ML19339B237
| ML19339B237 | |
| Person / Time | |
|---|---|
| Issue date: | 10/10/1980 |
| From: | Schroeder F Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-75-087, RTR-NUREG-75-87 NUDOCS 8011060553 | |
| Download: ML19339B237 (5) | |
Text
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gu OCT 1 0 1999 MEMORANDUM FOR: NRR Branch Chiefs FROM:
Frank Schroeder, Acting Of rector Division of Safety Technology
SUBJECT:
GUIDANCE ON REASSESSMENT OF SECONDARY REVIEW RESPONSIBILITY ASSIG!." DENTS FOR STANDARD REVIEW PLAN REVISIONS In preparing revisions to SRP sections as requested by !!r. Denton's remorandum of Septerber 15, 1980, attentien should be given to the assigreent of secondary review responsibilities, so that the revised SRP will accurately reflect our current review process and provide assurance that the integrated review is complete and well-coordinated among branches.
Harold Denton's remorandum to NRR Division Directors of August 12, 1930 assigned pricary and secondary review respcnsibilities to specific branches and instructed these branches to reassess their secondary review assign-acnts in If ght of the criteria contained in the neco. At present,175 SRP sections have over 650 secondary review responsibilities assigned. k'e expect that cpplication of the criteria (which limit the designation of secondary review responsibility to cases where a branch provides written infornation routinely to the project canager or the primary review branch) will result in a decrease by sixty percent or core in secondary review assignments. The basic reason for this is that previcusly the secondary revicw responsibility assignment was used as a means to define the sometimes complex interfaces that occur arong branches or among other SRP sections. In most cases, the needed information or support was minor in nature so that it did not represent a direct input into the primary branch's SER write-up. What was reflected was the effort involved in coordinating the overall review to assure completeness.
As secondary review responsibilities are deleted, the interaction between branches for providing needed inforration or identifying the review cxpected froc: other branches that are required to permit the primary review branch to corplete its review will be clearer. But the coordinating effort with other branches not now listed as secondary reviewer could be lost. We believe that a clear picture of the treans used to coordinate the review effort between branches reust be preserved. Thus, individual SRP sections should indicate in some canner this necessary coordination.
In the present version of the SRP, a branch designated as a secondary reviewer was often only expected to examine sor.e aspect of the design where its area of expertise could be used in the review. In rany such cases, the secondary branch perfoms the intended review in the context of another SRP secticn where it is the prinary branch. The revised SRP sections should docuuent the staff's actual review process, so that the integiated review can
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b NRR 2 ranch Chiefs ! 0 500 is deleted, in e.any cases it may be ' appropriate to replace it with a reference that instructs the reviewer to coordinate his review effort with the branch -
that was previously listed as secondary reviewer, identify what portion of soce particular design aspect they are reviewing, and identify the SRP section under which the review f s performed. This aspect is especially significant when the reviewing branch for one SRP section is indicating that a require-nent has been satisfied (for the systems under review in that SRP section),
but complete _ satisfaction of that requirenent is deter ained by additional reviews being perfomed under other SRP sections.
Three subject areas: F1re 'rotectfon, Technical Specification, and the Quality Assurance have been identified where reviews are perfonred for the most part entirely and completely by the branches responsible for those SF#
sections. Any effort necessary to coordinate the review uill be directed by those branches. For each of these reviews approximately 80 to 90 percent of the SRP sections could and/or should list one or more of the T1t1e 10 regulations that are associated with these subjects.
Since the review of each of these subjects is done in an integrated manner within a specific SRP section it will suffice that the other SRP sections to which each topic applies make specific reference to the review conducted elsewhere (see example). Each SRP should only address these subject areas (with review procedures and evaluation findings) when review aspects beyond the normal accpe in the referenced areas are necessary to make the review sufficiently complete.,
i The enclosure provides an exacple of the sort of reanalysis and revision of secondary review responsibilities we believe is appropriate. flote that it is provided only for illustration and nay not accurately reflect the situation for tk SRP section chosen.
Orfsinal signed y >
N Schnetee Frank Schroeder, Acting Director Division of Safety Technology
Enclosure:
Exarple of Reassessnont of Secondary Review Responsibilities and Review Process Interfaces with other Branches cc:
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J EXNPLE OF REASSESSMENT OF SECONDARY REVIEW RESPONSIBILITIES AND REVIEW PROCESS INTERFACES WITH OTHER BRANCHES A.
