ML20034D485
| ML20034D485 | |
| Person / Time | |
|---|---|
| Issue date: | 10/20/1992 |
| From: | Miraglia F Office of Nuclear Reactor Regulation |
| To: | Jordan E Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20034D486 | List: |
| References | |
| NUDOCS 9211020197 | |
| Download: ML20034D485 (5) | |
Text
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UNITED STATES y
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NUCLEAR REGULATORY COMMISSION S*k. *
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WASHINGTON. D.C. 205S5 o%.% j' October 20, 1992 MEMORANDUM FOR:
Edward L. Jordan, Chairman Committee to Review Generic Requirements FROM:
Frank J. Miraglia, Deputy Director Office of Nuclear Reactor Regulation
SUBJECT:
MODIFICATION OF TECHNICAL SPECIFICATION ADMINISTRATIVE CONTROL REQUIREMENTS FOR EMERGENCY AND SECURITY PLANS The staff is proposing a generic letter for a line-item improvement to technical specifications (TS), to address a request by the Duke Power Company for this TS change. The proposed generic letter, " Modification of Technical f
Specification Administrative Control Requirements for Emergency and Security Plans," attached to the enclosed CRGR review package, is submitted for review as a Category 2 item.
The TS change removes the administrative control requirements for the emergency and security plans that are adequately addressed by existing regulatory requirements. The generic letter includes a model TS to help i
licensees and project managers process license amendments to implement the changes. The staff intends to implement a similar TS modification in the improved standard technical specifications for each nuclear steam supply system (NSSS) vendor.
Brian K. Grimes, Director, Divirion of Operating Reactor Support is sponsoring this work.
Plea:e schedule a meeting at the earliest opportunity for the CRGR to review this proposal.
dI.
Frank.
iragl a, Deputy Director Office of Nuclear Reactor Regulation
Enclosure:
As stated l
I CONTACT: Tom Dunning, 504-1189 mrmmmenwxma:wman mm (92//0MMb sy A 3/23/95 on
Enclosure' l
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CRGR REVIEW PACKAGE i'
Prooosed Action: Issue a generic letter to give licensees guidance for implementing a line-item technical specification (TS) improvement to remove specific administrative control requirements for auditing and reviewing the emergency and 1
security plans and for implementing procedures for the i
emergency and security plans.
l CATEGORY 2 RESPONSE TO REOUIREMENTS FOR CONTENT OF PACKAGE SUBMITTED FOR CRGR REVIEW l
(i)
The proposed generic requirements or staff position as'it is proposed to be sent out to licensees. Where the objective or intended result i
of a proposed generic requirement or staff position can be achieved by setting a readily quantifiable standard that has an unambiguous relationship to a readily measurable quantity and is enforceable, the proposed requirements should merely specify the objective or result to
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be attained, rather than prescribing to the licensee how the objective i
or result is to be attained.
L See the proposed generic letter, " Modification of Technical i
Specification Administrative Control Requirements for Emergency and Security Plans." (Attachment) l' (ii)
Draft staff papers or other underlying staff documents supporting the requirements or staff positions.
A list of existing regulatory requirements for emergency and security plans are provided in Enclosure 1 to the proposed generic-letter.
l These requirements are listed so that licensees can readily identify duplicative requirements in the administrative control section of i
individual plant technical specifications.
j (iii)
Each proposed requirement or staff position shall contain the sponsor-ing office's position as to whether the proposal would increase requirements or staff positions, would implement existing require'ments or staff positions, or would relax or reduce existing requirements or r
staff positions.
j This TS change does not change requirements or staff positions.
It only removes portions of TS that duplicate 10 CFR Parts 50 and 73 l
i requirements.
(iv)
The proposed method of implementation along with the concurrence.(and' any comments) of the Office of the General Counsel (0GC) on the method proposed. The concurrence of affected program offices _or an explanation of any nonconcurrences.
Each licensee would voluntarily propose TS changes consistent with9the.
generic letter.
Project managers would review proposed changes,-
prepare the safety evaluation report (SER), and process the license
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-l amendment to implement the TS changes. OGC has reviewed the proposed L
generic letter and had no comment or objections. This TS improvement does not directly affect other offices.
(v)
Regulatory i.nalysis generally conforming to the directives and guidance of NUREG/BR-0058 and NUREG/CR-3568.
l A regulatory analysis is not required because action taken by licensees in response to the generic letter is voluntary.
.l (vi)
Identification of the category of reactor plants to which the generic requirement or staff position is to apply.
