ML20059F249

Submits Staff Implementation Plan for Rrg Recommendations

ML20059F249
Person / Time
Issue date:	01/07/1994
From:	Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:
References
FRN-59FR47565, FRN-60FR15878 AF08-1-003, AF23-1, AF23-1-007, AF23-1-7, AF8-1-3, SECY-94-003, SECY-94-3, NUDOCS 9401130232
Download: ML20059F249 (23)

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POLICY ISSUE (Information)

January 7, 1994 SECY-94-003 FOR:

The Commissioners FROM:

James M. Taylor Executive Director for Operations

+

SUBJECT:

PLAN FOR IMPLEMENTING REGULATORY REVIEW GROUP RECOMMENDATIONS PURPOSE:

To submit the staff's implementation plan for the Regulatory Review Group recommendations described in the final report.

BACKGROUND:

On January 4, 1993, the Executive Director for Operations established the Regulatory Review Group (RRG). The RRG conducted a disciplined review of power reactor regulations and related processes, programs, and practices, riacing special attention on the potential for using performance-based requirements and guidance in place of prescriptive requirements and guidance.

The RRG reviewed the regulations of 10 CFR Ptrt 50 affecting operating reactors, the contents of four power rcactor licenst, rr.gulatory guidance supporting selected technical areas, public comments related to the Marginal-to-Safety Program, the 1992 review by the Coraittee to Review Generic Requirements, and recent, related industry correspondence.

In August 1993, the RRG issued its final report containing recommendations aimed at reducing the reguhtory burden on power reactor licensees and l

strengthening NRC admin:tirative practices.

The RRG report discussed several key areas in which changes in the way NRC conducts business could I!1b CONTACT:

NOTE:

TO BE MADE PUBLICLY AVAILABLE Roy Zimmerman, EDO IN 10 WORKING DAYS FROM THE 504-2969 DATE OF THIS PAPER

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The Commissionet. significantly reduce industry and NRC staff costs '41thout adversely affecting the level of safety at operating plants.

For example, the RRG suggested using more performance-based and risk-based approaches in such areas as quality assurance, security, fire protection, and inservice inspection and testing.

Additionally, the RRG examined agency administrative practices and proposed possible efficiencies in the areas of commitment management, reporting requirements, and rulemaking practices.

DISCUSSION:

The staff has prepared an implementation plan for the RRG recommendations.

This plan (see Enclosure 1) contains general implementation strategies, priorities, major milestones and target schedules for the timely resolution of each RRG recommendation. The activities associated with the development of the implementation plan resulted in some instances in which the planned actions differ from those recommended by the RRG. In each of these cases, the merits of the RRG recommendation were carefully considered.

In completing the RRG effort and preparing the implementation plan, the staff identified several key areas in which substantive burden could be reduced for licensees, staff, or both, without adversely impacting safety at currently operating plants. These areas include: enhancing and expanding the uses of probabilistic risk assessments to improve the regulation of operating reactors, revising existing quality assurance program guidance to encourage a more graded approach, and revising existing prescriptive regulations in security and fire protection to be more performance-based.

Staff and industry initiatives in these and other burden-reducing areas (such as cost-beneficial licensing actions, developing a risk-based approach to inservice inspection and testing, and rulemaking considerations in the security, fitness-for-duty, and containment testing areas) are under way and can lead to significant improvements in our regulation of the nuclear industry without adversely affecting plant safety.

The staff constructed the implementation plan by dividing the RRG recommendations into specific topic areas such as quality assurance and security.

Each topic area of the implementation plan contains:

(1) the specific issues (the numbers beneath each issue correspond to the appropriate sections in the RRG report), (2) the RRG recommendations for each issue, (3) an action plan for implementing individual RRG recommendations, (4) the priority assigned by the task group, based primarily on burden reduction, (5) the lead office for the resolution of each RRG recommendation, and (6) the targeted completion dates for each item, recognizing that the staff is still reviewing integrated resource loading.

Although not specifically stated in the action plan, completion of a number of the items will necessitate training of headquarters and regional staff, and will require ongoing dialogue with industry in order to achieve a smooth transition from action plan to actual practice.

l

The Commissioners The NRC " Principles of Good Regulation" are the foundation for many of the specific recommendations of the RRG and the enclosed implementation plan.

The plan, including the completion schedule, has been endorsed by the regional administrators and appropriate office directors. The staff is implementing the agreed upon actions.

