Resolution of Generic Safety Issues: Task V.F: Organization and Management ( NUREG-0933, Main Report with Supplements 1–35 )
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The objective of this task was to improve Commission organization and management.
ITEM V.F.1: STUDY NRC top MANAGEMENT STRUCTURE AND PROCESS
DESCRIPTION
This NUREG-0660,48 Rev. 1 item called for the Commission to hire an independent management consulting firm to examine the internal management approaches and procedures used by the Commissioners to execute their responsibilities and to examine possible improvements in the Commission's efficiency and effectiveness.
The FY-80 NRC Authorization Act required the Commission to contract for the completion by July 1981 of an independent review of the Commission's management structure, processes, procedures, and operations at all levels of agency management. This item was originally identified as Item 10 in Chapter V but was made Item V.F.1 in Rev. 1 to NUREG-0660.48
In May 1980, the Commission developed and issued a Policy and Planning Guidance (PPG)210 document to provide direction to the staff on general policies and objectives of the agency. The PPG provides a common basis for establishing agencywide priorities and is instrumental in shaping NRC programs and plans. The PPG is updated and revised annually.
In support of the PPG, the EDO Program Guidance was developed to help determine appropriate resource needs through the budget process. Together, the PPG and the EDO Program Guidance form the basis for agency planning and program development. The EDO Program Guidance is updated and revised annually.
In an NRC letter934 to the Congress in March 1981, it was indicated that Congressional concerns involving the Commission's management structure, processes, and operations were adequately addressed by actions already underway. Plans to have a consulting firm examine internal management were therefore dropped.
This item is related to increasing knowledge, certainty, and understanding of safety issues in order to increase confidence in assessing levels of safety and is, therefore, considered a licensing issue.
CONCLUSION
This Licensing Issue has been resolved.
ITEM V.F.2: REEXAMINE ORGANIZATION AND FUNCTIONS OF THE NRC OFFICES
DESCRIPTION
This NUREG-0660,48 Rev. 1 item called for the Commission to examine the organization and functions of the NRC offices to identify possible improvements in the overall efficiency and effectiveness of NRC including (1) an evaluation of the consolidation of all NRC resources and activities for monitoring operating reactors in a single office; (2) the reorganization of NRR to elevate human factors in criteria development and systems evaluation to a level of prominence equivalent to that of the safety equipment; (3) the reorganization of OIE to increase inspection and enforcement effectiveness; (4) the establishment of an integrated program for modifying regulatory requirements based on systemic identification and assessment of safety issues; and (5) the use of technical consultants to increase staff capability in discrete technical areas. This item was originally identified as Item 11 in Chapter V but was made Item V.F.2 in Rev. 1 to NUREG-0660.48
Over the past several years, a number of organizational changes have taken place at NRC to improve the effectiveness and efficiency of the agency. Some of the major changes are listed below.
Monitoring Operating Reactors: AEOD was created to identify and communicate lessons of operating experience to all appropriate parties. ORAB was also created in NRR to perform systematic assessments of operating reactor experience. Following the NRR reorganization in November 1985, ORAB was made the Operating Reactors Assessment Staff (ORAS).
Human Factors Considerations: The Division of Human Factors Safety (DHFS) was created within NRR to provide increased emphasis on the benefits and problems represented by the human element in nuclear operations. Following the NRR reorganization in November 1985, DHFS was made the Division of Human Factors Technology (DHFT).
Inspection and Enforcement:
(1) The emergency preparedness function was transferred to OIE and the Division of Emergency Preparedness and Engineering Response (DEPER) was created. An OIE component to manage NRC's incident response operations and planning efforts was also added.
(2) Improvements and intensification of inspections at operating reactor sites and at plants under construction were made that included (a) more inspection effort at operating power reactors directed toward verification of licensees' implementation and completion of actions specified in the TMI Action Plan; (b) special attention in the construction inspection program focused on quality assurance, on-site design, and review of as-built structures and systems; (c) raised limit on NRC fine for a single violation from $5,000 to as much as $100,000 per day with no ceiling on the total fine for any 30-day period; (d) NRC Policy changes that strengthened enforcement measures to prohibit operations by licensees who fail to meet adequate levels of protection and made non-compliance more expensive than compliance; (e) various improvements to inspector training; (f) studies by SNL, the results of which were used to further increase the effectiveness and safety efficiency of the operating reactor inspection program (NUREG/CR-1368935 and NUREG/CR-1369936); (g) revisions to inspection programs making safety verification the highest priority; (h) at least one inspector assigned to every site with an operating power reactor and every site where construction activities are in progress; and (i) identification of licensee management control problems through NRC team appraisals. These changes are documented in NRC Manual Chapter 0127.335
Safety Issues: (1) A systematic review has been performed of all candidate issues from the TMI investigations and continues to be performed for issues identified from operating reactor experience; (2) Generic issues are integrated into an agencywide program according to priority based on potential safety significance and cost of implementation; (3) NRC uses a 10-criteria evaluation process to determine which of the safety issues could be designated as USIs. Task Action Plans are developed to resolve those issues identified for further pursuit.
