ML19250D616
| ML19250D616 | |
| Person / Time | |
|---|---|
| Issue date: | 02/17/1981 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Ahearne J, Gilinsky V, Hendrie J NRC COMMISSION (OCM) |
| Shared Package | |
| ML19247D563 | List: |
| References | |
| REF-10CFR9.7 NUDOCS 8103170688 | |
| Download: ML19250D616 (4) | |
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EG:ase TPa rl e y HRDenton DCrutcMield WJDircks CEisennut EDD Mail R, Cross BRussell RVollmer REaer EHanauer HThorcson MEMORANDUM FOR: Chairman Ahearne Commissioner Gilinsky Commissioner Hendrie Commissioner Bradford FROM:
William J. Dircks Executive Director for Operations
SUBJECT:
PLANS 10 IMPLEMENT SECTION 110 REQUIREMENTS The purpose of this memorandum is to provide you with a brief outline of our revised plans to implement the requirements contained in Section 110 of the NRC FY 1930 Authorization Act.
If approved by the Commission, the staff intends to implement that portion of the program relating to operating plants by reviewing those plants in groups of 10 to 15 plants per year over the next eight years. Plants will be placed in a groJo depending on when the plant is scheduled for SEP and IREP/NREP reviews.
The first groups of plants to be reviewed in accordance to the requirements of Section i10 are those that are now being reviewed under Phase II of the SEP program.
For subsequent SEP at
- IREP/NREP reviews, plants will be grouped based on such factors as the age of the plant, population density near the plant site, ant design similarities.
The major steps in the review of tr<h group of plants to comply with the requirements of Section 110 of the FY 1980 Authorization Act are:
1.
The staff will identify the list of the most significant safety issues
~ based upon the experience gained from the current Systematic Evaluation Praycam on the eleven oldect reactors. Our experience to date indicates that tce list will be smaller than the present 137 safety issues being evaluated as part of SEP II. As experience is gained from IREP/NREP reviews, from opersting experience or from knowledge gained from additional SEP reviews; safety issues of particular significance may be added to the list and safety issues of lesser significance may be deleted from the list. The list of safety issues of particular significance will g
be reviewed annually.
Generic Issues, such as TMI Action Plan Items and
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The Cor.ission Unresolved Safety Issues, cnd new Issues which require crompt resolution ill continue to be evaluated and imple-ented on all reactorsindepender.
of the SEP and will not be included on the list.
2.
From the list of safety issues, the staff will develop the list of current rules and regulations, compliance with..ich ne Commission determines to be of particular significance to tne protection of the public health and safety. The list wculd be limited to those rules and regulations that are related in whole or in part to the safety issues to be evaluated under the Systematic Evaluation Program (SEP) for that group of plants.
3.
For each rule and regulati n identified in Step 2, each licensee for the plants in a given group will be asked to describe the extent to "ch its plant complies w'th these rules and regulations, including an acceptance criteriag compliance was tchieved by use of the SRP indication where su related to these rules and regulations, and where compliance was achieved by equivslent means.
Only for those SPT acceptance criteria related specifically to issues 4.
developed from SEP, IREP/NREP reviews identified in Step 1, will each licensee for the plants in a given group be asked to identify and describe differences between the design and/or procedural measures actually used in the plant and these SRP acceptance criteria. The licensee will also be asked to discuss whether and how the alternative measures tsed provide an acceptatsle method of complying with the regulation (s) or portion (s) thereof that are related tc the SEP safety issues.
5.
The taff will e;ciuate the licensee responses developed in steps 3 and 4 to detare.ine the extent to which each operation facility cortplies with regulation identified in 2 above and the need fcr design or each culr. or pro:edwal chaages in the plant.
The SEP IREP/NREP and Section 110 reviews for each group of plants will be coordinated as showr on Attachment 1.
Based upon the current status of SEP Phasc II reviews, e in.egrated assessment should start on the first plant this su..mer.
By A.egu:t 1981, the staff will be able to propose a list of the most significan; safety issues from SEP Phase II reviews and would also identify the first group of plants for SEP Phase III.
Frcr this list of
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A revised SRP, scheculed for completion in Aprii 19El, will consist of tr.e ".ay 1950 version of the SRo, podi'ied to referer.ce all a;plicable safety and safeguards regalations ano those Divisior i regulatory guides.
staff positions, and other dacurrnts currently used by the staff to ir.terpret the intent of these regulations, including re:;uirements resulting from the TMI accMnt.
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The Commission 3-safety issues, the staff would develop the *ist of related rules and regulations of particular significance. Th' first group of SEP Phase III licensees would, over a period of 9 months tt year, provide the documen-tation, comparison to SRP criteria and analysis > ' quired by Stepr, ? and 3 above. During this sarac period the staff would em.plete the Afety issue reviews and integrated assessments for the remaining SEP Phare II plants.
This coordination of reviews will minimize fluctuations in s+.aff review requirements and optimize use of both staff and industry resuurecs. To insure this overall coordination occurs, all aspects of the impleentatin of Section 110 of the NRC AuthorizatSn Act, SEP Phase III and IREP/NREP will be the management responsibility,f one unit within the Office of Nuclear Reactor Regulation, i.e., the carrent Systematic Evaluation Program Branch.
I wish to emphasize that the list of regulations of particular sigt.ificance to the protection of public health and safety developed in Step 1 will not be an immutable list. As the SEP and IREP/NREP re',1ews are carried out for a group of plants and data are collected on actual plant designs and their significance to safety, changes can and will be m:de to the safety issue list and the list of related regulations to be applied to tne next group o-plants to reflect their importance to overall rea:*nr safety.
