ML052020424
| ML052020424 | |
| Person / Time | |
|---|---|
| Issue date: | 09/26/2005 |
| From: | Hiland P NRC/NRR/DIPM/IROB |
| To: | |
| Schulten C. S., NRR/IROB/TSS, 415-1192 | |
| Shared Package | |
| ML052020360 | List: |
| References | |
| GL-91-018, TAC MC6479, Y020050052 RIS-05-020 | |
| Download: ML052020424 (4) | |
See also: RIS 2005-20
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, DC 20555-0001
September 26, 2005
NRC REGULATORY ISSUE SUMMARY 2005-20:
REVISION TO GUIDANCE FORMERLY CONTAINED IN NRC
GENERIC LETTER 91-18, INFORMATION TO LICENSEES
REGARDING TWO NRC INSPECTION MANUAL SECTIONS ON
RESOLUTION OF DEGRADED AND NONCONFORMING
CONDITIONS AND ON OPERABILITY
ADDRESSEES
All holders of operating licenses for nuclear power reactors, including those who have
permanently ceased operations and have certified that fuel has been permanently removed
from the reactor vessel.
INTENT
The U.S. Nuclear Regulatory Commission (NRC) is issuing this Regulatory Issue Summary
(RIS) to inform licensees that it has revised the guidance contained in two sections of NRC
Inspection Manual Part 9900, Technical Guidance, Operable/Operability: Ensuring the
Functional Capability of a System or Component and Resolution of Degraded and
Nonconforming Conditions, and has combined these two documents into a single document.
The revised inspection guidance reflects relevant changes that have been made to NRC
regulations, policies, and practices, and clarifies selected issues based on operating
experience. This RIS requires no action or written response on the part of an addressee.
BACKGROUND INFORMATION
The NRC staff inspection guidance contained in the two NRC Inspection Manual sections
described above were initially provided to licensees in Generic Letter (GL) 91-18, issued on
November 7, 1991. The NRC staff revised the guidance in NRC Inspection Manual Part 9900,
Technical Guidance, Resolution of Degraded and Nonconforming Conditions, and issued it in
Revision 1 of GL 91-18 on October 8, 1997. The purpose of Revision 1 of GL 91-18 was to
more explicitly discuss the role of the 10 CFR 50.59 evaluation process in the resolution of
degraded and nonconforming conditions.
In the summer of 2003, the NRC staff sought public comment on the technical guidance, which
included holding a public workshop in August 2003. The staff revised the guidance based on
the inputs received, and held a second public workshop to discuss it in August 2004.
Subsequently, the NRC staff met several times in 2005 with an industry task force formed by
the Nuclear Energy Institute (NEI), and resolved the comments received from various
stakeholders.
Page 2 of 3
SUMMARY OF ISSUE
Attached is a revised NRC Inspection Manual, Part 9900, Technical Guidance, Operability
Determinations & Functionality Assessments for Resolution of Degraded or Nonconforming
Conditions Adverse to Quality or Safety. This guidance supercedes the guidance previously
provided in GL 91-18 and Revision 1 to GL 91-18.
The attached inspection manual section provides guidance to NRC inspectors for reviewing the
actions of licensees pertaining to the operability of structures, systems, and components
(SSCs) following the discovery of degraded and nonconforming conditions in SSCs. However,
many licensees have found NRCs guidance to be very useful in developing their plant-specific
processes, and therefore the NRC staff is communicating it to licensees as a RIS.
The NRC revised its inspection guidance to reflect ongoing regulatory changes, including
implementation of the revised reactor oversight process, the requirement that licensees
appropriately assess and manage risk related to proposed maintenance activities (10 CFR 50.65(a)(4)), and implementation of the revised change control process in 10 CFR 50.59,
Changes, Tests and Experiments. The revision also clarifies selected issues in the guidance
based on operating experience and industry feedback.
