUNTING OFFICE, HOUSE OF REP., ENERGY & COMMERCE, HOUSE OF REP., GOVERNMENT OPERATIONS, HOUSE OF REP., INTERIOR & INSULAR AFFAIRS, OFFICE OF MANAGEMENT & BUDGET, SENATE, ENVIRONMENT & PUBLIC WORKS, SENATE, GOVERNMENTAL AFFAIRS |
| References | |
| NUDOCS 8604150470 | |
| Download: ML20202H855 (25) | |
Text
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[c uc %c, UNITED STATES
- y t NUCLEAR REGULATORY COMMISSION
- ! WASHINGTON, D. C. 20555 e . ,1 h j?
- March 27, 1986 CHAIRMAN The Honorable William V. Roth, Jr.
Chairman, Committee on Governmental Affairs United States Senate Washington, D. C. 20510 i
Dear Mr. Chairman:
In accordance with the statutory obligation to respond to recommendations by the General Accounting Office (GA0) within 60 days of publication, we hereby submit our responses to the recommendations made by the GA0 in their report, " Oversight of Quality Assurance at Nuclear Power Plants Needs Imprevement."
The U.S. Nuclear Regulatory Commission (NRC) is pleased to note that GA0 recognized NRC's ongoing effort to explore ways to improve utility management and the agency's program to evaluate utility management's performance. The report recognizes that assessment of each utility's performance in operating its nuclear power stations will continue to play an important role in NRC's initiatives. Furthermore, GA0 stated in their report that "NRC's utility management-oriented approach is a prudent one..." and
"...that NRC's periodic assessments have provided the agency and the utilities with a useful perspective on utility management's performance in operating nuclear power plants."
Nevertheless, the GA0 report does contain useful recommendations for further improvements.
As reflected in the enclosed Responses to GA0 Recommendations, the staff agrees with the substance of each of the four recommendations made by GA0. While our responses, like the GA0 recommendations, focus on the Systematic Assessment of Licensee Performance (SALP) process, it is important to recognize that the NRC has other mechanisms and is instituting new initiatives for detecting and improving marginal plant performance. In responding to the recommendations, the Commission notes that improvements which. address GA0 findings in the assessment of utilities' performance had already begun. Completion of these initiatives are being given high priority by the NRC, and will result in more effective, efficient, and consistent oversight of quality assurance at nuclear power plants.
~
8604150470 860327 COMMS NRCC PDR CORRESPONDENCE PDR ,,
i Commissioner Asselstine adds the following:
The Commission has known for some time that the key to achieving quality in operations, maintenance and plant modifications at the operating plants lies with utility management. Your report points out that there have been 40 incidents since the Three Mile Island accident that have safety implications serious enough to be reported to the Congress. I believe that there is a common root cause for many of those incidents --
weaknesses in utility management. Most if not all people believe that the single greatest contributor to the core meltdown likelihood derives from the capabilities, commitments and attitudes of the utility management. Yet, this Agency takes a timid approach to
- this primary determinant of safety and waits for the occurrence of a serious operating event before it can find a justification to suggest that fundamental changes in management need to be made.
Some argue that management is not a strong suit of NRC and that we should, therefore, rely on the nuclear utilities to self-police their management capabilities.
The industry has been striving to achieve standards of excellence in performance for the last six years. The number and nature of the significant events occurring in 1985 suggest that for many this is still a distant goal and that some are still not achieving a standard of adequacy. If performance does not improve substantially in the near term, I believe the Congress should mandate that NRC develop an effective regulatory program governing utility management. In my view, until that happens, the NRC oversight of quality assurance at nuclear power plants will not be substantially improved.
Chairman Palladino adds the following:
The GA0 Report made four recommendations which would enhance the effectiveness of the NRC's program for periodically assessing the performance of utilities that operate nuclear power plants. The NRC agreed with all four of these recommendations.
Although Commissioner Asselstine's comment does'not address any of the GA0 recommendations or NRC's agreement with these recommendations, his thoughts have been reviewed. Contrary to Commissioner Asselstine's conclusion, the Commission believes that quality assurance at nuclear power plants has improved significantly over the last several years as documented in our 1985 report to Congress, " Improving Quality.and the Assurance of Quality iii the Design and Construction
of Nuclear Power Plants." Both the NRC quality assurance program and the industry's quality assurance actions emphasite the importance of nuclear safety.
This report further indicated .that the NRC did not recommend any changes to its authorizing legislation.
I continue to support the conclusions of this report.
