ML20023B341
| ML20023B341 | |
| Person / Time | |
|---|---|
| Issue date: | 03/09/1983 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Fraley R Advisory Committee on Reactor Safeguards |
| References | |
| FRN-48FR12619, RULE-PR-MISC NUDOCS 8303180682 | |
| Download: ML20023B341 (7) | |
Text
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MEMORANDUM FOR:
Raymond F. Fraley Executive Director, ACRS
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FROM:
William J. Dircks Executive Director for Operations
SUBJECT:
REGIONALIZATION OF HRC STAFF ACTIVITIES This-merorandum is in reply to Mr. Ray's letter to me dated February 15, 1983, concerning the impact that decentralization may have on the safety of nuclear facilities. Answers to the specific questions in Mr. Ray's letter are provided in the enclosure.
William J. Dircks Executive Director for Operations
Enclosure:
As Stated cc:
Chaiman Palladino Commissioner Gilinsky Comissioner Ahearne Cocmissione" Roberts Comissioner Asselstine OPE SECY
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RESPONSE TO ACRS QUESTIONS OUESTION 1:
Basis for regionalization.
The Members were unable to elicit a convincing safety-related rationale regarding the basis for the proposed expansion of regional activities and would like an opportunity to discuss this matter further to develop a better understanding of the basis for this proposed change.
ANSWER.
The proposed expansion of regional activities is one aspect of the Commission's October 1981 decision on reorganization within the NRC staff.
The basis for this decision was an expectation by the Commission that
-management of NRC regulatory programs would be improved by the combination of f actions that were directed by the Comission.
The Comission's decision was intended to:
improve its coordination of licensing, inspection and enforcement activities at each facility bring NRC nearer to.iState and local Governments and the public by formalizing the role of regional offices to represent NRC in their regions strengthen incident response capability by delegating certain responsibilities and authorities to the regions upgrade the position of the NRC Regional Director Thus, the primary purpose of further decentralization is to improve the effectiveness and efficiency of the NRC staff in providing better service to the public and the regulated industry.
While a safety-related rationale was not a separate decision criterion, we expect that expansion of regional activities will have the overall effects described above and will thereby have a positive impact on the safety of licensed plants.
~_0'JESTION 2:
How are these changes expected to impact on reactor safety?
The decentralization of a competent body of technical talent may have a negative effect.
ANSWER.
We believe that decentralization activities will strengthen the safety capability of the Regional Offices while maintaining the essential technical competence of the Headquarters Offices.
The regions will bring a relatively small number of headquarters staff with broad safety perspectives into daily contact with regional staff who have much better detailed knowledge of the
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plants 'and their operation.
This is expected to enhance the regions' ability to respond to plant operating events, emergencies, and licensee regulatory netos.
In the current plans for decentralization, it is not expected that the transfer of technical talent will reduce any headquarters organization to a level below that which is necessary to perform its assigned functions.
The NRC does not plan to transfer entire organizational units of technical talent associated with operating reactors from NRR to the regions.
The NRC staff expects that some people within the technical review disciplines in NRR would opt for regional assignments provided that their skills and expertise match regional needs.
NRR would maintain adequate capabilities in the areas of expertise needed to perform its functions.
The issue is one of distributing technical talent in a way that enables NRC to manage its resources and to provide effective and e.ificient. service to licensees and.the public.,
Several more specific questions and answers are presented below:
OUESTION 3:
How will technical competence of the NRC headquarters staff be maintai.ned once technical decision making is dispersed to regional 6ffices?
ANSWER.
adopted an approach of dispersing all technical The NRC staff ha no decision making to Regional Offices.
The attached " Delegation and Assignment to Region IV of Certain Licensing Functions for the Fort St. Vrain Nuclear Generating Station" described the portions of technical decision making that Region IV has received and that NRR has retained.
The delegation is a model that will be followed in future transfers.
Maintaining adequate technical competence to make technical decisions in NRC headquarters con-tinues to be a fundamental management responsibility of the respective office directors.
