ML20196G077
| ML20196G077 | |
| Person / Time | |
|---|---|
| Issue date: | 04/07/1997 |
| From: | Ross D Committee To Review Generic Requirements |
| To: | Callan L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20196G081 | List: |
| References | |
| NUDOCS 9705130421 | |
| Download: ML20196G077 (9) | |
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UNITED STATES g
j NUCLEAR REGULATORY COMMISSION 4'
WASHINGTON, D.C. 20565 4001 o
- ,o April 7, 1997 i
i MEMORANDUM T0:
L. Joseph Callan Executive Director for Operations /
FROM:
Denwood F. Ross, Jr., Chairman Committee to Review Generic Re eEnts
SUBJECT:
COMBINED MINUTES OF CRGR MEETING NUMBER 299 AND 300 The Committee to Review Generic Requirements (CRGR) met on Tuesday, January 28, 1997, from 9:00 a.m. to 12:00 noon, and on February 4, 1997 from 9:00 a.m. to 11:00 a.m.
A l ht of attendees for the two meetings is provided in Attachment 1-A and 1-B, recpectively.
~
At the 299th meeting, G. Lainas (NRR) presented for CRGR review and endorsement the generic letter titled " Modification of the NRC Staff's Recommendations for the Post-Accident Sampling System." This generic letter addresses a shift in the previously accepted staff position; the staff would now entertain licensee-initiated requests to modify their current post-accident sampling system (PASS) requirements based on NRC's previous recommendations for PASS, originally specified in NUREG-0737.
The CRGR made several comments on the technical aspects and the scope of the proposed generic letter.
Saecific recommendations were offered.
It was also agreed that the Director N1R, in accordance with,Section IV(b)(x). CRGR Charter, Revision 6, would forward a letter to the Chairman, CRGR, stating that the public health and safety and the common defense 6nd security would be adequately protected if the proposed reduction in requirements or position were implemented (Attachment 2). Contingent upon the receipt of such a letter, and the staff's satisfactorily incorporating the Committee's comments, the CRGR agreed to endorse the generic letter for issuance for public comment.
. contains the details.
Subsequently', an e-mail, dated March 5.
1997, from Associate Director, for Technical Review, NRR to CRGR Chairman, affirmed that he represented the office position when transmitting the PASS generic letter proposing to eliminate certain redundant and marginal requirements. Thus, satisfying the intent of the above cited CRGR Charter j
requirement. The CRGR endorsement was formally relayed to the staff on f
March 13, 1997.
W At the 299th CRGR meeting G. Lainas (NRR) also presented for CRGR review and endorsement the generic letter titled "Degradat',on of Control Rod Drive Mechanism and Other Vessel Head Penetration." The discussion on this topic was continued on February 4th at the 300th meeting of the Committee.
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I L. Joseph Callan Prior to CRGR Meeting No. 299, the CRGR Chairman and the CRGR staff were approached by the Nuclear Energy Institute (NEI) to request a meeting with the Committee alleging that the staff had not appropriately addressed their comments when the subject generic letter was issued for public comments (NEI.
in its January 23, 21997 letter to D. Ross states that a copy of the December 26, 1996 memorandum from the staff was obtained from the Document Room on January 17, 1997. Subsecuently. NEI sent a letter to the Chairman, CRGR, dated January 23, 1997, celineating their concerns regarding the scope and contents of the generic letter as-published for comments (Attachment 4).
Although the Committee did not meet with the NEI representatives, this letter was distributed to the CRGR members and also to the cognizant NRR management and staff.
NEI was informed that the concerns outlined in their letter would be considered as public comments.
Specific CRGR recommendations were as follows:
(1)
As p;4(f) information request to verify compliance with existingroposed, the
- 50..
regulations (namely, 10 CFR 50.55(a) and 10 CFR Part 50. Appendix A, GDC 14).
The CRGR recommended that the wording in the pertinent paragraphs be re-phrased to ask the licensees only the information that is currently required to be reportable.
(2)
The staff had initially asked for collection and reporting of new information that would also be continued in the future, and for which no cost-benefit analysis was provided to the Committee.
Consequently, the licensee responses sought entailed "com)liance" with new requirements.
which were beyond their current legal o) ligations, and which, in the future, could be regarded as written commitments.
On July 25, 1996, a memorandum from E. L. Jordan to F. J. Miraglia, the CRGR review of the generic letter was deferred until the final version (i.e., after addressing the public comments). Also, a copy of an AE0D-s)onsored report, pre)ared by INEL. " Assessment of Pressurized Water Reactor Control Rod ) rive Mechanism Nozzle racking."
(NUREG/CR-6245, published in 1994) was forwarded as an attachment to send along with the generic letter, for information.
In this communication, the Acting Chairman. CRGR. specifically noted that although the staff asserts that NRC is not requesting any new actions
[ step (ix) of the CRGR Charter questions]. action 1.2.a of the generic letter makes it clear that the results of the subsequent inspections are wanted (and clearly this information must be gathered in the future).
In addition, in this memorandum appropriate wording was suggested for use in the context of the backfit discussion.
Some concerns regarding i
The cognizant staff had informed the CRGR staff that this predecisional document was inadvertently placed in the NRC Public Document Room.
l L. Joseph Callan l the scope of the information being asked for and the backfit aspects of the proposed generic action remained outstanding at this round of CRGR review.
