ML19257B447
| ML19257B447 | |
| Person / Time | |
|---|---|
| Issue date: | 01/03/1980 |
| From: | Hanauer S NRC - TMI-2 UNRESOLVED SAFETY ISSUES TASK FORCE |
| To: | NRC - TMI-2 UNRESOLVED SAFETY ISSUES TASK FORCE |
| Shared Package | |
| ML19257B448 | List: |
| References | |
| REF-GTECI-0000, REF-GTECI-A-24, REF-GTECI-A-42, REF-GTECI-AC, REF-GTECI-EL, REF-GTECI-PI, TASK-0000, TASK-A-24, TASK-OR SECY-79-677, NUDOCS 8001160275 | |
| Download: ML19257B447 (24) | |
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MEMORANDUM FOR:
USI Personnel FROM:
S. H. Hanauer, Director Unresolved Safety Issues Program
SUBJECT:
GUIDANCE RELATED T0 " RESOLVING" AN UNRESOLVED SAFETY ISSUE On November 14, 1979 I provided you with some initial guidance regarding the procedural aspects of " resolving" a USI.
I also promised to update that gui-dance as we gained some experience from the first few USI's to make they way through the various steps.
Our experience has indicated that certain changes are needed. The guidance provided in the enclosure to this memo includes such changes. Accordingly, this memo supercedes in its entirety my November 14, 1979 memo, and its su:plement dated November 27, 1979.
The enclosed also in-cludes the substances of my memo dated August 27, 1979, on the contents of the NUREG report that sets forth the technical resolution of an issue.
4 oo ew
/S. H. Hanauer, Director Unresolved Safety Issues Program
Enclosure:
1.
Commission Paper 2.
Memo to Chase Stephens 3.
Memo to ACRS 4.
Ltr to Congressional Committees 5.
Generic letter to Licensees 6.
Generic letter to Applicants cc:
H. Denton E. Case C. Eisenhut R. Mattson D. Muller D. Ross R. Fraley 1750 237 80 011 60 2
UNRESOLVED SAFETY ISSUES PROGRAM GUIDANCE ON PROCEDURAL STEPS IN RESOLVING AN ISSUE JANUARY 2,1980 1.0 Steps In Resolving An Issue Table 1 shows the steps involved in the total process of treating an issue.
TABLE 1 STEPS IN " RESOLVING" AN UNRESOLVED SAFETY ISSUE PRODUCT STEP 1.
Description of Problem and Technical Task Action Plan App voco.
2.
Generate and assemble the necessary Technical Reports technical information.
3.
Analyze and decide what licensing NUREG Report containing requirements are needed for public Proposed Requirements and Safety Evaluation safety.
4.
Peer, Public and ACRS Review.
Comments 5.
Final Decision on Requirements.
RRRC/ Director NRR/Connission Decisior.
6.
Promulgate the Requirements.
Rules, Guides, Standard Review Plans 7.
Implementation Changes in Designs, Hardware, Procedures 1750 238
Steps 1, 3, 5 and 6 are performed by the NRC staff and its management.
Rules must be approved by the Commission; Guides and Standard Review Plans by NRC staff management. The ACRS advises the Commission and the staff.
. Step 2 can involve academia, industry, RES, NRR and its consultants and contractors - or all of these. We take applicable technical information anywhere we can find it.
Step 4 involves anyone who has a coment to offer.
Usually, organizations involved with nuclear power -- both nuclear industry and intervenors --
send in most of the comments on issues such as those we are discussing.
Step 7 must be accomplished by the owners of plants, together with their designers and manufacturers.
Only after the hardware or procedures are changed in the actual plants is an issue truly " resolved".
However, it is convenient to track the decision point of Step 3 and the promulgation point of Step 6 as the times when the issue is " resolved generically"; that is, when the staff (Step 3) and the NRC as an agency (Step 6) decide what the requirements should be, and whether new ones are needed.
The process following Step 3 will vary for different issues, and will in peneral require different treatment for operating reactors than fo:- appli-c.ations in future licensing reviews.
The " Gil treatment" for a new requirements would be the following:
Finalize a staff NUREG report providing technical solution (Step 3) and obtain NRR Division Management concurrence.
Develop and document a proposed implementation method and schedule.
This could include draft regulations, Regulatory Guides, or SRP revisions.
Send the proposal and the NUREG to the Comission for information and out for public comment (Step 4).
ACRS review (Step 4).
Review ACRS and public comments; modify proposed as necessary (Step 5).
Submit to RRRC for decision (Step 5).
Approval by Director, NRR (for licensing requirements; Director, SD for Guides and Commission for rules) (Step 5).
Implement decision (step 7).
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Starting from scratch and goi,g step by step, this could take almost forever.
However, for an issue with the importance and visibility of a USI, many of these steps are likely to be partly or fully completed before the NUREG is actually issued, and we should compress the process as much as possible.
For example, implementation may begin after Step 1 in some cases.