OUESTION 4:
When new, unt.nticipated technical issues arise, will the headquarters staff or regional offices handie them initially?'
How will direction be provided to prevent overlapping and possibly conflicting activities?
ANSWER.
When new, unanticipated technical issues arise, the nature of the issue will determine how it will be handled.
Two examples of significant issues that caused immediate but not duplicative action in both headquarters and regions were the scram discharge volume problem at boiling water reactors (June 1980) and failure of reactor trip breakers to trip at a pressurized water reactor (February 1983).
Response to these events demonstrated that both
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P headquarters and regions are capable ~of and do exercise proper technical judgment in identifying and referring significant issues to the appropriate The level of communication between regions and -
organization in NRC.
headquarters (e.g., dissemihation of prompt notifications, daily. calls on events, written preliminary notifications, and task interface agreements) is.
adequate to prevent significant overlapping and possible conflicting
. activities from occurring.
OUEST10N 5:
How will existing channels of communication be altered with respect to flow of information to and from the regional offices?
For example, how will the interpretation of safety research results and other technological developments be promulgated to the-regional offices in support of their
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technica4 decision making?
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ANSWER.
Existing channels of communication between Regional and Headquarters Offices have already been strengthened in recent months in terms of content and frequency to support increased interaction, and we expect this trend will continue as decentralizafion continues. Safety research results and other technological developments wil1 be interpreted in headquarters in their application to existing unresolved safety issues or identification of new safety issues.
H,eadquarters offices are now and will remain responsible for technical resolution of unresolved safety issues and similar multiplant issues.
To the extent that safety research results and technological developments apply to plant-specific issues, these results and headquarters interpretations as to how they apply to a specific plant will be promulgated to the regions via reports and other written communication, telephone con-ferences and meetings as necessary.
l OUESTION 6:
How will an appropriate degree of consistency be maintained among the different field offices to avoid differences in interpretation of HRC regulations and differences in policy / judgment / attitude among regional directors? What are the standards of consistency to be used in judging how well regional offices function? What mechanisms will exist for licensees to appeal substantive inconsistencies, if they do occur, without concern regarding punitive action?
i ANSWER.
Consistency is an issue the agency has been dealing with since the initial decentralization of the inspection and enforcement functions.
This initiative does not introduce new problems over those that have had to be faced previously.
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f" Cc cunication of many forms will be used among regions and headquarters to ensure that consistency of interpretation is maintained.
Examples include periodic meetings of counterparts at management and working levels, discussion of issues that riise questions of interpretation and monitoring and oversight of regional implementation by headquarters offices.
The regional offices are not in a position to make policy, but rather to implement the program policies of headquarters offices.
The standards of consistency are developed by headquarters offices and applied during evaluation of the regions as part of program oversight activities. The safety implications of regional decisions are believed to be an essential part of.these standards.
Licensees may communicate to appro-l priate levels of NRC management any situations in which they believe that l
substantive, inconsistency exists or has occurred.
. Enforcement actions, if warranted in response to violatio'ns of NRC
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' regulations, will be administered according to approved NRC enforcement policy and the NRC rules of practice.
QUESTION 7:
What quali,ty assurance mechanism will be in place to monitor and contr61 the performance of the regional offices?
How will overly rigid or overly permissive performance by individual 3
offices be recognized and addressed?
ANSWER.
The Executive Director for Operations holds each headquarters program office director responsible for the success of assigned programs irrespective of whether these programs are implemented in headquarters or the regions.
program oversight and monitoring by headquarters offices is the quality assurance mechanism.
1 OUESTION 8~:
What will be the dividing line for those technical decisions to be made by the regicnal offices and those to be made by the headquarters staff? Will these be based on safety significance, generic versus plant specific considerations, I
scheduling, or other factors?
ANSWER.
As a specific example, the dividing line between decisions made in head-quarters and those made in the field are delineated in the attached dele-gation and assignment that has been executed for Fort St. Vrain.
