ML20199F775
| ML20199F775 | |
| Person / Time | |
|---|---|
| Issue date: | 01/29/1998 |
| From: | Collins S NRC (Affiliation Not Assigned) |
| To: | Brian D AFFILIATION NOT ASSIGNED |
| References | |
| NUDOCS 9802040110 | |
| Download: ML20199F775 (8) | |
Text
. _ _ _
January 29, 1998 Ms. Danielle Brian, Executive Director Project on Government Oversight 1900 L Street, NW, Suite 314 Washington, DC 20036-5027
SUBJECT:
MANAGEMENT OF SAFETY ISSUES 1
Dear Ms. Brian:
I am responding to your letter of December 2,1997, to Chairman Jackson of the Nuclear Regulatory Commission (NRC) concerning the management of safety issues and the maintenance of tracking systems. In your letter, you asked about NRC's current progress l
in the management of safety issues. Reports on tha status of generic safety issues vere i
previously sent to Project on Government Oversight (POGO) in a March 29,1996, letter from Frank P. Gillespie to Scott Amey. An update to those reports is enclosed in this letter. Please l
note that, as with the reports sent earlier, the summary is generated from a working file and l
that no overall quality check has been made for issues that have open items. Issues that are statused as 100% complete have undergone a quality assurance process to ensure proper closeout. Also, the staff has enclosed a description of the process for managing generic safety issues and a response to the recommendations in your December 2,1997, letter.
Your concern about this important area of regulation is appreciated. I have designated Joseph Birmingham of my staff as the contact for this letter. He may be reached at 301-415-2829.
Sincerely, Orighalsignedby SamuelJ. Collins Samuel J. Collins, Director Office of Nuclear Reactor Regulation I
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Enelosures: As stated PFp3 DISTRIBUTION: See attached page W~
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DOCUMENT NAME: G:\\JLB\\POGO_LTR.yLB, GREEN TICKET 970854 JM OFFICE PM:PGEB()(f) SC:PGEf[
(A)BC:PG)iB, (A)D:DRPM hN NAME JBirmingh[m:sw FAkstulehicz TEssig [ JRk hue DATE 01/26/98 01r,L(/98 01/26/98 01/*3 /98 01TLQ98 OFFICIAL OFFICE COPY ll!!ll!Ill!I1111111!!I e
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NRR Mailroom (w/ incoming)(GT 970854)
LCallan AThadani HThompson PNorry JBlaha SBurns, OGC JLieberman, OE E
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j NUCLEAR REGULATORY COMIAISSION WASHINGTON, D.C. 30666 4 001
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January 29, 1998 Ms. Danielle Brian, Executive Director Project on Government Oversight 1900 L Street, NW, Suite 314 Washington, DC 20036-5027
SUBJECT:
MANAGEMENT OF SAFETY ISSUES
Dear Ms. Brian:
I am responding to your letter of December 2,1997, to Chairman Jackson of the Nuclear Regulatory Commission (NRC) conceming the management of safety issues and the maintenance of tracking systems, in your letter, you asked about NRC's current progress in the management of safety issues.. Reports on the status of generic safety issues were previously sent to Project on Government Oversight (POGO) in a March 29,1996, letter from Frank P. Gillespie to Scott Amey. An update to those reports is enclosed in this letter. Please note that, as with the reports sent earlier, the summary is generated from a working file and that no overall quality check has been made for issues that have open items. Issues that are statused as 100% complete have undergone a qudity assurance process to ensure proper closeout. Also, the staff has enclosed a description of the process for managing generic safety Issues and a response to the recommendations in your December 2,1997, letter.
Your concem about this important area of regulation is appreciated. I have oesignated Joseph Birmingham of my staff as the contact for this letter. He may be reached at 301-415-2829.
Sincerely, or Office of Nuclear Reactor Regulation
Enclosures:
As stated Y
Summary of the Status of Safety issues (From the Safety issues Management System, January 23,1998)
The status of the four types of generic safety issues tracked by the NRC staff is provided below:
Unresolved Safety lasue (USI)
There were seven USIs with either open plant implementation or verification fields. Most of the USIs were open to track Browns Ferry (BF), except for USI A-46, " Seismic Qualification of Equipment in Operating Plants," which is tracking 58 plants as not implemented and 65 plants as not verified.
Three Mile Island lasue (TMI)
There were 15 TMI issues identified as not implemented and 10 TMl issues identified as not verified. These were all for BF-Unit 1 except for issue Ill, d.3.4.3, " Control Room Habitability-l Implement Modifications," which also included Millstone-1, and Zion-1 and -2.
