ML19339C403
| ML19339C403 | |
| Person / Time | |
|---|---|
| Issue date: | 10/29/1980 |
| From: | Ahearne J NRC COMMISSION (OCM) |
| To: | Mcintyre J OFFICE OF MANAGEMENT & BUDGET |
| Shared Package | |
| ML19339C386 | List: |
| References | |
| NUDOCS 8011180301 | |
| Download: ML19339C403 (2) | |
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t UNITED STATES NUCLEAR REGULATORY COMMISSION j. h[' > f
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W ASHIN GTON, D.C. 20555
% m: p October 29, 1980 OFFICE OF THE CHAIRMAN t
The Honorable' James T. McIntyre, Director Office of tianagement and Budget Washington, D. C. 20503
Dear Mr. McIntyre:
In accordance with Section 236 of the Legislative Reorganization Act of 1970, the U.S. Nuclear Regulatory Commission (NRC) is hereby submitting a statement on the Comission actions being taken with regard to the recommendations made by the U.S. General Accounting Office (GAO) in a report entitled, "Do Nuclear Regulatory Commission Plans Adequately Address Regulatory Deficiencies Highlighted By The Three Mile Island Accident?"
The GA0 recommends that "... the Commission periodically report to i
Congress on its progress in implementing the Action Plan, specifically j
providing the status of each action compared to the original Plan."
In our next Annual Report to the Congress we plan to devote an entire l
chapter to the aftemath of the TMI accident. This chapter will include, among other things, a report on the status of Action Plan items. Of course if the Congress desires additional information on the Action 1
Plan, we will be pleased to provide it.
Howeve., we do request that the Congress first review our initial report to determine if it is sufficient.
We believe the Annual Report is an appropriate vehicle for periodic reports to Congress on NRC's progress in implementing the Action Plan in
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the current year, and in succeeding years as applicable.
For the most part NRC agrees with the GA0 report.
Two observations made by GAO, however, merit additional comments. These are summarized on the 4
j attached page.
Sincerely, f
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John F. /hearne Chairman 4
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Attachment:
As stated i
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COMMENTS ON GA0 OBSERVATIONS IN THE REPORT "D0 NUCLEAR REGULATORY' COMMISSION PLANS ADEQUATE *Y' ADDRESS REGULATORY t
DEFICIENCIES HIGHLIGHTED BY THE THREE MILE ISLAND ACCIDENT?"
1 GA0 Obser vation "The Commission's estimated resources and time frames do not leave much margin for error."
i NRC Comment The observation is valid.
However, since completion of the development of the Action Plan, the NRC has taken action that will lessen the staff resource impact of the plan.
First, many items that were initially envisioned as requiring pre-implementation review and approval by the NRC have been l.
changed to require post-implementation review.
This removes the NRC from the critical path of implementing the needed improvements.
Second, for a number of reasons, the scheduled implementation dates have been extended.
This allows more flexibility in completing the needed staff effort. Botn of these factors were the subject of industry meetings conducted in September (see attachment) on the Action Plan.
6 GA0 Observation i
"The Commission is relying heavily on the nuclear industry for the development of most corrective actions."
NRC Comment The NRC is establishing new requirements based on the analysis of the accident that occurred at Three Mile Island.
The NRC is responsible for setting the guidelines and criteria for corrective action.
Nevertheless, in many cases the method used by the industry to meet assigned require-ments will be plant-specific, and it should be expected that industry personnel are more able to analyze and develop plant-specific modifications.
However, the Congress can be assured that NRC intends to oversee vigorously the process of implementing the requirements to make certain that the action items 1are. completed properly.
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$Eo F1530 TO ALL LICENSEES OF OPERATING PLANTS AND APPLICANTS FOR OPERATING LICENSES AND HOLDERS OF CONSTRUCTION PERMITS GENTLEMEN:
SUBJECT:
PRELIMINARY CLARIFICATION OF TMI ACTION PLAN REQUIREMENTS Over the past months since the TMI-2 accident, the NRC has developed a number of requirements that must be implemented on operating reactors and on plants under construction.