A similar delegation and assignment will be executed for each function that is transferred to the regions.
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OUESTION 9:
What distribution of technical talent will be needed in NRC headquarters and the regional offices to deal with the wide variety of technical issues which are already know to exist and those which may develop in the future? What is the basis for this allocation of resources?
Recognizing that this shift is partly to accommodate an increased emphasis on support of plant operations versus licensing actions, what action will be taken to reorient and/or redirect the activities of head-quarters and regional personnel in this direction?
ANSWER.
The distribution of technical talent will be dependent on (1) the needs of the regions to perform inspection, licensing and response functions that will be transferr.ed to the regions and (2) the needs of headquarters to deal with
-technical issues that currently-exist and may develop in the future.. In the
- next few years, we expect a general strengthening of engineering skills and operating reactor project management skills in the Regional Offices.
The distribution of technical talent in Headquarters Offices will remain about the same during this period.
In the longer term, the regions will continue their strengthening of engineering and project management talent as well as an increase in inspectors for the new plants coming on line.
The shift in emphasis from operating.Ticense casework to operating reactor licensing activities will undoubtedly lead to some realignment of headquarters skills (for example, a reduced need for environmental review skills).
However, the Headquarters Offi.ces.will maintain the essential safety skills of the staff.
OUEST10N 10:
In view of the observations of the NAS/NRC Cornittee on FAA Airworthiness Certification Procedures (Reference 1) that the regional structure of the FAA has centributed to a lesser technical competence in the FAA, and their recornendation-regarding the need for a strong centralized technical staff to accomplish various FAA regulatory functions, what are the differences between FAA and NRC regulatory responsibilities, functions or procedures that make decentralization of technical functions appropriate for NRC.
ANSWER.
The NRC plans to maintain a strong centralized technical staff to perform all the safety, environmental and antitrust reviews of applications for Construction Permits (CP), Operating Licenses (0L), Standard Plants design approval and topical report approval.
The NRC headquarters offices will also perform the activities associated with the resolution of Unresolved Safety Issues (USIs) and other generic issues, generic studies, the performance of risk and reliability assessments, and the systematic assessments of reactor operating experience.
The development and approval of new regulatory re-i quirements and modification of existing requirements resulting from the safety improvement efforts will continue to be the responsibility of the
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headquarters offices.
Relative to licensing actions associated with oper-ating reactors, NRC headquarters will review and implement all actions during the first year after a reactor receives a full power operating license.
In addition, headquarters offices will be responsible for implementing the Systematic Evaluation Program (SEP) for operating reactors and will be responsible for implementing certain generic licensing actions (e.g., re--
quirements associated with pressurized thermal shock and steam generator tube integrity) on all reactors to which they apply.
The major difference in regulatory responsibilities of FAA and NRC deal with the facilities to which they are applied.
NRC licenses single custom-built reactor facilities whereas FAA certifies facilities (aircraft) in a pro-duction environment where many duplicate units are built.
The FAA study also points out that the appeal has diminished from that which FAA jet propulsion
-projects on'ce held for rechnical experts on the frontier.crf technology.
This
- has had an impact on the ability of FAA to attract experts to the extent that technical competence at FAA has decreased.
It is not suggested that FAA technical competence is now inadequate for a mature industry, but that the nature of FAA regulation has changed.
QUESTION 11:
What pland have or will be made for a satisfactory interface of the ACRS with the regional offices to be sure that the Committee can fulfill its statutory responsibilities?
ANSWER.
Regional personnel including Administrators have appeared before the ACRS in the past in situations where regional personnel had been most knowledgeable of plant operations or events, for instance, and could provide the best information to the ACRS.- This practice will continue and will be expanded by virtue of regional personnel being most knowledgeable of those activities that are conducted in the regions.
As noted above, significant unresolved safety issues, generic issues, multiplant actions and significant hazards considerations remain the purview of headquarters offices, which would interact with ACRS according to established practice.