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Generic Safety lasue (GSI)
There were 9 GSIs (13 plants) identified as not implemented and 5 GSis (18 plants) identified as not verified, Multinlant Actions (MPA)
There were 26 MPAs identified as not yet implemented by all plants and 8 MPAs identified as not verified (18 of the not implemented MPAs have been verified or did not require verification),
Of the 26 MPAs identified as not yet implemented 16 were open for only 1 plant. The more recently initiated MPAs had a much higher number of plants identified as not implemented, e.g.,
the MPA for Bulletin 96-02 had 100 plants identified as not yet implemented.
. The staff notes that the number of safety issues identified in SIMS as not yet implemented and the number of safety issues identified as not yet verified has been reduced since the response to POGO in March 1996. This is particularly noticeable in the reduced number of plants not yet verified. The staff is looking into means to make the entry of completed temporary inspections a more timely update of the SIMS database.
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NRC Process for Management of Generic Sa'ety issues Several1,' pes of generic safety issues are managed by the NRC: (1) issues identified as Generic Safety issues (GSis) that have been formally transmitted to the Office of Nuclear Regulatory Research (RES) for priontization and technical resolution, (2) unresolved safety issues (USIs) that have also been sent to RES for prioritization and technical resolution, (3) issues that arose from the accident at Three Mile Island Nuclear Station in 1979 (TMI items),
and (4) generic safety issues discussed in NRC generic communications that require certa'n licensees to provide a response or to perform actions. Thesu types of generic issues are tracked as multi-plant actions (MPAs). Other generic activities that arise from the staff's review of safety data are identified as generic communication and compliance activities (GCCAs).
On December 19,1995, the staff of the Nuclear Regulatory Commission (NRC) briefed the Commission on mechanisms for addressing generic safety issues. After this briefing, the Commission issued a staff requirements memorandum (SRM) on January 19,1996, that directed the staff to ensure that each NRC office understood its role pertaining to generic safety issues. The SRM also stated that there should be orie agency-wide generic issue tracking system. The staff has developed an integrated process for managing generic safety issues that has improved the overall timeliness for identification and resolution of generic safety issues.
The staff plans to improve the manner in which verification of licensee actions is entered into 'he data management systems The systems for managing generic or potentially generic safety issues are described below:
The Events Trackina System (ETS) l ETS is a data system used to track events of potential safety significance identified during NRC's organized review of incoming safety data. Evaluation of some issues tracket in ETS may determine that a generic communication is reg ' ired and result in an MPA being developed. A few issues may be sent to RES for evaluation as potential j
GSis.
The Workload Information and Schedulina Proaram (WISP)
WISP is a data system used to organize, schedule, and audit the progress of work within the Office of Nuclear Reactor Regulation (NRR). Individual work tasks within NRR are tracked by technical assignment control (TAC) numbers. MPAs are assigned a TAC number and are tracked in WlSP.
The Reaulatorv Information Trackina SystemjRITS)
RITS is a data system that documents staff hours and the status of all actions within NRR. RITS receives input from several subsystems and interfaces with WISP. The TAC system is a subsystem within RITS.
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2-The Safety issues Manaoement System (SIMSJ SIMS is a data system used to collect, tracM, and retain generic and plant-specific data on various safety or regulatory issues. GSis, USls, TMI items, and MPAs are tracked in SIMS. SIMS is automatically updated from WISP for issues with TAC numbers. If no TAC number exists, SIMS is updated by the NRR SIMS Coordinator. NRR Office Letter 501, " Procedures for Generic Safety issues and Unresolved Safety issues, " and the related users' manual, " Safety issues Management System (SIMS)," provide policies and procedures for using and updating information related to GS!s and USIs in SIMS.
The Generic issue Manaoement Control Svstem (GIMCS)
GIMCS is a data system used by RES to issue qusrterly reports on the status of GSis and other generic issues tracked 11MS.
NUREG-0933. "A Prioritization of Generic Safety Issues" NUREG-0933 is a periodic report on the status of GSis, USls, and other types of generic l
issues. NUREG-0933 also lists closed GCCAs. NUREG-0933 is issued approximately l
every 6 months.
The above data systems and repnrts are tools for tracking and publishing the statu,, d 'sentified
- generic safety issues.
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The process for review of incoming safety data to identify safety issues is described in NRC l
Management Directive 8.5, " Operational Safety Data Review," NRR Office Letter 503,
" Procedure for Integrated identification, Evaluation, Prioritization, Management, and Resolution of Generic issues." These procedures prescribe the data to be reviewed, the process for review and assessment of the data, and the means for documenting initial and final regulatory actions including issuance of generic communications. For generic communications requiring licensaes to respond or to take actions, a determination is made by the staff for the need to track the implementation and verification of those responses or actions by an MPA. MPAs are tracked in the WISP and SIMS data systems.
