ML19291F700
| ML19291F700 | |
| Person / Time | |
|---|---|
| Issue date: | 01/27/1982 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML19291F701 | List: |
| References | |
| NUDOCS 8202230692 | |
| Download: ML19291F700 (7) | |
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'l gEdiVW MEMORANDUM FOR:
Victor Stello, Deputy Executive Director for 7 FEB 519825 'B Regional Operations & Generic Requirements g n e s t s m 2 2,;
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Harold R. Denton, Director Q
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SUBJECT:
PROPOSED RULE CONCERNING DOCUMENTATION OF DIFFERENC FROM THE STANDARD REVIEW PLAN In SECY 81-648, a final rule was proposed which would require certain pending applicants and all future applicants to document differences from the Standard Review Plan (SRP) acceptance criteria. The Executive Director for Operations recommended that the Commission take no action on the proposed rule until the safety benefits and the staff and applicant resources required to implement the proposed rule had been reviewed by the Committee for the Review of Generic Requirements (CRGR). The enclosure provides the estimate of the resource requirements and our perception of the safety benefits for the committee's consideration.
Briefly stated, we estimate that each applicant may require up to a maximum of approximately 10 person-years to prepare the documentation required by the proposed rule and answer staff questions concerning the documentation. We expect that this will decrease as the industry develops experience with this effort and it becomes part of the normal application preparation process.
In addition, we estimate that on the first plants reviewed the staff will require up to an additional 1 to 2 person-years to review this documentation for each application but that in the longer term this approach will result in a net decrease in staff review effort. We consider these estimates to be somewhat pessimistic and, therefore, they should be considered as maximum resource requirements.
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The safety benefits evolve from the staff's audit-type review; by requiring the applicant to assess conformance with the SRP acceptance criteria the staff can concentrate on the differences and, thus, j
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-2 JAN 2 71992 We also note that the plants affected by this proposed rule may need to be slightly revised because of the passage of time since the rule was first proposed.
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MEf t0RANDUM FOR: Victor Stello, Deputy Executive Director for Operations Regional Operations and Generic
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Harold R. Denton, Director
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SUBJECT:
\\PROPOSEDRULECONCERNINGDOCUMENTAT1011OF DIFFERENCES FROM THE STAHOARD REVIEW PL AU-
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In SECY 81-M8, a final rule was proposed which would require certain pending applicants and all future applicants to docunent dif ferences from the Standard Review Plan (SRP) acceptance criteria.
The Executive Director for Operations recommended that the Commission take no action /on the proposed rule until the safety benefits and the staff and applicant resources required to inplement s
the proposed rule had been reviewed by the'Connittee for the Peview of Generic Requirements (CRGR). The attachnent provides the estinate of the resource requirenents and the perception 1of the ~ safety benefits for the committee's consideration.
N, Priefly stated, we estinate that' each applicant may require up to a maxinun of approxinately 10 person-years to hrepare the documentation required by the pronosed rule. We expect that this will decrease as the industry becomes experienced by with this ef fort.
In addition, we estinate that on the first plants reviewed the staff will require uh to an additional 2 person-years to review this documentation for each application but that in the longer torn this approach Will result in a net staff ef fort decrease. We consider theso estinates soneuhat pessimistic and, therefore, should be considered as raxirum resource requirements.
The safety benefits evolve fron the staff's audik-type review; hy requirino the applicant to assess conformance with the SRP ar,ceptance criteria the staf f can concentrate on the dif ferences and, thus,\\there is a greater like-libood that desiqn deficiencies will be identified. N 1
We also note that tha plants af fected by this proposed 1 rule nay need to be sliqhtly revised because of the passage of tine since first proposed.
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Harold R. Denton, Direc hr Of fice of nuclear Reactor' regulation
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SUBJECT:
PROPOSED RULE CONCERMING 00C'JMENTATI0f.' 0F 4
DIFFERENCES FROM THE STANDARD REVIEk' M41 i
In SECY 81-648, 1 final rule was proposed which would require certain pending applicants and all future apolicants to document differences from the Standard Reviet Plan (SRP) acceptance criterin. The Executive Director for Operations recortrxmded that the Comid'on take no action on the proposed rule until the ufety benafits and the staff and 4 applicant resources required tn smolenerr. the proposed rule had been reviewed by the Comittee for th't/Peview of Generic Reouirements (CRGR).
The enclosed menorandum provides tha. Mtimate of the resource recuirements md the perception of the safety bdncfits for the comittee's consideration.
u Brieflv stated, we estimate,that each applicant may k.nuire un xo a maxinum i
of approxW.itely 10 person-years to prenve the documentation required by the proposed rule. We expect that this will decrease as the industry becomes experienced with this effort.
In addition, we estinate that en the first niants reviewed the staff will require un to an addtional 2 nerson-years to, review this documentatica for each application but that in the lonner term A '
this approach wfil result in a net staff effort decrease. We consider these estimates sonewhat pessimistir, and, therefore, should be considered as naximum resource requirenan%.
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The safety benefits evolvinq.from ~the staff's ipdit-ty A review,'that is, by requirfoq the Aool! cant to actass conformance with the SPP acceptance 3
criteria the itaff can concentrate on 1.he difSrences end, thus, there is a greater likelihood that design,&ficiencies kFl be Wntified.
e We also note.that the plants affected oy thb Scoporr'd rule nay need to be revised because of tbc hassaqe of tim since first pronosed.
