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UNITED STATES NUCLEAR REGULATORY COMMISSION 8 WASHINGTON, D. C 20655 n j
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January 28, 1987 CHAIRMAN The Honorable Charles A. Bowsher Comptroller General of the United States General Accounting Office Washington, D. C. 20548
Dear Mr. Bowsher:
I am enclosing a summary of actions taken by the United States Nuclear Regulatory Commission (NRC) in response to recom-mendations concerning the NRC which were in reports issued by the Comptroller General. It includes significant actions taken on recommendations in reports issued in 1986 and in prior years. This summary is required by Section 236 of Public Law 91-510, the " Legislative Reorganization Act of 1970."
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Lando W. Z L
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Enclosure:
Summary of NRC Actions 8703030691 870226 PDR COMMS NRCC CORRESPONDENCE PDR
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SUMMARY
OF NRC ACTIONS RESPONSE TO GAO REPORTS Page
- 1. Oversight of Quality Assurance at Nuclear Power Plants Needs A-2 Improvement
- 2. Process for Rackfitting Changes in Nuclear Plants has Improved A-6
- 3. Safety Analysis Reviews for DOE's Defense Facilities can be A-7 Improved
- 4. The Nuclear Regulatory Commission Should Report on Progress A-8 in Implementing Lessons Learned from the Three Mile Island Accident
- 5. Management Weaknesses Affect Nuclear Regulatory Commission A-9 Efforts to Address Safety Issues Common to Nuclear Power Plants
- 6. Additional Improvements Needed in Physical Security at A-11 Nuclear Power Plants
- 7. NRC Should Specify User Needs and Improve Cost Control for A-12 its Document Control System
- 8. Letter to Congressman Dodd on NRC's Procedures to Assure A-13 Safety in the Transportation of Radioactive Materials e
O NRC ACTIONS IN CY 1986 IN RESPONSE TO COMPTROLLER GENERAL RECOMMENDATIONS Report - January 23, 1986 (GA0/RCED-86-41)
Oversight of Quality Assurance at Nuclear Power Plants Nee _ds Improvement Recomendation No.1 (Chapter 2)
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:
The NRC has established uniform criteria for agency actions to be taken when the NRC's Systematic Assessment of Licensee Performance (SALP) evaluations indicate that improvement programs may be necessary. Noted that SALP evaluations, which cover a reactor operating period of up to 18 months, are not the only method for identifying the need for regulatory improvements and initiating appropriate staff actions. Apart from the SALP program, established i NRC enforcement policy promotes unifonn and prompt agency actions in dealing with 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 very useful in the identification of emerging or continuing nuclear safety performance problems. 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. Since December, the NRC has taken several new steps to identify and address emerging performance problems at power reactors. Among these initiatives are senior management meetings held periodically to discuss selected facility performance problems and development of a performance indicator program (see response to Recommendation 3). These initiatives, in conjunction with SALP, are intended to provide the basis for identification of sites that need special regulatory attention.
Recommendation No. 2 (Chapter 2)
Routinely analyze historical assessment results and discuss marginal and 1 declining performance trends in individual assessment reports.
NRC Response:
. NRC agrees with this recommendation. On November 5, 1985, the Director.
Office of Inspection and Enforcement, issued fnr 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
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Q discernible, and (2) continuation of the trend may result in a change in performance level. Also, the analysis section for each functional area evaluated should contain a brief summary of the previous evaluation, if there has been a significant change or if there should have been a significant improvement, but there was not. ,
Additionally, a computerized SALP Management Summary System has been established to provide sumary and detailed SALP information to Region and Headquarters offices on a periodic basis. Management decision infonnation and tracking information can be developed with the aid of this systeny 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.
Recommendation No. 3 (Chapter 2)
Expand the information considered in periodic assessments to include readily available data on trends in nuclear power plant operating performance.