Sincerely,
,.')-) -
')
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, c' ' }lfWf,b;cb.C-Nunzio J. Palladino
Enclosure:
Responses to GA0 Recommendations cc: Sen. Thomas Eagleton 1
1 d 'o UNITED STATES
. 8" -
t NUCLEAR REGULATORY COMMISSION h :. E WASHINGTON, D. C. 205S5 e-
% J CHA AN The Honorable Jack Brooks Chairman, Committee on Government Operations United States House of Representatives Washington, D. C. 20515
Dear Mr. Chairman:
In accordance with the statutory obligation to respond to recommendations by the General Accounting Office (GA0) within 60 days of publication, we hereby submit our responses to the recommendations made by the GA0 in their report, " Oversight of Quality Assurance at Nuclear Power Plants Needs Improvement."
The U.S. Nuclear Regulatory Commission (NRC) is pleased to note that GA0 recognized NRC's ongoing effort to explore ways to improve utility management and the agency's program to evaluate utility management's performance. The report recognizes that assessment of each utility's performance in operating its nuclear power stations will continue to play an important role in NRC's initiatives. Furthermore, GA0 stated in their report that "NRC's utility management-oriented approach is a prudent one...' and
"...that NRC's periodic assessments have provided the agency and the utilities with a useful perspective on utility management's performance in operating nuclear power plants."
Nevertheless, the GA0 report does contain useful recommendations for further improvements.
As reflected in the enclosed Responses to GA0 Recommendations, the staff agrees with the substance of each of the four recommendations made by GAO, While our responses, like the GA0 recommendations, focus on the Systematic Assessment of Licensee Performance (SALP) process, it is important to recognize that the NRC has.other mechanisms and is instituting new initiatives for detecting and improving marginal plant performance. In responding to the recommendations, the Commission notes that improvements which address GA0 findings in the assessment of utilities' performance had already begun. Completion of these initiatives are being given high priority by the NRC, and will result in more effective, efficient, and consistent oversight of quality assurance at nuclear power plants.
{
Commissioner Asselstine adds the following:
The Commission has known for some time that the key to achieving quality in operations, maintenance and plant modifications at the operating plants lies with utility management. Your report points out that there have been 40 incidents since the Three Mile Island accident that have safety implications serious enough to be reported to the Congress. I believe that there is a common root cause for many of those incidents --
weaknesses in utility management. Most if not all people believe that the single greatest contributor to the core meltdown likelihood derives from the capabilities, commitments and attitudes of the utility management. Yet, this Agency takes a timid approach to this primary determinant of safety and waits for the l
occurrence of a serious operating event before it can find a justification to suggest that fundamental changes in management need to be made.
Some argue that management is not a strong suit of NRC and that we should, therefore, rely on the nuclear utilities to self-police their management capabilities.
The industry has been striving to achieve standards of excellence in performance for the last six years. The number and nature of the significant events occurring in 1985 suggest that for many this is still a distant-goal and that some are still not achieving a standard of adequacy. If performance does-not improve substantially in the near term, I believe the Congress should mandate that NRC develop an effective regulatory program governing utility management. In my view, until that happens, the NRC oversight of quality assurance at nuclear power plants will not be substantially improved.
Chairman Palladino adds the following:
The GA0 Report made four recommendations which would enhance the effectiveness of the NRC's program for periodically assessing the performance of utilities that operate nuclear power plants. The NRC agreed with all four of these recommendations.
Although Commissioner Asselstine's comment does not address any of the GAO recommendations or NRC's agreement with these recommendations, his thoughts have been reviewed. Contrary to Commissioner Asselstine's c o n c'l u s i o n , the Commission believes that quality assurance at nuclear power plants has improved significantly over the last several years'as documented in our 1985 report to Congress, " Improving Quality and the Assurance of Quality in the Design and Construction
5 l
i of Nuclear Power Plants.". Both.the NRC quality ,
j assurance program and the industry's quality assurance ~
1 '
actions emphasize the importance of nuclear safety. '
This report further indicated that the NRC did-not recommend any-changes to its authorizing legislation.
! I continue to support the conclusions of this report.
L Sincerely,
.-},
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Nunzio . Pal adino i
Enclosure:
Responses to GA0 Recommendations I cc: Rep. Frank Horton I
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UNITED STATES NUCLEAR REGULATORY COMMISSION
. j .j WASHINGTON, D. C. 20555 o
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- i March 27, 1986 CHAIRMAN l
l The Honorable Alan Simpson Chairman, Subcommittee on Nuclear Regulation ,
Committee on Environment and Public Works !
United States Senate Washington, D. C. 20510
Dear Mr. Chairman:
In accordance with the statutory obligation to respond to j recommendations by the General Accounting Office (GA0) within 60 days of publication, we hereby submit our responses to the recommendations made by the GA0 in their l report, " Oversight of Quality Assurance at Nuclear Power Plants Needs Improvement."
