ML19275E441
| ML19275E441 | |
| Person / Time | |
|---|---|
| Issue date: | 04/16/1980 |
| From: | Mattson R Office of Nuclear Reactor Regulation |
| To: | Harold Denton, Minogue R, Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE), Office of Nuclear Reactor Regulation, NRC OFFICE OF STANDARDS DEVELOPMENT |
| Shared Package | |
| ML19239A281 | List: |
| References | |
| FOIA-81-405 NUDOCS 8005220970 | |
| Download: ML19275E441 (8) | |
Text
.
s Distribution:
Central File NRR R/F DSS R/F RJMattson Steering Group April 16, 1980 Technical Support Staff l
l I
MEMORANDUM FOR: Harold Denton, Director, NRR l
Robert Minogue, Director, SD j
Victor Stello, Director, IE FROM:
Roger Mattson, TMI Action Plan Steering Croup l
SUBJECT:
STEERING GROUP REVIEW 0F 0FFICE DIRECTOR l
COMMENTS ON TMI ACfl0N PLAN i
In his memorandum of March 12, 1980, the Executive Director for Operations asked for your coments and concurrence with the TMI Action Plan for your areas of responsibility by ciarcn 24.
In the responses received from the i
four major offices affected by the Plan, only RES stated its concurrence.
l The Steering Group has incorporated your coments, resource allocations i
and schedule changes into the final draft of the plan, except for the items described in the enclosure.
l By noon on Monday, April 21, please provide by memorandum to the E00 a statement of your concurrence, or specific reasons for nonconcurrence, in the Plan plus a point by point response to the items listed ir the enclosure for which you have lead responsibility.
Oricinal siped by Roger J. Mattson Roger J. Mattson, Ti1I Action Plan Steering Group
Enclosure:
as stated cc: L Dircks, EDO K. Cornell, E00 R. Sudnitz, RES C. Michelson, AE00 J. Fouchard, OPA
- 0. Donoghue, ADM y
H. Shapar, ELD
,9 J. Shea, IP G. Wayne Kerr, SP
/
k 1i n
'hGrour f7()
,:ts 8005220
STEERING GROUP REVIEW 0F 0FFICE DIRECTOR COMMENTS ON TMI ACTION PLAN CHAPTER I Task I.A.1.4 Operating Personnel and Staffing - Long-Term Upgrading SD recommended that this item be changed from Decision Group D to Priority Group 2 and that specific NRR resources be identified in the plan to support completion of the task.
This item was designated Decision Group D by the Commission in its meeting on February 11, 1980, and the Steering Group continues to support that decision.
It is noted that SD is presently proceeding with this task within its normal guidance development process.
Continuation of this work is encouraged. Much of the short-term work from Tasks I.A.l.1, I.A.l.2, and I.A 1.3 is directly applicable to Task I.A.1.4; thus, in the view of the Steering Group, significant additional NRR resources are not necessary for accomplisnment of this item.
It is assumed NRR will review the final product out of management overhead resources in the Division of Safety Technology to assure that it agrees with overall reactor regulatory policy.
Task I.A.2.2 Training and Qualification of Operations Personnel NRR indicated that it could not carry out this task in FY80 and FY81.
This task involves a licensee reviewing its training program for all operations personnel, including maintenance and technical personnel and auxiliary operators, and upgrading training and qualifications based on the results of this review.
Previous TMI actions of the NRC have dealt with training and qualifications of licensed operators and the evaluation of management and technical resources of the utility.
No significant action has been taken by the NRC for immediate upgrading of the training of other personnel.
Accomplishment of this task will do much to correct this deficiency.
In view of the very low resource requirements for NRR, it should reconsider its decision not to take early action on this item, particularly in view of its decision to defer work beyond FY81 on Task I. A.3.4, " Licensing of Additional Operations Personnel." (NR1 manpower to accomplish its portion of this task is estimated at 0.1 my in FY80.
No NRR resources are required in FY81.)
Task I.A.2.7 Accreditation of Training Institutions NRR indicated that it could not devote technical resources to this task in FY80 or FY81.
SD agreed with deferral of the task.
However, Chairman Ahearne has specifically requested NRR to take action in this area.
In a memo of November 19, 1979, NRR informed Chairman Ahearne that it had instituted a study that would assist in the establishment of the procedures and criteria for accrediting training institutions for potential operators and senior operators.
The Steering Group also notes that the President has requested that the NRC inform the Oversight Committee on its progress in implementing the President's Commission recommendation for criteria to accredit training institutions.
In view of these expressions of high interest in accreditation, NRR should either change its decision or provide in writing its basis for deferring work until FY82.