In addition, the NRC concluded that the two inspection manual documents were closely related.
The NRC staff therefore combined the documents, and at the same time re-wrote them to make
them clearer and more process-oriented. However, the NRC understands that licensees may
collectively refer to the processes described in the revised Part 9900 as the GL 91-18 process
or the operability determination process (ODP).
BACKFIT DISCUSSION
This RIS requires no action or written response and, therefore, is not a backfit under 10 CFR 50.109. Consequently, the staff did not perform a backfit analysis.
FEDERAL REGISTER NOTIFICATION
A notice of opportunity for public comment was published in the Federal Register on August 3,
2004 (69 FR 46599), to give interested parties an opportunity to suggest ways for improving the
guidance. The staff concludes that this RIS and the attached NRC inspection guidance are
informational and pertain to a staff position that does not represent a departure from current
regulatory requirements and practices.
SMALL BUSINESS REGULATORY ENFORCEMENT FAIRNESS ACT OF 1996
This RIS is not a rule as defined in 5 U.S.C. 804 and therefore is not subject to the
Congressional review provisions of the Small Business Regulatory Enforcement Fairness
Action of 1996.
Page 3 of 3
PAPERWORK REDUCTION ACT STATEMENT
This RIS does not contain any information collections and, therefore, is not subject to the
requirements of the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). The
information collection requirements referenced in Manual Chapter 9900 are approved by the
Office of Management and Budget approval number 3150-0011 which expire February 28,
2007. The NRC may not conduct or sponsor, and a person is not required to respond to, an
information collection unless the requesting document displays a currently valid OMB control
number.
CONTACT
Please direct any questions about this matter to the technical contacts listed below, or to the
appropriate Office of Nuclear Reactor Regulation (NRR) project manager.
/RA/
Patrick L. Hiland, Chief
Reactor Operations Branch
Division of Inspection Program Management
Office of Nuclear Reactor Regulation
Technical Contacts: Carl S. Schulten, NRR James M. Trapp, (R-I)
301-415-1192 610-337-5186
E-mail: css1@nrc.gov E-mail: jmt1@nrc.gov
Randall A. Musser, (R-II) Stephen C. Burton, III, (R-III)
919-362-0601 920-388-3156
E-mail: rxm1@nrc.gov E-mail: sxb3@nrc.gov
Charles R. Stancil, Jr., (R-IV)
817-276-6532
E-mail: crs1@nrc.gov
Attachment: NRC Inspection Manual Part 9900: Technical Guidance, Operability
Determinations & Functionality Assessments for Resolution of Degraded or
Nonconforming Conditions Adverse To Quality or Safety
Note: NRC generic communications may be found on the NRC public website,
http://www.nrc.gov, under Electronic Reading Room/Document Collections.
PACKAGE: ML052020360, RIS: ML052020424, ATTACHMENT: ML052060365
OFFICE TSS:IROB:DIPM Tech Editor PMAS RI:DRP:DD RII:DRP:DD RIII:DRP:DD
NAME CSSchulten Pkleene/ TMMensah CKhan/by fax JShea/by e-mail TKozak/by e-mail
by e-mail
DATE 9/15/05 07/18/2005 08/14/2005 08/05/2005 08/12/2005 08/22/2005
OFFICE RIV:DRP:DD TSS:IROB:DIPM D:DLPM OE OGC (NLO) OGC (SBREFA)
NAME AHowell/by e-mail THBoyce Lmarsh/CHaney CNolan RWeisman SCrocket
by e-mail
DATE 08/19/2005 9/19/05 08/12/2005 08/18/2005 09/01/2005 09/13//2005
OFFICE PMAS OIS OES:IROB:DIPM OES:IROB:DIPM C:IROB:DIPM
NAME DLMcCain/PNei BStMary AWMarkley MJR-Lee PLHiland
bert for
DATE 08/30/2005 08/30/2005 09/15/05 09/16/05 09/26/2005