2.0 Contents of the NUREG Report of Step 3 Besides the usual requirements of a good staff technical report, the document that purports to resolve an Unresolved Safety Issue has some special require-ments.
2.1 Resolution of the Issue The report should state and explain the " resolution of the issue".
This is the new criteria, methods, codes, or whatever that the staff is proposing be used to make the licensing decisions in the area covered by the issue.
These criteria, etc., are the central point of the whole job and therefore their discussion is the central point of the report.
We should not be bashful in stating just what we intend to require.
Clarity and precision are the essen-tials in drafting such material.
Unless they are enormously long, the requirements should be set forth directly, in full detail.
If this is impossible or impractical, as in the case of a large computer program or the ASME Boiler and Pressure Vessel Code, or a pro-prietary report, precise reference should be made to the place where the re-quirements are set forth.
This referenced document should be in hand (not just scheduled to appear at some future date) and available.
If it is proprietary, the usual restrictions and requirements apply, including the necessity for mak-ing it available to people entitled to consult it.
Where the requirements are in another referenced source, the NUREG report should include a summary that gives its technical essentials to an appropriate extent.
How much of this is needed will depend on the source; for example, the ASME Code is well enough known and understood that no " explanation" is required in a NUREG.
However, we should remember that interested members of the public who are in-telligent but not expert should also be able to read an NRC staff report that purports to " resolve" an " Unresolved Safety Issue".
2.2 Staff Safety Evaluation An essential element in this class of report is a staff safety evaluation of the issue, as it is proposed to be resolved.
The reasons why the proposed criteria, or whatever, provide adequately for the health and safety of the public should be given.
This may be brief, but see Section 2.3 below.
t 1750 240
If the evaluation concludes that there is not a significant safety pro-blem, that should be stated.
If we now decide that there never was a problem, we should say so. On the other hand, if even the " resolution" leaves us with a problem, that must also be stated. That is, if the staff (the authors first, as reviewed by management) believe that a significant hazard exists, or that public safety requires additional measures, this
. should be stated.
If the problem is perceived as serious, it should of course have been surfaced long before NUREG drafting time and outside the sometimes stately pace of report writing. But any time a significant safety problem is perceived is the time to get something done about it.
2.3 Technical Basis The report should give the technical basis for the resolution of the issue and the staff safety evaluation. The minimum is a summary of the techni-cal reasons for the choice of the resolution and for the staff conclusions.
For such a summary to suffice, the technical basis must be set forth else-where.
The usici place for that is in industry and NRC technical reports.
There is nothing wrong with referencing industry work.
It is the appli-cant's obligation to set forth the technical basis for acceptability of any proposed licensing action.
For Unresolved Safety Issues, the" applicant" is usually a group of utilities, plus one or more reactor vendors, often plus other groups.
In meeting their burden of safety analysis, they pro-perly generate a substantial fraction of the technical basis for issue resolution.
NRC technical work can take the form of staff technical work, tech assis-tance contractor reports, and research products.
Some of the NUREG reports that " resolve a USI" will contain brief summaries only - just enough to give the logical structure and principal facts of the underlying technical basis. Others will lie in a spectrum of increasing technical detail; a few reports are planned to include most of the technical analysis. A variant is to bind into the report as an appendix a single tech assistance contractor report that contains the technical analysis.
Even in this case, the main report should contain the summary described above.
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Since part of the technical basis is almost always contained in other documents, set of detailed references is essential.
The list should be annotated as a
appropriate, so the reader can tell what information is where, if it isn't obvious.
2.4 Style The three essential elements discussed in 2.1-2.3 should be fleshed out with the usual introduction, background, etc., and subdivided into chapters and sections according to the writers' preferences and as set forth in an approved outline.
Here are some guidelines dealing with report organization:
The abstract, the title page, and the first paragraph of the introduction should all indicate that this report constitutes the resolution of TAP-X.
The first paragraph of the introduction should include summaries of the problem, the resolution, and the staff evaluation.
The last paragraph of the introduction should briefly describe what the reader will find in each of the succeeding chapters.
A brief abstract should also include very brief summaries of the problem, the resolution, and the staff evaluation.
3.0 Papers that accompa_ny the report The staff technical report that resolves an issue is the centerpiece of a group of papers that inform interested parties of the issuance of the report.
For the technical report of Step 3, public comments and ACRS advice are also solicited.
The Step 3 package is fully described belcw in Section: 3.1-3.5 and in Enclosures 1-6.
is not described in this enclosure.By contrast, the Step 6 promulgation is more formal and The documents that must be prepared are listed below.
Each is discussed briefly and examples are included in Enclosures 1-6.
Table 2 provides a set of procedural steps that will assure that the handl-ing and distribution of these documents is properly orchestrated.
3.1 Commission Paper A Commission Paper (Information Report) should be prepared transmitting the NUREG to the Commission.
The report should include (1) a brief description of the technical studies presented in the NUREG, (2) a summary of the safety conclusions based on these technical studies, and (3) the staff's plans for public comment and implementation on operating reactors and future plants.
An example is provided in Enclosure 1.
