ML19322C434
| ML19322C434 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/30/1977 |
| From: | Haass W Office of Nuclear Reactor Regulation |
| To: | Knight J, Ross D, Tedesco R Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19322C433 | List: |
| References | |
| TASK-TF, TASK-TMR NUDOCS 8001170565 | |
| Download: ML19322C434 (4) | |
Text
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p MEMORANDUM FOR:
J. Knight, Assistant Director f
for Engineering D. Ross, Assistant Director for Reactor Safety R. Tedesco, Assistant Director for Plant Systems
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FROM:
W. P. Haass, Special Assistant for Standardization Division of Systems Safety
SUBJECT:
DEFINITION OF RGCOD FOR PDA REVIEWS In accordance with recent discussions regarding the RESAR-414 review, DSS staff members should proceed on the basis of the following definition for the Regulatory Guide Cut-Off Date (RGCOD) established for PDA reviews:
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RGCGD is a soecific date, established by the cognizant LPM to be generally the same as the date for transmittal of all taff positions (0 's) to the applicant, af ter 2
which no new positions approved through the Roc and the
.i Director, NRR, as necessary, may be applied in' the h
review of PDA applications. The date of NRR management approval, not the date for implementation-on CP applica-tions given in the Regulatory Guide, is the detarmining factor for applicability.
Note that this definition applies only to those new positions determined to be neces-sary for forefit only (i.e., Category 1 positions).
W. P. llaass, Special Assistant for Standardization Division of Systems Safety cc:
R. J. Mattson L. Crocker F. Schroeder D. Hood R. Boyd C. Stable R. DeYoung l:
D. Vassallo DSS B/Cs K. Kniel
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UNITED STATES j
NUCLEAR REGULATORY COf.i!.itsSION 3'#
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MEMORANDUM FOR:
Harold R. Denton, Director Office of Nuclear Reactor Regulation FROM:
Roger S. Boyd, Director Division of project Management, NRR
SUBJECT:
TREATMENT OF RRRC CATEGORY II AND III AND NRR CATEGORY IV MATTERS ON UTILITY APPLICATIONS REFERENCING PDA'S A matter that we believe requires your immediate attention is that of establishing the procedure for the staff review of the subject matters on utility applications that reference pDA's.
In our view, there seems to be some diversity of understanding about what we are,-1md are not, going to do.
This uncertainty is associated with h'owjand ymore specifically,e when the j
staff should review conformance of the applfcant to approved RRRC Category II and III matters and the NRR Category IV matters. The problem originates because a distinction was not made on the applicability of these matters between custom plants and those plants involving a standardization option, i.e., reference designs, duplication, or replication.
The problem only concerns past RRRC decisions, since the new implementation schedules nake l-sd. M gard to standard plants aub4 sh 4 hd....'s % s.4.
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clear with re the applicabiliEt g u.s
,.e. cce We believe it is necessary to establish and document a review procedure for standard plant applications to assure that our reviews are reconciled with the Commission's recent policy statements on standardization as well as our recent pronouncements to Congress concerning the need to limit design changes to approved standard designs. As I-am-sure you are-aware,
the Commission, in its June 29, 1977 policy statement, notes that "... the full benefits of standardization will only be realized if both government I
l and industry management are firm in their commitment to limit changes to an approved standard design to those clearly needed for public health and safety reasons." We find it difficult to see how many of these Category II, III and IV natters could meet that test.
CONTACT:
C. J. Heltemes x 27745
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? G73 Harold R. Denton We have developed for your approval an approach that we belicve is consistent with the standardization policy, and at tLa same time, provides for consid-eration of each of the significant matters in an orderly and structured way.
The approach would involve deferral of the review of these matters until the FDA or OL, as apprcpriate. This would permit PDA's to remain valid when referenced in a CP application and provide the needed predictability for utilities.
The alternatives to this approach are to reopen PDA's each time they are referenced, or to take ep the matters in the referencing Cp a ppl ica tion s.
In our view, either of these alternatives would deal a seyere blow to the standardization program.-
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We have tailored our proposed generic approach to the t;ew Haven 1 & 2 review in draft letters (attached) to fiYSEG, C-E, and S&W, These lette s were sent out for review and comment to Ed Case, Dick DeYoung and Roger Mattson.
Ed and Roger endorsed the approach while Dick suggested that it was improper to set policy in the form of letters to applicants.
He recormiended that the matter be brought before RRR: to receive their recommendation.
While we do agree in general w;th Dick's comment, we believe the folicwing factors argue in favor of having this issue decided by you:
(1)
The decision is urgently needed in that the detailed review of t!cw Haven 1 & 2 is about to begin.
(2)
These matters are being deferred routinely to the OL stage on approved custom plants and those in the late stages of approval, thus raising these issues on flew Haven will give the appearance of penalizing applications that reference standard designs.
(3)
The RRRC decisions are silent as to the applicability of their decisions to standard plants, and thus, only an interpretation is needed.
(4)
RRRC decisions are in the form of recommendations and are subject to final approval or modifir>'. son by the Office Director prior i
to tteir implementation.
To reiterate, we propose to (1) defer the review of Category II, III, and IV matters on applications referencing pDA's, (2) in' form the appliaant/ vendor /
A/E that implementation of subsequent regulatory requirements will be reviewed at the OL/FDA stage, and (3) any designs which are inconsistent with our present regulatory requirements and for which suitable design alternatives might be foreclosed at the OL/FDA stage, must be brought to the staff's
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attention without delay.
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3-FEB 2 8 7:79 liarold R. Denton
[f further discussion or inforration would be useful in daciding this r.attcr perhaps I can get togcther t;ith you on Thursday, i: arch 1,1979,
'since I will be auay from the office the following tw 5.echs, and, as noted, the cetter has a ti.e.2 constraint.
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Oridir.31 sib::ed tY a" Roger S. Boyd, Director Division of Project Manage =ent
Enclosure:
As stated cc: E. Case
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NRR Reading SB Reading SB Chron W Kane DB Vassallo
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