ML20140B612
| ML20140B612 | |
| Person / Time | |
|---|---|
| Issue date: | 02/27/1997 |
| From: | Callan L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| SECY-97-052, SECY-97-052-R, SECY-97-52, SECY-97-52-R, NUDOCS 9703070127 | |
| Download: ML20140B612 (26) | |
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POLICY ISSUE l
(Notation Vote)
February 27, 1997 SECY-97-052 FOR:
The Commissioners FROM:
L. Joseph Callan Executive Director for Operations
SUBJECT:
COMMITTEE TO REVIEW GENER.C REQUIREMENTS (CRGR) -
SCOPE OF REVIEW AND PERIODIC REVIEW OF ACTIVITIES I
PURPOSE:
To obtain Commission approval of staff proposals relating to scope of review of the Committee to Review Generic Requirements (CRGR) and periodic review of its activities.
BACKGROUND:
In the staff requirements memorandum (SRM) dated August 21,1996, regarding COMSECY-96-028 - Strategic Assessment issue Paper: Independent Oversight (CSI 19), the Commission stated:
(1) the CRGR should be retained but its scope should be expanded to include NMSS activity; (2) consideration should be given to including reactor inspection guidance within the scope of CRGR; I
'Oj (3) each independent oversight committee, and CRGR, should be evaluated periodically to determine what value it is contr5buting to achieving tne agency's mission; the committee should be directly tr Wved in this evaluation; (4) each committee is requested to produce a set of criteria, for Comminsion consideration, under which the performance of the committee would be evaluated in the future; and the committee should then periodically review itself against these criteria and provide the results of this evaluation to the Commission.
Contact:
Denwood F. Ross, Jr., AEOD NOTE:
TO BE MADE PUBLICLY AVAILABLE WHEN THE (301) 415-7473 FINAL SRM IS MADE AVAILABLE of h' fem
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l DISCUSSION:
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Retain The CRGR And Expand Its Scope To include NMSS Activity l!'
in SECY-96-032, dated February 9,1996, the staff sent to the Commission a proposed major l
revision to the CRGR Charter (i.e., Revision 6), which included a proposal to expand the CRGR review scope, on a trial basis, to includs selected items in the nuclear materials area.
. The items selected for CRGR review would be identified by the Director, NMSS or the EDO; and, the results would be evaluated to determine if the "value added" by CRGR review of the j
l selected items seemed to justify a recommendation to the Commission that the CRGR scope be expanded permanently to include CRGR review nuclear materials, or some other course i
of action. In a staff requirements memo (SRM) dated March 22,1.996 (Attachment 1), the
. Commission approved Revision 6 to the Charter and the proposal for CRGR review of selected nuclear materials on a trial basis, in preliminary discussions with CRGR of this matter, the Director, NMSS identified the proposed major revision to 10 CFR Part 70 (for regulation of activities at the large SNM processing facilities) as one possible candidate for CRGR review (Attachment 2).
Subsequently, in a separate action, the Commission directed the CRGR to review the proposed Part 70 rJiemaking (Attachment 3).
CRGR held one meeting with the NMSS staff to begin its consideration of Part 70; the Committee was briefed.on an early' draft of the Part 70 rulemaking package at that meeting, and provided some preliminary views on possible improvements to the package (Attachment 4). The Committee also visited two fuel fabrication facilities (i.e., the Westinghouse facility at Columbia, S.C., and the Siemens facility at Pasco, WA.) in connection with the Part 70 review effort.
Following the initial CRGR meeting with the NMSS staff.on the prooosed Part 70 revision, the staff held a public meeting with the licensees of the major fuel facilities to solicit comment on the early draft of the proposed revision considered by CRGR. Following the public meeting, the proposed rulemaking was put on hold by the Commission to allow further consideration of attematives. That process has included further discussions with affected licensees,'
preparation of an attematives paper (SECY-96-079) submitted by the NMSS staff in April 1996, and submittal of a Petition for Rulemaking by the Nuclear Energy Institute ("the NEl Petition") in September 1996, on behalf of certain licensees and potential licensees, outlining industry-proposed attematives in the Part 70 matter.
- in a SRM dated December 4,1996, SECY 96-079 was retumed to the staff with the request
~ by the Commission that NMSS evaluate the effect, if any, of the NEl Petition on the staff-proposed attematives provided in that Commission Paper (Attachment 5). CRGR will continue its consideration of this item, as appropriate, based on the staff's further j
consideration of attematives, including evaluation of the NEl Petition and comments received on that item, and possible further direction by the Cornmission. The schedule for completion of the Part 70 item is indeterminate at this time. In view of these developments, NMSS is i
actively seeking to identify other candidate items for CRGR review, based on the potential for significant value-added to the product and the balance of costs and benefits that can be no w
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The Commissioners 3
projected for the supplemental activities involved, with the objective of identifying additional candidates by the end of February 1997.
1 It was initially proposed, in SECY-96-032, that after a trial period of about a year (i.e., in February 1997) a conclusion could be drawn whether sufficient value is added by CRGR i
review of the selected nuclear materials items to justify the costs and additional NMSS staff and Committee effort required to support such reviews to warrant a permanent expansion of the CRGR review scope to include NMSS activities more broadly. Due to the circumstances and developments outlined above, there is not an adequate bases for making an informed j
decision on these questions on the originally proposed schedule.
The staff recommends', therefore, that the Commission approve a one year continuation of the trial program of CRGR review of selected NMSS items, including Part 70 (as appropriate) and additional items to be identified by NMSS, as discussed in the preceding, to provide additional time and information needed to property decide whether the CRGR scope should be expanded to include review of NMSS activity on a permanent basis.
Consider Expandino The Scope of CRGR Review To include Reactor inspection Guidance Reactor inspection guidance has not been routinely reviewed by CRGR in the past, alttiough the language of.the CRGR Charter would permit such review. In rethinking the past practice, corisideration must be given to the balance between resources applied and results obtained in ensuring against inadvertent, uriauthorized backfits being included in approved inspection guidance, while at the same time maintaining a strong safety focus in NRC inspection activities and a culture that encourages the aggressive pursuit of deficiencies identified by inspectors. Any decision to review inspection guidance must take into account the large volume of guidance which is necessary for the inspection program. Thus, an audit would have to recognize this, and would have to consider the length of a trial period, as well as
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evaluation criteria at the end of the trial period. The approach taken to addressing the j
potential for backfit issues arising from inspection guidance has been to include in the agency's backfitting guidance and procedures clear prohibitions against going beyond approved, applicable requirements and staff positions in inspection guidance, and reinforcing these prohibitions in backfit training provided to the staff and in management oversight of the inspection guidance development process.
