ML19347C793
| ML19347C793 | |
| Person / Time | |
|---|---|
| Issue date: | 01/08/1981 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| Shared Package | |
| ML19347C794 | List: |
| References | |
| FOIA-81-145 NUDOCS 8103030323 | |
| Download: ML19347C793 (7) | |
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_SECY-81-13 January 8,1981
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gv f POLICY ISSUE (Commission Meeting)
For:
The s unissioners From:
William J. Dircks Executive Director for Operations
Subject:
SYSTEMATIC SAFETY, EVALUATION OF ALL CURRENTLY OPERATING NUCLEAR POWER REACTORS
Purpose:
To request Coranission approval of the issuarce of the following items:
(1) a draft Federal Register notice for a final rule requiring cocumentation of deviations from the Stancar d Review Plan, NUREG-75/087; (2) a cetailed plan to 1.nplement the systematic safety evaluation of currently operating nuclear power reactors as a draft ituREG Report for public couaent; (3) a Federal _ Register notice announcing the availability of and requesting c a..ents on the draft NUREG report; (4) a puolic announcement ca the issuance of tne final rule and draft NuREG report; and (5) letters to Con-gress on the issuance of the final rule and draft NUREG report.
These items are part of tne staff's program to adoress the require-meats of Section 110 of Public Law 96-295, the NRC FY-80 authori-zation Bill.
Background:
On September 9,1960, the staff suomitted an Action Paper (SECY 414) entitled " systematic Safety Evaluation of All Currently Operating Nuclear Pcwer Reactors" to the Cormaission.
In this paper the staff requested approval of the proposed conceptual elements of a plan designed to meet the requirements of Section 110 of Public Law 96-295, the NRC FY-80 Autnorization sill. The Comission met on September 16,19 and 22 to discuss that paper and anotner related program, which will require the documentation of deviations from tne Standard Review Plan (SRP), NUREG-76/087, by all licensees and applicants. These discussions resulted in the issuance of the 90-day status report to Congress (Enclosure 1), as required by Section 110(c) of Puolic Law 96-295, on September 30, 1980, and in the pub-lication of a Notice of Proposea RJlemaking in the Federal Register on October 9, 1980 (FR 67us9, Enclosure 2).
Because of tne nexus of tne s'jbaect of the Federal Register notice to the requirements of Section 110 of Public Law 90-r)5, wnicn includes tne icentification of ano occuentation of compliance to the regulations of particular safety significance, tne lan9uele in tne notice of proposea rulemaking was chosen to track that of
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2-the 90-cay status report and tnus, to be fully compat.iola with the lar.guage in the Puolic Law. Also, as presentea in botn Enclo-sures 1 and 2, the " Revised SRP," scheauled to be issued in April IP;1, was explicitly designed and defined to be equivalent to the
" Division 1 Regulatory Guices and staff technical positions," which is the language tnat the Public Law usea to indicate compliance with the regulations.
The actions outlined in the Federal Register Hotice of proposed rulemaking are fully concoraant witn the requirements of Sunsec-tions 110(b)(1) and (2) of the law for all reactors operating as
' June 30, 1980. This notice further extended tne same require-ents to apply to all reactors issuec operating licenses in tne near future and would impose full cocuraentation requirements on all other reactors in tne licensing process. Also, as stated in the 90-cay status report, the documentation gregram will be inte-grated witn an existing safety issues study of the 11 oldest reac-i tors, (Phase II of the Systematic Evaluation Program (SEP)), and with a reliabiluy-risk assessment study, (the Interim Reliability Evaluation Program (IREP)), sucn that the resultant proauct will be a comprehensive and cooroinatea reactor safety review program.
On October 7,1980, the staff briefad tne Reactor Operations Suo-Connittee of the ACRS, and on OctoDer 10,198u, the full ACRS on the staff's plan, as presented in SECY-80-414, and on the initial effort to icentify the regulations of particular safety sisaificance.
By memorandum dated October 14, 1980 (Enclosure 3) the ACRS provided its couments on tne staff plan. The staff ccknowledged th9se comments in a nemorancum dated Novenber 7,1980 (Enclostre 4).
In a memoranoum for the record dated Octooer 24, 1960 (Enclosure 5),
the Office of the Secretary closed SECY-80-414 as an active action itsn. This action was based upon we issuance of the Octooer 9tn Federd, Register Notice ano on the unoerstanding that the staff woulo suunnt a new action paper subsequent to the expiration date of the Federal Mster conaent period (Novemoer 24,1980). This pre".ent action paper is submittea to the Consission to present the statf's analysis of the puolic consents received on the Octuber 9th Federal Register Notice (see Enclosure 6); to present the staff's proposea fin:1 rule for cocumentation of aeviations frce. the SRP (Enclosure 7); to provide the staff's analysis of tne regulations, i
l including several cnoices for a list of regulations considerec to be of particular safety significance (Enclosure 6); and to obtain Conaission 9t! dance on those issues in SECY-80-414 wnica have not as yet been acted upon.