NRR Office Letter 303, "NRR Office Workload Procedure = Manual," prescribes the process by which identified generic safety issues, including Cf.e, era amered into WISP, RITS, and SIMS and updated. The procedure describes the process by which project managers, technical staff, and region based inspectors document their actions, including the review of licensee responses and the verification of licensee actions. As the elements of an MPA are completed, the information is entered into WISP or RITS. In general, updating the fields in WISP and RITS automatically updates the corresponding field in SIMS. An exception is the closeout of temporary inspections (Tls) which are entered separately from WISP or RITS. The staff is looking into a method to make updates in SIMS for closed Tis more automatic.
As ar, ategrated system, the processes for management of safety issues promote the positive tracking of generic safety issues from the point of identification to the pcint of closure.
. l Comments on POGO Recommendations The following information pertains to the recommendations in your letter.
1.
Update databases detailing the status of safety issues at nuclear power plants.
The staff has placed increased emphasis on timely updates of the databases that detail safety issue status. As a result, the number of safety issues identified as not yet implemented and the number of safety issues not yet verified by the NRC has been reduced. The staffintet.ds to continue this emphasis on timely updates and as a consequence expects the databases to more accurately reflect the status of safety issues. A summary of the status of the various generic safety issues is provided in this enclosure.
2.
Create time limits for plants to implement NRC resolutions for safety issues. Impose penalties if these time limits are not adhered to.
When NRC issues a generic communication requesting licensees to respond or to take actions regarding a safety issue, a time period for the response is usually specified.
Because of the differences in design and operation of plants, licensees are generally requested to propose a schedule within which any requested actions will be implemented. Additionally, licensees may propose altemative actions that are more suitable to the operation and configuration of their plant. As appropriate, these l
attemative proposals are reviewed by the project and technical staff for acceptability.
The NRC may, in accordance with NRC procedures, impose penalties for licensees that fail to comply with NRC requirements.
3.
Require NRC verification of implemented licensee actions within a reasonable time.
The NRC verifications of licensee actions for generic safety issues are implemented in an expeditious manner consistent with the need for inspection and the safety significance of the issue. This is accomplished by incorporating inspections to verify licensee actions into the Master Inspection Plan for each region so that verifications are implemented consistent with the availability of the item to be inspected, the urgency for the inspection, and the availability of NRC resources. Because past updates of the SIMS database for completed verifications have not been timely, the staff is working to make updates to the SIMS database more automatic.
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DUE: _12/22/97 EDO CONTROL: G970854 DOC DT: 12/02/97 Daniolle Brian FINAL REPLY:
Projcct on Government Oversight Ipes dd g'^'J sbPW TO:
Chairman Jackson FOR SIGNATURE OF :
ROUTING:
SAFETY ISSUES AT NUCLEAR REACTORS Callan Thadani Thompson Norry Blaha DATE: 12/11/97 Burns Lieberman, OE Merschoff, RIV ASSIGN".D TO:
CONTACT:
l NRR Collins SPECIAL INSTRUCTIONS OR REMARKS:
Put EDO and Chairman on for concurrence.
Chairman's office to review response prior to dicpatch.
Rof. G970596.
FlRR RECEIVED:
DECEMBER 12, 1997 NRR ACTION:
DRPM:R0E ACTION
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December 2,1997 The Honorable Shirley A. Jackson United States Nuclear Regulatory Commission Washington, DC 20555-0001
Dear Chair Jackson:
The Project On Government Oversight (POGO) is informing the local media and the public, in the aress surroaMing nuclear reactors, about unimplemented and unverified "high priority" safety issues.
As we discussed in our February 11,1997 meeting with you, "high priority" safety issues go unfixed i
for nearly twenty years before, if ever, being ftxed.
On August 12,1997, POGO sent you an update of our 1996 report, "Who The Hell Is Reculating Whom?'The NRC's Abdication Of Resoonsibility. Our update documented the Nuclear Regulatory Commissions's (NRC) lack of progress in fixing these safety deficiencies.
However, a recent comment made by Breck Henderson, an NRC spokesperson in Arlington, Texas, heightens our concern about this lack of process. The article in which he made this comment is attached. NRC databases detail the current status of safety issues at every plant in the United States.
In reference to an unverified "high priority" safety issue (Station Blackout -- A-44) at Washington Nuclear 2, Mr. Headerson stated that for a decade or longer the NRC has not cleared its database.
The NRC spokesperson stated,"We had this on our to-do list - for a while," He added that the NRC oever updated its database and that it does not have a plan to do so.
This assertion is extremely disturbing. If Mr. Henderson's statement is true, then the NRC is unable to unequivocally ide:itify which safety issues are unimplemented and unverified at which plants. If so, the NRC truly is not performing one ofits most basic requirements as an industry regulator.