The U.S. Nuclear Regulatory Commission (NRC) is pleased to '
note that GA0 recognized NRC's ongoing effort to explore ways to improve utility management and the agency's program !
to evaluate utili'ty management's performance. The report )
recognizes that assessment of each utility's performance in operating its nuclear power stations will continue to play 1 an important role in NRC's initiatives. Furthermore, GA0 i stated in their report that "NRC's utility management-oriented approach is a prudent one..." and i
"...that NRC's periodic assessments have provided the agency and the utilities with a useful perspective on utility management's performance in operating nuclear power plants."
Nevertheless, the GA0 report does contain useful recommendations for further improvements.
As reflected in the enclosed Responses to GA0 Recommendations, the staff agrees with the substance of each of the four recommendations made by GAO. While our responses, like the GA0 recommendations, focus on the Systematic Assessment of Licensee Performance (SALP) process, it is important to recognize that the NRC has other mechanisms and is instituting new initiatives for detecting and improving marginal plant performance. In responding to the recommendations, the Commission notes that improvements which address GA0 findings in the. assessment of utilities' performance had already begun. Completion of these initiatives are being given high priority by the NRC, and will result in more effective, efficient, and consistent-oversight of quality assurance at nuclear power plants.
Commissioner Asselstine adds the following: -
The Commission has known for some time that the key to achieving quality in operations, maintenance and plant mo.difications at the operating plants lies with utility management. Your report points out that there have been 40 incidents since the Three Mile Island accident that have safety implications serious enough to be reported to the Congress. I believe that there is a common root cause for many of those incidents --
weaknesses in utility management. Most if not all people believe that the single greatest contributor to the core meltdown likelihood derives from the capabilities, commitments and attitudes of the utility management. Yet, this Agency takes a timid approach to this primary determinant of safety and waits for the occurrence of a serious operating event before it can find a justification to suggest that fundamental changes in management need to be made.
Some argue that management is not a strong suit of NRC and that we should, therefore, rely on the nuclear utilities to self-police their management capabilities.
The industry has been striving to achieve standards of excellence in performance for the last six years. The number and nature of the significant events occurring in 1985 suggest that for many this is still a distant goal and that some are still not achieving a standard of adequacy. If performance does not improve substantially in the near term, I believe the Congress should mandate that NRC develop an effective regulatory program governing utility management. In my view, until that happens, the NRC oversight of quality assurance at nuclear power plants will not be 1 substantially improved.
Chairman Palladino adds the following:
The GA0 Report nade four recommendations which would enhance the effectiveness of the NRC's program for periodically assessing the performance of utilities that operate nuclear power plants. The NRC agreed with all four of these recommendations.
Although Commissioner Asselstine's comment does not address any of the GA0 recommendations or NRC's agreement with these recommendations, his thoughts have been reviewed. Contrary to Commissioner Asselstine's conclusion, the Commission believes-that quality assurance at nuclear power plants has improved significantly over the last several years as documented in our 1985 report to Congress, " Improving Quality and ,
the Assurance of Quality in the Design and Construction
l
, l of Nuclear Power Plants." Both the NRC quality i assurance program.and the industry's quality assurance l 3 . actions emphasize-the.importance of nuclear safety. l This report further indicated'that the NRC did not )
recommend any changes to its authorizing legislation.
I continue to support'the conclusions.of.this report.
c 1 Sincerely,
' '~
V',' : {. l< fl c
.s l L C h Nunzio . Palladino
Enclosure:
Responses to GA0 Recommendations
^
cc: Sen. Gary Hart 1
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gpurag[94g UNITED STATES NUCLEAR REGULATORY COMMISSION rn - E WASHINGTON, D. C. 20555 Y
%, . . . . . J CHAIRMAN March 27, 1986 The Honorable Morris K. Udall Chairman, Subcommittee on Energy and the Environment Committee on Interior and Insular Affairs United States House of Representatives Washington, D. C. 20515
Dear Mr. Chairman:
In accordance with the statutory obligation to respond to recommendations by the General Accounting Office (GAO) within 60 days of publication, we hereby submit our responses to the recommendations made by the GA0 in their report, " Oversight of Quality Assurance at Nuclear Power Plants Needs Improvement."
The U.S. Nuclear Regulatory Commission (NRC) is pleased to note that GA0 recognized NRC's ongoing effort to explore ways to improve utility management and the agency's program to evaluate utility management's performance. The report recognizes that assessment of each utility's performance in operating its nuclear power stations will continue to play an important role in NRC's initiatives. Furthermore, GA0 stated in their report that "NRC's utility management-oriented approach is a prudent one..." and
...that NRC's periodic assessments have provided the agency and the utilities with a useful perspective on utility management's performance in operating nuclear power plants."