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, Discus = ion: As stated previously, the SRP is in tne process of being revised,
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with completion scheculed for April 1981.
This revision will incorporate (1) a more thorough reference to existing regulations, (2) tne approved TMI-related requirements, (3) other new require-ments as are clearly necessary and appropriate at this time, and (4) necessary eoitorial ano aaministrative changes.
The revi' sed SkP will then be the base document against wnich the determination
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of compliance to the regulations, as required by Section 110 of Public Law 96-295, will be performed.
It is the intent of the staff not to publish the proposed SRP revisions for public conent Decause of tha nature of the revisions and because it would delay the issuance of an effective SRP.
The implementation scheme for the proposed requirement for documen-tation of deviations from the SRP, as detailea in a Federal Register notice issued on Octo!:cr 9, 1960 (Enclosure 2), was the suoaect of a great deal of public connent. Enclosure 6 provides the staff's evaluation of these conaents and Enc:osure 7, developed as a result of that evaluation ano as a result of aaministrative airectives, is a draft final rule on the documentation requirements. Changes made to the proposed rule based on public conuent and further staff evaluation are:
responses from operating reactor licensees will be spreaa out over a seven year period to alleviate near-term resource constraints for both the NRC and the incustry; flexibility is provided to moaify the program for operating reactors based on experience gained in implementing tne program; and near-tenu construction pennit applicants will not be required to cocument confonnance with tne SRP as a conoition for licensin9 Some of the reconaenaations maae by the staff in SECY-80-414 are still open items requiring Conaission guidance. These items are:
1.
The alternative methods for aeveloping the list of particularly significant re9ulations (Alternatives A-1, A-2, and a-3 of SECY-d0-414j. These alternatives concern the aegree of strin-gency of the screening criteria to be usea, and whether the final aetennination of particular significance shoula be deferred until after review of licensees' responses in orcer to penuit recognition that, for a given plant, a particular regulation might have more or less safety significance depending on the metnod and degree of compliance of the plant to it and to other relatea regulations.
In SECY-80-414 we recommendad that the staff develop the list of particularly significant regulations generically using mocerately stringent screening criteria, recognizing that such a list woulu pronaoly inc;uce at least 751, of the safety-relateo regulation. A memorandum l
from the ACRS (Enclosure 3) provides the Conaittee's couaents l
on this matter. provides the initial results of screening performed by the staff using tne sets of screening criteria discussed in SECY-80-414. Tnat Enclosure also provices l
a recounenced list of regulations of particular safety significance.
, 2.
The ceyree of justification to be required of tne licensees regarding:
(a) the safety significance of deviations from the applicable sections of the SRP; and (o) assertions that com-pliance is achieved by equivalent means, rather than by the nethods identified in the revised SRP.
In SECY-80-414 wp reconnended that licensees be ;equired to provide only brief technical bases for their juaguents of equivalence and brief technical discussions of the safety significance of any devia-tions (Alternative B-1), rather than full tecnnical analyses (Alternative B-2).
In making this recouandation, we recognized tnat more detailed responses inay be requested in selected areas after staff review of the initial submittal.
3.
The nature and extent of the staff's evaluations of the licensees' analyses. An alternative could be a full evalua-tion of all ceviations from and/or assertions of equivalence to the applicable sections of the revisea SRP. However, the staff recomended that evaluations be perfomed on a selective (audit) basis, cased on staff judgments as to tne likely valicity of assertions of equivalence and tne relative poten-tial safety significance of deviations (Alternative C-1). is a Draft NUREG Report that provides tne staff's re:omended detailed plan to implement Section 110 of Puolic Law 96-295 for operating reactors. This plan incorporates the recoasaenced alternatives presented above ano provices more detail on tne actual implementation of tne plan. A feature of tnis plan tnat shoulo ce notea is tne flexibility in tne documentation and review process nas oeen provicea. That is, as experience is gainea from implementa-tion of tne plan, tne requirements may oe alterea so that tne plan will focus on those areas wnere experience ilas snown the greatest contribution to the recuction of risk to public health and safety eaay be acnieved. In tnis regard, as noted above, the licensees' responses will be staggered over a perica of about seven years.
The priority of response will be dictated by factors such as the ase and type of the plant and the density of population surrouncing the site. This type of scnedule is necessary consicering tne NRC ana incustry resources necessary to implement the program, anc it also will permit the flexibility described above.
The detailed plan presented in the Draft NUREti Report also snows the interrelv.ionsnips of IREP/NREP, SEP, and tne requirements of Section 110 for tne documentation of compliance to the regulations, and presents the staff plan for the icentification and resolution of generic issues.
The sta99erea scheaule for response to tne documen-tation requireu.ents will be coorcinated witn tne NkEP and SEP reviews so tnat all tnree are integrated into one coordinatec program and implenented at the same time on eacn inoiviaual plant. The ma or s
parts of tne staff plan are snown scnematically on Figure 1 of the Draft NOREG, anc the proposed implementation schecule for tne Ma Jr parts of tne staff plan are snown on Fi,ure 2 of tnat report.