Interests of the ACRS that are within the cognizance of the regions will cause the appropriate level of interaction with the regions.
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OEc 3 133?.
w MEMORAhDUMFOR: John T. Collins Regional Adininistrator c
Region IV '-[
FROM:.
William J. Dircks Executive Director for Operations Harold R. Denton, Director
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Office of Nucl. ear Reactor Regulation
SUBJECT:
DELEGATION AND ASSIGNMENT TO REGION IV 0F CERTAIN LICENSING FUNCTIONS FOR THE FORT ST. VRMN NUCLEAR GENERATING STATION
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hersuant to NRC Manual Ch. apter 0128, " Organization and Functions - Regional Offices", the Region IV Region.al, Administrator is hereby assigned and authorized to perfom certain licensing functions described herein related to the Fort St. Vr.ain Nuclear Generating Station (FSV) of Public Service Company of Col'orado,(License No. DPP,-34, Docket No. 50-267).
As a result of this delegation and as.signment, certain.1icensing functions previously perfomed by the Office of Nuclear Reactor Regulation (NRR) will now be perfomed by Region IV.. Other licensing fu'nctions,.as described herein,
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. ill re:nain the responsibil.ity of NP,R.
w pursuant to the Energy P.$ organization Act of 1974, the Director NRR is respon-
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sibic for the principal licensing and regulation involving facili. ties and materials associated with the construction and operation of nuclear reactors licensed un' der the Atomic Energy Act of 1954, as amended.
Tnerefore, NRR will re.ain. responsible for detemining overall licensing and regulatory policy To enable NRP, to execute pertaining to all licensed reactors, including FSV.
this responsibil.ity prcperly, NRR will maintain oversicht of all licensing functions related to FSV, int 10 ding those that are delegated pursuant to this Tnis oversight will be implemented by HRR'. staff review of corre-as si enment.
spondence to and frcca the l'icensee, by periodic implementation assessments 'of Region IV licensing activities, and by coordination and consultation between ine Director of HRR Region IV and NRP, regarding selected licensing actions.
retains the authority to take actions detemined necessary in all matters hereby assigned and delegated to Region IV.
Pursuant to this delegation and assignment, Region IV is responsible for Tne implementing established NRC licensing and regulatory policy at FSV.
Licensing and regulatory specific assignments to Region IV are set' out below.
matters which hav.e not been specifically delegateii.an,d assigned to Region IV y@
remain IVe responsio111T.y of' ERR.
- .9 Should NRR and Region IV dis' agree on whether a FSV licensing action is
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being suitably handled by, Region IV in accordance with overall licensing and regulatory policy, the matter will be resolved between th'e Director of Licensing, NPR, and -the Director, Diyision of Resident Reactor Projects..'
and Engineering Programs, Region IV.-
Should attempts at resolution be unsuc'cessful at that level, the matter will be referred to the Director
'l of HRR who will consult with the Regional Administrator of Region IV and other appropriate officials before reaching a decision.
Soecific Dele".tions and Assignments to Region IV
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Review, process and take final. action on all licensing actions -
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related to FSV except those relat'ed to generic issues and those' inyelvi.ng-exemptiontto the..Cor.i ssion's resul ations.
Before acting ".
(( on appTications that seek to amend License D?P,-34 its' elf, conc,ern anti-trust or safeguards matters, affect established licensing and regulatory policy, or involve potential significant hazards cen' sider '-
ations, Region IV wilr consult with HRR.
Before denying an application to amend the FSV license or Technical Specifications and before maki.ng -~
a detennination that.an application involves significant hazards con'siderations, Regioff IV will~ consult with N?.R.
(Significant hazards considerations and established regulatory, policy are discussed in the guidance sdction of this Memorandum.)
Tne degree of censultation With
, NRR will vary l.cdepending on.the cceplexity of the i'ssue involved, and may involve the. furnishing of draft evaluations to NRR.
Region IV will subsequently act upon'such matters after ccmpleting consultations with NRR.
