ML20236X138
| ML20236X138 | |
| Person / Time | |
|---|---|
| Issue date: | 08/03/1998 |
| From: | Callan L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Seale R Advisory Committee on Reactor Safeguards |
| References | |
| ACRS-GENERAL, NUDOCS 9808070163 | |
| Download: ML20236X138 (10) | |
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION t
WASHINGTON, D.C. 20555-0001
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August 3, 1998 Dr. Robert L. Seale, Chairman Advisory Committee on Reactor Safeguards U.S. Nuclear Regula'ory Commission Washington, D.C. 20555-0001
SUBJECT:
PROPOSED IMPROVEMENTS TO THE SENIOR MANAGEMENT MEETING PROCESS
Dear Dr. Seale:
I am responding to your letter of March 13,1998, in which the Advisory Committee on Reactor Safeguards (ACRS) forwarded its views and recommendations following several briefings by the staff on proposed improvements to the senior management meeting process and the integrated review of the assessment process (IRAP).
As the ACRS is aware, on June 30,1998, the staff requirements memorandum (SRM) fcr SECY-98-045 was issued. This SRM approved soliciting public comment on the concept for an assessment process as presented in the Commission paper, with the provision that the Cortmission views be included in the solicitation and evaluation of comments. Specific ACRS views will be considered in an integrated manner with the commission and public comments.
The staff will continue to involve the ACRS in the efforts to integrate the assessment process.
Sincerely, L.
o eph Callan Exe tive Director for Operations b.. fr '
cc Chairman Jackson Commissioner Diaz
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t Commissioner McGaffigan SECY (J (n - G t i 6, i s,;,6
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August 3, 1998 Dr. Robert L. Seale, Chairman Advisory Committee on Reactor Safeguards U.S. Nuclear Reculatory Commission Washington, D.C. 20555-0001 l
SUBJECT:
PROPOSED IMPROVEMENTS TO THE SENIOR MANAGEMENT MEETING PROCESS 1
Dear Dr. Seale:
l l
l am responding to your letter of March 13,1998, in which the Advisory Committee on Reactor Safeguards (ACRS) forwarded its views and recommendations following several briefings by l
the staff on proposed improvements to the senior man::gemer,t meeting process and the integrated review of the assessment orocess (IRAP).
As the ACRS is aware, on June 30,1998, the staff requirements memorandum (SRM) for SECY-98-045 was issued. This SRM approved soliciting public comment on the concept for an assessment process as presented in the Commission paper, with the provision that the Commission views be included in the solicitation and evaluation of comments. Specific ACRS views wiu be considered in an integrated manner with the commission and public comments.
The staff will continue to involve the ACRS in the efforts to integrate the assessment process.
Sincerely, Ob 500 Sig.::j 1 8
L. Jose. L Cnno,, 4 L
p 1 t,oo.,
Executive Director for Operations cc:
Chairman Jackson Commissioner Diaz Commissioner McGaffigan SECY Distribution:
Central Files PIPB R/F PUBLIC NRR Mailroom (GT 980170)
WTravers HThompson PNorry JBiaha EDO DOCUMENT NAME: G:\\SECY2\\ACRSLTR1.WPD
- See previous concurrence. '
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OFFICE l PIPB: DISP lE PIPB: DISP l5 AEOD l E Tech. Ed.
lN PIPB; DISP lN NAME TJFrye
- MRJohnson
- RJBarrett
- BCalurc
- RWBorchardt
- DATE 04/09/98 04/
hy22/98 04/13/98 04/14/98 04/13/98 aggiinsseussumammunusuunni munquemuuuununu==
nummmenesmeman siii=!=le OFFICE DISP:NRR NytR EDO /
NAME FPGillespie
- SW LJh l
DATE 04/14/98 07/ % /98 081 ) /98 OFFICIAL RECORD COPY bW m
Dr. Robert L. Seile, Chiirman Advisory Committee on Reactor Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001
/
SUBJECT:
PROPOSED IMPROVEMENTS TO THE SENIOR MANAGEMENT MEETING PROCESS
/
/
Dear Dr. Seale:
I am responding to your letter of March 13,1998, in which the Advisory' Committee on Reactor Safeguards (ACRS) forwarded its views and recommendations following several briefings by the staff on proposed improvements to the senior managementJn6eting process and the integrated review of the assessment process (IRAP).
