ML20236H432
| ML20236H432 | |
| Person / Time | |
|---|---|
| Issue date: | 05/19/1998 |
| From: | Mcgaffigan E 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 9807070207 | |
| Download: ML20236H432 (3) | |
Text
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l NOT ATIO N VOTE RESPONSE SHEET I
l TO: John C. Hoyle, Secretary -
FROM: . COMMISSIONER MCGAFFIGAN
SUBJECT:
SECY-98-045 - STATUS OF THE INTEGRATED REVIEW OF THE NRC ASSESSMENT PROCESS FOR OPERATING COMMERCIAL NUCLEAR REACTORS (SRM 9700238)
Approved X' Disapproved Abstain Not Participating Request Discussion i
COMMENTS:
See attached coments.
N SIGNATURE /0 0 U Riase Vote / >< / ) *l , ll4 DATE U Withhold Vote / /
l Ent: red on "AS" Yes K No W*lB*EBM _
i
e Commissioner McGaffican's Comments on SECY-98-045 As I indicated at the April 2.1997 Comission briefing. I have major concerns with the staff proposal for integrating the various NRC assessment processes
'for commercial nuclear reactors. I appreciate the staff's effort to think
~outside the box" and the initiative to come to the Comission and stakeholder early to take a sounding on whether the staff proposal is acceptable before too many resources are expended. But in the end I believe the staff may have reached too far.
-I am doubtful that the process outlined by the staff is implementable or that it will save resources. Scoring every plant issues matrix (PIM) item in an assessment template with at least sixteen elements in the matrix in a consistent fashion with quasi-adjudication on each score is a monumental task.
The staff has tried to narrow the task by not including good or neutral assessments in the PIM and by not attempting to distinguish excellent or superior performance from performance that meets regulatory requirements with less robustness. I disagree with both of these " boundary conditions ~ /
" fundamental principles." I also disagree with the " fundamental principle" that "any new process must be closely aligned with the enforcement policy."
By focusing anly on negative items in the PIM. the assessment process and the ,
enforcement process almost become one and the same. It is only at the annual I regional and headquarters staff meetings behind closed doors where additional information such as performance indicators and AE00 trending methodology are compared and reconciled with the template assessment.
I should also note that I disagree with the need for an additional " management effectiveness". category in the performance template as discussed in my vote on SECY-98-059.
.I understand that the staff considered a less radical approach to streamlining the assessment process during its deliberations. I would hope that that option might be revived during the coment period. I personally would support '
aligning the PPR. SMM and SALP processes in a straightforward manner. I could imagine semi-annual PPRs. an annual SMM (incorporating the ongoing improvements from the Arthur Anderson follow-up work), and an annual update on ,
SALP scores done at the same time as the SMM preparations, all utilizing the 4 same inspection reports, performance indicators, trending methodologies, etc.
The PIM would not be scored and it would include positive as well as negative findings. The current four SALP categories and the three grades (superior.
good, acceptable) would be maintained. The Comission would endorse the proposed actions resulting from the SMM by a negative consent process, as l
2 previously proposed by Commissioner Diaz. Aligning and integrating the three existing processes to save resources in this or a similar fashion appears to me to have a greater chance to succeed in implementation than the staff
. proposal.
This all said. :I am not~ opposed to seeking formal public comments on the proposal. as requested by the_ staff, if the staff still believes that that u would be~ worthwhile in light of the' comments received thus far (from ACRS..
UCS. the Commissioners and other stakeholder). The staff can not, however.
possibly keep'to the schedule proposed in the paper. The staff will likely need a second round.of comments if the proposal is significantly altered as a result of the comment process, and implementation of other than modest changes in the' existing processes (such as an annual S M) will likely prove impossible in fiscal year 1999.
r '
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. ja uc UNITED STATES
' * [4' *k NUCLEAR REGULATORY COMMISSION WASHINGTON. O C. 20555-0001
- ' ,j June 30, 1998 dFFICE OF THE-f: . SECRETARY l- i
- y J
L Joseph Callan 0 MEMORANDUM TO: . %
Executive Dire or for Operations
' FROM: -John y,Ncehryl y
SUBJECT:
STAFF REQUIREMENTS - SECY-98-045 - STATUS OF.THE .
INTEGRATED REVIEW OF THE NRC ASSESSMENT PROCESS
- FOR OPERATING COMMERCIAL NUCLEAR REACTORS i The Commission has approved the staff soliciting public comments on a proposed new L
y . assessment process as presented in SECY-98-045, as guided by the following general principles (the Commission desires that this SRM, the Commission voting record, and the comments of the Commissioners be included in the Federal Register Notice soliciting public
, comments):
- 1. While the ' enforcement program is a valuable regulatory tool,'the Commission' does not
.- desire that enforcement be used as a " driving force" of the assessment activities.
. 2. The Commission supports the position that the staff continue to identify positive, as well as negative findings in inspection reports (this should not be construed as requiring inspectors to strive for a " balance" of positive and negative findings in their reports).
- 3. The Chmmission does not support the transition to an assessment process based primarily on. a quantitative " scoring" of plant issues matrix entries at this time. The Commission is interested in ~ obtaining a quantitative " input" to the assessment process, and desires additional feedback on potential grading mechanisms during this public comment period.
.: 4.' ~ The Commission supports the development, if possible, of leading or, at least, concurrent indicators that can identify emerging s,afety problems. The Commission l recognizes that neither the staff nor industry has thus far been successful in developing leading indicators, and resources devoted to this effort need to be commensurate with .
the probability of success.
i l 5. The definitions for the performance rating categories should not be " color coded".
- SECY NOTE
- SECY 045 was released to the public at the Commission Meeting on April 4,1998. This SRM and the Commission voting record will be made publicly available 5 working days from the date of this SRM.
1
.~ . .
In addition to the processes discussed in the paper, the staff should remain open during the
' public comment period to less dramatic changes which might integrate the existing processes in
- a manner which saves resources and may be more readily implemented.
The staff snould continue to involve the ACRS in the efforts to integrate NRC's assessment procest The staff should inform the Commission of the results of their review of public comments and their recommendation for changes to the assessment process. The staff should address how the new process will ensure inter and intra regional consistency and the equitable treatment of plants receiving varying levels of inspection effort. The staff should include any conceptual-changes to the inspection program needed to conform with the new assessment process.-
L (EDO); - (SECY Suspense: 1/1/99) -
The staff should report to the Commission the reasons that Level IV violations have doubled in the past two years while performance indicators show an improving trend of industry
. performance.-
. (EDO); (SECY Suspense: -7/31/98;
,The.results and proposed actions associated with the senior management review should be .
- forwarded to the Commission for an expedited (three day) review under.a negative consent - .
process'under which, absent a Commission majority to the contrary, the result would be for the L staff's actions to go forward as proposed.
- (EDO) -
(SECY Suspense: 7/1/98) .-
In fiscal year 1999, the staff should transition to an annual senior management review.-
(EDO) -
.(SECY Suspense: 1/1/99) cc- Chairman Jackson Commissioner Dicus Commissioner Diaz -
- OlG '
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Office Directors, Regions, ACRS, ACNW, ASLBP (via E-Mail) '
PDRL DCS'
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