' intend to monitor the steady progress toward completion of the implement ation plan by receiving periodic updates from the office directors and will act to ensure that the action plan is implemented.

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Enclosure:

RRG Implementation Plan DISTRIBUTION:

Commissioners OGC OCAA OIG OPA OCA OPP REGIONAL OFFICES EDO ACRS ASLBP SECY

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REGULATORY REVIEW GROUP IMPLEMENTATION PLAN ENCLOSURE 1 TOPIC ISSUE RRG' RECOMMENDATION ACTION PLAN.

PRI LEAD.

TARGET.

AREA 0FFICE SCHEDULE QUALITY Graded Quality Guidance needed to address use of

1. Public meeting with NUMARC 1

NRR COMPLETE ASSURANCE Assurance graded Quality Assurance working group on 12/16/93 to define specific action plan 2.3.13

2. Develop staff guidance in parallel 7/94 4.4.6 with industry efforts 4.10.la

3. Initiate pilot program 9/94

4. Issue / revise (draft) regulatory 7/95 guides (see item # 4)

Note: NUMARC considering a pilot program using a risk-based Q-list as a graded approach to quality

, assurance programs m

Revise Part 21 Revise definition of Commerrial

1. Evaluate need for rulemaking to 1

RES 5/94 Grade and Dedication asere congruence between Part 21 2.3.1 and graded QA efforts

2. If rulemakmg is necessary, schedule should be consistent with schedule for graded QA (item # 1)

Note: Federal Register notice requesting comments on NUMARC petition for rulemaking expired 2

12/28/93 1

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TOPIC ISSUE RRG RECOMMENDATION ACTI0a PLAN PRI LEAD TARGET l

AREA 0FFICE SCHEDULE 10 CFR 50.54(a)

Establish regulations as minimum Altemative Recommendation:

1 NRR l

- Quality Assurance standard - allow changes to program Integrate any rulemaking with without NRC approval as long as graded quality assurance initiative

(

2.3.9 quality assurance program meets (see item # I) l 3.3 regulations I. Meet with industry on issues l

specific to QA plans and changes to QA plans.

l

2. Develop draft industry guidelines 9/94 or staff guidance that defines acceptance criteria that would permit plan changes without NRC review.

3

3. Assess need for rulemaking 9/95 Revise Regulatory Reduce the number of regulatory

1. Revise Standard Review Plan and 3

RES 7/95 Guides 1.26,1.28, guides that discuss NRC expectations reduce / revise draft regulatory guides 1.29,1.30,1.33, for Quality Assurance -include NRC as appropriate 1.37,1.38,1.39 position on commercial grade

2. Publish final regulatory guides 7/96 dedication 2.3.15b Note: Directly affected by plan to 4

move to graded Quality Assurance DfERCDiCY 10 CFR 50.54(q)-

Establish regulations as minimum Alternative Recommendation:

NA RES

""U Emergency standard - allow changes to plan Defer action until experience has 6/96 Preparedness without NRC approval as long as been gained with security and emergency plan meets regulatkos possibly quality assurance 5

3.3.4c Policy Statement on Withdraw - 10 CFR 50.47 and Part Publish Federal Register notice 3

RES 6/94 Planning Basis for 100 supersede withdrawing Policy Statement on the Emergency Responses grounds that the rule has superseded to Nuclear Power the neccessity for it Reactor Accidents 2.3.11 6

3.3.4a 2

I I

TOPIC ISSUE RRG RECOMMENDATION ACTION PLAN PRI LEAD TARGET-AREA' 0FFICE SCHEDULE F

CURRENT Define " commitment" Propose rulemaking to define Alternative Recommendation:

1 NRR LICENSING and implement a commitment and describe a change

1. Either: 1) endorse industry 7/94 3

change process process for commitment in 10 CFR guidelines, or 2) develop and for commitments 50.54 promulgate staff guidance on what constitutes a commitment and the 2.3.2 types of controls to be placed on 2.3.9 changing commitments

2. Staff reassessment of need to 7/95 7

develop rulemakmg after guidance is implemented Define " current In recognition of the rulemaking on Relook at definition to modify as 3

NRR Commensurate with licensing basis" -

Part 54, the definitions for current necessary and incorporate definition Part 54 rulemakmg CLB licensing basis should be consistently of CLB into both Part 50 and Part schedule (12/94) applied in Part 50 also 54 8