, Enclosure 10 of this paper is a preposea Federal Register Notice announcing the availability of the Draft NUREG Report anc requesting comment on the detailea plan. This notice also cetails the relation-ship of the requirements presented in the Proposed Final Rule (Enclo-sure 7) for documenting deviations from the SRP ar.d the requirements for cemonstrating compliance with the rebulations presentec in the Draft duREG Report (Enclosure 9).
. 1 is a Proposed Public Annoncement which discusses the Federal Register Notices on the Final Rule for cocumentation of ceviations from the SRP (Enclosure 7) ano on the availability of the Draft HUREG Report (Enclosure 9). Also in our effort to keep Congress informed of our progress in satisfying the requirements of Section 110 of Public Law 90-295, we have drafted the information letters in Enclosure 12. Attached to tne letters will De a copy of the Draft NUREG Report ana the Final Rule on documentation of deviations from the SRP.
Reconnendatio.is : We recomend that the Connission:
1.
Approve the general content of the craft Final Rule requiring cocumentation of deviations from the SRP (Enclosure 7).
After receipt of this approval, tne staff will prepare the final woraing of the final rule ana associated Federal Register Notice for Commission approval.
2.
Approve the content ano tne issuance as a HUREG report of tne pro'posec detailed craft plan to implement Section 110 of Puolic Law 96-295 (Enclosure 9);
3.
Approve the issuance of the proposea Feceral Resister Notice (Enclosure 10) announcing the avallaoility of anc requesting comments on the draft NUREG report.
4.
Approve tne issuance of tne Proposea Puolic Announcenent (Enclosure 11);
5.
Approve the issuance of the information letters to Congress (Enclosure 12).
O.
Note tnat tne staff will subnit the Final Rule requiring i
accumentation of deviations from the SRP for Commission approval.
7.
Note that the staff will recommend a final plan to implement Section 110 of Puolic Law 96-295 after receipt ana analysis of public comment.
Resources:
Estimates of resources to implement Section 110 can only be pro-aected with assurance after the extent of aeviations identified by licensees are cetter known.
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., However, while more manpower would be required to review the older operating reactors tnan those of more recent vintage, we currently estimate tnat the resources required to conduct the review of equivalence assertions and areas of nonconformance and resolve any ensuing potential safety issues for each oper-ating reactor would average about 2.8 staff years per plant based upon a learning curve process. This is in aadition to the resources required to extend the safety issue review of the oldest operating reactors to all other currently operating i
reactors (SEP Phase III) and to perform the NREP evaluations.
This estimate of additional staff-years per plant could prove to be hisn if:
1.
Tne responses from the the licensees are sufficiently defin-itive to facilitate very effe;tive prioritization of issues for subsequent safety evaluation by the WRC; and 2.
Most of the areas where equivalence is asserted or potential nonconformance is identified that are selectea for further avaluatior, fall within the scope of what would have been evaluated anyway in the SEP Phase III and NREP programs.
If the staff's plan for selective prioritized evaluation turns out to be unworkaole, or if a large fraction of tne areas of equivalence and potential nonconformance do not fall within the scope of wnat would have been reviewed anyway in the SEP Phase III and NREP programs, then the aoditional resource neecs identified above could prove to be uncerestimates.
Taole 1, attached to this paper, presents the latest combined Section 110/SEP/NREP estimatea NRC resource requirements for the anticipated curation of the program, (through FY 1990).
The resources estimated to be required to accomplish Phase II and Phase III of the SEP are listed separately, as are tne estimated NREP resources. Also listea separately is a breakcown of the acaitional resources estimated to be needeo to implement the requirements of Section 110(a) ano (b)(1) and (2), including appropriate safety evaluations of licensee responses as to tne safety significance of possiole ceviations from tne SRP acceptance requi rements.
Tne total effort for the overall Section 110/SEP/NREP program for operating reactors was levelized at 51 staff-years per year from FY 1982 to FY 1990, inclusive. This is equivalent to aoout 37 professional staff-years per year. Contractual resources of 21,000K for FY 83 and $600K for FY 84-90 are neeced to substitute
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. for some of tlie NRC staff resource needs in the SEP and Sec-tion 110 reviews, so as to levelize the NRC staff resources to the above value. The FY 1092 President's Budget currently includes 38 staff-years for the SEP and ' REP /NREP portions of the overall program. The details of the assumptions used l
to estimate the resources are presented on the second page of Table 1.
The resources to implement Subsections 1100)(3),(4),and (5) are not large, and the staff intcaded t carry out the intent of these Subsections in any event. kus, no aedi-tional resources are needed to implement these portions of Public Law 96-295.
William J. Dircks Executive Director for Operations
Enclosures:
1.
September 30,1980 St:tus Report to Congress 2.