Technical Consultants: (1) NRR technical assistance in Operating Reactors and Casework more than tripled from FY-79 to FY-81 mostly because of the TMI-2 accident impact. This increase reflected additional technical assistance from such technical experts as the Franklin Research Institute to complete the growing number of reactor licensing amendments/actions. Efforts were also augmented for casework activities through technical support from contractors such as SAI and from the DOE National Labs; (2) Additional members were added to the panel of ASLBs which, in many cases, were reconstituted to minimize schedule conflicts.
Other Reorganizations: (1) During 1981, the Offices of Nuclear Regulatory Research (RES) and Standards Development (SD) were consolidated into a single RES Office. This change made the research function more responsive to the regulatory needs of the agency, by more direct application of research to regulations and rules, and made more effective use of staff resources. (2) A new position (Deputy Executive Director for Regional Operations and Generic Requirements) was created in 1981 in the EDO office to bring tighter control and coordination to new regulatory requirements and to help manage the enlarged role of NRC regional offices. (3) Also in 1981, regional operations were expanded to improve the quality of regulation by transferring a number of headquarters functions to the regions. Regional Administrators report directly to the EDO and act as key agents in NRC's interactions with licensees. This change is documented in NRC Manual Chapter 0128.335
This item is related to increasing knowledge, certainty, and understanding of safety issues in order to increase confidence in assessing levels of safety and is, therefore, considered a licensing issue.
CONCLUSION
This Licensing Issue has been resolved.
ITEM V.F.3: REVISE DELEGATIONS OF AUTHORITY TO STAFF
DESCRIPTION
This NUREG-0660,48 Rev. 1 item called for the Commission to improve NRC's organizational and management capabilities for effective pursuit of safety goals by clarifying and, as necessary, revising delegations of authority to the staff. This item was originally identified as Item 12 in Chapter V but was made Item V.F.3 in Rev. 1 to NUREG-0660.48
The Commission delegated substantial rulemaking authority to RES. To reflect the requirements of the President's Reorganization Plan No. 1 of 1980,929 NRC reviewed and changed manual chapters335 that dealt with the delegation of authority to staff office directors. These changes were documented in an EDO memorandum to the Chairman in December 1980.937 NRC also reviewed delegations of authority to Commission-level offices and concluded no changes were required. This conclusion was documented in SECY-80-497.938 Additional rulemaking authority was delegated to the staff in 1985.992
This item is related to increasing knowledge, certainty, and understanding of safety issues in order to increase confidence in assessing levels of safety and is, therefore, considered a licensing issue.
CONCLUSION
This Licensing Issue has been resolved.
ITEM V.F.4: CLARIFY AND STRENGTHEN THE RESPECTIVE ROLES OF CHAIRMAN, COMMISSION, AND EXECUTIVE DIRECTOR FOR OPERATIONS
DESCRIPTION
This NUREG-0660,48 Rev. 1 item called for the Commission to clarify and strengthen the respective roles and authorities of the Chairman as chief executive officer, the Commission as head of the agency, and the EDO as chief staff officer. This item was originally identified as Item 13 in Chapter V but was made Item V.F.4 in Rev. 1 to NUREG-0660.48
The President's Reorganization Plan of 1980929 served to strengthen the authority of the NRC Chairman relative to the Commission. For example, the Chairman is the official spokesman and principal executive officer of the Commission and directs and delegates various functions to the EDO who reports to the Chairman on all matters. Two Commission-level offices (Public Affairs and Congressional Affairs) also report directly to the Chairman. The Commission retains responsibility for policy formulation, rulemaking, orders, and adjudication. The Chairman initiates personnel actions, subject to Commission approval, for heads of offices reporting directly to the Commission, for the EDO, and for the heads of the major program offices. The Chairman directs and delegates to the EDO responsibility for all administrative functions, distribution of business, preparation of reorganization proposals and budget estimates, allocation of funds, and personnel matters other than those affecting the major program offices and certain other offices reporting to the Commission.
The EDO position was also strengthened relative to the program staff. For example, all program offices and regions report to the EDO. The EDO keeps the Commission fully and currently informed through the Chairman. The EDO is to be consulted regarding actions affecting the program offices and regional offices. These procedures are documented in NRC Manual Chapter 0103.335
This item is related to increasing knowledge, certainty, and understanding of safety issues in order to increase confidence in assessing levels of safety and is, therefore, considered a licensing issue.
CONCLUSION
This Licensing Issue has been resolved.
ITEM V.F.5: AUTHORITY TO DELEGATE EMERGENCY RESPONSE FUNCTIONS TO A SINGLE COMMISSIONER
DESCRIPTION
This NUREG-0660,48 Rev. 1 item called for the Commission to seek authority to delegate specific management responsibilities to an individual Commissioner in the event of defined emergencies. (See also Item III.A.3.1 in which NRC is to develop its role in responding to nuclear emergencies.) This item was originally identified as Item 14 in Chapter V but was made Item V.F.5 in Rev. 1 to NUREG-0660.48
The Commission's emergency response functions were transferred to its Chairman, as documented in the Reorganization Plan No. 1 of 1980.929 The responsibilities of the Commission and staff are set forth in detail in NRC Manual Chapter 0502.335
This item is related to increasing knowledge, certainty, and understanding of safety issues in order to increase confidence in assessing levels of safety and is, therefore, considered a licensing issue.
CONCLUSION
This Licensing Issue has been resolved.
REFERENCES
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