Nevertheless, the GA0 report does contain useful recommendations for further improvements.
As reflected in the enclosed Responses to GA0 Recommendations, the staff agrees with the substance of each of the four recommendations made by GA0. While our responses, like the GA0 recommendations, focus on the Systematic Assessment of Licensee. Performance (SALP) process, it is important to recognize that.the NRC has other mechanisms and is instituting new initiatives for detecting and improving marginal plant performance. In responding to the recommendations, the Commission notes that improvements which address GA0 findings in the assessment of utilities' performance had already begun. Completion of these initiatives are being given high priority by the NRC, and-will result in more effective, efficient, and consistent oversight of quality assurance at nuclear power plants.
Commissioner Asselstine adds the following:
The Commission has known for some time that the key to achieving quality in operations, maintenance and plant modifications at the operating plants lies with utility ma'nagement. Your report points out that there have been 40 incidents since the Three Mile Island accident that have safety implications serious enough to be reported to the Congress. I believe that there is a common root cause for many of those incidents --
weaknesses in utility management. Most if not all people believe that the single greatest contributor to the core meltdown likelihood derives from the capabilities, commitments and attitudes of the utility management. Yet, this Agency takes a timid approach to this primary determinant of safety and waits for the occurrence of a serious operating event before it can find a justification to suggest that fundamental changes in management need to be made.
Some argue that management is not a strong suit of NRC and that we should, therefore, rely on the nuclear utilities to self-police their management capabilities.
The industry has been striving to achieve standards of excellence in performance for the last six years. The number and nature of the significant events occurring in 1985 suggest that for many this is still a distant goal and that some are still not achieving a standard of adequacy. If performance does not improve substantially in the near term, I believe the Congress should mandate that NRC develop an effective regulatory program governing utility management. In my view, until that happens, the NRC oversight of quality assurance at nuclear power plants will not be substantially improved.
Chairman Palladino adds the following- !
The GA0 Report nade four recommendations which would enhance the effectiveness of the NRC's program for periodically assessing the performance of utilities that operate nuclear power plants. The NRC agreed with all four of these recommendations.
Although Commissioner Asselstine's comment does not address any of the GA0 recommendations or NRC's agreement with these recommendations, his thoughts have been reviewed. Contrary to Commissioner Asselstine's conclusion, the Commission believes that quality assurance at nucleWr power plants has improved significantly over the last several years as documented in our 1985 report to Congress, " Improving Quality and the Assurance of Quality in the Design and Construction
. ~ . .
e l
! l
) i i of Nuclear Power Plants." Both the NRC quality assurance-program and the industry's quality assurance l actions emphasize the importance of nuclear safety.
This report further indicated that the NRC.did not recommend any changes to its authorizing legislation.
l I continue to support the conclusions of this report.
t Sincerely, a
I7fu*~w 7g 2/.'$/ c[ s.c Nunzio J. Palladino
Enclosure:
Responses to GA0 Recommendations cc: Rep. Manuel Lujan l
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555
- 7. j
,o CHAIRMAN March 27, 1986 1
The Honorable Edward J. Markey Chairman, Subcommittee on Energy Conservation and Power
! Committee on Energy and Commerce United States House of Representatives j Washington, D. C. 20515
Dear Mr. Chairman:
! In accordance with the statutory obligation to_ respond to 1
recommendations by.the General Accounting Office (GAO)
, within 60 days of publication, we hereby submit our
! responses to the recommendations made by'the GA0 in their l
~
report, " Oversight of Quality Assurance _at Nuclear Power.
Plants Needs Improvement."
4 The U.S. Nuclear Regulatory Commission (NRC) is pleased to i note that GAO recognized NRC's ongoing effort to explore j ways to improve utility management and the. agency's program l to evaluate utility management's performance. The report
- recognizes that assessment of each utility's performance in operating its nuclear power stations will continue to play 4
an important role in NRC's initiatives. Furthermore, GA0
- stated-in their report that "NRC's utility management-oriented approach-is.a prudent one..." and 1
...that NRC's periodic assessments have provided the agency i and the utilities with a useful perspective on utility management's performance in operating nuclear power plants."