Upon occasion, to meet a particular purpose or concem (e.g., to minimize the potential for inconsistent inspection practices or unauthorized backfitting arising from unresolved differing interpretations), CRGR has reviewed proposed inspection guidance at 1he specific request of the NRC staff. One such example was the guidance on operability determinations for degraded conditions (initially proposed as simply a revision to the NRC Inspection Manual, but in final form transmitted to all licensees in GL 89-12). Such instances have been relatively few in number, however; and no need was identified from such experience for requiring CRGR review of inspection guidance more generally. Fu'ther, in those instances in l
the pas' where complaints regarding unauthorized or proscribed backfitting practices have risen to a level requiring NRC attention and corrective action (i.e., the Regulatory impact l
Survey in 1989, and the Towers-Perrin Report in 1992), the lack of CRGR review of inspection guidance was not identified as a major contributing factor.
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l The Commissionere 4
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The CRGR staff meets periodically with an industry association known as the Nuclear Utilit.ies l
Backfit Reform Group (NUBARG). During the past year, in one of these meetings, a number of licensees claimed that there were unauthorized plant-specific backfits in connection with inspections associated with the efficacy of the 50.59 process. Tne NUBARG licensees l
recommended CRGR review of " interim" inspection criteria and enforcement policy guidance j
l that were being applied by the staff in the ongoing design and licensing basis examination l
effort. They also recommended that CRGR become involved in the review of proposed new inspection guidance and enforcement policy revisions more generally in the future.
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l The staff believes that the experience and results that could be obtained from a two year trial program of CRGR review of inspection guidance on selected items to be identified by the l
Director, NRR and/or the CRGR would provide a proper basis for making a final recommendation to the Commission regarding whether permanent expansion of CRGR review activity to include review of selected inspection guidance is warranted. The staff recommends that the Commission approve initiation of a two year trial program.
l Periodic Evaluation of CRGR Contribution To Achievement of NRC Mission l
As noted in the CRGR Charter, the Committee to Review Generic Requirements (CRGR) was established by the Commission with the responsibility to review and recommend to the Executive Director for Operations (EDO) approval or disapproval of new or changed requirements or staff positions promulgated by the NRC that impact the licensees of nuclear l
power reactors and associated fuel cycle facilities. The objectives of the CRGR review process are to eliminate unnecessary burdens to the licensees, to reduce the exposure of workers to radiation in implementing new or changeJ regulatory raquirements, and to conserve NRC resources while at the same time assuring the adequate protection of the public health and safety. Consistent with these objectives, the Committee reviews NRC staff proposals that would increase existing requirements or staff positions, and proposals that would reduce existing requirements / positions as well. The Committee also visits one or more operating facilities each year to obtain feedback directly from licensees regarding the overall effectiveness of the CRGR process.
l A summary of CRGR activities is included routinely in the NRC Annual Report and the AEOD Annual Report. In the most recent AEOD Annual Report, the summary was expanded to l
include a brief "value-added" evaluation for each item considered by CRGR during the reporting period (Attachment 6); and the staff intends to continue this practice in the future.
The staff believes that it is possible to draw conclusions from the summary regarding the effectiveness of the CRGR review process (a) in assuring that new or changed requirements and staff positions to be issued do in fact contribute effectively and significantly to the protection of public health and safety and result in the efficient utilization of both NRC and licensee resources, (b) in assuring the technical quality of NRC's generic regulatory i
issuances, and (c) in assuring regulatory coherence in regulatory actions taken by the j
agency. The staff believes that, with only minor adaptations, this established annual reporting mechanism provides an acceptable framework for periodic reporting of CRGR activities, and evaluation of the Committee's contribution to the NRC regulatory mission against criteria derived from the objectives stated in the Commission-approved CRGR Charter (as in a through c, above), consistent with the intent of the SRM. The adaptations r_
involved would be for the Committee to review the summary report of CRGR activities I
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The Commissioners 5
l normally prepared for inclusion in the NRC/AEOD Annual Reports and to provide to the Commission an evaluation of the summarized activities addressing (a) through (c) above, along with the summary itself, in a Commission Paper. The same evaluation metrics would apply to trial programs beir.g conducted during the time period.
The staff recommends that the Commission approve the process and criteria discussed in the preceding for periodic reporting and evaluation of CRGR activities.
RECOMMENDATIONS:
1.
The staif recommends that the Commission approve a one year continuation of a trial program of CRGR review of selected NMSS items to provide additionalinformation needed to decide whether the CRGR scope should be expanded to include review of selected NMSS activities on a permanent basis.
2.
The staff recommends that the Commission approve initiation of a two year trial i
program of CRGR review of inspection guidance to determine whether the CRGR scope should be expanded to include review of selected inspection guidance.
3.
The staff recommends that the Commission approve the proposed process and criteria for periodic reporting and evaluation of CRGR activities.
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w L. J eph Ca lan Executive Director for Operations Attachments:
1.
SRM dated Maich 22,1996
- 2. to the. Minutes of CRGR Meeting No. 269 3.
SRM dated March 22,1995
- 4. to the Minutes of CRGR Meeting No. 271 5.
SRM dated December 4,1996 6.
Excerpt from AEOD Annual Report -(Summary of CRGR Review Activities, with 'Value-Added" comments for each review item)
DISTRIBUTION:
Comissioners ' coments or consent should be provided directly Comissioners to the Office of the Secretary by COB March 17, 1997.
OGC' OCAA Comission Staff Office comenr.s if any, should be OIG submitted to the Comissioners NLT March 10, 1997, with l
.an information copy to the Office of the Secretary.
If OCA the paper is of such a nature that it requires additional CIO review and coment, the Comissioners and the Secretariat CFO should be apprised of when coments may be expected.