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Harold R. Denton, Director Office of Nuclear Peacter goulation ONRR DGEisenhut HRDenton cc: E. Case R. Bernero *See Previous Conc.
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M010RU!n!!n FOR: Vict r "*ello, Deputy Executive Dir ' tor for Onerations Regirpal Operations end Generic FechWenents
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Harold \\R. Denton, Director Office 'pf Nuclear Reactor Pegulation
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SUBJECT:
PRDPOSEDMULE CONCERf!!NG DOCUMENTATIDs OF DIFFERDJCES FR0ti THE STANDARD REVIEW PLAN
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In SECY 81-648, a final rule Was proposed whichhould require certain pending applicants and all future applicants to document differences from the Standard Review Plan (.SRP) acceptance criteria. The Executive Director for Operations recommended that th'e Commission take no action or, th> proposed rule until the safety be,nefits and the staff and noihnt resources required to innleme6t the proposed rule had been reviewet by the Generic Requirements, Review Conmittee (GRRC). The enclosed trecrandum provides the istimate of the resource requirements and the perception of the safety penefits for the committee's consideration.
Briefly stated, we estinate Sa't each 'epplicant will require approxinately an additional 30% (10 person-3rs) to ' prepare the documentation required by the proposed rule and the aff will tequire up to an additional 107 (7 perst '-years) to review this doctmentation for each application. He consider these estimates pessimistic and, \\therefore, should 6.-
onsidered as naxinum resource requirements. The safety benefits evolve f t,..n the staff's audit.. type review; by requiring the applicant to assess conformance s
with the SRP acceptance criteria the staf f can concentrate on the dif ferences and, thus, there is a greater likelihood that design deficiencies will be identified.
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Harold P. Dhnton, Director
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Office of Nuclear Reactor Regulation
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ENCLOSURE RESOURCE ESTIMATES AND SAFETY BENEFITS FOR THE PROPOSED SRP RULE In SECY-81-648, the staff proposed a final rule which would require certain pending applicants and all future applicants to document differences from the Standard Revia' Plan (SRP) acceptance criteria, in response to a request by the Commission la SECY-COMP B 81-4A.
The proposed final rule would require that applicants describe and evaluate all differences in design features, analytical techniques, and procedural measures proposed for a unit with the corresponding features; techniques, and measures given in the SRP acceptance criteria. The proposed rule further identified an implemen-tation schedule for pending and future applications.
In forwarding the proposed final rule, the Executive Director for Operations recommended that the Commission take no action on the rule until the newly formed Committee for the Review of Generic Requirements (CRGR) had an opportunity to review the resource and safety benefit estimates associated with the rule. Such estimates were previously described in SECY 81-13 in tthe context of the original version of the rule which applied to the Systematic Evaluation Program for operating reactors. We have discussed the present version of the proposed final rule with both the staff and industry repre-sentatives and have developed the following estimates.
Staff Resource Estimate The staff has been reviewing current applications in accordance with the procedures and acceptance criteria in the SRP (NUREG-0800). There is a wide range of views on the extent to which that review is complete, i.e., the staff's review is only intended to be an audit, but the degree to which a reviewer assures conformance with the SRP acceptance criteria will vary from branch to branch and, occasionally, between applications.
The amcunt of additional resources that would be needed would depend or, the extent to which the review remains as an audit; however, on the whole, we estimate that up to an additional one to two person-years of effort would be required for the first several applications. In time, the impact of the proposed rule would result in a resource savings for the staff, as reviewers learn how to use the information provided by industry.
Inddslt[y Resource Estimate The industry representatives uniformly estimated that a significant effort would be required to provide the documentation required by the proposed final rule. This is principally caused by the anticipated difficulties associated with interpreting the SRP acceptance criteria. The industry believes that it should be sufficient for an applicant to make a proposal and let the staff judge the relative acceptability. Further, the industry believes that the proposed rule elevates the SRP to the status of a regulation.
The resource estimates provided by the industry representatives are based on pending applications and, like the staff, appear pessimistic due to the interpretation difficulties and the change to their routine process.
Their estimates
- of the additional resources that would be required on each application are:
Commonwealth - seven person-years TVA - ten person-years AIF - ten to fifteen person-years Here again, the resource estimate may only affect the short-tenn or pending app'ications. As the industry becomes accustomed to providing such documentation, the additional resources may no longer be necessary.
Safety Benefitz The safety benefits of the proposed rule depend on the extent to which the required docunentation would uncover deviations that would not otherwise be uncove ed by the staff in the normal review process. The staff's review of an application is termed an audit review, i.e., the staff reviews only part of the cpplication to all of the SRP acceptance c ri te ri a.
The proposed rule would not alter the staff's review, but would supplement it by having one party (the applicant) review all of the application to all of the SRP acceptance criteria, and subsequently, report the results of their review to the staff. Deviations would be identified and justified. This would assure that a systematic assessment of the proposed plant design has been made to the SRP acceptance criteria and, by virtue of the bases for those criteria, to the Commission's regulations.
In addition, the staff would be able to focus on the differences and spend less time searching for them.
Such a concentrated review effort would be more likely to identify design deficiencies and, thus, would enhance the overall safety of the plant.
- These estimates were provided verbally and are not intended to be precise because of the judgements involved.