October 9, 1980 Federal Register Notice on Documentation of Deviations from the SRP 3.
October 14,1980 ACRS Memorandum to W. J. Dircks on Section 110 Plan 4.
November 7,1980 W. J. Lircks i
Memorandut to ACRS on Secticn 110 Plan 5.
October 24, 1980 Memorandum for the Record from E. W. McGregor on SECY-80-414 6.
Staff Analyr's of Coments on October 9,1980 Federal Register i
Notice 7.
Proposed Final Rule on Documentation of Deviations from the SRP 8.
Staff Analysis of Regulations of Particuler Significance 9.
Draft NUREG-0745
- 10. Proposed Federal Register Notice Announcing NUMtG-U/4b
- 11. Proposed Public Announcement
- 12. Proposed Congressional Information Letters A briefing and possible vote on thir. paper is scheduled for consideration at an open meeting on Thursday, January 15, 1981.
TAB L_C_1 Resource Requirements -- SEP/IREP-NREP/Section 110 (Dollars in thousands) 0 FY 1981 FY 1982 FY 1983 FY.1984-1990 SEP Phase II (11 plants)
$1,4852/
$ 850 Program Support Staff-Years 32 24 3/
Phase III (59 plants)-
$1,650
$1,000 Program Support 15 25 Staff-Years IREP/NREP (93 plantsk
$1,400
$2,200
$2,200 Program Support Staff-Years 6
6 6
Section 110(a), (b)(1) and (2)
Initial Prioritization of Issues
$ 200 Program St;pport Staff-Years 7
9 Review of SEP Phase II plants (11 plants)
$ 600 Program Support 12 18 Staff-Years Raviewofremainingoprating reactors (82 plants) -
$ 950
$1,600 Program Support 12 20 Staff-Years TOTAL 9;
5;
$4,800
$4,800 Prograr.i Suppor'
$1,48S-
$3,050 3./
Staff-Years 39 51 51 51 1/ For each fiscal year.
'f/ Does not include $535,000 request for use of prior year unabligated funds.
7/ Based on the current number of operating reactors less the 11 plants in SEP Phase II, and Humboldt Bay and Indian Point I which have operating licenses but are shut down indefinitely.
4/ Includes SEP Phase III plants and 23 additional plants to have supplemental SERs issued on or before April 1982 (as identified in SECY-80-508 Enclosure 2 Attachtent 4).
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5/ FY 1982 President's Budget for SEP and IREP/NREP is 38 staff-years and $2,250,000.
J/82pl:nts(footnote 4)plus11SEPPhaseIIplants
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Resource and Planning Assumptions SEP Phase III:
to assess the adequacy of design ond operation and provide an integrated safety assessment of the Phaso III plant issues:
.06 professional staff-years / issue
- 40 issues / unit
- 59 units
- approximately $1.0 million in program support per fiscal yearj/
NREP: -2/
to monitor licensees' performance of analyses
- 0.1 professional staff-years / unit
- $100,000 program support / uni'
- 93 units to evaluate potential safety lisues
- 0.3 professional staff y-sr/ unit
- 100,000 program support / unit
- 93 units Section 110(a), (b)(1) and (2); Public Law 96-295:
to identify and prioritize issues generically
- 11.5 professional staff-years
- $200,000 program support to review the documentation submitted by the licensee and prioritize issues
.5 professional staff-years / unit
- 33 units to conduct the review of equivalence assertions and areas of nonconformance and r: solve any ensuing potential safety issues
- 1.5 professional staff-years / unit i
- 93 units
- approximately $50,000 in program support per in-house staff-year to provide contractual technical review assistancel/
l 1/ Program support is also used to substitute partially for in-house staff at a rate of $90,000/ professional staff-year.
2/ These are the same planning assumptions used in the formulation of the FY 1982 budget.
However, there are new more plants included in the program, and it extends over a longer period of time.
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ENCLOSURE 1 1
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ENCLOSURE 1 STATUS REPORT ON THE EFFORTS OF THE NUCLEAR REGULATORY C0tttISSION TO DEVELOP AND I"PLEMENT A COMPREHENSIVE PLAN FOR THE SYSTEMATIC EVALUATION OF NUCLEAR POWER REACTORS
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Subsection 110(a) of Public Law 96-295 (NRC FY 1980 authorization) requires the NRC to der 21op, submit to Congress, and implement as soon as practicsble after notics and opportunity for public comment, a comprehensive plan for the systematic safety evaluation of all currently operating nuclear power plants.
The Conference Report states that the above requirement was written so as to enable the NRC to build upon the systematic safety evalcation it is currently conducting for the oldest operating nuclear power plants.
The need to systematically assess the safety of operating reactors resulted in the establishment several years ago of the Systematic Evaluatien Program (SEP) by the NRC.