EOD SECY i
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SRM Dated March 22,1996 l
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Action:
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'o UNITED STATES Cys:
Taylor 1
i, NUCLEAR REGULATORY COMMISSION Milhoan l-E WASHINGTON. D.C. 20556 Thompson Blaha JConran,
March 22, 1996 L
I CFFICE OF THE l-SECRETARY
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MEMORANDUM TO:
James M. Taylor Exec i e irector for Operations h
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FROM:
Johr C.
oy e, oecretary l
SUBJECT:
ST FF REQUIREMENTS - SECY-96-032 - CHARTER OF l
THE COMMITTEE TO REVIEW GENERIC REQUIREMENTS j
l (CRGR) - (PROPOSED REVISION 6) 4
)
i The Commission, with all Commissioners agreeing, has approved i
l revision to the CRGR Charter subject. to the attached changes and l
the-following comments.
The Commission has approved the proposed
. trial program for CRGR review of selected issues and proposed new requirements in the nuclear materials area, j
l 1.
Exemptions from regulations should not be favored.
In any case where the staff on the advice from CRGR conclude that a proposed backfit does not meet the requirements of the backfit rule yet should be promulgated, the staff should seek advice from the Commission prior to finalizing a proposed rulemaking package for Commission consideration.
In coming to the Commission for guidance, options other than an exemption should be discussed.
2.
The paragraph contained in Attachment 3 to the CRGR Charter pertaining to the incorporation of industry standards into NRC rules or staff positions, should be clarified to also address the incorporation of revisions to industry codes and standards that are already endorsed in existing regulations (i.e., the American Society of Mechanical Engineers (AS.ME)
Code vis-a-vis 10 CFR 50.55a) or staff positions 3.
The NRC staff should use PP% for materials licensees, as well as power reactors, when the potential safety consequences warrant! its use, sufficient data are available, and the licensees can reasonably be expected to be capable of. performing such analyses.
PEDO) AE0D-(SECY Suspense:
4/19/96) 9300113 SECY NOTE:
THIS SRM, SECY-96-032, AND THE VOTE SHEETS OF ALL COMMISSIONERS WILL BE MADE PUBLICLY AVAILABLE 5 WORKING DAYS FROM THE DATE OF THIS SRM.
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Attachment:
.As stated i
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Chairman Jackson Commissioner Rogers
' Commissioner Dicus.
OGC OCA-OIG.
Office Directors, Regions,.ACRS, ACNW, ASLBP (via E-Mail) 4 4
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1-Revision 6 Draft achievement of protection of public health and safety.
By having the Comittee submit recommendations directly to'the EDO, a single agency-wide point of control will be provided.
The CRGR will focus primarily on proposed new requirements and staff positions,' but it may also review selected existing requirements and staff positions which may place unnecessary burdens on licensee or agency resources.
In reaching its recommendation, the CRGR shall consult with the proposing office to ensure that the reasons for the proposed requi.rement or staff position are well understood and, (a) for power reactors, that the applicable provisions of 10 CFR 50.109, 50.54(f), and 10 CFR 2.204, are appropriately addressed by the staff proposal: or (b).for nuclear materials related activities, that the applicable provisions of the NRC Regulatory Analysis Guidelines are addressed by the staff proposal.
The CRGR shall submit to the EDO a statement of its recommendations in accordance with IV.D below.
Tools used by the CRGR for scrutiny are expected to include cost-benefit analysis and (for pay /cr reacters) probabilistic risk assessment where dis 5dIEdIidl255I5fE55lNE@5s@ff5dEM$615ffidMd!N5NN5 Nil @M!
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add 3tiERMdiffeasIssgsssg#a6EbE3Migtsgdgy5#8ti]Dmtfsggiggs!j php]hj52dataforitsproperuseareadequate. Therefore, to the extent possible, written staff justifications should make use of these evaluation techniques.
The use of cost-benefit analyses and other tools should help to make it possible to determine which proposed requirements and staff positions have pitijdij quantifiable safety significance, enWor readily-demonstrated significant safety benefit based on straightforward and compelling qualitative considerations.
These EMultE#@iitR8fd]M may be distinguished from those proposed requirements and staff positions not amenable to quantification @fd for which more arguable, tentative or indirect qualitative judgments must be tAedecidingfactor[.'
The EDO may authorize deviations from this Charter when the EDO, after consulting with the CRGR l
See Attachment 2.
See Attachment 3 for guidance regarding consideration of such l
gualitative factors Mdsfenisij[ffiy[idistlisitliE[EMi[5IsUb5tadtill i
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Proposed Expanded Scone of CRGR Review to include Nuclear Materials issues 1
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TOPIC l
The CRGR discussed with R. Bernero, Director, NMSS the possible expansion of CRGR review scope to include proposed new requirements in the nuclear l
materials area.
MSS proposed that the CRGR review of materials items be.
i limited to selected nuclear materials items on a trial. basis. This discussion was'in response to the June 15,.1994 Commission directive (Background Item 2
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l below) that' the staff consider expanding the scope of the CRGR review to J
include proposed requi,'ements in the nuclear materials area.
(This topic was J
' also discussed previously by the Committee at Meeting No. 259.)
l BACKGROUND 1.
Cossiission Paper (SECY-94-109), dated April 21, 1994, " Scope of Review for the Committee to Review Generic Requirements'(CRGR)"
2.
SRM (SECY-94-109), dated June 15, 1994, " Scope of Review for the' L
Committee to Review Generic Requirements (CRGR)"
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- 3. to the Minutes of CRGR Meeting No. 259, dated August 3 -1994 i(
CONCLUSIONS \\RECOPMENDATIONS R. Bernero, Director, MSS identified several nuclear materials areas that might benefit from CRGR review; selected topics for future CRGR consideration a
discussed.with the Committee included the following:
l 1.
Dry cask storage of spent fuel - Items such as. certification.of multi-purpose' (storage as well as transportation) canister systems-through rulemaking.
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40 vs 100 year licensing of monitored retrievable storage sites east of l
Yucca Mountain (proposed legislation is currently pending before Congress).
3.
Interim on-site low-level waste storage issues - Currently there are no generic requirements for on-site storage of low-level waste. A joint NRR-18tSS generic letter on the subject, addressing concerns related to t
potentially flassable and\\or dispersible waste forms, is currently being considered.
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Radiation \\ chemical safety \\ hazards considerations and criticality
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issues' related to the low-er:richment-uranium (LEU) fuel fabrication y
facilities.
The planned revision of 10 CFR Part 70 was identified as a l
likely topic for CRGR review in this context.
