ML20210R990
| ML20210R990 | |
| Person / Time | |
|---|---|
| Issue date: | 06/06/1997 |
| From: | Callan L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| SECY-97-122, SECY-97-122-01, SECY-97-122-1, SECY-97-122-R, NUDOCS 9709040200 | |
| Download: ML20210R990 (7) | |
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................in m ic POLICY ISSUE (NEGATIVE CONSENT)
June 6, 1997 SECY-97-122 f.QB:
The Commissioners
'97 SEP -2 A11 :20 ERQM:
L. Joseph Callan Executive Director for Operat1&WLIC COCUMENT hoo
SUBJECT:
INTEGRATED REVIEW OF THE NRC ASSESSMENT PROCESS FOR OPERATING COMMERCIAL NUCLEAR REACTORS PURPOSE:
The purpose of this Commission paper is to inform the Commission of the i
staff's plan to perform an integrated revied of the current NRC assessment i
processes (including plant performance reviews
- PPRs, senior management meetings [SMMs), and systematic assessments of licens)ee performance (SALPs))
for operating commercial nuclear reactors.
This paper addresses several recent Commission staff requirements memoranda (SRMs), but the primary focus is on SRM M970129A, as discussed in detail below.
BACKGROUND:
In several recent Commission SRMs, the staff was tasked to seek improvements to processes used to assess the performance of licensees.
The SRMs and the pertinent staff action from the Maine Yankee Independent Safety Assessment (ISA) are summarized below.
In a memorandum dated November 27, 1996, the Executive Director for Operations directed the staff to resolve the staff actions resulting from the Maine Yankee ISA.
Issue 7, adequacy of agency expectations regarding licensee performance, tasked the staff to " evaluate the appropriateness of the existing SALP definitions of superior, good, and acceptable performance in light of the NRC's conteniporary expectations for licensee performance.
Revise these definitions as necessary." The staff intends to address this item in conjunction with its response to the Commission SRMs that are discussed below.
In response to the Commission briefing of October 18, 1996, on the Maine Yankee ISA, the Commission requested a followup briefing on the SALP system and the NRC assessment process.
This supplemental briefing was held on CONTACT:
NOTE:
TO BE MADE PUBLICLY AVAILABLE WHEN I
David L. Gamberoni, NRR THE FINAL SRM IS MADE AVAILABLE 415-1144 g90 0 970606 97-122 R PDR w w M M M M M M M M M AREF M JEEF M M m J
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2 December 16, 1996.
In response to the SALP briefing, the Commission issued SRM M961216 (January 17, 1997), " Staff Requirements - Briefing on SALP System and Assessment Process," which directed the staff to " continue to seek l
improvements in the processes used to assess performance and regulate the nuclear power industry." SRM M961216 contained eight specific imprcvement areas.-one of which augmented Maine Yankee ISA staff action number 7.
Specifically, SRM M961216 directed the staff to improve the timeliness, objectivity, accuracy, efficiency, breadth, use of risk insights, simplicity, and clar"a of the NRC assessment process.
The due date for the staff's response a this SRM was May 30, 1997. This Commission paper constitutes the staff's response to SRM M961216.
In response to a briefing on January 29, 1997, the Commission issued SRM M970129A (February 14ReactorsandFuelFacIlities),."" Staff Requirements - Briefing on Operati 1997 It directed the staff to " evaluate the efficacy of defining and femalizing a unified licensee perfomance assessment
_ program that integrates the various separate processes being utilized (i.e.,
SALPs PPRs, and SMMs)." SRM M970129A also directed the staff to reexamine the SALP process to detemine its value, including the need for, and structure of, numerical categorization of plants. The due date for the staff's response to this SRM is July 31, 1997.
In response to a briefing on February 13, 1997, the Commission issued SRM M970213A(March 17, 1997), " Staff Requirements - Briefing on Operating Reactor Oversight Program and Status of Improvements in NRC Inspection Program."
It directed the staff to address the use of engineering judgment in the performance assessment process and to " consider whether, when, and how the plant issues matrix should be made available to licensees and the public."
The Commission also emphasized that as improvement initiatives are L
implemented, the staff should ensure that regulatory actions ultimately lead to a clear and coherent view of operating reactor performance.
The due date for the staff's response to this SRM is July 31, 1997, in responso to the Commission briefing of February 18, 1997, on the Arthur Andersen assessment of the SM process and information base, the Commission issued SRM M9702186 (February 26, 1997), " Staff Requirements - Briefing on Analysis of Quantifying Plant Watch List Indicators (Arthur Andersen Study)."