The Committee recommended that the staff should clearly state that the information sought is one-time only, and should ensure that no new requirements for collection and reporting of information in the future are being " imposed" via the generic letter.
The )urpose of information collection was to enable the staff to determine tie licensees compliance with existing regulations, and to determine whether an augmented inspection program pursuant to 50.55(a)(g)(6)(1) is necessary.
(3)
The Committee noted that there was no immediate compelling safety issue; however, the degradation of the control rod drive mechanism (CRDM) and vessel head penetration (VHP) is certainly a long-term concern.
Therefore, monitoring of the CRDM and VHP degradation is important.
The Committee recommended that the staff ask for information about the licensees' current CRDM and VHP inspection programs, and their analysis that supports why no augmented inspection is necessary.
(4)
The CRGR accepted the staff's rationale that asking the licensees to submit information (discussed in (3) above) will enable the staff to determine whether or not an augmented ins)ection program is necessary.
However, th? Committee recommended that t11s point should be explicitly acknowledged. Additionally, the Committee recommended that a sentence be included in the " Purpose" and the " Requested Information" sections to the effect: The information requested is needed by the NRC staff to verify compliance with 10 CFR 50.55a and 10 CFR Part 50. Appendix A.
GDC 14. and to determine whether an augmented inspection program, pursuant to 10 CFR 50.55(a)(g)(6)(ii), is required.
(5)
The Committee recommended that a)propriate changes in wording be made in the " boiler plate" material of t11s generic letter as well, to make it consistent with similar other generic letters.
The Committee recommended several changes to the information and actions requested via this proposed generic letter.
Following the staff's satisfactory incorporation of the Committee's recommendations the revised generic letter was endorsed for issuance on February 13, 1997.
contains the details.
In accordance with the ED0's July 18. 1983 directive concerning " Feedback and l
Closure of CRGR Review." a written response is required from the cognizant office to report agreement or disagreement with the CRGR recommendations in these minutes.
The response is to be forwarded to the CRGR Chairman and if there is disagreement with the CRGR recommendations, to the EDO for decision making.
I
L. Joseph Callan The CRGR staff would also accept e-mail communications from the cognizant t
l staff.
l Questions concerning these meeting minutes should be referred to Raji Tripathi l
(415-7584).
i Attachments: As stated cc:
Commission (5)
SECY J. Lieberman. OE E. Halman. ADM H. Bell. OIG K. Cyr. OGC J. Larkins, ACRS Office Directors Regional Administrators, RI/RII/RIII/RIV CRGR Members B. Sheron, NRR
I I
L. Joseph Callan The CRGR staff would also accept e-mail communications from the cognizant staff.
Questions concerning these meeting minutes should be referred to Raji Tripathi l
(415-7584).
I l
Attachments: As stated cc:
Commission (5)
SECY J. Lieberman. OE j
E. Halman. ADM H. Bell. OIG K. Cyr. OGC l
J. Larkins. ACRS Office Directors Regional Administrators. RI/RII/RIII/RIV CRGR Members B. Sheron NRR Distribution of Minutes for CRGR Meetinas 299 and 300 See Next Page S:\\CRGR\\DMTS_299.
O CRG.
OD 0. ' 0D athi DF ss RTrip/97 4/5 4/ /97 l
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' Dis':ribur on of Combined Minutes for CRGR Meetinas 299 and 300 Cen';ralele w/att..
PDR (NRC/CRGR) e/o.att.
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CRGR SF CRGR CF S. Treby E.-Jordan
.J. Mitchell l-G.'Lainas-R. Tripathi A. Thadani J. Shapaker t
l W.-Burton L
G. Lainas J. Strosnider K. Perczweski D. Terao R. Weisman
.T. Martin i
F. Congel l~
R. Hasselberg J. Giitter l
C. Carpenter l
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. -A to the Combined Minutes of CRGR Meetino No. 299 and 300 Attendance List at the CRGR Meetina No. 299 January 28. 1997 CRGR Members NRC Staff D. Ross G. Lainas B. Sheron (for F. Miraglia)
K. Perczweski C. Haughney (for M. Knapp)
D. Terao J. Mur)hy R. Weisman D. Dam)1y R. Hasselberg C.W. Hehl J. Shapaker W. Burton CRGR Staff R. Tripathi i
l
I -B to the Combined Minutes of CRGR Meetina No. 299 and 300 l
l Attendance List at the CRGR Meetina No. 300 February 4, 1997 i
CRGR Members NRC Staff D. Ross J. Strosnider B. Sheron (for F. Miraglia)
C. Carpenter C. Haughney (for M. Knapp)
J. Shapaker J. Murahy W. Burton D. Dam)1y B. Sheron i
C.W. Hehl l
CRGR Staff R. Tripathi l
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- to the Combined Minutes of CRGR Meeting No. 299 and 300 In accordance with.Section IV(bXx).
CRGPs Charter. Revision 6.
a memorandum is required from the Director, of the sponsoring office to the Chairman.
CRGR. stating that the public health and safety and the common defense and security would be adequately protected if proposed reduction in requirements or position were implemented (The enclosed e-mail. dated March 5, 1997. from A. Thadani. Associate Director. for Technical Review. NRR to D. Ross. CRGR Chairman, affirmed that he represented the office position when transmitting the PASS generic letter proposing to eliminate certain redundant and marginal requirements.
Thus, satisfying the intent of the above cited CRGR Charter requirement.)
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