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3.2 Memo to Chase Stevens A memo to Chase Stevens transmitting a Federal Register Notice and a summary
-should be prepared. The notice should have all the Commission Paper items plus information regarding the availability of the NUREG report.
.is an example.
3.3 Memo to ACRS A memo to the ACRS transmitting the NUREG report should be prepared.
The memo should include a description cf previous and planned staff interactions with the ACRS on the issue.
It should also identify the time frame in which ACRS comments are desired. The Commission Paper should be attached.
is an example.
3.4 Letters to Congressional Committees Memos to Congressional Committees should be prepared.
They should be brief and include a copy of the Federal Register Notice.
The Office of Congressional Affairs should be on concurrence. is an example.
3.5 Generic Letters to Licensees and Applicants Generic letters to licensees and applicants should be prepared.
The letters should highlight the importance of the issue and describe the staff's plans for implementation on operating reactors (in letters to licensees) and on the different clases of plants in the review process (for cps and Ols).
The letter to licensees should be for Darrell Eisenhut's signature and the letter to applicants for Denwood Ross' signature. The letter to applicants should be coordinated with both DPM and DSS and Roger Mattson should be on Examples of such letters are included in Enclosures 5 and 6.
concurrence.
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TABLE 2 Procedural _ Steps _for I_s_ suing Staff NUREG _an_d Rela _ted Memoranda and Letters 1.
Task Manager provides draft NUREG to Marthe Singh (Room 534, Phone 28433) for typing / processing.
2.
Task Manager routes draft NUREG for technical and management review.
3.
Repeat 1 and 2 until management (Hanauer and appropriate division directors) approve NUREG.
4.
Task Manager provides NUREG to Marthe Singh for final typing (but not printing).
5.
Task Manager provides a package including the Commission Paper and other transmittal letters and memoranda to Marthe Singh with appropriate rout-ing slip.
6.
Marthe Singh attaches a xeroxed copy of the NUREG to transmittal letters and assures she is listed last on the routing slip. The package with appropriate concurrences and signatures is returned to Marthe undated.
7.
Marthe sends NUREG to printer ("For Comment" on cover when appropriate).
8.
Marthe sends copies of printed NUREG to Commission with Commission Paper.
9.
After 3 days from date Commission receives report (Marthe checks with Margo Bridgers in the ED0's office), Marthe sends memo to Chase Stevens and ACRS and letters to Congressional Committees.
10.
After 3 more days Marthe sends letters to licensees and applicants and makes general distribution of the report.
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. The reports receive wide distribution, including applicants and licensees, and also many non-industry interested parties.
4.0 ACRS Interface Public and ACRS review begins concurrer.tly. However,if we have done our job, ACRS,.or at least a subcommittee, knows all about the problems, our approach, the technical infonnation developed, and what we are thinking about in the way of requirements.
In a recent meeting (November 8, 1979) the Committee agreed with a staff representative to try out this procedure, on the promise that staff would in fact keep them up to date. This is a very important obligation.
It is the Task Manager's job to be sure that we keep the ACRS informed, scheduling meet-ings at the proper times.
Each Task Manager should have ACRS full and subcommittee meetings spotted approximately on his Task Plan schedule.
He should keep in touch with the cognizant ACRS staff member. The result should be that everything in a NUREG is well known and understood by the ACRS on the day the NUREG is published, except possibly only the very final decisions, if any, that have to be made by NRR management and put into the report.
This lets the ACRS participate as much as they want to in the technical resolution, yet gives them a "real NRR position" on which to give their final evaluation to the Commission if they choose or are asked to do so.
5.0 Documentation In view of the importance of Unresolved Safety Issues, it is impt etant to pre-serve and make available to the public the documents that form th,e basis for our requirements.
1.
For each USI task, a file has been opened in the NRC Public Document Room.
In addition, TERA enters all documents marked by a task number into the NRC document control system (DCS). These documents are currently filed in Cen-tral Files by subject.
Their file location is recorded in the TERA system.
We are considering whether or not separate hard copy files for each task in central files are necessary. A TERA representative will be meeting with each Task Manager in the near future to review the set of documents currently in the DCS. The Task Manager should identify and provide copies of any addi-tional documents and reports that should be in the system.
2.
All USI personnel should assure that the generic task number is included in the upper left hand corner of all documents they generate. Our perfornance in this regard is still poor. Task Managers should route relevant documents to files and the PDR if no task number is included and should remind offend-ing individuals to include the number.
3.
When a "for comment" NUREG report is Jublished giving the staff's proposed resolution of all or part of a USI, tie Task Manager should assure that copies of all relevant non-proprietary documents, both external and internal, are in the PDR, and chec( to make sure all are actually in files.
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4.
Copies of all coments received should be placed promptly in files and PDR.
5.
When a NUREG supplement or revision is issued, the Task Manager should again send all relevant documents to files and PDR, or confirm that they are already on file both places.
- 6. -The Task Manager should confirm in writing that he has done the checks of Items 2 and 4.
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