'2n Review, process, and respond to all requests for action pursuant to 10 CFR 2.205 and, as necessary, issue orders to suspend, modify, or revoke License No. DPR-34.
Before ac. ting on 10 CFR 2.206 requests or issuing orders related to FSV, Region IV will consult with HRR.
Region IV will subsequently act, upon such matters after completing consultations with NRR.
Rsiew, evaluate, and make safety findings on issues, problems, and 3.
Tnese incidents that relate to the cperation or modification of FSV.
matters may ' require consultation with HRR if they could reasonably be expected to involve amendments to license D?R-34 itself, anti-trust or safeguards matters, affect established licensing or regulatory policy, or involve significant hazards considerations.
Coordinate with the Division of Licensing, NRR, for those~ matters relating to assigned licensing actions that involve Consultation with 4.
NP.R or that require technical assistance from other HRR Divisions or Examples of areas.where technical assistance may be needed NRC Offices.
include emergency preparedness and safeguards licensing actions, and multi-disciplined reviews of proposed licensing actions involving health and safety considerations.
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Coordinate with License;-Ke Management Branch; ADM, regarding fees related to assigned licensing actions.
6.
Coordinate with Freedcm-of Infomation and Privacy Branch, ADM, :
regarding F0,IA requests ! relating to FSV.
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- 7.. Coordinate with the FSV local public doctnent room regarding activities and documents relating to FSV.
8.
Coordinate with the Docketing and Service Branch, SECY, regarding Federal Register Notices related to assigned licensing functions.
9.
Prepare and circulate environmental impact statements,'nppraisals,.
and negative declarations regarding assigned licensing actions.
.30.- Review -and evaluata submitGl's and reports made by the licensee,-
pursvant to FSV license condi-tions, Technical Specifications,
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- 11. Review periodic updates to the FSAS..
~32. Review, evaluate, an& process Multi-Plant Action items relating to FSV as assigned by' NRR.*,
- 13. Arrange with c.ontr. actors for' technical support in the conduct of assigned li' censing. matters.
Tnese arrangements shall be consistent with.budgst authority.
- 14. Complete specific action items pertaining to FSV, assigned to Region IV, and listed in the Transfer Memorandum executed By the Director, DivisiBh of Licensing, NRPJ, and directed to the Director, Division of Resident Reactor ' Projects and Engineering Programs, Region' IV, effecting the transfer of specific FSV-related-responsibilities frcha NRR to Region IV.
Tnis Transfer
. Memorandum will provide a complete and current status report on all FSV licensing action items transferred to Regica IV and will delineate clearly the. current licensing action items to be retained by HRR.
- 15. Coordinate site visits b.nd meetings with the licensee, including issuance of meeting notifications and meeting minutes, for matters
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relating to FSV.
- 16. Develop recommended Board notifications for matters relating to FSV and transmit them to the Director, Division of Licensing, NRR, fo'r e
further pr,ocessing.
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- 17. Review changes made by tfdflicensee pursuant to 10 CFP. 50.59 to detemine whether they may constitute an unreviewed safety question or a change in the Technical Specifications.
If,the change.is evaluated by Region IV as one involving a po.tential unreviewed safety question or a change in Technical Specifications, Region IV shall,'after consultation 'with NRR, inform the. licensee that the change cannot be implemented without NRC approval and that application pursuant to 10 CFR 50.g0 is required;
- 18. Review changes made by the licensee pursuant to 10 CFR 50.54(p) to determine whether they decrease the safeguards effectiveness of the security, guard training and qualification, or safeguards contingency pl ans.
Tnis review should consider the safety impact of the security J
or safeguards change.
If the change is evaluated by Region IV as one involving a decrease in the safeguards effectiveness of the plan or a significant safety.,',apact,.Begion IV shall, after consultation w.ith HRR, '
inform-t'he licensee--that the change cannot be implennted without NRC.
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approval and that application pursuant to 10 CFR 50.90 is required.
