ML20209B229
| ML20209B229 | |
| Person / Time | |
|---|---|
| Issue date: | 05/14/1999 |
| From: | Merrifield J NRC COMMISSION (OCM) |
| To: | Vietticook A NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20209B181 | List: |
| References | |
| SECY-99-024-C, SECY-99-24-C, NUDOCS 9907060307 | |
| Download: ML20209B229 (2) | |
Text
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NOTATION VOTE RESPONSE SHEET TO:
Annette Vietti-Cook, Secretary FROM:
. COMMISSIONER MERRIFIELD
SUBJECT:
SECY-99-024 - RECOMMENDATIONS OF THE SAFEGUARDS PERFORMANCE ASSESSMENT TASK FORCE (WITS 199800188)
Approved x
Disapproved Abstain Not Participating COMMENTS:
I am supplementing my initial vote of February 9,1999 with the attached comment!
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May.14, 1999 DATE Entered on "AS" Yes X
No 7 F #8:23 2 8e*'
CORRESPONDENCE PDR
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Commissioner Merrifield's comments:
On February 9,1999, I voted to approve with comments the recommendations of SECY-99-024 (Recommendations of the Safeguards Performance Assessment Task Force). Since that date, a differing professional opinion was submitted on February 12,1999, a closed Commission j
meeting on the Design Basis Threat was held on March 18,1999, and an open meeting on Safeguards Performance Assessment was held on May 5,1999. Given this new information, I believe it is appropriate to supplement my initial vote. At the outset, I want to commend the staff who provided their differing professional views / opinions (DPVs/DPOs) as part of this review process as well as the staff who developed the revised program while considering the DPVs/DPOs. I believe the final product, which is an Mtline for a new safeguards assessment program, has been greatly improved as a res alt of this interaction.
The comments in my initial vote are still valid. However, in the ensuing months, the staff has gone to considerable lengths to address my concerns and, as expressed at the Commission meeting, the concerns expressed in the DPV. I approve the staff's plan, as outlined in more detail during the May 5,1999 open Commission briefing, to use the remaining Operational Reactor Safeguards Examinations (OSREs) to pilot concepts for a revised safeguards performance assessment program. One key element of the revised assessment program is better integration of safeguards and operational activities so that risk informed performance based decisions can be made. Another key element of the revised program is that drills and exercises will be conducted more frequently by the licensees and periodically observed by appropriate NRC staff and contractors. At the May 5,1999 Commission meeting, the Commission emphasized the importance of continuing to have the NRC observe some portion of the drills and exercises to be required under the future safeguards performance assessment program In the upcoming staff proposal on the baseline reactor inspection program, the staff should include a specific recommendation on the baseline frequency of NRC inspector observation of these drills and exercises.
In SECY-99-024, the staff has proposed specific rulemaking to require periodic drills. As stated above, the staff will be piloting various concepts of the revised assessment program in the last 10 remaining OSREs. I expect the staff to consider and propose, as appropriate, any additional rulemaking (beyond the rulemaking proposed in SECY-99-024) identified as a result of the pilot program.
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UNITED STATES A
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g WASHINGTON, D.C. 20555-0001
[8 0So June 29, 1999 SECRETARY MEMORANDUM TO:
William D. Travers Executive Director for Operations FROM:
Annette Vietti-Cook, Secretary j
SUBJECT:
STAFF REQUIREMENTS - SECY-99-024 -
RECOMMENDATIONS OF THE SAFEGUARDS PERFORMANCE ASSESSMENT TASK FORCE The Commission has approved the staff's recommendations to modify the regulations to require
' power reactor licensees to identify target sets, develop protective strategies and exercise these strategies on a periodic basis. The exercises should be subject to NRC inspection and observation. As requested in the Staff Requirements Memorandum -- Briefing on Safeguards Performance Assessment on May 5,1999, dated June 2,1999, the staff proposal on the baseline reactor inspection program should include a specific recommendation on the baseline frequency of NRC inspector observation of drills and exercises. The rulemaking should also consider regulatory changes necessary to require licensees to maintain the effectiveness of their contingency plans and to upgrade their security plan commitments whenever these exercises reveal weaknesses in their ability to protect against the design basis threat. In addition, the Commission has approved development of associated regulatory guides, inspection program changes, revisions to the Enforcement Manual, and necessary training for NRC inspectors. The staff should provide the Commission a rulemaking plan and schedule for 7
these activities.
(EDO)
(SECY Suspense:
9/24/99) 1 As part of the staff's semiannual threat environment review and report to the Commission, the staff should brief the Commission in a closed meeting on events that occurred since the last semiannual review and the continued validity of the NRC's design basis threats, or recommend the need to change the current requirements.
(EDO/SECY)
(SECY Suspense:
8/30/99 and every 6 months thereafter)
The staff should ensure that the safeguards program is revised in a manner compatible with the ongoing changes to the overall NRC inspection and assessment program (i.e., with criteria for measurement, thresholds for action, and a focus on outcomes).
As the staff develops the rule and associated guidance and uses the remaining OSREs to pilot concepts for the revised safeguards inspection and assessment program, the staff should interact with stakeholders in an open process, while ensuring the protection of safeguards informationi D6NM eM/'
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l The staff should address the following questions in the rulemaking package to sat;sfy recommendation 1 of the Safeguards Performance Assessrnent Task Force:
' Why were the OSREs allowed to be conducted with security measures well a.
above the licensing commitments without, at least, evaluating if the minimum
' licensing conditions are adequate?
b.
Why is requiring a plant to meet its original licensing basis a back-fit?
c.
' Why are the NRC inspectors not inspecting compliance for all of 10 CFR Part 73.557 The staff should consider and propose, as appropriate, any additional rulemaking (beyond the rulemaking proposed in SECY-99-024) identified as a result of the pilot program.
cc:
Chairman Jackson i
Commissioner Dicus Commissioner Diaz Commissioner McGaffigan Commissioner Merrifield OGC ClO CFO OCA
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OPA Office Directors, Regions, ACRS, ACNW, ASLBP (via E-Mail)
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