It directed the staff to continue to make improvements to the SM process.
The Arthur Andersen report contained several recommendations, including (1) reengineering the current performance information to better support the Sm and other NRC processes. (2) increasing automation, and (3)he Commission reformatting data to meet the needs of process customers.
In SRM M970?l8B, t emphasized that " consistency must be=shown between the senior management meeting decisions and decisions which are reached in other evaluative processes." The due date for the staff's response to this SRM was March 31, 1997.
The staff issued SECY-97-072, " Staff Action Plan to Improve the Senior Management Meeting Process " on April 2, 1997, which responded to the principal points of SRM M970218B. The staff also briefed the Commission on April 23, 1997.
In response to a Commission paper on the strategic assessment, the Commission issued on March 25, 1997, an SRM titled, " Staff Requirements - CONSECY-96-060 j
1
3
- Operating Reactor Program Oversight ([ Direction-Setting issue) 051 11)."
It directed the staff to " continue with the ongoing comprehensive review and systematic reexamination of the areas of licensing, inspection, and performance assessment to identify areas for improvement, implement corrective actions, and verify their effectiveness."
It also directed the staff to
" develop objective standards to measure licensee performance that reduces l
subjectivity and establishes an understandable level of performance l
expectations" and to
- improve application of early indicators of declining performance to reduce reliance on event driven assessments." The due date for the staff's response to this SRM is July 31, 1997.
History of the NRC Assessment Process for Operatina Commercial Nuclear Reactors The individual components of the assessment process for operating commercial nuclear reactors were developed and implemented at different times.
The first major assessment process component, the sal.P. was being developed before the Three Mile Island accident and was implemented in 1980.
The second major assessment process component, the SMM, was developed in response to the 1985 Davis-Besse loss-of-feedwater event and was first implemented in April 1986.
PPRs were developed to provide for better allocation of NRC resources and were implemented in 1988.
All three of these major components of the assessment process have been subject to periodic, detailed reviews.
In addition, minor changes were made to each process to allow some integration with the other components.
- However, the agency has never conducted an integrated review of the entire assessment process.,
DISCUSSION:
Rather than addressing the SRMs individually, the staff proposes to conduct an integrated' review that examines all components of the current. assessment process.
This effort will be responsive to Commission direction in the various SRMs and the Maine Yankee ISA.
Preliminary results from the job task analysis (JTA) of resident and region'al Divisions of Reactor Projects provide an additional catalyst for the effort. The JTA preliminarily concluded that (1) the assessment-related )rocesses are strong candidates for reengineering; (2) rather than examining tie individual pieces, a more holistic approach is probably needed; (3) process repetition should be eliminated; and (4) the rate and multiple sources of process change are too high, not communicated clearly, and training is typically not provided on the process changes.
The proposed review is also fully responsive to Direction-Setting issue 11 as it applies to the NRC assessment process for operating commercial nuclear reactors.
The primary goals of the integrated review are to clarify objectives; eliminate redundancies; define roles, responsibilities, and authorities; improve consistency; match processes to staff resources; and reduce administrative burden.
The scope of the review will include an examination'of all components of the current assessment process in an integrated manner, focusing on process objectives, i:. puts (including inspection reports, which are the primary building blocks of the assessment process), efficiency, and u
4
- outputs, it will examine the assessment process in its entirety, including infrastructure, to see how it can be made more effective and more clearly focused on safety.
The effort may include a review of the regulatory practices of other organizations including nuclear and nonnuclear, foreign and domestic.
As discussed below, the ir,tegrated review of the assessment process will be somewhat lengthy (approximately 18 months through full implementation of a I
revised process) because of its scope and consideration of inputs from multiple stakeholders.
Therefore, the staff will continue to implement the existing processes in the interim with incremental improvemcats such as those l
in response to the Arthur Andersen study. These incremental improvements may be integral to the new assessment process as they will include development of objective, predictive performance criteria. However, the staff proposes to minimize changes to the existing individual components of the assessment process while the effort is underway.
This approach is being taken to minimize rework and to allow for better communication, training, and implementation of the final process that is develoW.
This effort will be facilitated by an independent contractor to minimize staff bias and to ensure that all stakeholder interests are considered.
The stakeholders will include Headquarters offices, all regional offices, the nuclear industry, and the public.
Significant regional office involvement is critical to the success of this effort, as the regional offices are the primary implementors of the NRC assessment process for operating commercial nuclear reactors.