- 19. Prepare and coordinate, consistent with current delegation auth'ority, responses to correspondence received by the NRC related to FSV, such as responses to Congg.essional inquiries, state and local correspondence, or inquiries by membe'rs of the public.
- 20. For licensing matters whic51 remain the responsibility of liRR and where Region IV technical expertise is required, Regi.on IV will prepare' draft SER and licensing actica inpuu.
- 21. Co. ordinate activities in suppoi-t of hearings related to FSV, including technical arrangements, staff participation, and legal assistance from OELD an'd/or the Region IV Regional Counsel,
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as appropriate.
- 22. Maintain the integrated schedule of NRC regulatory activities related to FSV and submit to NR?, the monthly input to the Operating Reactors Licensing Actions Summary (ORLAS) - NUREC-0748.
' 3. Cobrdinate the licensing input to the Systematic Assessment of Licensee 2
Perfomance (SALP) activities relating to FSV.
- 24. Maintain the official NRC Docket file for FSV.
- 25. Submit Daily and 'deekly Highlights input and Eevill Report input to NRR for matters relating to FSV.
- 26. Coordinate proprietary data reviews for matters related to the assigned licensing functions.
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- 27. Coordinate the licensingsnp'ut to Part 21 reports and Abnormal Occurrence reports for matters related to FSV.
- 28. Coordinate l liUPEG'-0020.. Licensed Operating Reactors (Grey Book) input for FSV.
- 29. Provide liRR with copies of all incoming and outgoing correspondence related to FSV, including corre'spondence related to all licensing actions.
- 30. Provide weekly input to the liPR Regulatory Activities Manpower System (RAMS) for staff utilization in support of FSV licensing activities.
Specific Authorities and Resoonsibilities Retained by liRR 13 Review, process and take ' action on applications for exemptions to the Commission's regulations.
liRR will consult with Region IV before -
' taking action on FSV exemption requests a'nd provide Region IV with copies of its actions on such requests.
. 2.
Review, process; and.take action on all generic licensing issues -
rel.ated to FSV.
Any action that may affect more than one reactor is considered to be generic'.
If liRR action on generic. issues is "
expected to im' pact. on.the Region IV activities regarding FSV, liRR.
liRR will will consult frith' Region IV prior to taking.such action.
issue generic letters to FSV and other licensees and provide copies
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to Region IV.
For generic actions resulting in an amendment to the FSV license or Technica) Specifications, Region:IV will prepare the amendment package based on technical itiput provided by liRR.
Region IV will issue the amendment package after completing consultations,with lip,R.
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Maintain oversight of Region IV licensing activities to assure 3.
that liRC licensing policy and programs are suitably implemented with respect to FSV.
Acalicable Guidance Criteria for a "no sigtiificant hazards" determination and a related 1.
rule change are under development.
General guidance (derived from the most recent draft of the proposed rule change) for making deter-minations regarding significant hazards considerations is provided as Enclosure i to this Memorandum.
!!RR may modify the guidance used in making significant hazards considerations by written memoranda to Region IV shall consult with liRR~if there is potential that
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an action contemplated by Region IV pursuant to this assignment may involve significant hazards.
Most license amendments involve no s.ioni.ficant hW.rds consideration and therefore are routige in nature.
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In performing technical, eta 1uations on matters relating to FSV, liRR
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and Region.IV may consuT.t'with and request technical assistance from each other in resolving specific tecfinical issues.
All Region IV zational entities shall.be directed to the Director,, Headquarters organi-requests for technical assistance from liRR or other Division of Licensing. _As pascribed by established pro:edures, t'he Division of Licensing will coordinate technical assistance with other organizational entities in liRC.
All liRR requests for technical assistance from Region IV will be directed to the Director, Division of Resident Reactor Project and Engineering Programs.
4.
In the event that the licensee disagrees with a decision made by Region IV regarding the assigned lice'nsing functions for FSV, resolution should be sought with the Regional' Administrator of Region IV.