The purpose of this letter is to provide you with a summary listing of all approved TMI-2 related requirements for operating reactors and for aoplicants for an operating license as we understand them today.
Also included for many items are proposed revisions or clarifications.
This letter is. for your information and review crior to NBC recional meetinos to be held during the week of September 22, 1980.
It is hoped that such a listina will out together in one place a tabulation of all such requirements for ease of use. contains a listing of all approved TMI-related recuirements for operating reactors.
Post -TMI requirements that have been comoleted, i.e., Short-term Lessons Learned requirements, have been included on Enclosure i for completeness. contains the approved list of recuirements for aplicants for an operating license. to this letter contains revisions and clarifications of the NRC position on most of these requirements.
One of two types of NRC reviews is specified for each rcquirement listed on.
" Pre-implementation review" requires that the licensee orocosal be reviewed and approved by NRC prior to implementation.
Post-implementation review requires that the licensee submit sufficient documentation to pemit NRC review following implementation.
In general, all reviews for Operating License applicants will be pre-implementation reviews.
To facilitate NRC review on all pre-implementation items, in a time frame consistent with the implementation schedule, dates for the submittal of required information or documentation for licensees are also listed on Enclosure 1.
Infomation or documentation for Operating License Applicant requirements is to be submitted four months prior to the expected issuance of an operating license or four months orior to the listed imalementation date, whichever is later.
A preliminary indicati^
ing whether the development of Technical Specifications to a facli> u.. cense will be required for each of the action items is also listed on Enclosures 1 and 2.
For those items which require Technical Specifications, the proposed Technical 3pecification should be submitted with the required documentation.
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Excerience witn implementation of these and orevious TMI Action Plan recuire-ments indicate that the seneduled imolementatien deadlines in seme cases may not allow reascnable time for ccmoletion of the work recuired.
In some instances, the schedules, review categories, or clarifications have been changed frcm previcus ccreescondence, or the recuirement is being fornally transmitted for the first time.
A summary of these orincioal changes is listed as Enclosure E.
The licensee / applicant should formally notify the staff as soon as any delays beyond the required imolementation dates become apparent. The licensee /apolicant submittal for these cases should include justification for the delsy, a discus-sion of the work that will be completed by the required date including any planned ccmcensatory actions, and an indication of the daze for completion of tne recuired actions. The staff intends to allow case-by-case exceptiens only for good cause.
In general, a completion deadline for a recuirement falls later than tne operating license date for a new olant, that requirement need not be met by the newly licensed plant until the completion deadline.
If a completion deadline falls before an coerating license decision date, that recuirement is a prerecuisite for the new operating license, except when a good cause is shown for any such exception.
- n view of tne comolexity and One rurber of issues discussed herein, the ?;RC is planning regional meetings to discuss these recuirements. Such meetings, whien will be similar to those held a year ago en the Short-term Lessons Learned recuirements, will be principally for the ourcose of discussing our prooosed clarification and revision reouirements, and to orovide a forum for cbtaining licensee /acolicant feecback.
Licensees and acolicants for coerating licenses are strongly encouraged to attend and participate. A Federal Recister Notice is being issued in the near future stating the exact time and location of sucn meetings which will be held during the week of September 22, 1980. To facilitate your review, Enclosure a contains a listing of previous, correspondence sent to licensees / applicants setting forth TMI-related requirements.
Although the requirements (Scoce and Schedules) contained herein will not be put in final form until after consideration of coments received at the regional meetings, all licensees and acplicants should anticipate that the final require-ments will closely resemble those identified in the Enclosures. As such, utilities should continue plans to implement these requirements.
Sincerely, varreliG.giLicensing Eise nuw, rec or Division c Office of Nuclear Reactor Regulation Enclosures Lbted on n
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