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Overall, the ACRS concluded that the staff has not deve op/
ed several critical aspects of the new assessment process in sufficient detail to enable,t e industry and the public to provide usefulinput. As a result, the ACRS recommended that additional developmental work be completed and presented to it for review before soliciting public comment. The response to these recommendations is attached.
As the ACRS is aware, on June 30,1998, the staff requirements memorandum (SRM) for SECY-98-045 was issued. This SRM ap oved soliciting public comment on the concept for an assessment process as presented in t Commission paper, with the provision that the Commission views be included in the solicitation and evaluation of comments. As directed in the SRM, the staff will continue to I,nfolve the ACRS in the efforts to integrate the assessment process.
Sincerely, L. Joseph Callan Executive Director for Operations cc:
Chairman Jackson Commissioner Dieus Commissioner Diaz Commissioner McGaffigan SEC '
Distribution:
Central FAes PIPB R/F PUBLIC NRR Mailroom (GT 980170)
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lN PIPB: DISP lN NAME TJFrye
- MRJohnsonf^g RJBarrett
- BCalure
- RWBorchardt
- DATE 04 04/13/98 DG V 04/13/98 04/14/98 04/13/98 M'mm/09/98 ens - : -
menamannuse n==es==umammanumsmanamena OFFICE /
DISP:NRR D:NRR EDO
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NAME/
FPGillespie
- SJCollins LJCallan DATE 04/14/98 07/
/98 07/
/98 OFFICIAL RECORD COPY I
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Response: The staff agrees that a set of more global perforrr,ance indicators is desirable,. As I
part of the evaluation process for the trending methodology, the staff requested the data for the current set of World Association of Nuclear Operators (WANO) indicators and the Institute of Nuclear Power Operators (INPO) plant performance indicator index from INPO. INPO has agreed to provide on a proprietary basis the data used for the WANO indicators. However, INPO I
has not agreed to supply the performance indicator index information. The staff is continuing discussions with INPO on obtaining the INPO data. The staff also plans to develop risk-based performance indicators that will measure performance at a more global level and be more directly related to safety. As part of this process, the staff intends to work with industry and the public in the development, trial use, review, and finalization of risk-based (rformance indicators. This effort will take several years to complete.
The proposed assessment process developed by the IRAf team is designed and structured so that it can accommodate any new or additional assessmdnt tools that become available in the future. As previously discussed in the response to Rec' commendation 4, the performance l
information (e.g., inspection findings included in the p'lant issues matrix) used as input a the l
g proposed assessment process was arrived at by using process re-engineering techniqu,s to l
determine the necessary inputs to achieve the de' sired outcomes.
Recommendation 8: The ACRS recommende that the assessment process contain strong provisions to ensure that consistent resultsIre obtained among the regions.
/
Response: The concepts for an assessrnent process developed to date contain strong provisions to ensure consistent implem' ntation among the regions. Thorough guidance, staff e
training, and management oversight,will be used to ensure that inspection findings are treated consistently among different plants,in a region. in addition, Headquarters' participation in the annual assessment meetings held in each region will ensure that assessment information is evaluated consistently throughout the agency. These provisions will continue to be developed and will be discussed in more detail by the staff following the public comment period.
/
I
/'
Sincerely, j
/
/
L. Joseph Callan
/
Executive Director j/
for Operations cc: Chairman Jac son Commissioner Dicus Commission'er Diaz Commissioner McGaffigan SECY
/
Distribution:/
Central Files PlPB R/F PUBLIC NRR Mailroom (GT 980170)
AThadani' HThompson PNorry JBlaha EDO l
DOCUMENT NAM'E: G:\\SECY2\\ACRSLTR1.WPD
- See previous concurrence.
