ML19308C943
| ML19308C943 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/30/1978 |
| From: | Case E Office of Nuclear Reactor Regulation |
| To: | Scott Freeman TENNESSEE VALLEY AUTHORITY |
| References | |
| TASK-TF, TASK-TMR NUDOCS 8002110682 | |
| Download: ML19308C943 (3) | |
Text
6
~
[pastop Oo UNITE D S TA TES f'
'l NUCLEAR REGULATORY CoMMISSloN O, ' ',N WASHINGTON. D. C. 20555 a, f.' w, }
t n '
h Mr. S. David Freeman, Director Tennessee Valley Authority Knoxville, Tennessee 37902
Dear Mr. Freeman:
Your letter of March ".1978 to Chairman Hendrie has been referred to me for reply. As you may know, Chairman Hendrie is recuperating from an injury resulting from a skiing accident and we are all anxious for his speedy recovery and return to duty.
You noted tnat approved reference standard designs are reevaluated only for significant safety issues, but expressed concern that this same policy should be applied to the application of Standard Review Plans and Regulatory Guides to plants with construction permits, and particularly plants well along in construction. Your concern is well-placed, and tnis matter has received a great deal of staff attention on several fronts over the last several years.
f In June 1976, a policy was established in the Office of Nuclear Reactor Regulation concerning the review of operating license applications whose construction permits were reviewed prior to the publication of the Stan-dard Review Plans. In general, plants designed prior to the puolication of our Standard Review Plans and now in or soon to be in for operating license review, were required to meet licensing criteria and practice at the construction permit stage that were in large measure identical to or substantially similar to those of the Standard Review Plans. Tnis resulted from the fact that the Plans, as published in Novencer,1975, documented and codified it. a uniform and consistent manner the criteria that generally
~
were in use at the time the Plans were developed. However, the SRPs do include some relatively more recent criteria and practices that, depending on the specific plant design and vintage, require some reevaluation. Thus for the review of operating license applications wnich are in this "transi-f.@
tional" phase, the tiRR policy establisned iri;1976 places;upon'the staff 3 ithelresponsibility:to' identify;significant deviations:of the design frod TI G
~
the: provisions:oflthe}SRP;and to Justify-theirlacceptability.E -(I' use s
" transitional""in'the sense ~that all future cperating licens~e reviews of g.
plants whose construction permit applications were docketed;afterzSeptemoer'1,*
L f~l976 %ill be consistent with the SRP, except for changes to tne SRPs anc p"-
other regulatory documents, which changes are controlled ana i.Tplemented by a process described later in this letter).
In the transitional cases,
{;.
the assistance of tne applicant is not required with respect to the identi-fication of such deviations, nor is an applicant required to justify tne
(,
plant design by comparing it to an alternate design developed by utilizing
{
.8002 ile 6 8 2..
m.
Mr. S. David Freerran tne acceptance criteria in the SRP. flowever, requests for inform $ tion m
related to a deviation may be made of the applicant to tne extent neecca g
oy tne staff to permit it to indepencently judge the current acceptacility T
of the cesign'.
Such deviations and requests for information are carefully reviewed oy staff managerrent, and only tnose items that cannot be disposed of oy the staff alone and which involve a significant safety issue, such as our recent requests for information of TVA concerning the seismic criteria of the Watts Bar, Sequoyah, and Bellefonte plants, are pursued in this f ashion.
Regarding our procedures for controlling changes to our require: rents, in Y
Maren 1974, as a result of concerns both within the industry as well as
~
the Comission regarding the escalation of regulatory requirements
("rateneting"), a top-level management review function was estaolished on a standing basis to juoge proposed significant enanges, adoitions, or revisions to existing Regulatori Guides, Rules and Regulations, Stancard Review Plans (af ter initial publication), and other regulatory documents, with particular empnasis on items that have tne potential for a " ratchet" or an escalation of requirerrents to operating plants, plants under construc-tion and plants in review. This Committee is called the Regulatory Require-ments Review Comittee (RRRC) and consists of the Otrectors of the Divisions F
involved in the review of nu;1 ear power plant applications a;:d also includes the Director of the Office of Standards Development, upper management representatives from the Office of Reactor Safety Research, and the Office of Inspection and Enforcement.
I am the Chairman of tnis Committee.
For your information, I am enclosing a copy of the charter of the RRRC
~
as well as tne press announcement issued at tne time tne Comittee was estaolished.
P-Since its inception, the RPRC has haa 72 meetings and has considered well over 200 separate items, including proposed new or revised Regulatory Guides, Standard Review Plans, and Rules and Regulations. A ratner formal process
/
.is followed for each meeting -- material is prepared and distributed for f
remers' review (including a value/ impact assessment of each issue), a t.>
presentation to the Comittee is r:ude by the originator of the item, ana
((
af ter Comittee deliceration, a recommenaation is made by the Ccamittee 4
to the Executive Director of Ooerations as to tne backfitting requirements of each issue.
g.;
Of the many items considered by the Comittee over tne past several years, k(,
a total'of seven items have been ~ judged lto~be matters wnere action needed
~
to oe taken to apply the requirerrent to all licensed facilities," plants'
?
under construction, and applications in review.
In addition,1some 22 L
items have been jucged to ce of sucn safety significance that'they may' "
L-
- T
} * ',. [
g e
r-o,
~
n Mr. S. David Freeman.
have the potential of requiring some backfitting. Consequently, the Comittee f'
has recomended in these 22 cases that additional staff review be perforced to
,s.
determine the necessity and practicality of applying these require: rents to I,'f specific licensed facilities, including those plants under construction and operating license applications under review, taking into consideration the status of the design, construction, operation or licensing review, and the added increment of safety provided oy these enanges. Staff review of tnese items is presently underway, and we will be requesting additional information from licensees and applicants on these issues in order to make our determi-
~
nation. By far the greater part of the items considered by the Comittee were judged to t>e forward-fit to new applications only, witnout any backfit I,4..
?
inplications.
I believe that our present program for controlling "ratcheting" has been increasingly effective, and coupled with increased use by industry of our standardization policy should result in further control and minimization of such backfit changes.
However, as the complex technology of nuclear power further matures, and as experience accumulates from the operating reactors and our research programs, p
it is likely that changes in regulatory requirements will continue to occur We ' elieve that industry recognizes and accepts this.
F from time to time.
o For our part, we recognize that such changes are not to be ar'itrarily l
o imposed but require careful and deliberate consideration as to the value and inpact of such changes prior to a decision.
I hope this discussion nas been helpful to you, and we welcome your offer of further suggestions on the licensing process. Such suggestions from your organization tnat has considerable experience in nuclear power plant licensing are a positive contribution and are valuable to us in our consideration of improvements in tne licensing process.
.:.E w.,
E. G. Case, Acting Director
.)
Office of Nuclear Reactor Regulation
($
Enclosures:
l.
Charter of RRBC Comittee 2.
Press Release e:
= f.
Y k
M W
t.
.-:a = -%
' ~..,,.
-