One of the objectives of the Program was to extend the experience gained in reviewing older plants to the safety evaluation of all operating re:ctors. The TMI Action Plan (NUREG-0660, "NRC Action Plan Developed as a Result of the TMI-2 Accident") appropriately recognizes this need in Task IV.E-5, which requires the improved and expanded systematic assessment of the safety of all operating reactors. While there are many other TMI Action Plan tasks that are aimed at operating reactars (such as more emphasis on the review of operating experience), tnere are two additional tasks that are directly related to the systematic assess-ment of the safety of operating reactors. These are:
(1) Task II.C.1 - Interim Reliability Evaluation Program (IREP), the development of an orderly classification of accident sequences suitable for qualitative analyses and for use in the probabilistic analyses of core melt accidents of a few representative operating plants; and (2) Task II.C.2 - c;ntinuation of IREP on all remaining operating plants by means of the National Reliability Evaluation Program (NREP).
Subsection 110(b) identifies certain information that, as a minimum, must ce incluceo as part of the systematic safety evaluation plan.
Subsections 110(b)(1) and (2) require:
the identification of each current rule and regulation, compliance with which the Commission determines to be of particular significance to the protection of the public health and sr.fety; and the deternination of the extent to which each currently operating plant complies with these identified rules and regulations, including an indication of where such compliance was achieved by use of Division 1 Regulatory Guides and staff positions j
and where compliaace was achieved by equivalent means.
Subsections 110(b)(3), (4) ar.d (5) require: the identification of all of the 1
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! generic safety issues set forth in NUREG-0410. "NRC Program for the Resolution of Generic Issues Related to Nuclear Power Plants," for I
which technical solutions have been developed; the determination of
- which of these solutions should be incorporated into the Commission's rules and regulations; and a schedule for developing a technical solution for the remining generic safety issues.
The need to address generic safety issues in a disciplined manner led to the establishment several years ago by the NRC of the program described in NUREG-0410 and recently to the establishment of the Generic Issues Branch in the NRC's Office of Nuclear Reactor Regulation which has the responsibility for management of the technical resolution of Unresolved Safety Issues and for tracking the status of activities on other designated generic issues. The TMI Action Plan also addresses generic safety issues; e.g., T:sk IV.E.2 requires the early identifica-tion, assessment, and resolution of' safety issues.
Integrating the objectives and msults of the above programs with the plan to satisfy the requirements of Section 110 wil1 lead to a more efficient use of available resources and to a more comprehensive and unified ' product.
Subsection 110(c) requires the NRC to provide to Congress a report on the status of tne NRC's efforts to satisfy the requirements stated above, not later than 90 days from the date of enact.7.ent.
Status As indicated above, the NRC intends that the cler. for the systematic evaluation of all operating reactors efficientl.y utili:e those aspects of the current SEP and IREP programs that are demonstrated to be effective in assuring public health and safety. The plan will also include the NRC's detemination of the extent to which each plant complies with the regulations of particular signift:ance and the means of such congliance.
As presently constructed, the current SEP review of the oldest reactors generally is focused on 137 specific safety issues or problems. These were culled, based on experience and engineering judgment, frc : a larger list of 1100 issues to focus en those issues of greatest potential safety significance.
On the other hand, the IREP program is geared tcward a reliability assessment of a complete plant.
These reviews involve developing plant-specific event and fault trees to identify those systems, subsystems, and components that are the' greatest contributors to accident sequences posing risk to public health and safety.
Both the SEP and IREP programs look at the safety of the plants from different perspectives, but they are amenable to l
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. integration into a single, coordinated plan of review.
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l neither of the progre.w; are based on an explicit comparison with the NRC's safety regulations.
The NRC is developing an overall plan that attempts to integrate the current SEP. IREP, and Generic Issues programs with the specific l
requirements of Section 110.
This plan would treat currently operating plants, operating license applications, and construction pennit l
applications. As currently seen, the principal features of such a plan are described below.
1.
The Comission currently has under consideration how to develop the list of what is "of particular safety significance" to the l
protection of tne public health and safety, as required by Section 110(b)(1).
2.
The NRC staff will develop a revision of the Stccdard Review Plan l
(SRP) by April 1981. The revised Plan will consist of the existing SRP, modified to reference all applicable regulations and those Division I Regulatory Guides, staff positions, 'and other documents currently used by the staff to interpret the intent of these i
regulations, including requirements from the ZiI accident.
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3.
All. licensees for plants issued operating licenses prior to l
June 30,1980 / and those licensees issued operating licenses based on staff SER's or SER TMI supplements issued prior to January 1,1982 will be required to identify and justify deviatiens from revised SRP in accg/rdance with the Section 110 plan as approved by the Comission after issuance of an operating license.
l 4.
Ali applicants for OL's for which staff SER's or SER TMI supplements are issued after January 1,1982 will be required to identify and justify deviations from revised SRP pribr to issuance of an operating license.
5.
In areas where the plant deviates from the revised SRP, the licensee will be requested to provide a technical discussion as i
to the safety significance of such deviation, including a judgment as to w uther the alternative provides an equivalent method of meeting the regulation. The licensee should also request any l
needed exemptions.