Task I.A.3.5 Establish Statement of Understanding With INPO and DOE SD recommended that this item be changed from Decision Group D to Priority Group 2 and that specific NRR resources be identified in the plan to support completion of this task.
This task was designated Decision Group D by the Commission on February 11, 1980, and the Steering Group sees no reason to appeal that decision.
NRR indicated it does not have the resources to devote to this item in FY80 and FY81. Although communications must be established and maintained with INPO and other groups, it may be more appropriate to allow INP0 to become fully functional prior to formal statements of understanding, and thus deferral of the statement has no impact.
If SD disagrees, it may wish to have the lead for this task transferred to its office.
SD should pursue this matter directly with NRR and report on the results to the EDO.
Task I.A.4.2 Long-Term Training Simulator Upgrade 50 stated that, although NRR indicated that the NRR resources on this item should be deferred, 50 would continue efforts on this task and that NRR resources should be provided and identified in the Action Plan.
NRR indicated it does not have the manpower to devote to this item.
(NRR is presently considering whether continued membership on the ANS 3.5 standard work group can be maintained.) SD should make every effort to keep the schedule in the Action Plan and should proceed without placing high reliance on NRR manpower.
NRR should make every effort to review the SD final product.
Task I.B.l.3 Loss of Safety Function SD stated that NRR and IE resources for this item should be included in the Action Plan, since both of these offices are workinq with SD on this item.
Since the paper has been forwarded to the Commission and resources of NRR and IE on the development of the paper were primarily from management overhead, no change in NRR and IE resources for this item was necessary, and the Steering Group considers the matter resolved.
Task I.D.4 Control Room Design Standard SD indicated NRR resources should be specified in the plan to support the SD effort and to incorporate the results of the control room design reviews (described in I.D.1) into the standards.
NRR indicated it does not have the manpower to devote to this item.
(NRR is presently considering whether continued membership on the control panel standards work group can be maintained.) SD should make every effort to keep the schedule in the Action Plan and proceed wihtout placing high reliance on NRR manpower.
NRR should make every effort to revies the SD final product.
Task I.E.5 Nuclear Plant Reliability Data Syst em (NPRDS)
SD recommended that this item be changed from Decision Group D to Priority Group 2, based on the description of this item in Draft 3 of the Action Plan, and that NRR resources to support this effort be added to the Action Plan.
This item was designated Decision Group D by the Commission on February 14, 1980, with the urging of the Steering Group.
The description of the task has been revised to be more consistent with the designated decision group.
Task I.F.1 Expand QA List SD commented that Table 1 of the Action Plan had designated SD for the lead for this item while the March 12, 1980 EDO memo assigned the lead to NRR.
SD recommended that the Action Plan should be revised to state that NRR has the lead for this item. An error was made in compiling the tables for the March 12, 1980 ED0 memo.
(Table 1 of the Action Plan was correct.) SD should maintain the lead for this item.
CHAPTER II Task II.B.1 - Reactor Coolant System Vents NRR indicated that current activity on this item implies a slip in schedule to complete NRR review of licensee designs prior to installation of primary system vents.
Since this is an NT0L requirement for design review prior to full power operation and installation by January 1,1981, the Steering Group does not believe that adequate justification has been provided by NRR for such a slip.
Task II.D.2 - Research on Relief and Safety Valve Test Requirements The research review group, following the reactor coolant system relief and safety valve test program being conducted by EPRI, has nr tified the Steering Group that the final test matrix will not be completed prics to Jul.s 680 and that the test program is not likely to be completed by July 1981 as currently required for NT0Ls and operating reactors.
NRR management should give immediate attention to this matter since it is an NT0L requirement and also has a relatively short deadline for operati.1g reactors.
Task II.E.2.3 - Uncertainties in Performance Predictions (see also Items 31 and 32 in Table C.3, Appendix C)
NRR management must r'.concile the differences in the Ross to Denton memo of March 19, 1980, which proposes acceleration of items 31 and 32 in Table C.3 related to revised small-break LOCA calculations to show compliance with 10 CFR 50, Appendix K; and Denton memo of April 1, 1980 on the Action Plan, which indicates no work on Item II.E.2.3 (companion action item) until FY82 or later.
This reconciliation is also necessary in view of ACRS comments to coordinate these activities to ensure efficient use of industry resources (see Dircks to Ahearne memo of April 1,1980).
Task II.E.3.3 (new) - Studies of Feed and Bleed Decay Heat Removal This item has been added to the Action Plan as a result of ACRS comments contained in its letter of March 11, 1980 on NT0L requirements.
The ED0 response to the Commission indicated that NRC staff will work with the ACRS Ad Hoc Subcommittee this year to define the study.
NRR should consider what resources should La assigned to this task in FY80-FY81, if any.