The fact that the NRC is disseminating information that has been outdated for a decade or longer is clearly outrageous. Plant safety is in jeopardy if the NRC cannot distinguish between what deficiencies have becn fixed, what deficiencies need to be fixed, and what deficiencies have or have not been verified by the NRC.
While this problem may be considered to be a computer glitch or a problem only on paper, POGO believes that plant safety is being neglected., The GAO recently confirmed this belief when it found, 1900 L Street, NW, Suite 314
- Washington, DC 20036-5027 * (202) 466-5539 I
Fax: (202) 466 5596
- E rnaih pogo@pogo.org
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"NRC has not taken aggressive enforcement action to force the licensees to fix their long-s safetyproblems on a timely basis. As a result, the plant's conditions have worsened, makin margins smaller."
POGO recommends that the NRC immediately perform the following:
Update all databases detailing the status of all safety issues at nuclear power plants.
This should include all Unresolved Safety Issues (USI), Generic Safety Issues (GSI),-
TMI Action Plan Requirements, and other Multiplant Action Issues.
Create time limits for plant: to implement NRC resolutions for safety issues. If these limits are not adhered to, the NRC should impose penalties upon the violating plant until the resolution has been implemented Require NRC verification of the plants' solutions within a reasonable time.
These recommendations are the least the agency can do to resolw safety concerns -- the vast majo
. of which have been defined by the NRC as being a "high priority."
I wouki appreciate hearing from you if there has been any progress concerning safety issues since our meeting. Thank you for taking the time to handle this very important safety issue. Ifyou have any questions concerning our report, update or the subject of this letter, please contact me or Scott Ame at (202) 466-5539.
Sincerely, Danielle Brian Executive Director i
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whatthegroup described asa three-r iav tis = '"'
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, issues."We wouldwelcomethemto e
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i contact us " Ace said.
mISSln9 But Brian said POGO won't-that i
the group doesn't see any need to connrm its press release visions of 9OneratOr' nuclear meltdowst "What (WPPSS) tells to me isn't enough," Brian sold Thursday. "I want the federal investigators to Mll ByDONMcMANMAN me."
Heesaanwer The federalinvestigators hadnt.
POGO faxed the Herald an NRC The case of the mi sing nuclear i document that listed several nuclear plant emergencyger ator-which power stations and listed whether wasn't missing at a.
- has been they had addressed the issue of solved.
emergencypowerduringa blackout.
And it all began with tax paper.
In the columnlabeled"implemen-work management at the Nuclear RegulatoryCom'nisaton!
tation status" the document said On Dionday, a self procialmed
" completed" next to WPPSS' name, watchdoggroup announced thecom.
Irut underthe columnlabeled"ver.
mercisinuclearplantnorthofRich.
ification status," tho document s aid land didn'thave an emergencygen.
"open." And that was a mist' ke,said a
erator.
Brect Henderson, an NRC i
The ProjeetOnGovernmentOYar.
spokesmanin Arlington,'Ihzas.
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sight (POGO)wenton to say such gen.
"We had this on ourto dolist-to erators are necessary"for the reac.,
clear that database - for a while,"
tor to continue functioning during a j Henderson said.
' blackout'withoutmeltingdown."
"For a while," in this case, was a Trouble is,the Weshington Publie Power Supply System has three ;
deeade-t,r even longer.
In 1987, NRC told nuclear plants emergencygenerators,and the Her-they must meet a new standard for and said so, emergoney power. For some plants, On Tuesday. POGO's executive timeant a third generatorto supple-director.Danielle Brian, denounced ment two emergency generators the Herald story, saying her press already on hand.
release neverindicated there were But WPPSS already had three.
no generators at%TPSS.
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Theywereinstalled beforethe plant But the Herald quoted her press began operatingin1964.
release word for word.
Brian said her Washington, D.C. j So WPPSS met the new require-ment even before the new require-based smup was trying to say the ment w as written.
NRC had notvertfled that the emer. l But the NRC never got around to gencygeneratorswereinplace.
updating its database, Henderson But another spokeswomanin her I said.
office had a different story onTues 1 When commercial nuclear plants day. POGO's Shata Stucky told make such paperwork ernrs, the KEPR.TV newsman RickMillerthe NRC gets downright peevish, issue was this:The WPPSS genera.
demandingexplanationsand plans tors hadn't been tested.
forimprovement.
But they had, every month,',most But does NRC have such a*self.
recentlylast week-and each time improvement plan forthis glitch?
Inthe presence of an NRCinspector, "I don't think we've progressed to said Mary Ace, a WPPSS spokes.
that pointyet,"Hendersonsaid.
aDon McManman canbe reachedet 582-l 1543 of via e enau at dmcmanment*
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