Nevertheless, the GA0 report does contain useful recommendations for further improvements. .)
l As' reflected in the enclosed Responses to GA0
- Recommendations,.the staff agrees with the substance of each l of the four recommendations made by GA0. While-our i responses.-like the GA0 recommendations, focus.on the Systematic Assessment of Licensee. Performance:(SALP) j process, it is important to recognize'that the NRC has other j mechanisms and is instituting new initiatives for detecting
! and improving marginal plant performance. In responding to the recommendations, the Commission notes that improvements-1 -which address GA0 findings in the assessment of utilities' j -performance had already begun. Completion of these-1 initiatives are being given high priority by the NRC, and F will result in more effective, efficient, and consistent j oversight of quality _ assurance at; nuclear power plants.
1
. - __ _ . _ . _ _ . . _ _ _ , . _ . , _ . _ , _ . ~ .
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. Commissioner Asselstine adds the following:
The Commission has known for some time that the key to achieving quality in operations, maintenance and plant modifications at the operating plants lies with utility management. Your report points out that there have been 40 incidents since the Three Mile Island accident that have safety implications serious enough to be reported to the Congress. I believe that there is a common root cause for many of those incidents --
weaknesses in utility management. Most if not all people believe that the single greatest contributor to the core meltdown likelihood derives from the capabilities, commitments and attitudes of the utility management. Yet, this Agency takes a timid approach to this primary determinant of safety and waits for the occurrence of a serious operating event before it can find a justification to suggest that fundamental changes in management need to be made.
Some argue that management is not a strong suit of NRC and that we should, therefore, rely on the nuclear utilities to self-police their management capabilities.
The industry has been striving to achieve standards of excellence in performance for the last six years. The number and nature of the significant events occurring in 1985 suggest that for many this is still a distant goal and that some are still not achieving a standard of adequacy. If performance does not improve substantially in the near term, I believe the Congress should mandate that NRC develop an effective regulatory program governing utility management. In my view, until that happens, the NRC oversight of quality assurance at nuclear power plants will not be substantially improved.
l Chairman Palladino adds the following: ,
i The GA0 Report made four recommendations which would i enhance the effectiveness of the NRC's program for periodically assessing the performance of utilities that operate nuclear power plants. The NRC agreed with all four of these recommendations.
Although Commissioner Asselstine's comment does not address any of the GAC recommendations or NRC's agreement with these recommendations, his' thoughts have been reviewed. Contrary to Commissioner Asselstine's conclusion, the Commission believes that quality assurance at nuclear power plants has improved significantly over the last several years as documented
.in our 1985 report to Congress, " Improving Quality and the Assurance of Quality in the Design and Construction
i .
of Nuclear Power Plants." Both the NRC quality assurance progra'm and the industry's quality assurance actions. emphasize the importance of nuclear safety.
- This report'further indicated that-the NRC did not recommend any changes to its authorizing legislation.
I continue to support the conclusions of this report.
Sincerely, 1 i
-}
- - t L o el ~
7
')dh 7 : f[i .. . .
Nunzio . Pad adino
Enclosure:
i j
Responses to GA0 Recommendations l cc: Rep._Carlos Moorhead l
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___.___.___________..._._._____..__..____m____.__.____.._--_______.._______.__.___.______________.__.____...______m__._______.___-__i._______.__-____.__
pnUc v oq% UNITED STATES 8 ,q g NUCLEAR REGULATORY COMMISSION g WASHINGTON, D. C 205S5
- March 27, 1986 CHAIRMAN The Honorable Charles A. Bowsher Comptroller General of the United States General Accounting Office Washington, D. C. 20548
Dear Mr. Bowsher:
In accordance with the statutory obligation to respond to i
recommendations by the General Accounting Office (GA0) within 60 days of publication, we hereby submit our responses to the recommendations made by the GA0 in their report, " Oversight of Quality Assurance at Nuclear Power Plants Needs Improvement."
The U.S. Nuclear Regulatory Commission (NRC) is pleased to note that GA0 recognized NRC's ongoing effort to explore ways to improve utility management and the agency's program to evaluate utility management's performance. The report recognizes that assessment of each utility's performance in operating its nuclear power stations will continue to play an important role in NRC's initiatives. Furthermore, GA0 stated in their report that "NRC's utility management-oriented approach is a prudent one...".and
"...that NRC's periodic assessments have provided the agency and the utilities with a useful perspective on utility
- maragement's performance in operating nuclear power plants."
Nevertheless, the GA0 report does contain useful recommendations for further improvements.
As reflected in the enclosed Responses to GA0 Recommendations, the staff agrees with the substance of each of the four recommendations made by GA0. While our i responses, like the GA0 recommendations, focus on the Systematic Assessment of Licensee Performance (SALP)-
process, it is important to recognize that the NRC has other mechanisms and is instituting new initiatives for detecting and improving marginal plant performance. In responding to the recommendations, the Commission notes that improvements which address GA0 findings in the assessment of utilities' performance had already begun. Completion of these initiatives are being given high priority by the NRC, and will result in more effective, efficient, and censistent oversight of quality assurance at nuclear power plants.