To rTceive a coph of this document. indicate in the box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No cop OFFICE PIPB: DISP lE PIPB: DISP lE AEOD l E Tech. Ed.
lN PIPB: DISP lN NAME TJFrye
- MRJohnsor
- RJBarrett
- BCalure
- RWBorchardt
- DATE 04/09/98 04/13/98 04/13/98 04/14/98 04/13/98 OFFICE '
DISP:NRR N
D:NRR EDO NAME FPGillespie
- SJCollins LJCallan DATE 04/14/98 04/
/98 04/
/98 OFFICIAL RECORD COPY L
- .~
Response: The staff agrees that a set of more global performance indicators is desirable. As part of the evaluation process for the trending methodology, the staff requested the data for the current set of World Association of Nuclear Operators (WANO) indicators and the Institute of Nuclear Power Operators (INPO) plant performance indicator index from INPO. INPO has
/
agreed to provide on a proprietary basis the data used for the WANO indicators. However.MPO j
has not agreed to supply the performance indicator index information. The staff is continuing discussions with INPO on obtaining the INPO data. The staff also plans to develop rjsk'-based performance indicators that will measure performance at a more global level and be'more directly related to safety. As part of this process, the staff intends to work with industry,and the public in I
the development, trial use, review, and finalization of risk-based performance indicators. This effort will take several years to complete.
/
The proposed assessment process developed by the IRAP team is designeo r e structured so that it can accommodate any new or additional assessment tools that become, milable in the future. As previously discussed in the response to Recommendation 4, the performance information (e.g., inspection findings included in the plant issu,es matrix) used as input to the proposed assessment process was arrived at by using proc,ess re-engineering techniques to determine the necessary inputs to achieve the desired outcomes.
/
Recommendation 8: The ACRS recommended that the assessment process contain strong provdo.a to ensure that consistent results are obtailied among the regions.
/
Response: The concepts for an assessment p provisions to ensure consistent implementation,rocess developed to date contain strong among the regions. Thorough guidance, staff training, and management oversight will be rised to ensure that inspection findings are treated consistently among different plants in a re,gion. In addition, Headquarters' participation in the annual assessment meetings held in each region will ensure that assessment information is evaluated consistently throughout the a~gency. These provisions will continue to be developed l
and will be discussed in more detail py the staff following the public comment period.
dir)c/
- erely, I
/
L. Joseph Callan i
Executive Director for Operations cc: Chairman Jackson Commissioner Dicus Commission' r Diaz e
l Commissiofier McGaffigan l
SECY
/'
i Central Files PUBLIC l
DOCUMENT NAME: G:\\SECY2\\ACRSLTR1.WPD
- See previous concurrence.
l To rvceive a copy of this document, indicate in the box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy OFFICE PIPB: DISP l E PIPB: DISP l E lAEOD
}E Tech. Ed.
lN PIPB: DISP lN NAME TJFrye
- MRJohnson
- RJBarrett
- BCalure
- RWBorchardt
- DATE 04/09/98 04/13/98 04/13/98 04/14/98 04/13/96 mmmmmmmme emessesumung =
OFFICE DISP:. _
W D:NRR EDO NAME FPGillbgEV SJCollins LJCallan DATE 04/ W /98 04/
/98 04/
/98 OFF;CIAL RECORD COPY
4
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desirable. As part of the evaluation process for the trending methodology, the staff '
requested the data for the present set of World Association of Nuclear Operators (WANO) indicators and the Institute of Nuclear Power Operators (INPO) plant performance indicator I
index from INPO. They have agreed to provide on a proprietary basis the data for the WANO indicators. However, INPO has not agreed to supply the performance indicator index
)
information. The staff is continuing discussions with INPO on obtaining the INPO performance indicator index data. The staff also plans to develop risk-based performance indicators which will measure performance at a more global levepend be more directly related to safety. As part of this process, the staff intends to ir)teract and work with industry and the public in the development, trial use, review, and fina 'tation of risk-based performance indicators. This effort will take several years complete.
1 The propoued assessment process developed by the AP team is designed and structured i
so that it can accommodate any new or additional a essment tools available in the future.