Task II.E.3.4 (old) - Reculatory Guide SD proposed a revision to this item, now II.E.3.5, related to Revision 1 of Regulatory Guide 1.139, including issuing the guide for comment.
The Steering Group disagrees with the SD proposed revision.
SD should review the scope for the task as now described in the final draft of the Action Plan and attempt to resolve any differences with the Steering Group.
Task lI.F.3 - Instruments for Monitoring Accident Conditions (Reg. Guide 1.97)
NRR indicated no resources related to issuance of Regulatory Guide 1.97 prior to FY82.
Because of the high priority given by the ACRS to tnis matter, _ _
the Steering Group believes that NRR should assign the necessary (small) resources to issue appropriate lettees for implementation of Regulatory Guide 1.97 in FY80 and FY81, but reserve until FY82 the resources necessary to review licensee implementation.
Task II.J.4 - Revise Deficiency Reporting Requirements SD proposed significant modificaticn to the scope of this item related to revised construction and noniicensce deficiency reporting requirements.
The Steering Group disagrees w:th the SD proposal and Draft 4 contains the same description as Draft 3 that was sponsored by IE.
The Steering Group suggests that SD and IE resolve their differences and report to the EDO.
CHAPTER III Task III.A.1.3 - Maintain Supplies of Thyroid Blockino Agent (Potassium Iodide)
The NRR memo of April 1, 1980 shows no resources to be committed to this action item until FY82 or later.
However, it is understood that the Emergency Preparedness Program Office plans to continue tnis task and complete it within a year.
NRR should reconcile this discrepancy.
Task III.D.2.3 - Liouid Pathway Radiological Control The NRR memo of April 1, 1980 indicates that initiation of this item is deferred until FY82, or later.
However, the description of the item, which calls for the results to be used as input to the rulemaking proceeding on degraded cores (Item II.B.8), remains unchanged.
NRR should reconcile this discrepancy.
Task III.D.3 - Worker Radiz cion Protection Improvements It is noted that essentially all of the adiation protection improvement action items in Chapter III are deferred by NRR to FY82 or later.
Although acknowledging that the priority group for most of these items is Priority Group 3, it is suggested that NRR take a closer look at the specific resources needed to move some of thece items forward.
It may well be that the disciplines involved in proceeding w'th some of these items may not be those that could otherwise be productively used on other work.
In addition, it is understood that very little additional NRR resources would be needed to initiate industry action on Item III.D.3.1, Radiation Protection Plans.
The bulk of the NRC effert in this action item would rest with IE.
Task III.D.3.5 - Radiation Worker Exposure Data Base SD recommended changing the decision group from a Category D to a Category A item on the basis of an exchange of letters between then Chairman Hendrie and Secretary Califano that has led to a joint NRC/NIOSH effort to ensure that a good worker registry is attained for TMI-2 cleanup operations.
This action plan item, however, is much broader than just the NRC/NIOSH effort and cannot be considered to have been approved by the Commission.
CHAPTER IV Task IV.E.2 - Plan for Early Resolution of Safety Issues NRR did not include any resources for Task IV.E.2, yet the recent NRR reorganization creates a division charged with the responsibility to produce such a plan.
The Steering Group reccmmends that NRR assign the relatively small resources necessary to accomplish this task in FY80 and FY81.
Task IV.E.4 - Resolve Generic Issues by Rulemaking SD should be aware of a Steering Group change to Task IV.E.4 as follows:
4.
Resolve generic issues by rulemaking.
a.
==
Description:==
Although the Commission already makes use of rulemaking to resolve generic issues, means to enhance the Commission's rulemaking efforts are addressed in a " Preliminary Statement on General Policy for Rulemaking to Improve Nuclear Power Plant Licensing" (NUREG-0499, November 1978), and some of the action items in this plan specifically call for additional rulemaking.
SD will undertake the additional task of developing a program, in coordination with other offices, for reviewing new criteria before their promulgation to determine whether rulemaking would be the desirable means of implementation.
The intent will be to implement new NRC criteria by rule, wherever feasible and timely, instead of by license changes, orders, changes in regulatory guides, or by litigation in individual license hearings.
b.
Schedule:
By January 1981, SD will develop a program for review of new criteria for rulemaking.
c.
Resources:
SD FY80 - 0.4 my, FY81 - 0.7 my; ADM FV8C - 0.1 my, FY81 -0.1 my.
Task IV.F.2 - Evaluate the Impacts of Financial Disincentives to the Safety of Nuclear Power Plants NRR has not provided resources for Task IV.F.2.
The Steering Group notes that in SECY 79-299 the Commission requested NRR to complete this action by April 11, 1980.
NRR should resolve this discrepancy.,