ML20236D892
| ML20236D892 | |
| Person / Time | |
|---|---|
| Issue date: | 05/19/1987 |
| From: | Rehm T NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Beckjord E, Jordan E, Murley T NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD), Office of Nuclear Reactor Regulation, NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20236D840 | List: |
| References | |
| FOIA-87-655 NUDOCS 8710280403 | |
| Download: ML20236D892 (6) | |
Text
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C MAY 191987 3
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MEMORANDUM FOR:
T. Murley, NRR E.' Jordan, AEOD E. Beckjord, RES J. Lieberman, OE J. Murray, OGC W, Mcdonald, ARM FROM:
T. A. Rehm. Assistant for Operations, EDO
SUBJECT:
DRAFT GA0 REPORT ON NRC'S SAFETY STANDARDS AND INSPECTION AND ENFORCEMENT EFFORTS I have attached a copy of the subject GA0 report which was discussed at Friday's staff meeting.
Please note the restrictions on dissemination. This copy has been marked up to reflect comments from your organizations. We do not know the extent to which GA0 will accept all of the comments, but understand the bottom line (see pages 16, 18 and 36) will remain about the same. We are not likely to see a further draft before the report is made public.
Because GAO's conclusions, as referenced above, are negative EDO has advised the Chairman that we will be prepared to respond with a press release as soon as the report is made public.
In that regard, request your comments on this draft by May 29, specifically:
Page 16. ARM, NRR Page 18 - RES, NRR, AE00, OE Page 36. NRR, AE00, OE 1
(Signid) T. A. Rehm~
T. A. Rehm Assistant for Operations, EDO
Enclosure:
As stated cc:
V. Stello J. Taylor l
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NRC COMMENTS ON THREE ISSUES RAISED IN THE GA0 REPORT ON NRC SAFETY STANDARDS AND INSPECTION AND ENFORCEMENT Issue: We (GAO) were able to determine from NRC's tracking system whether NRC l
and the utilities had reached agreement concerning actions that should be taken, but we could not determine in all cases whether the utilities actually
.took the action required.
Comment: The NRC recognized the need for improving its tracking systems to l
track not only the action taken by the agency, but to track actual implemen-tation of requirements at all plants. The NRC implemented-the Safety Issue Management System (sills) to provide for tracking generic safety issues from the time they are identified to the time they are actually implemented at each plant.
This system is now operational and efforts to verify implementation of requirements by licensees are underway. SIMS also tracks the status of this verification. The data for each plant is now being checked for accuracy and any errors are being corrected. The system indicates that, as of the end of j
May 1987, verification (utilities "actually took" the action) has been completed for about 70 percent of all required actions.
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Issue: Over the years the NRf has identified more possible safety issues than it has resolved. The longer these issues are unresolved, the longer plants j
may be operating in a less safe manner.
NRCs funding for these activities has
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Comment:
Funding for research, and resolution of safety issues, specifically Generic Issues (GIs), and Unresolved Safety Issues (USIs), has decreased over the years, as has the overall NRC funding level.
However, with the reduced funding level, for rea*pns discussed below the NRC is still able to provide reasonable assurance that the public health and safety is protected as its statutory mandate requires.
With regard to the GIs and USIs, many evolve out of the staff review of operational events. After each event, the safety implications of the event are analyzed, and any issue that is determined to affect safe operation is I
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-2 immediately corrected at affected plants. As a result of this analysis, the NRC ensures that all plants pose no undue risk to the public health and safety.
Beyond this safety analysis, a long-term resolution of additional j
issues, called GIs or USIs, is undertaken to assess the additional safety j
benefits that might be achieved, or to confirm that adequate safety margins exist.
Resources for the long-term resolutions are allocated based on the relative priority of the issue, which is based on overall safety significance.
If, during the resolution of the GI or USI, a plant is found to pose a j
potential hazard, action is taken to reduce the risk at the plant immediately, before final resolution of the GI or USI.
l The 1A0 is correct that over the years the NRC has identified more possible safety issues than it has resolved, however, the statistics used by GA0 to J
identify the number of open unresolved and generic safety issues are out of date and need clarification. The identified issues are not all of major significance.
The issue prioritization process described in NUREG-0933 has found that many of these issues have little or no safety significance and are thus assigned a low or drop priority rating. As of May 7, 1987 there were 69 generic safety issues remaining unresolved which are classified as either medium, high or nearly resolved. A large number of these are currently in the process of resolution. When new issues are identified they are promptly screened to determine their safety significance and, if judged high or medium t
priority, they are given to the NRC engineering staff to resolve.
4 In summary, as concerns or issues are identified relating to the safety of operating reactors, the NRC makes decisions based on the facts of each case, and allows continued operation only if plants pose no undue risk to the public health and safety.
Longer term studies t; esolve the need for additional improvements consider the potential benefits and the costs of implementation. The unresolved safety issues referred to by GA0 are the j
studies of these proposed improvements that have not yet been completed.
NRC is currently considering potential actions to apply resources more efficiently to this generic issues process.
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, i Issue: NRC has authority under the Atomic Energy Act to order a utility to j
stop plant operations but NRC lacks criteria by which to implement this l
statutory authority. As a result, utilities operate plants for many years with significant safety problems. We reviewed five cases and found that j
significant safety problems caused the utilities -- not NRC -- stop plant
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operations, i
Comment:
The NRC is responsible for licensing nuclear power plants, and ensuring that plants are operated in accordance with their license, NRC requirements, and commitments by the licensees.
The NRC establishes conditions for safe operation in the license, which includes the plant design and the technical specifications which ensure that plant systems ard operating conditions remain within their design bases. The NRC, through its inspection efforts, ensures that each plant operates in accordarie with its license. The license for each plant contains the specific criteria needed by the NRC to j
determine if unsafe conditions exist at a nuclear power plant. The safety significance of any deviations from the license are evaluated, and since the deviations can take any i o myriad of forms, each case must be evaluated on its merits by the collecuve expertise and judgment of the NRC staff. The licensee must comply with the conditions of the license, compensate by some means acceptable to the staff, or the plant is shutdown. Therefore, it is not necessary to develop a " cookbook" of specific criteria which could be used in making decisions on when a plant should be shut down.
The NRC makes its decisions based on the facts of each case, and allows continued plant operation only if the plant poses no undue risk to the public health and safety. This determination is made on the facts of each case, after consideration of the overall plant design, operating personnel, and management.
Licensees have the primary responsibility for the safe operation of their plants.
Each licensee must continually check for compliance with its license, NRC requirements, and its own commitments. Through this responsibility, licensees are expected to be the first to determine any areas of non-compliance with their license, NRC requirements, and their own l
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.r commitments.. The NRC, therefore, would expect licensees to stop plant operations before being forced to by the NRC. The fact that licensees shut down their plants more often than the NRC forces them to shut down is seen as a positive reflection on the industry, and on the regulatory process.
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The five cases noted by the GAO are Davis Besse, Rancho Seco, Pilgrim, Browns Ferry, and Brunswick.
Davis.Besse, Rancho Seco, and Pilgrim were each shutdown by safety systems in response to plant equipment malfunctions. These events, however, demonstrated the need for making safety improvements and NRC permission was required prior to restart. Rancho Seco and Pilgrim are still shutdown. Davis Besse was allowed to rettart. in December.1986. Browns Ferry and Brunswick were shutdown voluntarily due to safety concerns. Although these shutdowns were voluntarily, NRC permission was required for restart.
Both Brunswick units restarted in October 1982. All Browns Ferry units remain shutdown.
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