(The licensees' responses may be staggered 5
based on some priority system related to public safety, if the NRC concludes such is necessary for the most efficient use of industry and NRC staff resources.)
jf Date on wnica P.L.96-295 (5.262) was signed by the President.
,2] Section 110 requires identification of the means of compliance with regulations of "particular significance to the protection of public health and safety." Hence, licensees for plants in this category will be required to justify deviations for only those sections of the revised SRP that implement these particularly significant regulations.
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6.
All applicants for CP's and ML's for which staff SER's or SER TMI supplements are issued before January 1,1982 wil}/ e b
required to identify, and justify deviations from existing 4
SkP and NUREG 0718.i (as modified after public coments) prior to issuance of a construction pennit or manufacturing license.
7.
All applicants for CP's and ML's for which staff SER's or SER TMI supplements are issued after January 1,1982 will be required to identify and justify deviations from revised SRP prior to issuance of a construction permit or manu-facturing license.
8.
In parallel with the above steps, the staff wil1 review and evaluate the generic issues identified in NUREG-0410; and generic issues identified in the TMI Action Plan, the ACRS Generic Issues i
List, and new issues identified from operating experience or the systematic evaluation program.
Plans and schedule will be developed for those issues determined to require resoluti;n within the next several years. A response will be prepared to meet the requirements of Subsections 110(b)(3), (4)~ and (5).
The basic elements of this approach will be published shortly foi public coment. Sased on these coments, the Ccmission will decide what approach to follow.
.3/ Standard Review Plan dated May 1980.
4/ Proposed Licensing Requirements for Pending Applications for Construction Permits and Manufacturing License dated August 1980.
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AdditioM Information t
acusevtFarmers Home Adadaistration. P'.ame*co*e**s se'w*"8 **"*" *" -8
- widely available andimproves D
understanding d me sdrevww ards er USDA.
process by interested membes of the acTuesp,w : " rule: additional NUCLEAR REGULATORY public and the nuclear power industry.
%d
-- Conanaseeng
'1he NRC's current techniques for the 5
sumanaav: At 41FR 51816. August 5.
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safety evaluation of nuclear power facilities as set forth in the SRP. are the 1980. tha Farmers Home Administration PlanTo Resquire Liconoces and result of years of experience. A great (FmHA) published a proposed rule Appscante to Document Deviations deal of progress has been made in the regarding biomass energy and alcohol From the Standard Review Plan methods of review and in the i
fuela The purpose of this document L to Nuclear Regulatory development of regulatory gudes and 4
Pnsvide additionalinformation A,.cesecv:
.other staH positions referenced in the I
rega ding this program.
roer runvnen peronenaTross contacTt Actioet Notice of proposed rulemaking.
SRP.
E As this experience acquiredover the Mr. Weldon Barton. Director. Office ofsuasenany:h Nuclear Regulatory years is incorporatedinto the regulatory
'f 2
R:newable Resources. FmHA.Rm. 5175 Comnussion Is considering requin::3 all procs ss. regulatory guides. including the South 31dg USDA.14th and nuclece power plant !!censees and all SRP. are periodically r? viewed and L. dependence Ave.SW, Washington, applicata for construction permits and rev'aed to reflect the current state-of-f D.C. 250, phone:2-447-7196-manula etarms licenses to IdanrNy and the-art. This results in a varymg scope l
tum.mserraay menosensaTiosa N justify deviations frca the acceptance of review over tima and isnds to land to Biomass Energy and Alcohol Feels Act criteria of the applicable revision of the ' lack of unifonn daa~=a'*H-of each cf t980 (TItie H of the Energy Security Standard Review Plan. NUREC-75/0a7.
P ant's conformanr= with cusrent stall
[
Act. Public Law 96-294) provides for the This program will provide the NRC with acceptance criteria. Some plants, for l
l solicitation of applications for Ma=ari=1 uniform d-tation of the extent to instance, have been reviewed against assis*ance under Subtitle A within 120 which each plant deviates from current the SRP at the OL stage butnot at the d:ys after enactment (l.a Octabar2e.
licensing acceptance criteria.Coi tr.ent CP stage. while stillothers.although 19e0). Farmers Home Admim=tretion is sought on the proposal ami on the reviewed against the SRP at both the CP h
{FmHAl.USDA.has published (45 FR preferred methodof implanu nting such and OL stage lack uniformity becausa g
51818. August 5.19ho) proposed regulation.s to estab!Ish guidelines for a y.y of updating of the SRP after the CP r
o solicitation of such apfwdaa= and is onta h comment penod expute on revizw was completed.This lack of reviewmg ra===ats received pursuant November 24.19eo, uniform documentation makes it dif5 cult Commentsshouldh to detennina se extant te Weh plants t2 such pubn+aa and related heacass. submittedin writing to the Secre 7 of reviewed some time ago deviate from n
FmHA expec*. ta publish Final l
Regulations and to initiate the the Comnuseum.U.S. Nuclear current acceptance enteria.and if so.
p li ~ solicitation of applications as part of M
d'"D' ay the safety signinc+nce of such
- )
k deviations..
i*
such FinalRegulations on or before ll As a result of the accident at Three j
Serv, ice M A!! canammentsved wi!! be available itt public Mile Island.many regulatery.