2.3.10e Clarify scope and Clarify the scope and depth of the Alternative Recommendation:

depth of " design term

• design basis" as it is used in Consider need for changes to 3

NRR 12/94 basis" the regulations definition of design basis, as appropriate, that may arise from 2.3.10f efforts on current licensing basis and 9

change process for commitments Define

• material Amend 10 CFR 50 to add a definition Propose rulemakmg to add a 3

NRR 12/95 alteration" of

• material alteration" definition of " material alteration

• or revise sections of regulations which 2.3.10a require a construction permit for alterations, or document position in memo to EDO why rulemaking is 10 not appropriate cost Be responsive to The need for the staff to be

1. Continue to process CBLA I

NRR BENECIAL CBLAs responsive to licensee submittals that requests II are safety neutral but have a primary

2. Provide semiannual status reports 6/94, 12/94 ers 1.3.a aim of economic relief to EDO 3.3.4e 11 3.3.5 3

TOPIC ISSUE RRG RECOMMENDATION ACTION PLAN PRI LEAD-TARGET-AREA 0FFICE SCHEDULE-Identify regulatory Each licensee should review and

1. CBLA and related efforts address 1

NRR Ongoing vehicle and use identify the regulatory vehicle that is this issue flexibility the cause of unnecessary expenditures

2. Continue arranging and attending NO ADDITIONAL and aggressively pursue corrective public/ licensee meetings and ACTION 1.3.2 action fully utilizing the flexibility industry workshops REQUIRED 3.3.4e already available 3.3.4k 3.3.41 4.10.le 12 4.10.th SECURITY 10 CFR 50.54(p)-

Establish regulations as minimum Alternative Recommendation:

1 NRR security standard - allow changes to plans

1. Meet with industry on issues 2/94 without NRC approval as long as specific to security plans and 2.3.9, security plans meet regulations changes to security plans.

2.3.18d

2. Develop draft industry guidelines 6/94 3.3.4c Eliminate license condition or staff guidance that defines when a

• decrease in effectiveness

• occurs.

Consider developing acceptance criteria that would permit plan changes without NRC review.

3. Publish final guidelines or staff 12/94 guidance that defines when a

• decrease in effectiveness

• occurs.

13

4. Assess need for rulemaking 6/95 Allowed Outage Permit allowable outage times for

1. SECY-93-326, dated 12/2/93 2

NRR COMPLETE Times for Security security systems similar to safety included AOTs for door alarms equipment AOTs

2. Publish proposed rule 6/94 2.3.18c

3. Publish final rule 2/95 3.3.4 f

4. Staff should evaluate other 6/95 14 possible areas 4

e TOPIC ISSUE RRG RECOMMENDATION ACTION PLAN PRI LEAD

-TARGET -

AREA 0FFICE SCHEDULE Quarterly security Eliminate submittal of quarterly

1. Evaluate threshold for one hour 2

NRR logs security logs (73.71(c)(2))

and 30 day reporting requirements

2. Publish proposed rule to eliminate 6/94 2.3.1 the submittal of quarterly security 2.3.18b logs and revise threshold, if needed 15 3.3.4d

3. Publish fmal rule 12/94 Revise 10 CFR Part Make Part 73 more performance Provide Commission paper with 3

NRR 4/9G 73 based recommendation of feasibility of more performance based Part 73 2.3. I 8a Note: Need to gain experience with current proposals for revisions to 16 Pad 73 Policy Statement on Withdraw - 10 CFR 73.56 supersedm See item # 6 3

RES 6/94 Nuclear Power Plant Access Authorization Program 17 2.3.11 t 11 NESS Fitness For Duty Extend audit frequency based on Develop performance-based 10 CFR 2

NRR Commaw-te with FOR Audit Frequency performance from 1 year up to 3 26.80(a) to allow an extended audit current fitness for DUTY years frequency up to 3 years based on duty rulemakmg 18 2.3.5b past performance package (see item #

19)

Fitness For Duty Allow annual submittal of Fitness For I. Publish proposed rule to allow 2

NRR 6/94 Performance Data Duty performance data instead of annual submittal of performance data Submittal semi-annual submittals (included in fitness for duty lessons learned package) 2.3.5a

2. Publish fmal rule 1/95 19 2.3.16b Information Notice on Issue guidance discussing the Evaluate need for information notice 3