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NMSS indicated that the Committee's perspective and advice on structural,' electrical, and mechanical aspects.of the regulation of 1
l spent fuel and' waste storage / transportation operations, and LEU fuel fabrication facilities (from the systems, rather than process,
- perspective) could: be helpful.
6.
With regard to proposed new requirements that are risk \\ performance-i based, the Committee can provide a useful; independent assessment of under-regulation' or over-regulation in the nuclear. materials area.
For l
example, in the NRC-regulated states,.if the implementation of. alarming rate meters (under current 10 CFR 34 requirements) is shown to result in fewer. radiographer over-exposure events, that. finding may reduce the l
value of, and thus eliminate the need for, the proposed two-man rule.and 1
certification provisions in the p.roposed Part-34. revision under consideration.
The Committee agreed that' the selected nuclear. materials areas proposed by:
NMSS are appropriate. topics for CRGR review, on a trial. basis.
The CRGR Charter revision, now' under preparation, will be modified to reflect' this proposed change.in CRGR review scope. After a' trial' period of about one year, the Committee will examine.the experience from CRGR' reviews of nuclear materials items.- ' Specifically, the -Committee will assess the; value added by CRGR reviews, and based on that assessment will make appropriate'
- i recommendations to"the ED0'regarding whether or'not the Committee'should continue review of nuclear. materials items.. The Committee's assessment of whether or not the~ items that were identified by the staff for CRGR review actua11t ' warranted CRGR attention and, if so, whether there was significant value added by the Committee's review, will be included in the CRGR meeting
. minutes during.the trial period, and will also be reported to the EDO in the CRGR Weekly items of Interest to be reported to the Commission.
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SRM Dated March 22,1995 4
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REFER TO:
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UNITED STATES y
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NUCLEAR REGULATORY COMMISSION "o
E WASHINGTON. D.C. 20665 0001 g,
UM TO:
James M. Taylor l
Executive Director for Operations W
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FROM:
John C. Hoyle, Secretary
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STAFF REQUIREMENTS - BRIEFING ON STATUS OF
SUBJECT:
ACTION PLAN FOR' FUEL CYCLE FACILITIES, 10:00 A.M.,
WEDNESDAY, MARCH 22, 1995, l
COMMISSIONERS' CONFERENCE ROOM,'ONE WHITE 2
FLINT NORTH, ROCKVILLE, MARYLAND (OPEN TO PUBLIC ATTENDANCE)
The Commission was briefed by the NRC staf f on the status of the s
The Commission requested action plan for fuel cycle facilities.
that the staff reconsider the current plan to revise 10 CFR Part 70 in its entirety, including the following items:
the proposal should be discussed with the major fuel 1.
cycle licensees to determine their attitude touards revising Part 70, the cost to revise and implement a new Part 70 to both 2.
the NRC and licensees'should be determined, and 4
alternative approaches should be considered and 3.
evaluated.
The staff should proceed with plans for CRGR review of the Prior to returning to the proposed revision to Part 70.
the staff should consider the Commission with a proposed rule, items discussed above and.present the Commission with the pros cnd cons of the titernatives considered and a recommended course i
of action.
(SECY Suspense:
6/14/95) 4 l
(EDO) cc:
The Chairman Commissioner Rogers Commissioner de Planque OGC OCA Office Directors, Regions, ACRS, ACNW, ASLBP (via E-Mail)
OYG PDR - Advance DCS - P1-24 4
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h Excerpt from the Minutes of CRGR Meeting No. 271 Relating to Information Briefing on Propo::ed Major Revision to Part 70 '
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Information Briefino on Status of the Action Plan for Fuel Cycle l
Facilities and the Proposed Ma.ior Revision of 10 CFR Part 70 April 11, 1995 TOPIC R. Burnett (NMSS), L. Ten Eyck (NMSS), and W. Schwink (NMSS) briefed the t
CRGR on current status of the action Plan for fuel cycle facilities and the l
proposed major revision of 10 CFR Part 70, with emphasis on the recent redirection of the ongoing effort by the Commission to explore alternative approaches. outlined for the Committee proposed new procedures Copies of the briefing slides used in the presentation to the Committee are enclosed (Attachment 4A).
BACKGROUND
'A.
The following background documents were made available to CRGR members in connection with this information briefing:
1.
Transcript of Commission Meeting on March 22, 1995
" Briefing on Status of Acticn Plan for Fuel Cycle Facilities" 2.
SRM, dated 3/22/95, resulting from the NMSS briefing to the Commission on Status of Action Plan for Fuel Cycle Facilities 3.
Updated preliminary working draft, dated 3/31/95, of " Revision of 10 CFR Part 70" 4.
Draft document (undated), " Regulatory Benefits Impact Analysis" (compares " Rewritten'Part 70" to " Existing Part 70", point by point) 5.
Draft Revision 2, dated January 1995, to Regulatory Guide 3.52,
" Standard Format and Content for the Health and Safety Sections of License Applications for Fuel Cycle Facilities" i
6.
Draft NUREG-1520, " Standard Review Plan for the Review of a License Application for a Fuel Cycle Facility" (portions dated j
variously December 1994 through February 1995)
CONCLUSIONS / RECOMMENDATIONS 1
l No forual CRGR recommendations resulted from the discussions with HMSS staff at this meeting; but the Commitee offered several preliminary comments and suggestions regarding possible areas of focus in considering alternative approaches as directed by the Commission:
1.
It may be useful and practical to concentrate efforts on the " core" sections of the proposed rule that are directed to the large nuclear
7 l
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. materials processing facilities (the so-called C and D Categories of facilities / licensees), and consider separating out that portion of the current overall rulemaking package to be addressed on a priority basis and timeline.
It appears that this could simplify the current complex rulemaking package greatly, and would focus staff and licensee resources where the predominant risks are involved.
In conjunction with this simplification and streamlining theme, Committee members presented preliminary views, based on a first scan of the extensive Part 70 package elements provided, of specific areas to be reexamined for possible simplification or paring down; the areas focused on initially in this context were the proposed provisions on training, licensee QA programs and event reporting.
The Committee will now direct its review efforts to the draft SRP (that is already well developed and provided as a part of the extensive Part 70 revision package) for a better understanding of the planned implementation of these provisions.
