ML20034D484
| ML20034D484 | |
| Person / Time | |
|---|---|
| Issue date: | 10/27/1992 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| SECY-92-365, NUDOCS 9210290372 | |
| Download: ML20034D484 (7) | |
Text
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POLICY ISSUE October 27, 1992 (NEGATIVE CONSENT)
SECY-92-365 For:
The Commissioners From:
James M. Taylor Executive Director for Operations i
Subiect:
GENERIC LETTER ON THE AVAILABILITY AND ADEQUACY OF DESIGN BASES INFORMATION
Purpose:
To request the Commission to review draft Generic Letter 92-XX, " Availability and Adequacy of Design Bases Information" as stated in staff requirements memorandum (SRM 92-193) dated June 24, 1992 on Design Bases Reconstitution and to apprise the Commission that public comments on the generic letter will be solicited prior to issuance.
Discussion:
The Commission recently issued a policy statement' describing its exper.tations and the Agency's future actions to verify the availability and adequacy of design information.
In the policy statement, the Commission concluded that maintaining current and accessible design documentation is important to ensure that (1) plant physical and functional characteristics are maintained and are consistent with the design bases as required by U.S. Nuclear Regulatory Commission (NRC) regulations; (2) systems, structures, and components can perform their intended functions; and (3) the plant is operated in a manner consistent with the design bases.
The policy statement stated that the staff would issue a generic letter to request power reactor licensees (1) to describe the programs that are implemented or planned to ensure design information is correct, accessible, and maintained; and (2) to submit the schedule for implementing
Contact:
Eugene V. Imbro NOTE:
TO BE MADE PUBLICLY AVAILALBE 504-2967 WHEN THE FINAL SRM IS MADE AVAILABLE
'" Availability and Adequacy of Design Bases Information at Nuclear Power Plants," Federal Reaister, Volume 57, Number 154, pige 35455, August 10, 1992.
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O The Commissioners or completing reconstitution programs that they are conducting.
The policy statement also stated that the generic letter would request that licensees that are not implementing a design reconstitution program submit their rationale for not doing so.
On September 22, 1992, the generic letter was reviewed by the Committee to Review Generic Requirements (CRGR).
Responding to recommendations made during the CRGR meeting, the staff included in the generic letter a statement that a response to the generic letter is voluntary, and the staff revised the generic letter to airectly parallel the policy statement.
The CRGR agreed with the approach to solicit voluntary responses because the staff does not plan to modify the license of a non-responsive licensee and because there has been a fairly open relationship between licensees and the NRC on the subject of design reconstitution programs.
By letter dated August 3,1992, I irformed Mr. Byron Lee, Jr. of NUMARC that the NRC would be pleased to receive their comments on the issued policy statement and that, in view of the interest expressed at the recent Regulatory Information Conference the generic letter will be published in draft form for public comment prior to issuance.
By letter dated October 2, 1992, NUMARC informed the Chairman that they were pleased to be afforded the opportunity to comment on the draft generic letter. However, the NUMARC letter raised concerns that the issuance of ?he generic letter would have a negative impact on current design bases reconstitution efforts and have a potential for an adverse effect on future self-initiated licensee efforts. The staff is currently preparing a response to NUMARC.
Coordination:
The Of t' - of the General Counsel has reviewed the enclosed generic setter and has no legal objections.
Recommendation:
Unless advised to the contrary, by the Commission, within 10 working days of the date of this letter, the staff intends to proceed with issuing the enclosed generic letter in the Federal Reaister for public comment.
k mesM.T/ylor xecutive Director for Operations
Enclosure:
Generic Letter 92-XX, " Availability and Adequacy of Design Bases Information"
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SECY NOTE:
In the absence of instructions to the contrary, SECY will notify the staff on Tuesday, November 10, 1992, that the Commission, by negative consent, assents to the action proposed in this paper.