Resources A preliminary cost estimate to perform the integrated review is five direct full-time equivalents (FTE) and approximately $200 To initiate this program, NRR will reprogram approx,000 for contractor support.
imately $25,000 in FY 1997 with no programmatic impact.
The FY 1998 and FY 1999 resource requirements will be evaluated as part of the upcoming internal budget review and a recommendation on the resources will be made at that time.
Resource savings may result if a revised assessment process is implemented, but the primary goal is improved effectiveness.
Coordination This Commission paper was coordinated with the Chief Information Officer and the Chief Financial Officer.
Schedule The staff anticipates the following approximate schedule:
Three months to finalize the facilitator contract following Commission approval Six months to perform the integrated review
5 Two months to evaluate the results and compare them to the existing process and planned improvements four months to develop an integrated implementation plan, obtain e
industry and public feedback, and obtain the Comission's approval for implementation Three months to train personnel Therefore, the staff anticipates full implementation of a revised )rocess approximately 18 months after the Commission's opproval to begin tie integrated review.
REC 0mENDATION:
The staff recomends that the Comission --
1.
Note that the staff will initiate efforts to obtain a facilitator contract and begin the integrated review within 10 working days from the date of this paper unless instructed otherwise by the Comission.
The staff will update the Comission on the status of the integrated review periodically following completion of major project milestones.
SRM M970129A will be used to track this effort.
2.
Note that staff action to address the attached SRM M961216 will be subsumed by the planned review effort. Therefore, unless directed otherwise, the staff will defer action on SRM M961216 and close it out upon c,ompletion of the review effort.
L.
seph Callan Executive Director for Operations
Attachment:
As stated SECY NOTE:
In the absence of instructions to the contrary, SECY will notify the staff on Friday, June 27, 1997 that the Connissica, by negative consent, assents to the action proposed in this paper.
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DISTRIBUTION:
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NUCLEAR REGULATORY COMMISSION Cys: Thompsod Blaha g
WASHINGTON. O C. 20565-0001 Jordan Norry IN RESPONSE, PLEASE January 17, 1997 REFER TO:
M961216 OfflCI Of THE SECRETARY t
HEMORANDUM TO:
Hugh L. Thompson, Jr.
Ac ng Executive Director for Operations
~
FROM:
1111am Acting Secretary
SUBJECT:
STAFF REQUIREMENTS - BRIEFING ON SALP SYSTEM AND ASSESSMENT PROCESS, 2:00 P.M.,
- MONDAY, DECEMBER 16, 1996, COMMISSIONERS' CONFERENCE ROOM, ONE WHITE FLINT NORTH, ROCKVILLE, MARYIAND (OPEN TO PUBLIC ATTENDANCE)
The Commission was briefed by the NRC staff on the SALP system and assessment process.
The Commission urged the staff to continue to seek improvements in the processes used to assess performance and regulate the nuclear power industry.
In a follow on briefing, the Commission requests that the staff consider and present recommendations for 1) improving the timeliness of the NRC assessment capabilities, thereby enhancing the ability to identify declining performance earlier (e.g., Are SALPs effective in providing timely performance input?);
2) increasing the objectivity of the assessments by sharpening the distinction between the various SALP categories and defining when a clear transition is made between them; 3) more clearly distinguishin unacceptable performance; g between acceptable and 4) methods to better integrate the available data; 5) incorporating performance information regerding maintenance of the design basis and operation therein into the SALP and other assessment processes; 6) increasing the use of risk insights in assessments;
- 1) simplifying the evaluation processes; and 8) using more active, direct language in the SALP reports.
4EA%
(NRR)
(SECY Suspense:
5/30/97) 9700006 Attachment l
c'<
9 2-The commission requesta the following statistical data:
AEOD il row many Diagnostic Evaluacion Team (DET) inspections 9700006 hate been perforocd and what is the trend for these inop)ctions over time?
2)l How many Aggmented Inspection teams (Arts) have been Aused and what has *.he trend been?
3)
How many times has the NRC met with Boards of Directors t
t concerning declining or poor performance?
9 0007 4)
How long was Turkey Point on the Watch List?
I 5)
Provide an historical analysis of total inspection L---
hours with ar;tropriate breakouts (hours and percent of total) of the inspection hours spent for core, initiative, and generic safety issue inspections.gional re 4EDGF-(SECY Suspense 2/28/97) cci Chairman Jackson Commissioner Rogers Commissioner Dieus Commissioner Diaz Commissioner tMGaffigan OGC OCA OIG Office Directors, Regions, ACRS, ACNW, ASLBP (via E-Mail)