ML19308C306
| ML19308C306 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/24/1975 |
| From: | Case E Office of Nuclear Reactor Regulation |
| To: | Gossick L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML19308C302 | List: |
| References | |
| RTR-REGGD-01.097, RTR-REGGD-1.097, TASK-TF, TASK-TMR NUDOCS 8001220684 | |
| Download: ML19308C306 (3) | |
Text
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SEP e.I W5 Lee V. Gossick Executive Director for Operations REGULATORY REQUIREliErlTS REVIEW CG:'.MITTEE MEETII;G i;0. 31, JULY 11, 1975 1.
The Committee discussed issues related to the inlementation of Regulatory Guides en existing plants and the concerns expressed in the June 24, 1974 memorandum, A. Giambusso to E. G. Case, subject: REGULATORY GUIDE li:PLE;;E;!TATIO:1, and n:ade the follcr. ling recommendations and observations:
Approval of nevi Regulatory Guides and approval of revisient a.
of existing guides should move forward expeditiously in order that the provisions of these regulatory guides be available for use as soon as possible in on-going or inture staf f reviais of license applications.
The Cornittet noted that over the recent past, the approval of proposed regulatory guides -: hose content is acceptable for these purposes has experienc:.4!
significant delays in RRRC review pendino the deterniratinn of the applicability of the cuide to existing plants, of ten requiring significant staff effort.
To avoid the,e delays, the Comittee concluded that, henceforth, au;)coval of prorrsed regulatory guides shoulo be uncoupled from the consideration of their backfit applicability.
b.
The implementation section of neu regulator;f guid :s should address, in general, only the applicability of the guide ts so far applications inJhe licensing review process usin:. it as possible, a, standard approcco of applying tne ouin todate those applications docketed 3 conths after the issuonct of the guide for coument.
Exceptions to this generai cppreach will be handled on a case-by-case basis.
The regulatory position of each approved proposed guide (er c.
proposed guide revision) vtill be charact erizca by the Ce: -ittee as to its backfitting potential, by placing it in one of three ca tegorier :
Category 1 - Clearly forward fit only.
- 0 f artiar stcf f consideration of possible backfitting is required.
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9-Catc9n,ry_2_ - Further staff consideration of the need for back-fitting appears to be required for certain identified iters of the regulatory position--these individual issues are such tut existing plants need'to be evaluated to deter.nine their status with regard to these safety issues in orier to determine the need for backfitting.
Catenory 3 - Clearly backfit.
Existing plants should be evaluated to determine whether identified items of the regulatory position are resolved in accordance with the guide or by some equivalent alternative.
i.
From time to time, for a specific guide, there will probabiy be some variatiun among these categories or even within a category, and these three broad category characterizations will be qualified as required to meet a particular situation.
d.
It is not intended that the Committee categorization appear in the guide itself.
The purpose of the cateqorization is to indicate those iter:s of the regulatory po,ition for which the Cour,ittee can make a specific backfit recoatendation without additional staff work (Categories 1 and 3), and to indicate tho.c items for which additional staff work is g
required in order to deternine backfit considerations (Category 2).
The Comaittee recenenends that for approved guides in Catecary 2, c.
staf f ef forts be initiated in parallel with the process leading to publication ofqhe guide in order that sNcific Luckfit requirerents fo'r existing plants 1e deternined within a reasonable period of time after publication of the guide.
f.
The Committee observed that more attuntion.;cds to be given to the identification of acceptable alternatives to the positions outlined in the guides in order to provide additional options anti flexibility to applicants and licensees, with the possible benefits of additional innovation and exploration in the solution of safety issues.
2.
The Cernittee reviewed the pectosed "eculatory Guide 1.D::
THEF"AL OVERLOlD PP.0TT.CTIO:! FOR DTORS ON POT 01-0 PERI 4TED '.".L'.'E5 and recon = ended approval.
Inis guide was characterizec by the Corr.ittee as Category 1 - no backfitting, with the stipulation that as an appropriate occasien presented itself in conjunction with the review of scr r particular aspect of existing plants, the inermal overload protection provisions be audited.
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3.
The Comittee reviewed the proposed Regulatory Guide 1.XX:
lilSTRU;tE!!T SPAT 1S A'!D SETP0IrlTS and recomended approval
- subject to the following comment
Paragraph 5 of Section C (page 4 of the proposed Guide) should be reworded in light.of Comittee cocuents, to the satisfaction of the Director, Office of Standards Developnent.
This guide was characterized by the Comittee as Category 1 - no backfit.
4.
The Comittee reviewed Proposed Regulatory Guide 1.97:
IflSTRU",EilTAT10:1 FOR LIG!!T tlATER COOLED f UCLEAR PO'.lER PLA!;TS TO ASSESS PLAi:T C0ilDITI0 tis DURIt!G A:10 FOLLO'.fil!G A:1 ACCIDEtlT and deferred further consideration to a later meeting in.
order to permit incorporation of.recent conments by the Division of Technical Review.
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Edson G.
ase, Chairman Regulatory Requirements Review f'
Committee
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