This guidance applies to all power reactor plants.
(vii)
For backfits other than compliance or adequate protection backfits, a backfit analysis as defined in 10 CFR 50.109. The backfit analysis i
shall include, for each category of reactor plants, an evaluation which demonstrates how action should be prioritized and scheduled in light of other ongoing regulatory activities. The backfit analysis shall document for consideration inwrmation available concerning any of the following factors as may be deemed appropriate and any other information relevant and material to the proposed action:
(a) Statement of the specific objectives that the proposed action is designed to achieve; (b) General description of the activity that would be required by the licensee or applicant in order to complete the action; (c)
Potential change in risk to the public from the accidental offsite release of radioactive material; (d)
Potential impact on radiological exposure of facility employees and other onsite workers; (e)
Installation and continuing costs associated with the action, including the cost of facility downtime or the cost of construction delay-t (f) The potential safety impact of changes in plant or opera-tional complexity, including the relationship to proposed
-and existing regulatory requirements and staff positions; (g) The estimated resource burder on NRC associated with the l
proposed action and the availability of such resources; (h) The potential impact of differences in facility typc, design, or age on the relevancy and practicality of the proposed action; j
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(i) Whether the proposed action is inter.
- 1, and if interim, the justification for imposin3 sroposed action on an interim basis;
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(j) How the action should be prioritized and scheduled in light
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of other ongoing regulatory activities. The following information may be appropriate in this regard:
1.
The proposed priority or schedule, 2.
A summary of the current backlog of existing requirements awaiting implementation, 3.
An assessment of whether implementation of existing t
requirements should be deferred as a result, and 4.
Any other information that may be considered appropriate with regard to priority, schedule, or cumulative impact.
l For example, could implementation be delayed pending j
4 public comment?
Backfit considerations do not apply because a licensee's response to this generic letter would be voluntary.
t (viii) For each backfit analyzed pursuant to 10 CFR 50.109(a)(2) (i.e., not
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adequate protection backfits and not compliance backfits) the proposing office director's determinatiori, together with the rationale for the determination based on the considerations of partaraphs (1) through (vii) above, that (a) there is a substantial increase in the overall protection of j
public health and safety or the common defense and security to be derived from the proposal; and l
t (b) the direct and indirect costs of implementation, for the facilities affected, are justified in view of this increased protection.
Backfit considerations do not apply because a licensee's response to this generic letter would be voluntary.
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(ix)
For adequate protection or compliance backfits evaluated pursuant to l
(a) a documented evaluation consisting of:
(1) the objectives of the modification, (2) the reasons for the modification, and (3) the basis for invoking the compliance or adequate 7
i protection exemption.
(b)
In addition, for actions that were immediately effective, the evaluation shall documeni the safety significance and appropriateness of the action taken and consideration of how costs contributed to selecting the solution among various acceptable alternatives.
l Backfit considerations do not apply because a licensee's response to this generic letter would be voluntary.
i (x) for each evaluation conducted for proposed relaxations or decreases in current requirements or staff positions, the proposing office j
director's determination, together with the rationale for the 3
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determination based on the considerations of paragraphs (i) through (vii) above, that (a) the public health and safety and the common defense and security would be adequately protected if the proposed reduction in requirements er positions were implemented, and i
The TS change will not adversely affect the public health and e
safety since the regulations include adequate provisions to address the administrative control requirements removed from the TS.
(b) the cost savings attributed to the action would be substantial enough to justify taking the action.
The intent of this generic letter is to reduce a licensee's costs to prepare and the staff's cost to review a related license amendment request. The licensee's costs to maintain administra-tive controls for the emergency and security plans will be i
reduced by the elimination of duplicate requirements.
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(xi)
For each request for information under 10 CFR 50.54(f), (which is not
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subject to exception as discussed in III.A) an evaluation that includes at least the following elements:
j (a) A problem statement that des;ribes the need for the information in terms of potential safety benefit.
(b) The licensee actions required and the cost-to develop a response to the information request.
(c) An anticipated schedule for NRC use of the information.
(d) A statement affirming that the request does not impose new requirements on the licensee, other than for the requested I
information.
The generic letter would not request information under 10 CFR 50.54(f). However, it would request the licensee to voluntarily submit information on the licensee's time and cost to prepare the license amendment request and an estimate of long-term savings to be-realized from the proposed TS change.
(xii)
An assessment of how the proposed action relates to the Commission's j
Safety Goal Policy Statement.
l The proposed action is not related to the policy statement on safety' goals.
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