Excerpt from Present SRP Write-up SECTION 9.1.1 NEW FUEL STORAGE REVIEW RESPONSIBILITIES Primary -
Auxiliary Systems Branch ( ASB)
Secondary - Mechanical Engineering Branch (MEB)
Structural Engineering Branch (SEB)
Materials Engineering Branch (MTEB)
Core Performance Branch (CPB)
Radiological Assessment Branch (RAB)
Equipment Quatification Branch (EQB) 1.
AREAS OF REVIEW
[ Secondary Responsibilities are generally discussed af ter the -
discussion of specific review areas.]
Secondary reviews are performed by other branches and the results-used by the ASB to complete the overall evaluations of the system.
The secondary reviews are as follows:
the SEB determines the acceptability of the design analyses, procedures, and criteria used to establish the ability of facility structures to with-stand the effects of natural phenomena such as the safe shutdown earthquake (SSE), the probable maximum flood (PMF), tornadoes and tornado missiles. The MEB reviews the seismic qualification of components and confirms that components and structures are designed in accordance with applicable codes and standards. The MTEB veri-fies, upon request, the compatibility of the materials of construc-tion with service conditions. The CPB verifies, upon request, that the X f 1 aded storage racks is acceptable. The RAB reviews eff the adequacy of the-radiation monitoring system.
B.
Reassessment Analysis 1.
The Equipment Qualification Branch is the only branch listed as a secondary reviewer that intends, or needs, to provide direct input into the Auxiliary Systems SER write-up for this Systems review
[this is an assumption for the convenience of this example, and therefore, does not necessarily represent the actual case].
Enclosure m
i i.
2.
The interactions with Structural Engineering Branch, Mechanical Engineering Branch, and Radiological Assessment Branch reviews should continue to be noted, but the discussion should refer to the SRP section under which each branch performs the review as the primary review branch.
3.
The Core Performance Branch and the Materials Engineering Branch provide an evaluation upon request; they do not as a matter of normal routine perform a safety review of New Fuel Storage for each plant.
4.
The Fire Protection review, the Technical Specification review, and the Quality Assurance review are performed in accordance with SRP sections 9.5.1, 16.0 and 17.0, respectively.
We would conclude that the secondary review branches listed in items 2 and 3 above should be deleted from the assignments for the reasons stated. As part of the reassessment exercise each primary branch should review each regulation listed in the acceptance criteria to determine that all branches associated with the coordinated review are identified and referer.ced as in items 2 or 3 above. The branches identified must perform a portion of the review that contributes to the conclusion that, based on the integrated review, the requirements of the regulation are met. Delete references to regulations that pertain to fire protection,. technical specification or quality control in the acceptance criteria and evaluation findings sub-sections of this SRP section and replace with a reference as indicated below.
C.
Excerpt from Revised SRP Writeup SECTION 9.1.1 NEW FUEL STORAGE REVIEW RESPONSIBILITIES Primary -
Auxiliary Systems Branch (ASB)
Secondary - Equipment Qualification Branch (EQB) 1.
Areas of Review
[$ame as before, except delete some regulations as noted above.]
A secondary review is performed by the Equipment Qualification Branch, and the results are used by the ASB to complete the overall evaluation of the system. The EQB will provide a listing [ state what is needed by ASB] and verify that components can function in the environmental conditions for which they are designed [and any-
thing else necessary to support ASB conclusions or analysis in the SER writup].
In addition, the ASB will also coordinate other branches evaluations that interface with the overall review of the system as follows: SEB determines the acceptability of the design analyses, procedures, and criteria used to establish the ability of facility structures housing the system to withstand the effects of natural phenomena such as the safe shutdown earthquake (SSE), the probable maximum flood (PMF), tornadoes and tornado missiles as part of their primary review responsibility for SRP section 3.X.X. The RAB reviews the location and adequacy of the radiation monitoring system as part of their primary review responsibility for SRP sec-tien 12.XX. The MTEB verifies, upon request of ASB, the compatibility of the materials of construction with service conditions. The CPB verifies by independent analysis, upon request of ASB, that for plant unique designs the K,ff of loaded storage racks is acceptable. The reviews for Fire Protection Technical Specifications, and Quality Assurance are coordinated and performed by Chemical Engineering Branch, Licensing Guidance Branch, and Quality Assurance Branch as part of their primary review responsibility for SRP sections 9.5.1, 16.0, and 17.0, respectively.
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