Commissioner Asselstine adds the following:
The Commission has known for some time that the key to achieving quality in operations, maintenance and plant mo.difications at the operating plants lies with utility management. Your report points out.that there have been 40 incidents since the Three Mile Island accident that have safety implications serious enough to be reported to the Congress. I believe that there is a common root cause for many of those incidents --
weaknesses in utility management. Most if not all people believe that the single greatest contributor to the core meltdown likelihood derives from the capabilities, commitments and attitudes of the utility management. Yet, this Agency takes a timid approach to this primary determinant of safety and waits for the occurrence of a serious operating event before it can find a justification to suggest that fundamental changes in management need to be made.
Some argue that management is not a strong suit of NRC and that we should, therefore, rely on the nuclear utilities to self-police their management capabilities.
The industry has been striving to achieve standards of excellence in performance for the last six years. The number and nature of the significant events occurring in 1985 suggest that for many this is still a distant goal and that some are still not achieving a standard i of adequacy. If performance does not improve substantially in the near term, I believe the Congress should mandate-that NRC develop an effective regulatory program governing utility management. In my view, j until that happens, the NRC oversight of quality ,
assurance at nuclear power plants will not be substantially improved.
Chairman Palladino adds the following:
The GA0 Report made four recommendations which would enhance the effectiveness of the NRC's program for l periodically assessing the performance of utilities that operate nuclear power plants. The NRC agreed with all four of these recommendations.
Although Commissioner Asselstine's comment does not address any of the GA0 recommendations.or NRC's agreement with these recommendations, his thoughts have been reviewed. Contrary to Commissioner Asselstine's conclusion, the Commission believes that quality assurance at nuclear power plants has improved significantly over the last several years as documented in our 1985 report to Congress, " Improving Quality and the Assurance of Quality in the Design and Construction-
of Nuclear Power Plants." Both the.NRC quality assurance program and the industry's quality assurance.
actions emphasize the importance of nuclear safety.
! This report further indicated that'the NRC did not recommend any changes to its authorizing legislation.
- I continue to support the conclusions of this report.
Sincerely, s ')g tc
) . ,
c(((, a l.~~
$ t. t v t.
e
?
Nunzio J' Palladino
Enclosure:
l Responses to GA0 Recommendations i
1 1
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jP o UNITED STATES y"' i NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 23555 1
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- March 27, 1986 CHAIRMAN The Honorable James C. Miller III Director, Office of Management and Budget Washington, D. C. 20503
Dear Mr. Miller:
In accordance with the statutory obligation to respond to recommendations by the General Accounting Office (GA0) within 60 days of publication, we hereby submit our responses to the recommendations made by the GA0 in their report, " Oversight of Quality Assurance at Nuclear Power Plants Needs Improvement."
The U.S. Nuclear Regulatory Commission (NRC) is pleased to note that GA0 recognized NRC's ongoing effort to explore ways to improve utility management and the agency's program to evaluate utility management's performance. The report recognizes that assessment of each utility's performance in operating its nuclear power stations will continue to play an important role in NRC's initiatives. Furthermore, GA0 stated in their report that "NRC's utility management-oriented approach is a prudent one..." and
"...that NRC's ' periodic assessments have provided the agency and the utilities with a useful perspective on utility management's performance in operating nuclear power plants."
Nevertheless, the GA0 report does contain useful recommendations for further improvements.
As reflected in the enclosed Responses to GA0 Recommendations, the staff agrees with the substance of each of the four recommendations made by GA0. While our responses, like the GA0 recommendations, focus on the Systematic Assessment of Licensee Performance (SALP) process, it is important to recognize that the NRC has other mechanisms and is instituting new initiatives for detecting and improving marginal plant performance. In responding to the recommendations, the Commission notes that improvements which address GA0 findings in the assessment of utilities' performance had already begun. Completion of these initiatives are being given high priority by the NRC, and will result in more effective, efficient, and consistent oversight of quality assurance at nuclear power plants.
P Commissioner Asselstine adds the following:
The Commission has known for some time that the key to achieving quality in operations, maintenance and plant modifications at the operating plants lies with utility management. Your report points out that there have been 40 incidents since the Three Mile Island accident that have safety implications serious enough to be reported to the Congress. I believe that there is a
> common root cause for many of those incidents --
weaknesses in utility management. Most if not all people believe that the single greatest contributor to the core meltdown likelihood derives from the capabilities, commitments and attitudes of the utility management. Yet, this Agency takes a timid approach to this primary determinant of safety and waits for the occurrence of a serious operating event before it can find a justification to suggest that fundamental changes in management need to be made.
