ML20217M559
| ML20217M559 | |
| Person / Time | |
|---|---|
| Issue date: | 08/08/1997 |
| From: | Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM) |
| To: | Gejdenson S HOUSE OF REP. |
| Shared Package | |
| ML20217M566 | List: |
| References | |
| NUDOCS 9708250035 | |
| Download: ML20217M559 (4) | |
Text
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UNITED STATES g*
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August 8, 1997 CHAtRMAN l
The Honorable Sam Gejdenson United States House of Representatives Washington, D.C. 20515
Dear Congressman Gejdenson:
Thank you for your letter of June 18,1997, concerning the recently released General Accounting Office (GAO) report entitled Nuclear Reaulation Preventina Problem Plants Reauires More Effective NRC Action. I assure you that we intend to continue to strengthen the NRC's regulatory processes, including the senior management meeting (SMM) process, and to implement appropriate corrective actions for matters such as the Millstone leaking
- velve issue.
In your letter, you requested that I address three specific issues:
1.
Explain the reasoning behind the Nuclear Regulatory Commission policy that the 1995 systematic assessment of licensee performance (SALP) for Millstone not be made public.
2.
Has the Commission considered holding SMMs quarterly rather than bi annually?
3.
The Commission should consider adding the backlog of unresolved reactor maintenance items to the list of NRC performance indicators.
Our response to these issues is enclosed. I trust this information is responsive to your concems, I will ensure that the issues identified in the GAO report are carefully evaluated and considered and appropriate corrective measures are taken in a timely fashion. If I can be of further assistance, please do not hesitate to contact me.
Sincerely, k
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Enclosure:
Response to issues 6..> o., u, E N N]Iljiutju!ll 17 9708250035 970900 PDR COMMS NRCC CORRESPONDENCE FDR a
RESPONSE TO ISSUES RAISED BY CONGRESSMAN GEJDENSON 1.
Explain the reasoning behind tho Nuclear Regulatory Commission policy that the 1995 systematic assessment of licensee performance (SALP) for Millstone not be made public. The 1995 Millstone SALP was not finalized and issued because a series of special NRC regulatory and review activities essentially superseded the information contained in the draft SALP report. Expending the effort to complete the draft SALP report would not have been the most efficient use of staff resources and would noi have added new information to the public record, The staff's decision not to issue the SALP report was consistent with existing guidance in NRC Management l
Directive (MD) 8.6, " Systematic Assessment of Licensee Performance (SALP)," which governs implementation of the SALP program. This directive states:
The NRC will review and evaluate each power reactor licensee that possesses an operating license or construction permit at en interval of 12 to 24 months. The regional administrator shall determine the exact frequency within this interval on the basis of the licensee's performance and regional scheduling needs, with the following exceptions:
SALP frequency and scope of the assessment may be adjusted for plants in extended shutdowns, extended outages, or decommissioning. In each case, the regional administrator shall confer with the Director, NRR [ Office of Nuclear Reactor Regulation), and document the basis for the change.
The SALP process will be suspended for any plant that is shut down and requires authorization by the Commission (not the staff) to restart. As a part of a restart process, an ungraded evaluation of performance in the SALP functional areas may be performed.
The Millstone SALP board meeting was held on November 16,1995. Typically, the SALP report is issued about 2 months following the SALP board meeting. However, in Millstone's case, the NRC issued the first in a series of 10 CFR 50.54(f) letters to the licensee on December 13,1995, shortly after the SALP board meeting. These letters require all three Millstone units to affirm their compliance with all of the NRC's rules and regulations and their licensing bases. As a followup to the initialletter, five more 10 CFR 50.54(f) letters were issued over the next 5 months (two on March 7, 1996, and one e ach on April 4, May 17, and May 21,1996). The 10 CFR 50.54(f) letters were publicly available and clearly described the NRC's findings and concerns that led to the issuance of the letters. The 10 CFR 50.54(f) letters and other special NRC review activities at the site effectively superseded the SALP process.
Enclosure
2 Millstone Station was identified ns a NRC Watch List Category 2 facility at the January 1996 SMM. Plants in Category 2 have weaknesses that warrant increased NRC attention from both Headquarters and the regional office. Millstone Station was designated a Watch List Category 3 facility by the Commission subsequent to the June 1996 SMM. The Commission must approve restart of plants in Category 3.
1 l
In summary, the draft SALP report for Millstone was not issued as a final report because the significant NRC actions being implemented at the time the final SALP report was being prepared achieved the SALP's objectives of allocating inspection resources and publicly communicating the agency's assessment of the plants' performance to the licensee.
2.
Has the Commission considered nolding SMMs quarterly rather than bl.
annually? Over the past two years, the NRC staff has been making improvements to all of its licensee performance assessment processes. An integrated review of these processes has recently been initiated. As part of this review, the staff will better define objectives for the performance assessment processes and will develop options for enhancing their efficiency and effectiveness. The SMM, including the frequency of the meetings and its criteria for making decisions, will be evaluated in this integrated review.
The NRC staff continuously monitors licensee performance through inspections and reports of events at nuclear power plants, This information is provided to senior NRC management in a timely manner through the event reporting process, and through inspection reports and ongoing assessments of licensee actions. Through these processes, senior NRC management is kept aware of performance concerns on a continuing basis. For safety significant items requiring prompt regulatory 1,ntervention, the NRC would take appropriate action immediately, and would not wait for the next SMM to do so.
3.
The Commisalon should consider adding the backlog of unresolved reactor maintenance items to the list of NRC performance Indicators. The NRC agrees that aggressive responses to maintenance issues on the part of licensees is important to safe operations. Through its inspections, the NRC maintains an awareness of the size and content of the backlog of unresolved reactor maintenance items at nuclear power plants. However, after completion of the trial performance indicator program in October 1986, the agency made a conscious decision to not incorporate this measure within the set of NRC performancelndicators. Measures of performance should meet several criteria in order to be designated performance indicators. Reliable performance indicators should:
be related to nuclear safety and regulatory performance be based on information readily available to the NRC not be subject to manipulation be comparable among licensees
3 refisct a range of performance be independent of each other be leading The decision not to use plant maintenance backlogs as a performance indicator was made primarily because of its susceptibility to man!pulation and the subsequent potentially adverse impact on safety. For examplo, in order to reduce its backlog (and thereby improve the apparent performance as measured by this indicator), a licensee might elect to minimize the number of new work requests that are created or correct a large number of simple, relatively insignificant hems at the expent.e of correcting a few larger scope items of greater safety significance.
Within the context of the SMM, the SMM Nuclear Power Plant Performance Evaluation Template focuses on five majo? areas of licensee performanca; maintenance backlog is addressed in the area of meterial condition and safety system reliability / availability.
The SMM template is being revised to improve its effectiveness as a tool to identify plants that should be placed on the NF.C Watch List. One of the goals of this revision of the template is to develop appropriate quantitative measures and criteria for NRC actions. This may result in a perfor' nance indicator that incorporates maintenance backlogs in some form.
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