NRR 6/95 Fitness For Duty behavioral observation aspect of associated with fitness for duty 20 2.3.5c Fitness For Duty lessons teamed package 5

TOPIC ISSUE RRG RECOMMENDATION ACTION PLAN PRI ' LEAD TARGET AREA 0FFICE SCHEDULE Policy Statement on Withdraw - 10 CFR Part 26 See item # 6 3

RES 6/94 Fitness For Duty supersedes 21 2.3.11 ME Fire Protection Endorses continued licensee use of Consid r as follow-on to reflect 2

NRR Action deferred until

""*'"N Quality Assurance quality assurance in a graded manner revised implementation of graded fire barrier issue is prograrn for fire prevention and protection quality assurance (item # 1) resolved systems.

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Add sec ' a.,10 Establish regulations as minimum Alternative Recommendation:

NA See item # 22 e

CFR4 % - fire standard - allow changes to plan Defer action until experience has protection without NRC approval as long as fire been gained with security and protection plan meets regulations possibly quality assurance 2.3.9 3.3.4c Eliminate license condition 3.3.4h 23 3.3.4i Fire Protection Revise the regulatory guidance, I. Publish draft Supplement to NA NRR See item # 22 Guidance including inspection procedures, to Generic letter 86-10 on fire clarify that other alternative methods protection matters 2.3.4a,b of compliance (other than that

2. Publish final supplement to GL specified in various national fire codes and standards) can be developed and Note: Existing staff guidance be acceptable documents (SRP) indicates that alternative approaches can be 24 acceptable 6

i TOPIC ISSUE RRG RECOMMENDATION ACTION PLAN PRI LEAD.

TARGET AREA 0FFICE-SCHEDULE Fire Protection -

Revise the existing regulations for fire

1. Publish proposed rule to revise NA RES See item # 22 Rules pmtection to make them performance-the existing requirements for fire based protection to make them 2.3.4c performance-based requirements

2. Publish final rule i

Note: Industry considering proposal to revise Appendix R to be 25 performance-based PRA Agency Plan for PRA Plan needed to address research,

1. Offices to develop an NRR COMPLETE development, implementation and use Implementation Plan that integrates RES 4.9 of PRA for a consistent approach and PRA Working Group and RRG AEOD 4.10.g use of resources recommendations NMSS 4.10. li

2. Implementation Plan to be 1/94 reviewed at next Senior Management Meeting and balance of the schedule developed

3. Implementation Plan to 2/94 26 Commission Groundrules for PRA Develop guidance on content of

1. Endorse industry guidance or 1

NRR See item #26 use submittals, acceptable PRA methods, develop staff guidance separately and decision criteria and determme whether staff 1.3.4 guidance should be part of the 4.3 handbook for PRA i

4.4.5 4.5.2 27 4.6 Handbook for PRA identify methods for optimizing

1. Complete handbook for use on 1

RES 7/94 Technical Specifications using PRA technical specification optimization 4.9.3 techniques - or for using PRA in and A OTs 4.10. li other plant-specific applications

2. Develop other handbooks for k i'em #26 other uses (see item # 2, 30, 31, and 32 for potential candidates and 28 schedules) 7

TOPIC

. ISSUE RRG RECOMMENDATION' ACTION PLAN PRI LEAD TARGET AREA 0FFICE-SCHEDULE Pilot Program for Use pilot studies when expanding uses Select and implement pilot programs 1

Office-See item # 26 PRA of PRA into regulatory areas yvhere (see items # 2,30,31, and 32) dependent PRA has not been use to date 4.2 4.8 4.9 4.10. ld 29 Develop Guidelines PRA should be considered in Consi1er as part of the 1

NRR See item # 26 for use of PRA in 10 improving licensees reviews for 10 Implementation Plan CFR 50.59 CFR 50.59 - guidance needed 2.3.19 4.5 30 4.10. lb Multiple Actions if Recognize and advise the staff and Consider as part of the 1

NRR See it-m # 26 Safety Neutral public of the availability of an integral Implementation Plan approach to licensing actions such that 2.3.17b a number of issues may be proposed Note: Staff has used an integrated in a license amendment request if the approach in certain applications 31 lewI of safety remains the same Criteria for credit for Evaluate the adertuacy of existing Consider as part of the i

NRR See item # 26 redundancy guidance for reviewing design Implementation Plan features that exceed regulatory 3.3.4b requirements or provide alternative means of compliance. Such guidance should encourage flexibilityin the technical specifications for those design features for which the review concludes that increased safety margin 32 is provided.