With regard to event reporting, specifically, the Committee noted the relatively high incidence of precursor type events for such a small number of facilities involved; and the discussions on this point highlighted the fact that there appear to be important differences in the existing mechanisms for effective sharing of event information and lessons learned among the licensees of the large nuclear material processing facilities, as compared to power reactor licensees, that may indicate a greater safety significance to reporting provisions for the materials licensees (because NRC tends to function more importantly in a clearing house role for this important type of feedback for the large materials facilities).
2.
The Committee discussed plans to visit the Westinghouse Columbia fuels-facility in May in connection with the Part 70 review; and the f
information and discussions provided by the NMSS staff at this meeting were useful in identifying areas of focus in the CRGR discussions with the licensee and the planned tour of that facility (e.g., the integrated safety analysis of the facility and its operations currently being performed by the licensee). This will provide valuable insights to CRGR's evaluation of the benefits and costs associated with implementation of that key proposed provision of the current proposed Part 70 revision, and'the question of whether the associated schedules prescribed in the proposed rule is realistic.
3.
The Committee commended HMSS for a comprehensive, candid and informative briefing on the very complex proposed Part 70 rulemaking, and its understanding and implementation of the Commission's recent directive to consider alternative approaches.
In this regard, the Committee was informed that a public meeting has already been arranged with the large materials facilities licensees on May 2 to discuss current thinking and possible proposals in this regard.
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f SRM Dated December 4,1996 a
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Action:
Paper 1ello, w a8e UNITED STATES Cvs:
Taylor NUCLEAR REGULATORY COMMISSION can n
WASHINGTON, O C 20555-0001 E
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December 4, 1996 Morrison, RES Miraglia, NRR Sherr, NMSS OFFICE OF THE SECRETARY MEMORANDUM TO:
James M.
Taylor Exegt tive Dir ctor for Operations
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Jo C. Hoyle Secretary
SUBJECT:
STAFF REQUIREMENTS - SECY-96-079 -
ALTERNATIVES FOR REGULATING FUEI CYCLE FACILITIES 4
SECY-96-079 is being returned to the staff so that the staff can factor into its evaluation the Nuclear Energy Institute's (NEI)
Petition for R.ulemaking dated September 30, 1996.
The NEI's Petition contains a proposed. rule that would require 10 CFR Part 70 licensees to evaluate and enhance their overall safety program basea on data generated from an Integrated Safety Assessment, or an acceptable alternative, and predicated on specifically defined performance criteria.
The staff should evaluate the effect, if any, that the NEI Petition has on its analysis presented in SECY-96-079.
9500041 (iilDOF (NMSS)
(SECY Suspense:
5/30/97) cc:
ChairTnan Jackson Commissioner Rogers Commissioner Dicus Commissioner Diaz Commissioner McGaffigan OGC OCA OIG Office Directors, Regions, ACRS, ACNW, ASLBP (via E-Mail)
SECY NOTE:
THIS SRM AND SECY-96-079 WILL BE MADE PUBLICLY AVAILABLE 5 WORKING DAYS FROM THE DATE OF THIS SRM.
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Excerpt from AEOD Annual Report
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Summary of CRGR Activities with Value-Added L.
Evaluation for Each ReviewItem l
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.9 Committee to Review Generic Requirements j
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De Committee to Review Generic Requirements review and to evaluate various means of reducing i
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-(CRGR) reviews all generic requirements pro-the burden on CRGR members. On April 21, posed by the NRC staff that involve one or more 1994, the EDO transmitted to the Commission classes of power reactors. De CRGR consists of SECY-94-109 proposing to reduce the basic
-l senior managers from various headquarters pro-scope of CRGR review to include only *high l
gram offices and, on a rotational basis, from one impact" and " controversial" generic correspon-l of the NRC regional offices. De AEOD Director
' dence and rules before public comment, issues L
serves as the CRGR Chairman, and the AEOD which the staff has difficulty resolving after public
.i l
staff provides support for all of the Committee's comment, emergency and urgent generic corre-l activities. De AEOD Director also eversees spondence, and significant proposals with highly l
plant-speciSc backfit activities of the NRC staff expedited schedules. A June 15,1994, staff re-l in the headquarters program offices and the quirements memorandum (SRM) directed the i
regional offices. In 1994 four new members, three.
staff not to reduce the scope of the CRGR Char-L from headquarters and one from a region, were ter but to consider, and to recommend a course of appointed to the CRGR. In 1995 one new member action for, enlarging the scope of CRGR review to from headquarters was appointed to the'CRGR.
include proposed generic requirements in the De membership of the CRGR as of September nuclear materials area. He SRM also directed the 30,1995, is'as follows:
staff to look at measures which would lessen the -
time spent on CRGR reviews by individual Edward L. Jordan, Director, AEOD
'CRGR members. De Committee evaluated this (Chairman) option and agreed to address, on a 1 year trial basis, selected nuclear materials issues identified Fr::nk J, Miraglia, Deputy Director, NRIt by the NMSS Director or by the EDO. He Com-ininee w assess whder or not the nuclear Malcolm Knapp, Deputy Director, NMSS materials issues that are presented by the staff for i
CRGR review warrant CRGR attention and,if so, Joseph Murphy, Executive Assistant to whether the CRGR review adds sigmficant value.
' Director' RES Based on that assessment, the Committee will Ell;s Merschoff, Director, Division of Reac.
make appropriate recommendations to the EDO regarding continuation of the CRGR review of tor Projects, RII nuclear materials issues his assessment will be Dennis Dambly, Assistaat General Counsel included in the CRGR meeting minutes during for Materials, Antitrust and Special the trial period, and it will also be reported to the EDO in the CRGR Weekly Items of Interest to be Proceedings, OGC reported to the Commission. His aspect of the l
While performing the CRGR review function, a expanded scope of CRGR review was included in l
CRGR member expresses an individual ptofes-the ongoing CRGR Charter revision process.
sional opinion about each item considered, rather On February 9,1996, in SECY-96-032, the EDO than representing the view of his or her respective office.De members of the CRGR determine requested Commission approval for this 1 year whether proposed new generic requirements have trial program to include selected nuclear materials sufficient merit in terms of safety and are justified issues. De Commission was also informed that in terms of cost (where appropriate) before reach-the CRGR has considered and adopted measures ing a consensus recommendation about each issue to lessen the time spent by members on CRGR l
considered. Each independent CRGR recommen-reviews. When appropriate, based on lack of dation is given to the EDO for consideration.