If resolution still cannot be achieved, the licensee shall be informed in writing by Region IV, with a *cc@y to liRR, that it may seek resolution of the matter
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5.
liRR shall provide the support necessary to enable, Region IV to assena the responsibilities described herein.
This includes assisting in the training of Region IV personnel prior to and during the first three months following'the assumption by Region IV of its new responsibilities.
6.
Within six months of the transfer t'o Region IV of FSV-related
. licensing autho.rity, liRR will formally review and evaluate Region IV implementat. ion of the assigned licensing functions to assure consistency ~with liRC licensing policy.
WND Yliin:a J.Dirtb UEC 3 1331 Date William J. Dircks Executive Director for Operations fs 1 ~c - -
Date N/Je//Z Harold Denton, D.irector
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Office of liuclear Reactor
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EliCLOSURE 1 -
g r-SIGlilFICAliT HAZARDS DETERMIliATI0li GUIDAllCE
. EXAMPLES OF A'iEliDMENTS THAT ARE CONSIDERED LIKELY TO IliVOLVE SIGli1FICAliT HAIARDS CONSIDERATIONS ARE LISTED BELOW:
1.
A'significant relaxation of the criteria used to establish safety limits.
2.
A significant relaxation of limiting safety system settings or
. limiting conditions for operation.
3.
A significant relantion irt limiting conditions for -operation not accmpanied by cmpensatory changes,' conditions, or actions' that maintain a commensurate level of safety.
4.
Renewal of an operating license.
5.
For a nuclear power plant, an increase in authorized maximum core power level.
6.
A change' to Techni. cal Specifications involving a significant unreviewed safety question.
A change in plant cheration designed t6 improve safety but 7.
l which, in fact, allows p1 ant operation with safety margins of some significance reduced frm those. believed to have been
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present when the license was issued.
8.
Reracking of a spent fuel storage pool.
EXAMPLES O'? AMENDMENTS THAT ARE CONSIDERED liOT LIKELY TO INVOLVE SIGlilFICA!ii HAIARDS CONSIDERATION ARE LISTED BELOW:
for A purely administrative change to Technical Specifications:
1.
example, a change to achieve consistency.throughout the Technical Specifications, correction of an error, or a change in nemenclature. -
A change that constitutes an additional limitation, restriction, 2.
or control not presently included in the Technical Specifications:
for example, a more stringent surveillance requirement.
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For a nuclear power rea'clor, a change resulti6g from a nuclear reactor core reloading, if no fuel assemblies s.ignificantly different from those found previously acceptable to the NRC l
for a previous core at the facility in question are involved.
This assumes that no significant changes are made to the l
acceptance criter.ia for the Technical Specifications, that the analytical methods used to demonstrate conformance with the Technical Specifications and regulations are not significantly l
changed, and that NRC has previously found such methods acceptable, 4.
A relief granted upon demonstration of acceptable operation from '
an operating restriction that was imposed because acceptable op2 ration was not yet denonstrated.
This assumes that the operating restriction and the criteria to be applied to a request.for relie.f _have been. established in a prior review and that satisfaction of tYe criteria are essentia11'y self-
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evident.
5.
Upon satisfactory completion of construction in connection with an operating facility, a relief granted fran an operating res.triction that was, imposed because the construction was not yet completed satisfrectorily.
Inis is intended to involve only restrictions wh'ere it. is essentially self-evident whether construction has bean completed satisfactor.ily.
6.
A change which ei$her increases the probability or con' sequences of a previously-analyzed accident or reduces a safety margin but for which the results of the change are clearly within regulatory acceptance criteria:
for example, a change resulting from the application of a small refinement of a -
previously used calculational model or design methcd.
7.
A change to make a license conform to changes in the reguia-tions, where the license change results in very minor changes to f acility operations clearly in keeping with the regulations.
8.
A change to.a license to reflect a minor adjustment in owner-ship shares among co-owners already shown in the license.
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