ML19323B880

Forwards Revised Procedure for Documentation of Deviations from SRP & Implementation Program.Most Important Issue Is Documentation Rather than Safety

ML19323B880
Person / Time
Site:	Crane
Issue date:	12/31/1977
From:	Rusche B Office of Nuclear Reactor Regulation
To:	Boyd R, Heineman R, Stello V Office of Nuclear Reactor Regulation
Shared Package
ML19323B881	List: ML19323B880 ML19323B883
References
TASK-TF, TASK-TMR NUDOCS 8005140375
Download: ML19323B880 (3)

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M' MEMORdNDUM FOR:

R. Boyd, Director, Division of Project Management

.-a R. Heineman, Director, Division of Systems Safety 2E

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V. Stello, Director, Division of Opera. ting Reactors '

H. Denton, Director, Division of Site Safety and 3$$

Environmental Analysis EEd Ben C. Rusche, Director, Office of Nuclear Reactor 3

FROM:

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Regulation

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SUBJECT:

PcVISED PROCEDURE FOR DOCUMENTATION OF DEVIATIONS

- H OM THE STANDARD REVIEW PLAN i-ag w.,

. M' NRR Office Letter No. 2, issued on August 12, 1975', directed the staff W

to use the Standard Review Plan to assure consistent evaluation of 623 all applications.

It also directed that, except for clarification

.Mi and correction of errors, the Standard Review Plan would remain. fixed y

until any proposed change of substance was considered by the Division 5,j Directors, reviewed.by the Regulatory Requirements Review Cocmittee, gj and then authorized by the Director, NRR.

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NRR Office Letter No. 9, issued on June 18, 1976, addressed the special 93 problem associated with implementation of Office Letter No. 2 in M

operating license reviews when the construction permit reviews were

..i;s'i not conducted on the basis of the Standard Review Plan guidelines p.3j It noted the necessity to document decisions made on bases other than y

those defined in the Standard Review Plan and, of equal importance,

..-a the reasons for the acceptability of such bases.

It then directed Z."

);,'_j the staff to develop, for my approval, procedures for documenting the bases for deviations from the Standard Review Plan in each oper-z_f.;

ating license Safety Evaluation, and to implement those procedures 19 for all operating license Safety Evaluation Reports issued after 4.0 January 1,1977.

My memorandum of September 20, 1976, approved an

,3d implementing procedure recocmended to me by the NRR Division Directors.

1 This procedure addressed both operating license and construction per-

$;2 mit applications.

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The experience gained in attempting to use the implementing procedure

~751 for operating 1,icense reviews nearing completion has shown that, si contrary to our expectation at the time the procedure was developed,

.,3 the staff is unable at this time to confonn to the requirements of the implementing procedure without incurring a substantial delay in l

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M THIS DOCUMENT CONTAINS 3

POOR QUAUTY PAGES e

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Multiple Addressees JU.;:

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Knile there is no c mpleting the reviews for these applications.

concern as to the safety level. established by the staff review, the 55

[fM cfact remains that a significant effort would be required at this ld time for the staff to identify, for an ongoing operating license.

h review, all' deviations from the acceptance criteria set forth in

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the Standard Review Plan and to document.the bases for the' accepta-g,-

The Division Directors have now recom-

,bil.ity of these deviations. mended that I. withdraw the directive set forth in my 20, 1976, and in its. stead issue a superseding directive September C

establishing an alternate program that would:

Require the staff to assess the Standard Review' Plan, determine W=c (1) any changes needed to assure that all requirements therein are h

realistic and practical of achievement, and initiate the actions

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' needed to implement those changes in accordance with the policy

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established in NRR Office Letter No. 2.

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Require the staff to implement the policy established in NRR M,

(2)- (Office Letter No. 9 for all construction permit applications Y"g docketed after September 1,1976;

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X Require the staff to" implement the policy established in NRR M

(3)

Office Letter No. 9 for all operating license applications

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docketed after January 1,1977.

r-The Division Directors have indicated that approval of the proposed

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alternate orogram would pemit the-staff to conduct its review of W

operating.icense applications, almost from the start of such reviews, 1.5 with the knowledge that confomance to Office Letter No. 9 would be JP Such timely knowledge should limit the a requisite for licensing.

i2 impact of this ' requirement on the schedule for completio.n of the staff M

I.have also been infomed that if the alternate program is review.

M approved, then four operating license applications that would have otherwise been required to conform to Office Lettei No. 9 will not C

Rdd be required to so confom.

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I have decided to approve the recomended alternate program.

approval is based on (1) the conviction that the singular issue is

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Qq one of documentation and not safety, (2) the knowledge that the

9.1 alternate program will permit a limited number of operating license S.

applications (four) to be added ~ to the number reviewed j$

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-M is not prepared to implement the procedure in a timely manner for reEjj -

the' four applications involved. ' Accordingly, my memorandum of (dia '

September 20,1976, is withdrawn and is superseded.in its entirety by this memorcndum.

In essence, the procedure for documentation

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.. (Enclosure 1) remains unchanged for construction pemit reviews but modified so that only' limited participation will be required of

.Si licensees involved in operatino license reviews, and the implemen-tation program (Enclosure 2) has been nodified so that the appro-

..--3 priate Safety Evaluation Reports, including those associated with Ty operating ~ license, construction pemit, and design approval appli-

dm catioris, will document deviations from the Standard Review plan and W

the bases for the. acceptance of such deviation.

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' ~/.:.J Ben C. Rusche, Director 9-3 Office of Nuclear Reactor Regulation

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,nclosures:

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4A 1.

Procedure for Documentation TEG2 of Deviations from the dd.'M Standard Review Plan-T41Q 2.

Implementation Program

. :.;:C IM.i' cc w/ enclosures:

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NRR Technical Personnel

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