1 8

TOPIC ISSUE-RRG RECOMMENDATION ACTION PLAN AREA PRI.

LEAD' TARGET 0FFICE' SCHEDULE INSERVICE Revise ASME Code Continue to build consensus in Code

1. Continue staff participation in 1

RES TES m G requirements based Committees to revise the ASME Code activities on risk Codes goveming Inservice Inspection

2. Risk-based ISI program and Code late 1994 - incorporate

& Inservice Testing based on risk-revisions nearing completion into ASME 1995 2.3.7a based techniques Edition

3. Risk-based IST program and late 1996 - incorporate Code revisions underway into ASME 1997

4. Revise 10 CFR 50.55a after Edition completion of Code initiatives Note: Completion schedule of ASME activities not under NRC 33 control IST guidelines Continue staff work on IST Program

1. Publish draft Generic letter 89-1 NRR COMPLETE Guidelines to take advantage of 04, Supplement I and draft 2.3.7b generic approval for using the most NUREG-1482 recent addenda and editions of the

2. Issue final GL and NUREG 9/94 ASME Codes rather than outdated older codes listed in staff Safety 34 Evaluation Reports Revise Inspection Review and revise Inspection Revise inspection procedure to 2

NRR 9/94 Procedure 73756 Procedure 73756 for applicability include efforts and ' lessons-learned' given issuance of Supplement to from current Temporary Instruction Generic Letter 89-04 and NUREG-on Generic letter 89-04 35 1482 Revise Regulatory

'Ibese guides delineate ASME Code Regulatory Guides currently updated NA RES NO ADDITIONAL Guides 1.84, 1.85, &

acceptability and should be maintained on an annual basis - last revisions to ACTION 1.147 current all guides was Summer 1993 REQUIRED Continue to follow current practices 36 2.3.15m 9

. _ - _ -.~ -

TOPIC-ISSUE RRG RECOMMENDATION ACTION PLAN PRI LEAD TARGET l

AREA' 0FFICE SCHEDULE.

i DECOmfl5-OGC opinion on need Determine whether rule revision is

1. Publish proposed rule to define 2

OGC 6/94 SIONING to revise 10 CFR needed to address what type of license possession only license, other terms 50.82 is needed for decommissioning important to decommissioning, Explore use of new possessiondy modify 50.59 for decommissioning, 2.3.3a license or renewal of original license and resolve remaining issues 37 for possession only purposes

2. Publish fmal rule 3/95 Revise Regulatory Revise Regulatory Guide to be

1. Publish preliminary 3

RES 6/94 Guide 1.86 consistent with 10 CFR 50.82 decommissioning guidance with (Decommissioning proposed rule Plans)

2. Publish final regulatory guide 9/95 38 2.3.3b REGU-Prioritization in Add a discussion to the Regulatory Reformat Regulatory Agenda to 3

IRM 6/94 LATORY Regulatory Agenda Agenda that describes how implement RRG recommendation AG N A rulemakings are prioritized

^ ~

• 39 Schedules in Schedules should be included for all See item # 39 3

IRM 6/94

)

Regulatory Agenda rulemakmg in Regulatory Agenda 40 2.3.17f i

Abstract information Abstract information in Regulatory See item # 39 3

IRM 6/94

{

in Regu'. story Agenda Agenda should be current 1

41 2.3.17g i

10 1

1

TOPIC.

ISSUE RRG RECOMMENDATION ACTION PLAN PRI LEAD TARGET AREA 0FFICE SCHEDULE RULE-Guidance on Petitions Consider issuing guidance on scope

1. Develop Commission paper that 2

RES 6/94 MAKING for Rulemaking and level of detali needed on Petitions defines conceptual approach. Paper for Rulemaking that reduce regulatory to distinguish between 1) 1.3.3 burden requirements for petitions for 2.3.17c,d rulemaking potentially affecting safety and 2) requirements for petitions for rulemaking that focus on reducing regulatory burden. The latter petitions are to be consistent with the requirements on the staff for proposed rulemakmg.