I As previously discussed in the response to recom endation 4, the performance information l
(e.g., inspection findings included in the plant is es matrix) used as input to the proposed l
assessment process was arrived at using pro ss re-engineering techniques to determine l
the necessary inputs to achieve the desired tcomes.
l I
Recommendation 8: The ACRS recommend that the assessment process contain strong l
provisions to ensure that consistent results re obtained among the Regions.
l I
Response: The concepts for an as ssment process developed to date contain strong provisions to ensure consistent im ementation among the regions. Thorough guidance, l
staff training, and management ersight will be used to ensure that inspection findings are I
consistently treated among diff ent plants in a region. In addition, headquarters participation in the annual ass ssment meetings held in each region will ensure that assessment information is e aluated consistently across the agency. These provisions will l
continue to be developed d will be discussed in more detail by the staff following the public comment period.
/
/
/
L. Joseph Callan
/'
Executive Director for Operations
/
cc: Chairman Jackson Commissioner Dicus Commissioner'r Diaz missioner McGaffigan l
SECY j
w 4ral Files PUBLIC /
/
l DOCUMENT NAME: G:\\SECY2\\ACRSLTR1.WPD
- See previous concurrence.
/
T@ receive a copy of this document, indicate in the box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy OFFICE PIP 8: DISP l E PlPB: DISP l E AEOD l E PIPB: DISP lbl DISP:NRR l
NAME TJFrye*
MRJohnson
- RJBarrett
- RWBorchardt.(M y FPGillespie DATE 04/09/98 04/13/98 04/13/98 04// 3 /98 Mf-- 04/
/98 OFFICE D:NRR EDO l
l Tech Rjitts N NAME SJCollins LJCallan MCal ortN-M DATE 04/
/98 04/
/98 04/N /98
- * ^
OFFICIAL RECORD COPY
4 INPO has not agreed to supply the performance indicator index information. The st is continuing discussions with INPO on obtaining the INPO performance indicator ind x data. The staff also plans to develop risk-based performance indicators which will measure erformance at a more globallevel and be more directly related to safety. As part of this proc s, the staff intends to interact and work with industry and the public in the development, 'al use, review, and finalization of risk-based performance indicators. This effort will take veral years to complete.
The proposed assessment process developed by the IRAP tearp is designed and structured so that it can accommodate any new or additional assessmen 4ools available in the future.
As previously discussed in the response to recommendation
, the performance information (e.g., inspection findings included in the plant issues matri used as input to the proposed assessment process was arrived at using process re-en neering techniques to determine the necessary inputs to achieve the desired outcomes Recommendation 8: The ACRS recommended that th ssessment process contain strong provisions to ensure that consistent results are obtain 'd among the Regions.
Response: The concepts for an assessment rocess developed to date contain strong provisions to ensure consistent implementat' n among the regions. Thorough guidance, staff training, and management oversight I be used to ensure that inspection findings are consistently treated among different plan in a region. In addition, headquarters participation in the annual assessment eetings held in each region will ensure that assessment information is evaluated nsistently across the agency. These provisions will continue to be developed ar d will be iscussed in more detail by the staff following the public comment period.
L. Joseph Callan l
l Executive Director for Operations cc: Chairman Jackson Commissioner Dieus Commissioner Diaz Commissioner McGaffigan SECY Central Files l
PUBLIC j
DOCUMENT NAME: G:\\SEC \\ACRSLTR1.WPD
- See previous concurrence.
To receive a copy of this document, indicate in the box: "C" = Copy without enclosures "E" = Copy with enclosures *N" = No copy OFFICE PIPB: DISP 16 PIPB: DISP l E.
AEOD l 9-PIPB: DISP l
DISP:NRR l
NAME TJFrye
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DATE 04/
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3 of financial stress that may cause or contribute to an adverse effect on plant performance.
These conclusions are documented in the AEOD report, " Draft Special Study-Methodology For identifying Financial Variables For Trend Analysis." The staff will evaluate public comment on the use of financialindicators in the assessment process during the upcoming IRAP public comment period.