controversy, low expected impact, or small poten-i tial for error related to the proposed generic l
l In 1994 a staff proposal was submitted to the actions, the CRGR Chairman may agree to one of Commission to reduce the scope of the CRGR three courses of action:(1) defer the CRGR's i
l NUREG-1272. Section 9 55 i
AEOD Annual Report,1994-FY 95 review pending public comment on the proposal; Commission paper on reducing the scope of e
or (2) agree to a negative consent approach which, the CRGR review in essence, is an abbreviated review; or (3) forgo a he Committee suggested new criteria for the second CRGR review, thus reducing the number staff to use in determining the need for CRGR of dual reviews (i.e., review at both the proposed review of proposed new generic requirements.
and final stage). All other staff proposals will be scheduled for regular CRGR review.
proposed rule on reactor coolant pump seals e
The Committee recommended an analysis option On March 22,1996, the Commission approved (as opposed to plant modificatiens) as a means of Revision 6 to the CRGR Charter, which expan-satisfying the requirements of the rule, and sug-ded the scope of CRGR reviews, on a 1 year trial gested that the implementation of the proposed basis, to include selected nuclear materials issues rule be used as a test vehicle for evaluating the requested by the NMSS Director or the EDO.
risk-based approach to regulations.
Between January 1,1994, and September 30,1995, proposed rule for shutdown and low power e
the CRGR held 24 meetings during which it operations e Comnu. tee identified serious inadequacies in discussed 45 issues, including 4 related to nuclear t
materials. The Committee, in its reviews of pro-the probabilistic analyses supportmg the pro-posed new generic requirements, continued to Posed rule, but highlighted qualitative consider-place emphasis on less prescriptive, more perfor-attons (e.g., continued adverse operating experi-mance-based and riskinformed regulations. The ence) that justified new requirements for CRGR supported the expedited review of 10 items shutdown and low power operations.
requested by the staff. Of these, two were pro-proposed final rule on malevolent use of e
posed urgent bulletins, four were Generic Letters, vehicles three were rules, and one was a regulatory guide.
The followmg issues were reviewed by the CRGR De CRGR recommended several significant in 1994 and FY 95:
clarifying changes to the draft rule wording relat-ing to the appropriate backfit justification and the practicality of using a PRA approach in evaluat-proposed final Supplement I to Generic ing safeguards.
e Letter 86-10 on fire protection The CRGR recommended clarifying changes urgent bulletin on fuel pool drain-down e
regarding the use of the industry standards for
" Die Committee recommended changes to the text cable insulation testing.
to clarify ambiguity as to whether the requested actions were intended as a 10 CFR 50.54(f)infor-mation request or were also intended to impose a proposed urgent bulletm on plugging of backfit.
e strainers in ECCS pump suction lines Supplement 7 to Generic Letter 89-10 on e
The CRGR pointed out that, because of the low probability of a LOCA, there was sufficient time valve mispositioning in pressurized-water to incorporate the results of further studies and reactors request public comments. The Committee also The Committee identified serious weaknesses in recommended that additional training be included the limited-scope study supporting the proposed for appropriate emergency response personnel.
actions, and questioned the staff's rationale for promulgatmg the existmg position m the first P ace. The package was returned to the staff for l
o proposed Revision 3 to NUREG-0654 (crite.
substantial rework.
ria for protective actions for severe acci-dents) proposed rule to reduce the frequency of e
The CRGR recommended modifications to make emergency planning exercises clear that implementation of the revisions to The CRGR noted that licensees have not taken emergency plans was strictly voluntary.
full advantage of the significant flexibility that NUREG-1272. Section 9 56
CRGR proposed Generic Letter on voltage-based exists under the current requirements and guid-e ance relating to the annual emergency planning steam generator tube repair criteria exercise. He Committee recommended that this ne Committee highlighted the need for greater be clearly reflected m the propo9ed rule. Addi-emphasis in the proposed Generic Letter on tional recommended changes to the package were continued development and implementation of to clarify the following pomts: (1) what was m,,
better eddy current technology, data acquisition, tended by the term combmed functional drill;.
and analysis techniques.
(2) that no backfittmg is mtended or approved in connection with promulgation of this rule; and (3) i PmPosed expedited Generic Letter on BWR that the projected NRC savings were significantly core shroud crackm, g j
overestimated.
The Committee recommended that the staff (1)
Advanced Notice of Proposed Rulemaking expand the scope of the inspection plan to ad-e on steam generator surveillance and mamte-dress all shroud welds (or provide a justification nance for any exclusions) and examination methods ne Committee was in favor of issuing the notice utilizing the best available technology and indus-but expressed disappointment at the lack of try inspection experience; (2) include their asses-initiative and involvement of the cognizant codes sment of the BWR Owners' Group's efforts;(3) and standards groups in developing the criteria verify compliance with the structural integrity l
and guidance crucially needed in this important requirements of 10 CFR 50.55a: (4) assure, on the basis of estimates of risk contribution from 4
area.
shroud cracking, that shroud cracking poses a low proposed Generic Letter on analog-to-digi-risk; and (5) ask licensees to perform safety analy-1 e
tal upgrade ses to support continued operation of their facili-He Committee endorsed the Generic Letter for ties until the inspections are conducted.
publication subject to the following clarifications:
)
proposed final Revision 3 to Regulatory (1) make clear that the staff is endorsing the e
Electric Power Research Institute / Nuclear Man-Analysis Guidelines, NUREG/BR-0058 agement and Resources Council Technical Report ne Committee endorsed issuance of this revision f
TR-102348 for meeting the requirements of 10 to the Regulatory Analysis Guidelines subject to i
CFR 50.59, and (2) incorporate specific illustrative the following comments:(1) the staff make it clear examples relating to the determmation of an that it is appropriate to consider voluntary actions unreviewed safety question.
by licensees in developing proposed new require-ments (although voluntary actions are not to be handling of comments from outside the NRC credited in base case value/ impact analysis, they e
while rulemaking package is being developed may be included in the appropriate sensitivity he CRGR determmed that it would be appropri-analysis), and (2) the staff include in the package ate for the staff to consider any comments from a summary discussion of all major policy issues outside the NRC received during the development considered in this revision (e.g., status of the large of the rulen akmg package at the same time the release guidelines issue, and treatment of the staff evaluates other pubhc comments received in averted off-site costs).
response to the Federal Register Notice mvitmg public comments on the rule.