2. Publish proposed rulemakmg to 6 months after revise requirements on scope and Commission approval depth of petitions for rulemaking 42

3. Final rule 14 months after initial Commission approval Reassess need for old Provide a mechanism to reassess Update guidance to document 3

RES 6/94 or delayed rulemakings that are low priority and current practices for semi-annual rulemakmgs are old review of rulemakmgs and issuance of semiannual report to EDO 2.3.17h Specify reassessment of rulemakings that have not had msoumes applied for a long period of time (2-3 years) to determme whether they are still 43 needed MARGINAL Marginal to Safety Marginal to Safety Program should In Commission paper for item # 42, 2

RES 6/94 TO SAFETY Program focus on and be responsive to specific also discuss redirecting Marginal to and detailed petitions that are Safety Program to focus on petitions 2.3.17a performance based, eliminate burden, for rulemakmg and consider and are safety neutral renaming program 44 Consider renaming the program 11 4

i TOPIC ISSUE RRG RECOMMENDATION ACTION PLAN PRI LEAD TARGET AREA 0FFICE SCHEDULE POLICY Modify past practice Eliminate past practice of using

1. Issue EDO memo to Office 3

DEDR 1/94 STATE-of using Policy regulatory guidance documents such Directors that discusses proper use MENTS Statements, as policy statements, regulatory of communication vehicles and put Regulatory Guides, guides, generic letters, bulletins as in PDR or other documents as legal requirements without going

2. Each office should revise their Office 3/94 legal requirements through " appropriate" disciplined procedures as neassary dependent process for establishing regulatory 3.3.4a requirements Note: Some change to process has 2.3.11 occurred through CRGR review and public comments on generic communications and policy 45 statements Policy Statement on Withdraw - 10 CFR 50.65 supersedes See item # 6 3

RES 6/94 Maintenance 46 2.3. I 1 Policy Statement on Withdraw - revoked by Congress Federal Register notice published NA COMPLETE Below Regulatory 8/24/93 withdrawing Policy Concern Statement 47 2.3.11 Policy Statement on Withdraw - restates requirements of See item # 6 3

RES 6/94 Information Flow 10 CFR 50.72 and 50.73 48 2.3.11 TRAINING Policy Statement on Withdraw - training rule (10 CFR See item # 6 3

RES 6/94 and Training and 50.120) and Part 55 supersede STAFFING Qualification of Nuclear Power Plant Personnel 49 2.3.11 12

i l

l TOPIC-TSSUE RRG RECOMMENDATION ACTION PLAN PRI LEAD

' TARGET AREA 0FFICE SCHEDULE Policy Statement on Evaluate to determine if Policy

1. Determine whether training rule, 3

NRR 12/94 Engineering Expertise Statement has been treated as a Part 55, and SAT based training j

requirement supersede policy statement. If so, j

2.3.1 I withdraw policy statement.

2. If not, and considered necessary, publish proposed rule Note: Commission reaffirmed Policy Statement position after SECY 93-193 IN 93-81 issued which restates Commission's preferred position of 50 dual role STA/SRO Policy Statement on Evaluate to determine if Policy

1. Publish proposed rule 3

NRR 12/94 Nuclear Power Plant Statement has been treated as a

2. Publish fm' al rule 12/95 Staff Working Hours requirement Notes: Policy statement put into 2.3.11 Technical Specifications through generic letter GL 82-12 Policy Statement forms the basis for Technical Specification 5.2.2 in the new Standard Technical 51 Specifications Policy Statement on Evaluate to determine if Policy Determine whe'aer policy statement 3

NRR 12/94 Conduct of Nuclear Statement has been treated as a has been treatext as a r.quirement.

Power Plant requirement if not, no further action. If yes, and Operations considered necessary, publish proposed rule 52 2.3. I 1 13

TOPIC ISSUE RRG RECOMMENDATION ACTION PLAN PRI-

-LEAD'

. TARGET.

AREA 0FFICE SCHEDULE Policy Statement Evaluate to determine if Policy

1. Determine whether the training 3

NRR 12/94 on Education for Statement has been treated as a rule, Part 55, and SAT based Senior Reactor requirement training programs supersede this Operators and Shift policy statement Supervisors at

2. If yes, see item # 6 Nuclear Power Plant

3. If no, determine if imposed as a requirement. If yes, publish 2.3.11 proposed rule. If no, no further 53 action.

TECIINICAL Control over material 10 CFR 50.71(e),10 CFR 50.59,10 SRM dated 5/25/93 - asked staff to 2