Recommendation 7 The staff agrees that a set of more global performance indica s is desirable. As part of the evaluation process for the trending methodology, the aff requested the data for the present set of WANO indicators and the INPO plant perfo ce indicator index l
from the Institute of Nuclear Power Operations. INPO has agreed to pro e on a proprietary basis the data for the WANO indicators. However, INPO has not agr d to supply the performance indicator index information. The staff is continuing di ussions with INPO on 1
obtaining the iNPO performance indicator index data. The staff so plans to develop risk-based I
performance indicators which will measure performance at a ore globallevel and be more directly related to safety. As part of this process, the staffir ends to interact and work with industry and the public in the development, trial use, re performance indicators. This effort will take several y / view, and finalization of risk-based rs to complete.
The proposed assessment process developed by)he IRAP team is designed and structured so that it can accommodate any new or additional assessment tools available in the future. As previously discussed in the response to recorpinendation 4, thu set of performance indicators (e.g., inspection findings included in the plant issues matrix) used as input to the proposed assessment process was arrived at usinp$rocess re-engineering techniques to determine the necessary inputs to achieve the desired outcomes.
/
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Recommendation 8 The concepts or an assessment process developed to date contain strong provisions to ensure consistent i pigmentation among the regions. Thorough guidance, staff training, and management ovef ight will be used to ensure that inspection findings are consistently treated among d f'ferent plants in a region. In addition, headquarters participation in the annual assessment m 6) tings held in each region will ensure that assessment inform evaluated consistently a ss the agency. These provisions will continue to be developed and will be discussed in mo detail by the staff following the public comment period.
ck a% & rdo cc: Commissioner Dicus Commissioner Diaz Commissio r McGaffigan SECY
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l To rrceive a copy of this document. Indicate in the box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy OFFICE PIPB: DISP lE[
PIPB: DISP l
PIPB: DISP l
DISP:NRR l
AEOD l
NAME
.TJFrye -6p MRJohnson RWBorchardt FPGillespie TTMartin DATE
/ 04/ 9 /98 04/
/98 04/
/98
. 04/
/98 04/
/98 OFFICE D:NRR EDO l
NAME SJCollins LJCallan DATE 04/
/98 04/
/98 OFFICIAL RECORD COPY u____________
ACTION Wahet Me ru-I.
I EDO Principal Correspondence Control TROM:
DUE: 04/20/98 EDO CONTROL: G980170 DOC DT: 03/13/98 TINAL REPLY:
R. L. Seale ACRS I
- TO:
Chairman Jackson
'FOR SIGNATURE OF :
- GRN CRC NO: 98-0232
' 2*"'
I DESC:
ROUTING:
PROPOSED IMPROVEMENTS TO THE SENIOR MANAGEMENT MEETING PROCESS Thadani Thompson Norry plaha Burns DATE: 03/20/98 Mitchell, OEDO Knapp, RES l ASSIGNED TO:
CONTACT:
Paperiello,NMSS Martin, AEOD NRR Collins ACRS File gfS
'SPECIAL INSTRUCTIONS OR REMARKS:
@[
Prepare response to ACRS for EDO signature. Add 6
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Commissioners and SECY as cc's.