NRC Response NRC agrees with this recomendation provided 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 comercial activity are programatic ' bottom line' indicators of companies' strengths and weaknesses operating these facilities." NRC is cautious in the use of comercial or economic indicators in measuring a licensee's operational nuclear safety
, performance. For example, emphasis by NRC on economic indicators as a
, performance standard might be adverse to safety. Licensees could be motivated to keep a plant operating when circumstances indicate a safer action would be to shut down, reduce power, or delay a return to operations following an outage The NRC does agree that indicators of plant nuclear safety performance can and should be more extensively used in the regulatory process. The following actions are already in progress withir. 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 licensed since 1982. Reportable events are being identified and cataloged from
! computerized reactor event data such as 10 CFR 50.72 submittals, Licensee
- Event Reports, periodic summary reports of operating reactors, Nuclear Plant Reliability Data System information, etc. The initial effort is focused on the identification of valid and accessible performance measures.
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- The Office of Inspection and Enforcement has developed a program of screening and evaluating operating reactor events to identify generic problems, trends in plant safety performance, and areas requiring improvements within the plants. The 50.72 and regional morning
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reports are screened and evaluated on a daily basis to determine the generic implications of events and to determine the need for any additional action on the plant having an event.
In addition to reviewing specific events, The Office of Inspection and Enforcement's Events Analysis Branch analyzes events for-trends indicating changes in plant perfomance that may not have been apparent i during the short-tem event screening or indepth investigation into an i 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,Part21,50.55(e), regional morning and inspection reports, preliminary notifications, enforcement j actions, and Nuclear Plant Reliability Data System. The significant events include scrams, Engineered Safety Features actuations, and safety i system or component failures. The basic causes or areas of weaknesses include design, installation, random equipment failure, fabrication / manufacturing, procedure, maintenance, personnel error, and
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administrative controls.
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- The Office of Nuclear Regulatory Research is evaluating the effectiveness j of reliability program elements applicable to the safety of operating s reactors. This research will improve methods to evaluate quantitative measures of nuclear power plant safety performance.
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. During 1986 the NRC staff developed a performance indicator j program to enhance the NRC's abil.ity to detect and respond to poor or declining
! performance. The program was developed by an interoffice task group. The task group sponsored a trial pro' gram that was the basis for an NRC staff-recommended program. The recommended program was presented for Commission i review in SECY-86-317, dated October 28, 1986. Implementation of a program
! has been approved by the Commission. Readily available data indicative of
! power plant operating performance are being collected and analyzed. Reports will be prepared quarterly presenting the data and trends for each operating plant.
Performance indicator data are expected to be used in a structured l
decision-making process. Along with other information available to the
! staff, performance indicators will provide data for-NRC senior management to address performance problems and determine appropriate NRC responses.
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Systematic Assessment of Licensee Performance (SALP), conducted every 12-18 months, will remain most important to the NRC's assessment efforts. The more frequent reviews of performance indicators between SALP evaluations will assist in earlier detection of performance problems as well as provide more objective data to SALP.
Recommendation No. 4 (Chapter 2)
Include in the agency's assessment deliberations on a utility's quality program and administrative controls performance the results of-its-assessments in the other nine technical areas.
NRC Response NRC agrees with this recommendation. 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 address 0d 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. Some Regic s 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 Affecting 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. Clarification of the approach to assessments of the Quality Programs and Administrative Controls Affecting Quality area has been issued by the Office of Inspection and Enforcement.
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O Report - December 24, 1985 (GA0/RCED-86-27)
Process for Backfitting Changes in Nuclear Plants has Improved Recommendation No. 1 (Chapter 3)
Revise the agency's plant-specific backfitting procedures to explicitly state that the NRC staff is responsible for identifying and processing, in accordance with the plant-specific backfitting procedures, atl new or amended plant-specific positions taken by the staff.
NRC Response The NRC agrees with the substance of this recommendation. Statements conveying this direction are introduced at the beginning of Section 042 of the NRC Manual Chapter 0514, " Identifying Plant-Specific Backfits."