NRR RECIm removed from CFR 50.36, and parts of 10 CFR pursue possible ways to improve CATIONS Technical 50.54 should be reviewed and revised Technical Specifications mechanienui Specifications to ensure that the system of improved to achieve greater legal and Technical Specifications will maintain administrative efficiencies 2.3.10g appropriate control of changes to

1. Develop Commission paper to 5/94 materials that are removed from address SRM Technical Specifications and placed in

2. Review NSAC-125 and endorse, 6/94 licensee-controlled documents or develop and promulgate staff guidance separately, if appropriate Concerns with quality of FSARs and

3. Eva'uate adequacy of 10 CFR 12/94 10 CFR 50.59 process 50.71(e) and implementation and integrate with results of TI 2515-112 on Chapter 2 of FSAR and recommend appropriate action 54 SRM issue of updating FSARs Revise Generic letter Provide quicker review of core reload I. Issue guidance to licensees on 2

NRR 12/94 88 Cycle-specific codes.

necessary content of core reload parameter limits in packages technical Revise current Technical

2. Consider whether issuing 12/94 specifications Specifications to permit changes to guidance to licensees that contains improved analyses and approved core revised technical specification 2.3.8 topical reports without license language is appropriate 55 amendment 14

TOPIC;

' ISSUE" RRG RECOMMENDATION ACTION. PLAN:

'PRI LEAD TARGETJ AREA 0FFICE-SCHEDULES Allow line item Permit line-item improvements in Policy Statement on Technical NA COMPLETE improvements for accordance with the Technical Specifications dated 7/22/93 stated Improved Standard Specifications improvement policy for line item improvements would be Technical all individual licensees in addition to accepted by NRC Specifications lead plant licensees 1

56 3.3.4j REPORTING Delete y

License aa.crJuwots to delete Policy Statement on technical NA NA COMPLETE l

REQUIRE.

reporting reporting requirements for reports that specifications allows line item requirements are "not required" in the new improvements (see item # 56)

Standard Technical Specifications "I " I 57 staff Revise Regulatory Revise Regulatory Guide 1.16,

1. Revise and publish draft 2

RES 6/94 Guide 1.16 monthly operating report, to eliminate regulatory guide 1.16 to reduce unnecessary reporting requirements scope of monthly operating report 2.3.15c accordingly (see item # 59) 2.3.16

2. Publish final regulatory guide 1/95 58 2.3.18 Evaluate need or The RRG report recc,-- c.ds a major

1. Provide draft rule changes to the 2

RES 9/94 frequency for all staff effort to review all techmcal Commission on items decided by reporting specification reporting requirements RRG and Reporting Requirements requirements for special reports, situational reports, Tasit Force that can be eliminated l

contained in routine or periodic reports and reports

2. Publish final rule changes to 265 regulations, technical required by regulations.

eliminate requirements identified in i

specifications or item I industry codes and

3. Assess additional reporting NRR I?>95 standards requirements identified in public comments to deternune whether they 2.3.16d can be eliminated i

2.3.16e

4. Publish draft rule changes to RES 656 59 2.3.16f elimmate requirements from item 2

5. Publish final rule changes 12/96 15

TOPIC ISSUE RRG RECOMMENDATION ACTION PLAN PRI.

LEAD TARGET-AREA 0FFICE SCHEDULE MISCEL-Decrease Direct Decrease direct inspection effort by

1. Inspection program activities will 2

NRR 3/94 LANEOUS Ingection Effort by 10% in FY 1994 instead of FY 1995 be revised, as appropriate, to reduce 10 %

inspection resources in program areas where current levels of 1.5.1 oversight are not considered necessary.

2. Improve distribution of inspection 9/94 resources based on PRA insights and licensee performance

3. Evaluate impact of reduction of 9/95 60 direct inspection effort Update 10 CFR Revise the rule to address the office Alternative Recommendation:

NA NO ADDITIONAL 50.70(b)(2) space necessary for resident No rulemakmg for 50.70(b)(2)is ACTION inspectors necessary REQUIRED 2.3.10c No problems exist with current 61 implementation Generic Have one generic communication that

1. Administrative letter format has 3

NRR NO ADDITIONAL Communication requests information from licensees been initiated ACTION System and one that informs licensees REQUIRED

2. Evaluate effectiveness after 2 1/95 62 2.3.6b years 10 CFR 50.54(f)

No revision to 10 CFR 50.54(f)