s-NRR ACTION:
DISP:Borchardt NRR Received:
h 20, 998 NRR ROUTING 11 traglia s%*ron DUE TO NRR D' RECTOR'S OFFICE Tra v e r'.,
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Mailroom BY E
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OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET l*
PAPER NUMBER:
CRC-98-0232 LOGGING DATE: Mar 16 98 ACTION OFFICE:
EDO AUTHOR:
R.L SEALE AFFILIATION:
ADVISOta COMMITTEE ON REACTOR SAFEGUARDS ADDRESSEE:
CHAIRMAN JACKSON LETTER DATE:
Mar 13 98 FILE CODE: OM-7 ACRS
SUBJECT:
PROPOSED IMPROVEMENTS TO THE SENIOR MANAGEMENT MEETING PROCESS ACTION:
Appropriate DISTRIBUTION:
CHAIRMAN, RF SPECIAL HANDLING: NONE CONSTITUENT:
NOTES:
DATE DUE:
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SIGNATURE:
DATE SIGNED:
l AFFILIATION:
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EDO -- G980170
>a me UNITED STATES 8
NUCLEAR REGULATORY COMMISSION o
U I
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS k
WASWNGTON D. C. 205$5 March 13, 1998 The Honorable Shirley Ann Jackson Chairman U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001
Dear Chairman Jackson:
SUBJECT:
PROPOSED IMPROVEMENTS TO THE SENIOR MANAGEMENT MEETING P During the 448th and 449th meetings of the Advisory Comittee on Reactor Safeguards. February 5-7 and March 2-4, 1998. respectively, we met with l
representatives of the NRC staff and the Nuclear Energy Institute (NEI) to discuss proposed improvements to the Senior Management Meeting (SMM) process and the efforts of the Integrated Review of Assessment (IRA) Team. Our Subcommittee on Plant Operations discussed these matters during a meeting on February 3,1998.
j We also had the benefit of the documents referenced.
The proposed combined single process is an improvement over the existing three separate but related assessment processes. The new assessment process proposed by the IRA Team will retain many of the positive attributes of the current Also, the new process will not preclude taking appropriate regulatory process.
action in a timely manner and will be closely aligned with the NRC's enforcement policy.
Recommendations We recommend that the documents being developed from the IRA effort not be a
released for public comment until the staff develops a set of explicit i
program requirements, quantitative if possible, for the plant performance assessment, completes its work on.the Assessment Decision Logic Model, and presents both to the Comittee for its review.
l i
The overall objectives stated in Attachment 1 of the draft Commission a
paper, which was received on February 18. 1998, are not sufficiently specific to allow evaluation of the proposed assessment process.
We recommend the development of specific objectives and performance measures I
that can be applied directly to this process.
The Assessment Decision
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'93032 Q'c1C?" W
2
.4 Logic Model should show how the selected decision options noted in the draft paper will utilize these performance measures.
We recommend that the staff work through at least one example that uses e
[
. actual inspection reports. to demonstrate that the implementation of the l
Assessment Decision Logic Model is fully understood and workable.
This l
example should include the conversion of the report findings to numerical scores, the processing of these scores through the model, and the decision reachel We would like to review the example before public coments are solicited.
m We recommend that the six categories of the proposed template be evaluated to determine that they are at the appropriate level and whether they overlap unnecessarily. This evaluation must be done in the context of the Assessment Decision Logic Model, a
We recommend that the staff complete the development and testing of the tools for assessing management and operational effectiveness.
The l
Committee is interested in discussing the results of this effort with the l
staff when they have completed their work, a
We recommend that economic indicators in their present form not be used in the decisionmaking process at this time and that additional research be performed.
Indicators that measure plant performance at a more global level, such as l
s l
those discussed by the industry, would be more useful.
We would like to l
see the staff and NEI agree on a set of performance indicators.
We recommend that the assessment process contain strong provisions to m
ensure that consistent results are obtained among the Regions.
i l
Discussion The Committee has had discussions with the staff and NEI on the status of the NRC Integrated Review of Assessment (IRA) process for operating nuclear power plants.
Although the staff has acted upon some previous Committee recommendations, additional work remains to be done.
As discussed in our September 10, 1997 report to the Commission, the development of a hierarchical structure of program requirements and decision logic for the assessment process is important to the design of the new process.
3 In transitioning from a process that had three separate assessments -- systematic assessment of licensee performance (SALP) plant performance review (PPR) and the senior management meeting (SMM) -- to a single assessment process, it is essential to ensure that the requirements of the agency will still be met. These requirements for the single process should be expressed in explicit terms.
quantitative if at all possible. A list of these requirements would be useful for evaluating alternate approaches to the assessment process.
The staff is assessing the inputs to the Plant Issues Matrix that include most of the licensee performance indicators from the existing assessment process. We believe that these indicators measure performance at such a low level that the nexus between this performance level and overall plant safety is not evident.