proposed general revision of Appendix J e
recent Staff Requirements Memorandum on The CRGR endorsed promulgation of the rule scope of review for the CRGR subject to clarifications to address the value of The Committee identified several ways to better on-line monitoring and possible credit that could utilize the members' time, including more fre-be given in terms of leakage testing requirements quent use of the negative consent process and for its use, and how significantly increased leak-reducing the number of dual reviews (full review age rates can produce only marginal effects on the at both the proposed and final stages).
estimated accidental doses.
i 57 NUREG-1272, Section 9
AEOD A aual Report,1994-FY 95 proposed branch technical position on ducting other surveillance tests, and make it clear e
concentration averaging and encapsulation that the determination that response time testing of low-level waste is not needed is based principally on the conclu-The CRGR obtained industry cost estimates for sion that other testing, such as calibration testing, implementing the proposed action because these can detect response time degradation that might occur.
were not provided in the package. The Committee recommended clarifications to thc discussion of a
final rule to add the standardized NUHOMS concentration averaging over containment volume horizontal modular storage system to the list l
m mixed waste packaging that reduced projected of approved spent fuel storage casks in 10 costs by a factor of 2 (from $L5 billion to $750 CFR 72.214 million). The Committee also recommended to the EDO that attention be given to full coordination The Committee recommended to the staff the of this issue with other related policy issues (e.g.,
following revisions: (1) place more emphasis on implementation of the Decommissioning Rule) to experience accumulated with similar casks in use ensure Commission awareness of, and involve.
under facilityspecific licenses; (2) provide addi-ment in, any necessary policy development.
tional flexibility to the licensees with respect to temperature monitoring during the initial period; proposed NRR procedures to implement.
and (3) evaluate the endorsement of ACI-34-85 in e
selected Standard Technical Specifications leu of ACI-34-80 which is currently approved by at Based on discussions at the meeting, the Commit-
, ba kfi '
tee identified several ways for efficient handling of applications for license amendments to incorpo-final Generic Letter and NUREG-1482, e
- rate Technical Specifications improvements.
" Guidelines for Inservice Testing at Nuclear Power Plants" Supplement 2 to NUREG-0654 (Revision 1)
The Committee recommended numerous changes e
to provide gm, dance for the development, in the package to clarify that issuance of this review, and approval of radiological emer-guidance does not constitute approval of any new gency preparedness mformanon and plans NRC positions to be imposed on licensees, and submitted with early site permit applications that the plant-specific application o t is gmd-under Subpart A of 10 CFR Part 52 ance by hcensees is purely vo untary.
The Committee endorsed the issuance of the proposed Supplement to Generic Letter proposed guidance and recommended to the staff a
the following clarifying revisions: (1) make it clear 88-20 to raodify some seismic provisions that the proposed supplement does not completely applicable to licensees' conduct of the Indi-replace the existing emergency planning require-vidual Plant Examination for External ments for the affected facilities, and (2) include Events (IPEEE) review for their facilities any necessary modifications to ensure consistency The CRGR recommended changes to the package with the usage and implementation of the terms to clarify that the recent observations of cracks "should" and "shall."
associated with reactor internals is not yet re-solved and this matter is being evaluated sepa-Safety Evaluation Report (SER) on BWR rately both as an operating issue (within design-e Owners Group Topical report (NEDO-basis) and with respect to severe accident implica-32991)," System Analysis for Elimination of tions (i.e., beyond design basis); and that no Selected Response Time Testing Require-response is required from licensees who do not ments" wish to voluntarily modify their previously com-
'lhe Committee endorsed th'e SER subject to mitted seismic IPEEE programs.
substantial revision. In particular, the Committee 10 CFR 50.54(f) letter on Thermo-La8 e
recommended that the staff chmmate any imph,ca-tions that 5 seconds has been specifically proven The Committee recommended revisions to make to be a time delay that is detectable when con.
clear the staff s decision to separately pursue NUREG-1272, Section 9 58
CRGR seismic issue petitions (i.e., how degraded Ther-The Committee agreed to review, on a 1 year trial mo-Lag materials will respond to seismic motion) basis, selected nuclear materials issues at the raised under the provisions of 10 CFR 2.202.
request of the NMSS Director or the EDO. Spe-cifically, the Committee will assess the value added by CRGR reviews, and based on that proposed Generic Letter on pressure locking assessment will make appropriate recommenda-o and thermal binding of gate valves tions to the EDO regarding continuation of the The Committee endorsed this generic action review of nuclear materials issues.
subject to various comments.
n charpy upper shelf energy less than 50 lbs proposed revisions to 10 CFR Part 26, " Fit-o ness for Duty" The Committee complimented the staff on its efforts and recommended several minor changes ne Committee endorsed this rule for issuance, to the text.
subject to several comments. During a discussion proposed rule on reporting of risk-signifi-on this rule at the CRGR meeting, the staffindi-e cated that some of the proposed amendments cant reliability and availability data would not meet the test of the Backfit Rule In its review of the proposed new generic require-(50.109), thus it was recognized that the Comrm.
ments, the Committee continued to give emphasis s-sion would have to endorse an exception to this to less prescriptive, performance-based and rule for these amendments to be issued. The riskinformed regulations. Consistent with this Committee noted that the staff had considered approach, the Committee gave a high priority to and rejected the use of the qualitative factors the review of the Reliability / Availability Data outlined in Attachment 3 of the CRGR Charter, Rule and later review of the accompanying Regu-Revision 6 although the Fitness for Duty Rule latory Guide.
was specifically cited as one of the examples where qualitative arguments could be and have briefing on steam generator tube cracking at e
been used.
Maine Yankee The Committee offered suggestions on the work-CRGR charter requirements and the rule-ing draft of the Generic Letter regarding points o
making process improvements discussed in which needed emphasis or clarification. The SECY-94-141 and the associated Staff.
