ML20236H392
| ML20236H392 | |
| Person / Time | |
|---|---|
| Issue date: | 05/05/1998 |
| From: | Dicus G NRC COMMISSION (OCM) |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20236H374 | List: |
| References | |
| SECY-98-045-C, SECY-98-45-C, NUDOCS 9807070192 | |
| Download: ML20236H392 (3) | |
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NOT ATION VOTE u..
I RESPONSE SHEET l
l' TO:
John C. Hoyle Secretary of the Commission FROM:
COMMISSIONER DICUS l
SUBJECT:
Approved ___ Disapproved ~ X Abstain L
Not Participating' Request Discussion
. COMMENTS:
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L See attached.
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SIdNATURE Release Vote / X /
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DATE
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Withhold Vote /
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L Entered on "AS" Yes No i
9907070192 980630 PDR COPMS PGtCC CORRESPONDENCE PDR j
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Commissioner Dicus' vote on SECY-98-045," Status of the Integrated Review of
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the NRC Assessment Process for Operating Nuclear Reactors" I disapprove issuance of this paper for formal public comment in its present form. I j
believe the paper needs substantial revision in order to address some significant concerns and to help ensure that meaningful comments can be reviewed once the paper is released for formal public comment.
While i disapprove issuance of the paper at this time, the staff is to be commended for l
its willingness to address an issue of this magnitude and ;mportance. While I have substantial concerns about some of the concepts advanced in the paper and concerns
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about concepts that have not been addressed, I recognize that the paper represents an important first step in a thorough reappraisal of our reactor oversight program.
The se'f should revise the paper For to releasing it for public comment and so doing consider the following:
1)
The staff should develop the hierarchical structure of the new process to clearly define how the process will arrive at conclusions of plant performance. The staff should i
address the concerns raised by the ACRS.
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2)
The staff should also address how the new system will equitably treat those plants that receive a large number of inspection hours compared to those plants that receive a normal number of inspections hours.
3)
I believe the staff should consider positive as well as negative inspection findings in the new assessment process. In the benchmarking activity, the staff should assess how the new process would handle both positive and negative Plant Issues Matrix (PIM) entries. The staff should provide their conclusions concerning a) differences in inspection' effort and b) including positive and negative inspection findings in a paper to the Commission.
4).
The staff needs to address inter and intra regional consistency in the new process. While the new process willidentify inspections that do not find the same number of issues as other similar inspections, consistency between the regions is not assured with this process. The staff should prepare for Commission consideration their plans for monitoring equity among the regions.
5)
With performance indicators showing a trend of better industry performance, it is not clear to me why Level IV violations have doubled in the past two years. The staff should report to the Commission on why this disparity exists. The staff should continue their efforts to benchmark the new process against existing PIMs. The staff should test the new assessment system to determine the sensitivity of the new system to enforcement, perhaps by a comparison of current PIM data to PIM data from two years ago for the same group of plants. The staff should report to the Commission on whether r
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2 the new process retains the desired safety focus of the assessment process or becomes compliance oriented based on the overemphasis on enforcement.
6)
' The assessment process cannot be separated from the inspection process. The staff should continue their development of the IRAP and develop the necessary change; to the inspection program so that a combined package of changes to the assessment process and inspection program can be presented to the Commission for consideration. Because of the recent changes to the Senior Management Meeting i
process, I am comfortable using that system until the IRAP and corresponding changes '
i to the inspection program can be approved by the Commission.
7)
The assessment process must assure that it provides a method to help focus our recources where they are most needed and can give early warning of declining performance through the use of leading ( technical) indicators of safety penormance.
.j 8)
The staff should provide revised milestone dates for IRAP including a public comment period following Commission review.
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