No action necessary - line NA NO ADDITIONAL needed organizations review issues for ACTION 2.3.6a backfits, public and Commission REQUIRED comment period for generic communications, and cunent 63 50.54(f) letters reference applicable regulatory requirements Eliminate conflict Eliminate inconsistency between Final rule published 8/16/93 NA COMPLETE between 10 CFR words in 10 CFR 50.54 and newly 50.54(a)(3) and 10 revised 10 CFR 50.71 regarding CFR 50.71(e) frequency of reporting changes to QA plan 64 2.3.10d 16

TOPIC

-ISSUE RRG RECOMMENDATION' ACTION PLAN PRI LEAD TARGET-AREA 0FFICE SCHEDULE i

Revise 10 CFR 50.7 Revise 50.7 to reflect Energy Policy Final rule published 10/8/93 NA COMPLETE Act of 1992 for whistleblower 2.3.10b protection to extend statue of limitations for whistleblower to file a claim from 30 days to 6 months, expand definition of whistleblower and employer, and change the burden 65 of proof Graded Approach to Allow graded approach to review Ongoing initiative within the NO ADDITIONAL committees functions of licensee onsite or offsite improved standard technical NA ACTION review committees to permit review specification program to permit REQUIRED 3.3.4g of safety significant items only licensees to define role of review 66 committees (see item # 56) l 17

REGULATORY REVIEW GROUP IMPLEMENTATION PLAN -- ADDITIONAL ITEMS TOPIC' ISSUE RRGITF NEW RECOMMENDATION' ACTION PLAN-PRI LEAD.

TARGET AREA-0FFICE SCHEDULE-at a Rulemaking process Review rulemaking process to identify Perform staff review for potential 2

RES 3/94 takes too long any improvements that can be made improvements to rulemakmg process cy to accelerate rulemaking Document review in negative 4/94 A

consent Commission paper describing potential improvements SECURITY Staffing requirements Review existing staff positions Review staff guidance on number 2

NRR Commensurate with for implementing Part conceming use of onsite security and use of guard force as item #14 73 are too force to meet provisions of Part 73 compensatory measures to assure burdensome that effectiveness of security system (Note: J. Perry letter to J. Sniezek is not reduced by failure of security dated I/12/93) equipment or structures issue revised guidance and publish 3/94 B

administrative letter GENERIC Supervisory

1. Eliminate those generic Incorporate recommendation into 3

NRR COMPLETE COMMUN-Oversight of Draft communications that am old and not Office procedures ICATIONS Generic under active development.

Communications

2. Perform periodic supervisory 6/94 review oflist of generic c mmunications (initially on a 6 C

month interval) to monitor progress of all generic communications.

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TOPIC.

ISSUE RRGITF NEW RECOMMENDATION ACTION PLAN PRI LEAD TARGET AREA-0FFICE SCHEDULE PART 20 10 CFR 20.1703 Revise 10 CFR 20.1703 (a)(3)(v) to Publish proposed rule 2

RES 8/94 (medical respirator change the period of fitness uses) should be determinations from annually to Publish hnal mie 3/95 revised for potential periodic depending on age. Consider impr vements in using ANSI Z88.2 -1992 in this area.

D testing requirements Regulatory Guides Remaining Regulatory Guides should I. Publish draft Regulatory Guides 2

RES 6/94 for RG 8.13 for the revised Part be revised to be consistent with the 8.13 and 8.29 9/94 for RG 8.29 20 revised Part 20 requirements

2. Publish final Regulatory Guides 12/94 for RG 8.13 8.13 and 8.29 3/95 for RG 8.29

3. Publish remaining draft 12/94 regulatory guides or information notice, as necessary

4. Publish fina! regulatory guides 12/95 NOTE: The regulatory guides considered necessary by the staff to assist with the implementation of the E

revised Part 20 have already been issued. (IN 93-80) 4 i

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CRITERIA FOR PRIORITY DETERMINATIONS-PRIORITY I Programmatic, technical or administrative changes may have SIGNIFICANT reduction in regulatory burden to licensees, or in regulatory oversight requirements by NRC, or both and does not adversely impact safety.

PRIORITY 2 Programmatic, technical or administrative changes may result in SOME reduction in regulatory burden to licensees, or in regulatory oversight requirements by NRC, or both and does not adversely impact safety.

Establishes new programmatic requirements for an existing programmatic area.

PRIORITY 3 Changes to technical program areas that incorporate existing regulatory practices into the appropriate regulatory documents.

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