Recommendation No. 2 (Chapter 3)
Revise the agency's plant-specific backfitting procedures to explicitly state that to qualify as a plant-specific backfit, the technical basis for a new or revised staff position taken must be unique to a specific plant or plant location.
NRC Response The NRC differs with the substance of this recommendation. The NRC definition of plant-specific, already included in the Manual Chapter in Section 01, Purpose, says in effect that a position applied to two or more plants, even if they are at the same site would be a generic position. This definition is clear and has caused no problems in application. The GAO definition could cause a position unique to a plant location to be interpreted as plant-specific even though that position may be applicable to two or more essentially different plants at that location. Therefore, the NRC chooses to not include the phrase "...or plant location" in the definition. However, for additional clarity, the NRC will include its preferred definition in the first paragraph of Section 052 (definition of plant-specific backfit) of the Manual Chapter as follows:
Backfitting is " plant-specific" when it involves the imposition of a position that is unique to a particular plant.
The NRC plant-specific backfit policy, as NRC Manual Chapter 0514, was issued to NRC staff and all nuclear power plant owners in March 1986.
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Report - June 16, 1986 (GA0/RCED-86-175)
Safety Analysis Reviews for DOE's Defense Facilities Can Be Improved Recommendation No. 4 to the Secretary of Energy (Appendix I)
Establish an arrangement with an outside independent organization to review those SAR's for the most hazardous facilities. This could be accomplished either by establishing a working arrangement with NRC or an tndependent review panel.
NRC Response The NRC has a number of safety responsibilities which involve relationships with the Department of Energy (00E). They include activities related to review of certain DOE reactors, the West Valley Demonstration Project, and transportation casks and DOE activities under the Nuclear Waste Policy Act and the Low-Level Radioactive Waste Policy Amendments Act. The NRC has no comment on the merit of any expanded safety interaction of the NRC with DOE defense j facilities. Note that if the Secretary of Energy chooses to respond to the cited recommendation by seeking to establish "...a working arrangement with NRC..." for additional reviews of certain SAR's, the NRC has no resources currently available for such additional arrangements. If a working arrangement is to be realized, appropriate budgetary considerations would be necessary.
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- l NRC ACTIONS IN CY 1986 IN RESPONSE TO COMPTROLLER GENERAL RECOMMENDATIONS ISSUED IN PRIOR YEARS Report - July 19, 1985 (GA0/RCED-85-72)
The Nuclear Reculatory Commission Should Report on Progress in Implementing Lessons Learnec from the Three Mile Island Accident
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Recommendation In response to investigations into the TMI accident, the NRC prepared a TMI Action Plan for the necessary improvements in both the operation and regulation of nuclear power plants. The GA0 report recommended that the 4
NRC Chairman provide the Congress a one-time, detailed report on the TMI Action Plan that:
(1) describes utilities' progress in implementing TMI-related changes at their nuclear power plants; (2) describes the status and results of the Action Plan items that were the responsibilities of the NRC staff and the Commission; and (3) addresses the significance of incomplete Action Plan items to public safety and shows how these items will be pursued, accounted for, and reported on under the new generic safety issues management system.
NRC Response The NRC agreed to provide a one-time report to the Congress. This report incorporates data from a newly developed Safety Issues Management System (SIMS), and has been sent to Congress.
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NRC ACTIONS IN CY 1986 IN RESPONSE TO COMPTROLLER GENERAL RECOMMENDATIONS ISSUED IN PRIOR YEARS Report - Septenber 19, 1984 (GA0/RCED-84-149)
Management Weaknesses Affect Nuclear Regulatory Commission Efforts to Address Safety Issues Common to Nuclear Power Plants -- -
Recommendation The captioned GA0 report recommended the development and implementation of a management system that would, (1) individually track generic issues through completion of all work, including implementing changes at affected plants; (2) provide information on resource needs, expenditures and milestones; (3) retain summary information on th? disposition of resolved issues; and, (4) ensure that the most important safety-related plant modifications resulting from the resolution of generic issues receive priority attention.