DISTRIBUTION:
Commissioners OGC OCAA OIG OPP EDO ACRS SECY f
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Generic Letter TO:
ALL HOLDERS OF OPERATING LICENSES FOR NUCLEAR POWER REACTORS
SUBJECT:
AVAILABILITY AND ADEQUACY OF DESIGN BASES INFORMATION The Commission recently issued a policy statement' describing its expectations and the Agency's future actions to verify the availability and adequacy of design information.
In the policy statement, the Commission concluded that maintaining current and accessible design documentation is important to ensure that (1) plant physical and functional characteristics are maintained and are consistent with the design bases as required by U.S.
Nuclear Regulatory Commission (NRC) regulations; (2) systems, structures, and components can perform their intended functions; and (3) the plant is operated in a manner consistent with the design bases.
In October 1990, the Nuclear Management and Resources Council (NUMARC) issued NUMARC 90-12, " Design Basis Program Guidelines," containing guidance for t
organizing and collating the design bases for each nuclear power plant in a manner consistent with the definition of design bases information in Section 50.2 of Title 10 of the Code of Federal Reaulations (10 CFR 50.2).
NUMARC issued this document for voluntary use by NUKARC member organizations as a basis against which they could review their existing or planned efforts to collate supporting design information. On November 9, 1990, the NRC staff 2
sent comments on the guidelines to NUMARC.
'" Availability and Adequacy of Design Bases Information at Nuclear Power Plants," Federal Reaister, Volume 57, Number 154, page 35455, August 10, 1992.
2 Letter from W.T. Russell, NRC, to W.H. Rasin, NUMARC, November 9, 1990.
lV To ensure that the NRC is apprised of the industry's activities, the NRC hereby requests power reactor licensees to describe the programs that are implemented or planned to ensure design information is correct, accessible, and maintained.
To assist the staff in prioritizing its inspection program, the NRC requests that each addressee voluntarily submit the following information which would be particularly useful if submitted within 120 days:
1.
Submit a description of any programs already completed, planned, or being conducted to ensure the correctness and accessibility of the design bases information for your facility and to ensure that it is maintained current..
2.
If you are not implementing a design reconstitution program at your facility, submit your rationale for not implementing such a program and submit a description of the extent of the design information you have obtained from the nuclear steam supply system (HSSS) vendor and architect-engineer (A/E).
Describe the extent of any information not obtained from the USSS vendor or A/E, but which is accessible at the NSSS vendor or A/E offices.
3.
If your design reconstitution program is planned or being conducted but has not been completed, submit your schedule for implementation and the expected completion date.
W This generic letter does not impose any new requirements or modify any existing regulatory requirements.
Please address your response to the U.S. Nuclear Regulatory Commission, ATTN: Doc ~ument Control Desk, Washington, D.C.
20555 and a copy to Mr. Eugene V. Imbro, Chief, Special Inspection Branch, OWFN 9Al, U.S. Nuclear Regulatory Commission, Washington, D.C.
20555.
This request is covered by the Office of Management and Budget Clearance Number 3150-0011, which expires June 30, 1994. The estimated average number of burden hours is 200 person hours for each licensee response.
Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to the Information and Records Management Branch, (MNBB-7714) Division of Information Support Services, Office of Information Resources Management, U.S. Nuclear Regu'atory Commission, Washington, D.C.
20555; and to the Paperwork Reduction Project (3150-0011), Office of Management and Budget, Washington, D.C.
20503.
Backfit Discussion This generic letter is a request to submit information voluntarily.
This letter does not require modifications or additions to systems, structures, or components of a facility, the design of a facility, or the procedures or organization to design, construct, or operate a facility.
Therefore, this letter does not impose any backfits, as defined in 10 CFR 50.109(a).
The staff evaluated this letter in accordance with the charter of the Committee to Review Generic Requirements (CRGR) and will place a copy of that evaluation in the public document room with the minutes of the CRGR meeting 229 at which this letter was considered.
I If you have any questions about this matter, please contact the NRC project manager or the technical contact listed below.
i Sincerely, James G. Partlow Associate Director for Projects Office of Nuclear Reactor Regulation TECHNICAL CONTACT:
Eugene V. Imbro, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission, Washington, D.C.
20555, telephone (301) 504-2967.