October :s.1980. AppIIants wishing to lg
. undertake pt=Ilmiwy pieparatory work g,.hn la the '%=
ia= Ion's PuhDe requirements have bec.tevised ud yl ~
!l on such applications may consul 1the
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new requirements have been l
Proposed Regulations but are advised
~
th t sorne chango will be made in these gaalungton, D.C.
gated. Accordingly, the staff has f 'i a.
to revise the SRPto reflect these when the Final Regulations are een puemn mPCmeaMN CMACM new requirements. This next revision of n
published on or about October 28.1980t Malcolm 1. Penst. Assistant C' rector for L
lI Applications will not be eccepted by-l t
n 1
b
?
ft-g t7100 Federal Resister / Vcl. 45. No.198 / Thursday. Octge
/
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~
the Standard Review Plan, scheduled for Specifically, the NRC is considering revision scheduled to be issued in Apnl l
I comp!etion in April 1981. will consist of imposing the following requirements:
1981.
a The Commission published a Federal the Maf 198n version of the SRP.
- 1. All nuclear power plants issued
- Register Notice on October 2.1980 (45 modified to reference all applic3ble operating licenses on or before June 30, safety and safeguards regulations and gge0,swould be required to identify and FR 55247) inviting comment on those Division Regulatory Guides, staff justify all deviations from the' Requirements 4 and 5 of the currect positions, and o.her documents acceptance criteria of the SRP revision plan. The present notice reiterates those currently used by the staff to interpret scheduled to be issued in Apn} 1981 that. requirements and integrates them with the intent of these regulations, including relate to those regulations which the the requiremerts for operating plants.
requirements resulting from the TM1 Cmmission determines to be of and applicants for operating licenses.
L accident-particular significance to the protection The Commission will consider public Requiring license appI!cani.: to of the public health and safety.
comments received in response to this identify snd justify deviations fram the
- 2. All appilcants wh, are issued a notice in determming the appropriate
~~
acceptance criteria in the appucable nuclear pc ver plant operating Iicense action to be taken. including the r;
revision of the SRP would enhance the -
anerJune 30.1980, and for which the possible issuance of Snal ndes on some quality of the staffs review of NRC staffs Safety Evaluatien Report or d of these matters.
)
applicatiora and assist the staff m.
will be issued on or before January 1.
P2 rsuant to '.he Atomic Energy Ar.t of making the determinations required by 19828would be required to identify and 1954. as amended, the Energy 10 CFR Part 50. In addit:on. such justify. after issuance of an OL all Reorganization Act of1974. as amended.
documentation would more c4early deviauons from the acceptance criteria and Section 553 of Title 5 of the United 7
atentify the bases for the acceptability of ths SRP revision scheduled to be States Code notice is hereby given that t
of plant designs and their relationship to issued in April 1981 that relats to those amendment of the Commission's l
current Lcensing criteria. A similar post-regulatiens the Commission determines regulations in 10 CFR P:rt 50 wP t
y licensing requirement for currently g g gg g,; 3 gg - regard to some or all of the subvects and operating plants would improve the protection of the public health and issues desenbed in this notice is staffs ability to evaluate the extent and safety.
contemplated.
safety significtr;e of deviatio 13 from i
current stafI acceptance critu t:s for
- 3. All applicants for a nue.lest power Cated at Washington. D.C. this'2d day of i
d
' these Punts, plant operating license for which the Octotwrisac.
i In a related matter. the NRC in NRC staffs Safety Evaluation Report is For the Nuclear Regulatory Commission.
I required by Section 110 cf Public !.aw issued afterJanuary 1.19a2. would be samuel J. chak.
5 96-2G (NRC FY 80 Authorization Bill) to required to 1,.fentify and jusnfy. prior to s,cretsryof the Coma issiota.
)
develop a plan for the systematic safety issuance of the operatir.g licem all tra om ames rn.4 twa mis t i
f review of all operating nuclear power deviations from all acceptance criteria
.m coes n w.e of the SRP revisMn scheduled to be plants.This plan must include among J
other things: the identiScation of each issued in April 1381.
a
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current rule and regulation. compliance
. 4. All applicants for a nuclear power CEPARTMENT OF TRANSPCRTATION wi:h which the NRC determines to be of plant constructica permit or e
i particular significance to the protection r:anufacturinglicen e for which the Federal Aviation Administration
?
ef Se public health and safety: and be NRC staffs Safetf I aluation Report determination of the extent to which TMl Supplement is iswad before 14 CFR Ch.1 V
each currently operating plant complies January 1.1982. would be required to f
with those regulations, inch: ding an identify and frstify. prior to issuance of IDocket No. 20487; Petttion No*fte No. PR y
indication of whether such compliance the constructico permit or 80-151 i
was achieved by use of Division 1 manufactunng license. all deviations from all acceptance criteria of the May Petition for Rule Making of Rosenbalm -
i
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Regulatory Guides and staff positions and where such compliance was 1980 version of the SRP and from the Aviation,Inc.