NRC Response The NRC generally agreed with GA0's recommendations and adopted the Safety Issues Management System (SIMS). The Safety Issues Management System is being used on an agency-wide basis to track the progress and resolution of safety issues from their inception until any requirements are inplemented and verified, as necessary, at each facility.
The first phase of implementing this system was completed in September 1986 and data loading, including status of licensee implementation of requirements and verification needs, with few exceptions, has been completed. SIMS currently is being used to contribute to the management process. Its uses to data include:
(1) the genesis for several special reports used by the Senior managers during the October 1986 Senior Management Meeting held in Region V to evaluate licensee performance; (2) providing data for a cre-time report to the Congress on TMI items; I (3) data for the reassessment of the safety of all B&W reactors; )
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O (4) enable individual project managers to track implementation of multi-plant requirements at their plants; and (5) providing the means for sumarizing the content of generic proposals to CRGR and developing a long range agenda.
The implementation of the Safety Issues Management System is trhigh NRC ~
priority. SIMS will enhance the tracking and managerial efficiency required for safety-related issues. -
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o NRC ACTIONS IN CY 1986 IN RESPONSE TO COMPTROLLER GENERAL RECOMMENDATIONS ISSUF3 IN PRIOR YEARS Report - July 13, 1983 (GA083-141)
Additional Improvements Needed in Physical Security at Nucletr~ Power Plants The GA0 requested that it be kept informed on how the Commission disposed of the recommendations in the Safety / Safeguards Committee report (Safety / Safeguards Review Committee - Final Report, NUREG-0992) and on actions taken with regard to the NRC proposed Access Authorization Rule.
NRC Response Recommendations of the Safety / Safeguards Committee have been accommodated except for the issue of using psychological testing as a pre-employment screening tool. This final item will be completed with publication of the NRC Access Authorization Policy Statement and the Industry Guidelines for Access Authorization. Commission approval and publication are expected in the next few months.
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D NRC ACTIONS IN CY 1986 IN RESPONSE TO COMPTROLLER GENERAL RECOMMENDATIONS ISSUED IN PRIOR YEARS Report - June 3, 1981 (EMD-81-90)
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NRC Should Specify User Needs and Improve Cost Control For Its Document Control System -
Recommendation No. 2 Resolve problems that NRC staff is experiencing in using the system.
NRC Response During CY 1986 NRC staff has developed procedures to increase the integrity of ,
the database. Additionally, a system design has been developed to allow for l subject searching.
Recommendation No. 3 Prevent the processing of duplicate documents.
NRC Response Specific procedures were written into the 1986 contract for the document I control system that eliminate the processing of duplicate documents.
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NRC ACTIONS IN CY 1986 IN RESPONSE TO COMPTROLLER GENERAL RECOMMENDATIONS ISSUED IN PRIOR YEARS Report - May 11, 1977 (GA0/ReportB-164105)
Letter to Congressman Dodd on NRC's Procedures to Assure Safety in the Transportation of Radioactive Materials.
Recommendation (pg. 6)
The letter recommends that the NRC include crushing as one of the container performance standards.
NRC Response Crush as a container performance standard has been included as a 1985 revision to the International Atomic Energy Agency'(IAEA) Regulations (Safety Series No. 6) for the Safe Transport of Radioactive Materials. The IAEA recommenda-tions were presented to member states for acceptance at the September 1984 Board of Governors meeting. Formal rulemaking action will be initiated by NRC and DOT to incorporate and provide compatibility of U.S. and international regulations. This will include a new crush standard in the U.S. regulations.
The IAEA has recommended January 1, 1990, as a target date for the 1985 Edition of Safety Series No. 6 to become an effective regulation for all member states.
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