Some argue thct management is not a strong suit of NRC and that we should, therefore, rely on the nuclear utilities to self-police their management capabilities.
The industry has been striving to achieve standards of excellence in performance for the last six years. The number and nature of the significant events occurring j in 1985 suggest that for many this is still a distant goal and that some are still not achieving a standard )
of adequacy. If performance does not improve substantially in the near term, I believe the Congress shculd mandate that URC develop an effective regulatory program governing utility managecent. In my view, until that happens, the NRC cversight of quality assurance at nuclear power plants will not be ;
substantially improved. i Chairman Palladino adds the following:
The GA0 Report made four recommendations which would enhance the effectiveness of the NRC's program ter periodically assessing the performance of utilities '
that operate nuclear power plants. The NRC agreed with all four of these recommendations.
Although Commissioner Asselstine's comment does not address any of the GA0 recommendations or NRC's agreement with these recommendations, his thoughts have I
been reviewed. Contrary to Commissioner Asselstine's conclusion, the Commission believes that quality assurance at nuclear power plants has improved significantly over the last several years as documented in our 1985 report to Congress, " Improving Quality and the Assurance of Quality in the Design and Construction
of Nuclear Power Plants." Both the NRC quality assurance program and the industry's quality assurance actions emphasize the importance of nuclear safety.
This report further indicated that the NRC did not recommend any changes to its authorizing legislation.
I continue to support the conclusions of this report.
Sincerely, 9/ 1).,
/ ,l n ' sa
' l g (,(,.,( .
Nunzio J. Pal- adino
Enclosure:
Responses to GA0 Recommendations
7 RESPONSE TO GA0 RECOMMENDATIONS The GA0 report states that implementing the following recommendations would enhance the effectiveness of NRC's program for periodically assessing the performance of utilities that operate nuclear power plants.
- 1. GA0 Recommendation:
Establish assessment-related criteria that, when met, would require the agency to either mandate a utility management improvement program or document the reasons why such a program is not warranted.
NRC Response:
We agree with the recommendation regarding the establishment of uniform criteria for agency actions to be taken when the NRC's Systematic i
Assessment of Licensee Performance (SALP) evaluations indicate that improvement programs may be necessary. However, it should be noted that :
SALP evaluations, which cover a reactor operating period of up to 1 18 months, are not meant to be the only method for identifying the need for regulatory improvements and initiating appropriate staff actions.
Separate frcm the SALP program, the established, formal NRC enforcement policy promotes uniform and prompt agency actions in dealing with 1 significant, specific or programmatic facility problems as they occur. The NRC's enforcement policy includes criteria for uniformly determining the appropriate level of enforcement action. Nevertheless, the SALP process is ven useful in the identification and articulation of emerging or continuing nuclear safety performance problems. It is in this area that NRC believes development of unifonn criteria for agency follow-on actions is needed. On December 12, 1985, the Director, Office of Inspection and Enforcement, distributed a draft approach for staff actions to be taken based upon SALP evaluation results. Following the resolution of comments and sugge:tions by the Regional Offices and Headquarters Program Offices, formal guidance will be issued for implementation. We expect to complete this process in July 1986.
- 2. GA0 Recommendation:
Routinely analyze historical assessment results and discuss marginal and declining performance trends in individual assessment reports.
NRC Response:
NRC agrees with this recommendation. On November 5,1985, the Director, 4
Office of Inspection and Enforcement, issued for implementation an interim revision to the SALP Manual Chapter (NRC 0516). This revision provides for SALP reports to include an appraisal of the licensee's performance trend in those functional areas where: (1) a definite trend of performance is discernible, and (2) continuation of the trend may result Enclosure 1
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in a change in performance level. Also, the analysis section for each functional area evaluated is to contain a brief sumary of the previous
, evaluation, if there has been a significant change or if there should have l been a sienificant improvement, but there was not.
l Additionally, a computerized SALP Management Summary System has been established to provide summary and detailed SALP information to Region and Headquarters offices on a periodic basis. Management decision information and tracking informat. ion can be developed with the aid of this system, which incorporates several search and sort capabilities. Each report contains a SALP Summary Report for each Region and a SALP History Report for each operating facility. The SALP History Report shows the results of all SALPs completed at a given facility since the date that SALPs were first implemented.
- 3. GA0 Recommendation:
Expand the information considered in periodic assessments to include
- readily available data on trends in nuclear power plant operating I performance.