We believe that the use of indicators that measure performance at a more global level (such as those discussed by the industry) would be more useful. We would like to see the staff and NEI agree to a set of performance indicators.
This work could be accomplished during the workshops planned by the NRC staff.
]
1 l
At present. the staff has found that economic indicators alone are not useful i
plant performance indicators. They may have value when used in conjunction with technical ' plant performance indicators but in their present form are not essential for decisions that have to be made.
Because economic pressures arising from deregulation may have a significant effect on long-term safety performance, additional research on economic indicators is needed.
The new assessment process moves the evaluation and decisionmaking back to the l
Regional Offices, where it was before the Senior Management Meeting process began. A key requirement for the new process is that the tools employed, i.e..
l the Plant Issues Matrix and Assessment Decision Logic Model, contain provisions l
to ensure that consistent results are obtained among the Regions.
l The staff has not completed its work on the Integrated Assessment Process and has i
not developed an agreed-upon set of requirements for the new process.
The process by which the plant performance template leads to the formulation of decisions is not apparent. Development of a hierarchical structure begins with the desired outcome, considers alternate ways to achieve it, and then works down to the most effective means to ensure this outcome. The Committee has yet to see i
such a design process applied to this issue. We do not believe the staff will receive useful public comment on the proposed IRA documents as they now exist.
We recomend that the documents not be released for public comment until the l
staff develops a set of requirements for the plant performance assessment
1,-
4
!8 program. describes the Assessment Decision Logic Model in sufficient detail, and presents both to the Comittee for its review.
I Sincerely, R.
L.
Seale Chairman i
References:
1.
Draft Comission paper from L.-
Joseph Callan, Executive Director for Operations. NRC, to the Commissioners,
Subject:
Update on the Status of the Integrated Review of the NRC Assessment Process for Operating Commercial Nuclear Reactors, received February 18. 1998. (Predecisional) 2.
Draft report (LA-UR-97-4911) dated December 17, 1997. Prepared by Los e
Alamos National Laboratory for Office of Nuclear Reactor Regulation,
" Integrated Review of the Nuclear Regulatory Commission Assessment Process for Operating Commercial Nuclear Reactors," Working Report 3: Conceptual Design of the Revised Assessment Process.
(Predecisional)
L 3.
Note dated February 27,1998, from Jack E.
Rosenthal, Office for Analysis and Evaluation of Operational Data, NRC, to Michael T.
Markley, ACRS, transmitting Draft Report AE0D/S98-xx, Prepared by William S.
- Raughley, AE0D, "Special Study Identifying Financial Indicators." dated February 27, 1998.'(Predecisional) 4.
Memorandum dated January 20.1998, from Richard J.
Barrett. AE00,- to John T.
Larkins. ACRS, transmitting AE00 draft report. " Interim Report on the Development of the Plant Performance Template," dated January 22, 1998.
(Predecisional) 5.
Memorandum dated November 6,1997, from C. E. Rossi, AEOD, to Addressees,
)
Subject:
Request for Review of Interim Report - Development and findings of the Performance Trending Methodology.
(Predecisional) 6.
Memorandum dated February 10,1998, from John C.
Hoyle. Secretary of the Comission, to L.
Joseph Callan Executive Director for Operations. NRC.
Subject:
Staff Requirements - Briefing on Operating Reactors and Fuel Facilities. January 21, 1998 7.
Memorandum dated October 24. 1997, from John C.
Hoyle, Secretary of the Commission, to L.
Joseph Callan, Executive Director for Operations, NRC.
Subject:
Staff Requirements - Briefing on Improvements in Senior Management Assessment Process for Operating Reactors September 19, 1997.
8.
Report dated September 10, 1997, from R.
L.
Seale, Chairman. NRC, to Shirley Ann Jackson, Chairman, NRC,
Subject:
Staff Action Plan to Improve the Senior Management Meeting Process L
l.
5 9.
Memorandum dated September 11. 1997, from John T.
Larkins ACRS. to the Commissioners.
Subject:
ACRS Letter on the Senior Management Meeting Process. September 11, 1997.
l 4
1
.