(Stes ylmim J. Dinh William J. Dircks Executive Director for Operations cc: SECY
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9 The Commission Unresolved Safety Issues, and new Issues which require prempt resolution will continue to be evaluated and implemented on all reactorsindependent of the SEP and will not be included on the list.
2.
From the list of safety issues, the staff will develop.the list of current rules and regulations, co.npliance with which the Commission determines to be of particular significance to the,protectier of the public health and safety. The lie would be limited to those rules and regulations that are related in whole or in part'to the safety issues to be evaluated under the Systematic Evaluation Program (SEP) for that group of plants.
3.
For each rule and regulatio:. identified in Step 2, each licensee for the plants in a given group will be asked to describe the extent to which its plant complies with these rules and regulations, including an indication where su acceptance criteriagy compliance was achieved by use of the SRP related to these rules and regulations, and where compliance was achieved by equivalent means.
4.
For the SRP acceptanca criteria related to each of the SEP safety issues, each licensee for the plants in,a given group will a?so be asked to identify and describe differences between the design and/or procedural measures actually used in theJplant and these SRP acceptance criteria and to discuss whether and how the alternative measures used provina an acceptable method of complying with the regulation (s) or portion (s) thereof that are relateo +o the SEP safety issues.
5.
The staff will evaluate the licensee responses developed in steps 3 and 4 to determine the extent
'.o which each operation facility complies with each rule or regulation identified in 2 abcVe and the need for design or procedural changes in the plant.
The SEP. IREP/NREP and,Section 110 reviews for each group of plants will be coordinated as shown on Attachnent 1.
Based upon the current status of SEP Phase Il reviews, an integrated assessment should start on the first plant this summer. By August 1981, the staff will be able to propose a list of the most significant safety issues from SEP Phase II reviews and would also identify the first2 group of plants for 3EP Phase III.
From thic inst of
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T/ A revised SRD, scheduled for compittion in April 1981, will consist of the May 1980 version of the SRP, modified to reference all applicable safety.and >:#aqu:rds regulations and those Division 1 regulatory guides, staff positions, and other documents currently used by the staff to interpret the intent of these regulations, including requirements resulting from the TMI accident.
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DI5TRIBUTION Central F N S oss EGCase RVollmer HRDenton SHanauer NJDircks HThompson CD0 Mail Rm WRussell RBaer MErnst MEMORANDUM F,:
Chairman Ahearne i ld ~ '
Comissioner Gilinsky e ut Comissioner Hendrie Comissioner Bradford FROM:
killiam J. Dircks Executive Director for Operations
SUBJECT:
PLANS TO It'PLEMENT SECTION 110 REQUIREMENTS
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The purpose of this memorandum is to provide you with a brief outline of our revised plans to implement the requiremer.ts contained in Section 110 of the NRC FY 1980 Authorization Act.
If approved by the Comission, the staff intends to implement that pcrtion of the program relating.to operating plants by reviewing those plants in groups of 10 to/15 plants per year over the next eight years. Plants will be placed in a group depending on when the plant is scheduled for SEP and IREP/NREP reviews.
/
The first group: of plants. to be mvfewed in accordance to the requirements of Section 110 are those that are now being reviewed under Phase II of the SEP program. For' subsequent SEP and IREP/NREP reviews, plants will be grouped based on such factors as the age of the plant, population density near the plant site, and design similarities.
The major steps in the review of each group of plants to comply with the requirenents of Section 110 of the FY 1980 Authorization Act 3re-1.
Staff will develop a list of current rules and regulations, com liance with which/the Comission detemines to be of particular significance to the prstection of the public health and safety. The list would be limitpd to those ruic', and regulations tbt are related in whole or in part to the safety issuer to be evaluated under the Systematic Evaluation Program (SEP) for that group of plants.
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5 The Ctanission 2.
For each rule and regulation identified in Step 1, each licensee for the plants in a given group will be asked to describe the extent to which its plant complies with these rules and regulations, including an indication where of the SRP acceptance criteria _y/ related to these rules andtJch compliance was regulations, and where compliance was achieved by equivalent means.
3.
For the SRP acceptance criteria relt!ed to each of the SEP safety issues, each licensee for the plants in a given group will also be asked to identify and describe differences between the design and/or procedural measures actually used in the plant and thse SRP acceptance criteria and to discuss whether and how the alternative measures used provide an acceptable method of complying with the regulation (s) or portion (s) thereof that are related to the SEP safety issues.
4.
The staff will evaluate the licensees responses developed in Steps 2 and 3 using the results of the IREP/NREP reviews (if ava11atle) to determine the need for design or procedural changes in the plant.
It thould be nott.d that the list of regulations of parthular significance to the protection of public health and safety developed in h.,' 1 will not be an frutable list.
As the SEP and IREP/NREP reviews are carried out for a group of plants and data are collected on actual plant designs and their significance to safety, changes can and will be made to the safety issue list and the list of related regulations to be applied to the nex! group of plants to reflect their importance to overall reactor nafety.
William J. Dircks Executive Director for Operations cc: OPE OGC SECY M A revised SFP, scheduled for completion in April 1981, will consist of the May 1980 version of the SRP, modified to reference all applicable safety and scfeguards regulations and those Division 1 regulatory guides, s2aff positions, and other documents currently used by the staff to interpret the intert of these 'egulations, including recuirements resulting from the Dil accident.
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