Committee emphasized that the staff should, after Requirements Memorandum, date June evaluation of the nondestructive test data is com-28,1994 plete, clearly indicate whether the test indications n ted in the Maine Yankee inspections were due o
discussion with NMSS Director on CRGR Primarily to the sensitivity of the test method or review of nuclear materials items to the rapid crack growth. De staff should also The CRGR discussed possible expansion of the clarify whether or not the continued use of the CRGR review scope to include proposed new rotating pancake coil (RPC) probe, and plugging requirements.in the nuclear materials area. NMSS of steam generator tubes when circumferential indicated that the Committee's perspective and cracking is first indicated by RPC inspections, is advice on structural, electrical, and mechanical acceptable. The Committee also noted that, re-aspects of the regulation of spent fuel and waste gardless of the approach used to address the storage / transportation operations, and on the concerns raised by the steam generator tube systems aspects of low-enriched uranium fuel circumferential cracking experience 1.1 Maits fabrication facilities could be helpful. It was also Yankee, the clearly stated objective should be that suggested that, with regard to proposed new NRC staff know the threshold sensitivity of the requirements that are risk-and/or performance-measurement with respect to crack growth, the based, the Committee can provide a useful inde-crack growth rate based on comparison of the pendent assessment of under-or over-regulation cycle-to-cycle inspections, and why it is safe to,
in the nuclear materials area.
operate to end-of-cycle. The urgent Generic 59 NUREG-1272, Section 9
AEOD Annual Report,1994-FY 95 Letter on the subject was later issued without.
mittee and the CRGR staff's input contributed additional CRGR review.
signi5cantly to resolution of issues raised by the Office of General Counsel concerning the proper final rule (10 CFR 50.36) to codify the Tech-use of the compliance exception. He outcome will o
nical Specifications Improvement Program be reflected in the revised generic guidance to the criteria staff.
The Committee endorsed the proposed amend-Proposed Genen. htter on madequate e
ment subject to several modifications and clarifi.
testmg of safety-related logic circuits cations to the proposed text. The Committee felt that the staff's intended use of PRA results to The CRGR recommended that the staff consider include or exclude items from Technical Specifica.
developing a standard practice for enforcement tions (TS) was too restrictive. The Committee actions against licensees for inadequate testing of specifically noted that probabilistic analyses have safetyrelated logic circuits while performing the been the bases of a number of proposals brought actions requested in this Generic Letter.
to the CRGR regarding elimination or relaxation urgent Generic letter on circumferential e
of TS surveillance requirements, and that a re.
cracking of steam generator tubes (issued strictive mterpretation and application of Criten-prior to CRGR review) on 4 seemed mconsistent with previous actions by the staff. In addition, the Committee suggested As noted previously, the Committee had provided that the four proposed criteria should be used as significant comments on a working draft of the a set and not individually to include or exclude Generic htter during the staff's briefing on Maine Yankee steam generator tube circumferen-items from the TS.
tial cracking.
riefi g on proposed revision to 10 CFR o
proposed urgent Generic Letter on reactor e
pressure vessel structural integrity (issued
- De CRGR review of the planned revision of 10 without public comment)
CFR Part 70 was done at the Commission's direc-The Committee agreed with the staff's position tion. The Committee suggested that it nught be that the provisions of the proposed Supplement to useful for the staff to concentrate on the core,
Generic Letter 92-01 did not impose any new sections of the proposed rule that are directed t requirements or modify existing requirements, the large nuclear materials processing facilities and it is only a request for information under 10 and address that portion of the rulemaking pack-CFR 50.54(f). He Committee's approval was age on a priority basis.
subject to several clarifying comments.
De discussion at this meeting with the staff was discussion with OGC on Compliance and e
especially useful to the CRGR in the light of the Adequate Protection exceptions to the Back-forthcoming meeting with the licensee and the fit Rule (50.109) and 50.54(f) information i
tour of the Westinghouse Columbia Fuels facility requests by the Committee members and the CRGR staff.
The staff benefitted from the CRGR's discussion Based upon the candid dialogue with the licensee with OGC staff on Compliance and Adequate dunng the site visit, the Committee provided Protection exceptions to the Backfit Rule (50.109),
valuable msights and feedback to the NMSS and the ensuing guidance for future generic ac-I rnanagennent.
tions pertaining to information requests (50.54(f)).
ne Committee and the CRGR staff's input y
final rule to incorporate Subsections IWE contributed significantly to resolution of issues e
and IWL of the ASME Boiler and Pressure raised by OGC concerning the proper use of the Vessel Code into 10 CFR 50.55a Compliance exception. The outcome will be re-In the CRGR review of the proposed final rule flected in the revised generic guidance to the staff.
revising 10 CFR 50.55(a) to incorporate contam-proposed final Generic Letter on voltage-ment inspection provisions (Subsections IWE/
e IWL) of Section XI of the ASME Code, the Com-based repair criteria for Westinghouse steam NUREG-1272, Section 9.
60
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l' CRGR 1
l generator tubes with outer diameter stress bulletin to include that the staff has reasonable l
corrosion cracking confidence that the interim actions taken in re-De CRGR endorsed these generic actions subject sponse to previous bulletins are adequate in 1
to various editorial and clarification comments.
assuring public health and safety, and to provide rationale for long-term continued operation until 4
proposed final rule and Regulatory Guide on the final actions are completed; (2) acknowledge
)
e reactor pressure vessel annealing the ongoing industry efforts; (3) address uncer-tainties m the analysis, as no guidance currently The CRGR supported the staff's action to pro-exists in the Regulatory Guide; and (4) provide ceed with the issuance of the final rule and the
-estimates of the costs associated with the re-4 l
accompanying regulatory guide, subject to various quested actions.
j comments. De Committee noted that one aspect of this rule for which backfit considerations re-briefing by NRR staff on reexamination of e
ceived some attention at the proposed rule stage the Oconee station emergency electrical was the subject of the use of nuclear heat for distribution system hydrostatic pressure and leak testing in BWRs. At The EDO requested that the Committee give an~
the final rule stage, this issue was raised again.
independent assessment of the Oconee station ne Advisory Committee on Reactor Safeguards emergency electrical distribution system. The i
recommended that the staff do a n,sk assessment Acting CRGR Chairman and the CRGR staff of this. In light of this recommendation, the visited the Oconee station as part of this review.
CRGR deferred any additional recommendations This effort continues.
on this issue.
proposed amendments to 10 CFR 26 -
e proposed Bulletin and Revision 2 to Regula-Fitness for Duty Rule e
tory Guide 1.82 on post-LOCA ECCS The CRGR review of this rule highlighted the strainer pluggmg question of separating proposed relaxations from De CRGR endorsed the generic actions subject proposed backfits, if necessary, in order to pro-4 to various comments. The Committee asked the ceed with implementation of clearly justified staff to do the following: (1) modify the text of the relaxations.
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61 NUREG-1272, Section 9
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