NRC Response: )
NRC agrees with this recommendation insofar as the data has relevance to nuclear safety. The GA0 report states that " capacity and availability factors, inservice hours, and other measures of a utility's commercial activity are programmatic ' bottom line' indicators of companies' strengths and weaknesses operating these facilities." NRC, however, is cautious in the use of commercial or economic indicators in measuring a licensee's operational nuclear safety performance. For example, it can be postulated that emphasis by NRC on economic indicators as a performance standard l mioht be adverse to safety. Licensees could be motivated to keep a plant
! operating when circumstances indicate a safer action would be to shutdown, reduce power, or delay a return to operations following an outage.
Notwithstanding the above, the NRC does agree that indicators of plant
! nuclear safety performance can and should be more extensively used in the l regulatory prccess. The following actions are already in progress within l the NRC to identify and utilize safety-related performance indicators:
The Office for Analysis and Evaluation of Operational Data is assessing the operating performance of U.S. nuclear power plants i licensed since 1982. Reportable events are being identified and cataloged from computerized reactor event data bases, such as i
10 CFR 50.72 submittals, Licensee Event Reports, periodic summary reports of operating reactors, Nuclear Plant Reliability Data System l information, etc. The initial effort is focused on the l identification of valid, accessible performance measures.
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1 The Office of Inspection and Enforcement has developed a program of scree.ning and evaluating operating reactor events to identify generic problems, to assess trends in. plant safety performance, and to, identify problem plants and areas requiring improvements within the plants. The 50.72 and regional morning reports are screened and .
evaluated on a daily basis to determine the generic implicit. ions of events and to determine the need for any additional actionion the plant having an event.
In addition to reviewing specific events, IE/EAB analyzes events-for
, trends indicating changes in plant performance that may not have been apparent during the short-term event screening or indepth investigation into an event. For this type of analysis, significant events and the associated basic causes or areas, of weaknesses are identified through a systematic review of documents such as 50.72, 50.73, Part 21, 50.55(e), regional morning and inspection reports, preliminary notifications, enforcement actions, and NPPOS. The significant events include scrams, ESF actuations, and safety system or component failures. The basic causes' or areas ~of weaknesses include design, installation, random equipment failure, fabrication / manufacturing, procedure, maintenance, personnel error, and administrative controls.
The Office of Nuclear Regulatory Research is evaluating the effectiveness of reliability program elements applicable to the safety of operating reactors and is identifying the attributes of successful reliability programs through case studies and trial use.
This research may' provide a methodology for developing a. quantitative measure of nuclear power plant safety performance.
The Office of Nuclear Reactor Regulation (NRR) is developing nuclear power plant maintenance performance indicators. Additionally, NRR collects and evaluates data on the frequency of occurrence of certain events, such as reactor trips, on an individual plant basis. This data is periodically published and distributed to Regional Administrators.
In November 1985, the Executive Director for Operations requested the staff to develop an integration plan for the agency's development and use of performance indicators. That effort has begun. -During the next several months, the staff-will concentrate on the selection of appropriate indicators which can be incorporated into the SALP evaluation process in the key areas of plant operations and maintenance. It is expected that -the staff will give a high priority to this important subject over the next 12 months.
- 4. GA0 Recommendation:
Include in the agency's assessment deliberations on a utility's quality.
program and administrative controls performance the results of.its asseysments in.the other nine technical. areas. p .
y ,
9 NRC Response:
NRC agrees with this recommendation. As identified in the GA0 report, Quality Programs and Administrative Controls Affecting Quality was added as a distinct, required SALP functional area beginning in March 1984.
Prior to this date, the topic was addressed as an evaluation criterion for each functional area. The scope of this new functional area was intended to be broad, encompassing a comprehensive management control system for oversight of the quality of work performed, as well as the quality of verification activities that confirm the work was performed correctly. As discussed in the GA0 report, some Regions have assessed utility performance in the quality area on the basis of the results of quality assurance-related inspections. The scope of these evaluations was narrower than was intended. This probably occurred for several reasons.
First, the functional area was new and some differences were anticipated in the transition to addressing it as a separate topic. Second, while there are specific inspection procedures addressing quality assurance, there are no distinct procedures that address the broad topic of Quality Programs and Administrative Controls Affectino Quality. Finally, there were concerns for overlap in assessment which would result in duplication of report preparation and holding licensees doubly accountable for the same issue. While progress has been made in clarifying the approach to assessments of the Quality Programs and Administrative Controls Affecting Quality area, additional clarification is needed. The Office of Inspection and Enforcement plans to prepare and issue additional clarification on regional assessment of this functional area by July 1986.
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