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I achieved by equivalent means.
" Proposed 1.! censing Requirements for Acs#cy: Federal Aviation In order to carry out the requirements Pending App!! cations for Construction Arfministration(FAA).D IT.
'f of Pub. L 96-295, to document-Termits end Manufacturing !.icenses." in 1
deviations from the SRP and to improve NUREGC18 (as modified after public f ticn A o p
I s the staffs ability to eyeluate the safety comment).
J
. signiScance of such deviations. the NRC
- 5. All applicants ice a nuclear power suumany: By letter dated March 31.
l is considering requiring ali nucleu plant construction permit or 1963. Mr. Arthur J. Schmidt. Vice power plant licensee 7 and license manufacturing license for which the President. Rosent.sim Avistion. !nc.,
I applicants to identify and provide the NRC staffs Safety Evaluation Report is petitioned the Feceral Av stion safety bases for deviations from issued after January 1.1982. would be Administrat.ungAA) to amead 1
applicable revisions of the SRP.Several required to identify and justify. prior to li 25.832 and 121.220 of the Federal
}
method 4 ufimplementing this issuance of the construction permit or Aviation Regulations (FAR) to exempt requirement are under consideration.
manufacturing license, all deviations large. cargo.only aircraft : rom installing These methods are issuance of a from all acceptance criteria of the SRP ozone control equipment or using ozone Regulatory Guide. speafication of s avoidance procedures.
l ;
construction permit or operating license
'Th date on wioch Puts t. so-2ss beca*'
oAtas: Comments must be :eceived on ThEmeta ree the lanomy s.tsee date. ie io I
- I'**"
pt adequets et,se anw i e.ance of the re-d.
or before December 10.1SJa.
i Anonass: Send comments on the SRP tur a licenate to decrnent and just(
petitionin duplicate to: Federal Aviation
- -.7%,,,, sed SRP IAeret testI has be== demened decadene end for the NRC staf! to ancorporate Administration. Office of the CM. ef and (efined to be equivalent to Omsson 1 eveinererte of the more safety sigmftcant deviettons Resuletary Cwdes and staff poamons.
into the sta# Sofety Evolust.we Reports.
Counsel. Attn: Rules Docket (ACC-204t 1
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ENCLOSURE 3 I
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e l [.J [ poc %Io, UNITED sTATSs O
imCLEAR REGULATORY COM'MISSid.
ENCLOSURE 3 y h, s..
g ADVISORY COMMITTEE.ON REACTOR SAFEGUARDS r
(M~.
t
., E WASHINGTON, D. C. 2Ct 5 5 8
yxs,$,
t October 14, 1980
?'CRANDUM FOR: William J. Dircks, Executive Dir fo Operations FRCH:
Raymond F. Fral frector, ACR SU3 JECT:
COIMNTS 0:1 THE NRC STAFF'S PRELIMINARY PLNiS FOR ADDRESSING THE REQUIREMENTS IN SECTION 110 0F THE FY-80 NRC AUTHORIZA-TION BILL 9-11, 1980, the ACRS discussed with the NRC During its.146th meeting, October Staff their preliminary plans for addressing the requirements of Section 110 of the NRC FY-80 Authorization Bill.
The Staff also discussed this subject with the Reactor Operations Subcommittee on October 7, 1980 and requested ACRS comments.
The Committee had the benefit of written comments oy the Atomic Industrial Forum.
It is tne Committee's view that the lists cerived from Criteria II and III as currently presented by the NRC Staff do not include all the items of particu-lar significance to safety.
For example, General Design Criterion 29 is not included.
Additional screening should be done to ensure that all items of particular significance are included. The Committee also recommends that some other groups within the NRC Staff, such as PAS and AE00, carry out an inde-pendent review in order to increase the likelihood that the screening process This review could also be nas not omitted items of particular significance.
used to establish a priority, based on risk reduction potential, in which the revies items sneuld be addressed.
The C:mmittee noted your. ec.iment on SECY-80 dla and endorses your intent to impl ement tight management controls to limit st&ff and industry effort to areas of potential safety payoff; guarding against tne potential for a large drain on Staff and licensee resources that would not produce commensurate improvements in safety.
The Committee would appreciate being kept informed Of additional developments in this area, particularly on the nature of com-
. ants received as a result of the call for puolic comments scheduled to begin following issuance by the Staff of the final draft plan for addressing Section 110.
c::
aCRS Members H. Centon, !;?.R F. Schroeder, DST j
.;. Ernst, DST
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G. Isch, *;RR g&g l
S. Ohilk, SECY c' \\
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O ENCLOSURE 4 4
4