ML20038B988
| ML20038B988 | |
| Person / Time | |
|---|---|
| Issue date: | 11/03/1981 |
| From: | Stello V Committee To Review Generic Requirements |
| To: | Eisenhut D, Jordan E, Mausshardt D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS), Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8112090395 | |
| Download: ML20038B988 (14) | |
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November 3, 1981 MEMORANDUM FOR:
Darrell G. Eisenhut, NRR Edward L. Jordan, IE Dorald B. Mausshardt, NMSS Robert M. Bernero, RES Clemens J. Heitemes, Jr., AE0D Joseph Scinto, ELD FROM:
Victor Stello, Jr., Chairman Committee to Review Generic Requirements
SUBJECT:
FIRST MEETING 0F CRGR The first meeting of the Committee to Review Generic Requirements (CRGR) will be on Thursday, November 12, from 1 to Spm, in Room 6507 MNBB.
The purpose of the meeting will be to discuss the operating policy of the Committee with the objective to adopt the policy and charter for the Comittee.
jV Victor Stello, Jr.,
hairman Committee to Review Generic Requirements l
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i 8112090395 811103 PDR REVCP NRCCRCR PDR
Nov. '13,1981 f
i COMITTEE TO REVIEW GENERIC REQUIREMENTS (CRGR)-
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Charter-i i
i II. Membership l
III. Scope i
IV. Operating Procedures i
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Reporting Requirements 6
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Nov. 13,1981 I.
CHARTER The Comittee to Review Generic Requirements (CRGR) has the responsibility to review and recomend to the Executive Director for Operations (ED0) approval or disapproval of requirements to be imposed by the NRC staff on one or more classes of reactors. The CRGR will develop means for controlling the number and nature of the requirements placed by NRC on licensees. The objectives of these controls are to eliminste the unnecessary burdens placed on licensees, reduce the exposure of workers to radiation in implementing some of these requirements, and conserve NRC resources while at the same time not reducing the levels of protection of public health and safety.
The controls should make sure that requirements issued (a) do in fact con-tribute effectively and significantly to the health and saf'ety of the public, and (b) do lead to utilization of both NRC and licensee resources in as optimal a fashion as possible in the overall achievement of protection of public health and safety.
By having the committee submit recommendations directly to the EDO for approval, a single agency-wide point of control will be provided.
j The CRGR will focus primarily on proposed new requirements, but it will also review selected existing requirements which may place unnecessary burdens on licensee or agency resources.
In reaching its recommendation, the CRGR shall consult with the proposing office to ensure that the reasons for the proposed requirement are well understood.
If the CRGR recommends disapproval or major modifications of a proposed requirement, it shall submit to the ED0 a statement of the reasons for its recommendation.
This
' statement shall provide a clear indication of the basis for the decision I
not to apply the requirement to individual reactors or classes of reactors.
Tools used by the CRGR for scrutiny would be expected to include cost-benefit analysis and probabilistic risk assessment where data for its proper use are adequate. Therefore, to the extent possible, written just-ifications should be based on these evaluation techniques. The use of cost benefit analyses and other tools should make it possible to determine which proposed requirements have real safety significance, as distinguished from those proposed requirements which should be.given a lower priority or those which might be dropped entirely.
II. MEMBERSHIP This Committee shall be chaired by Victor Stello, the Deputy Director occupying the newly formed position of DED0 for Regional Operations and Generic Requirements, and it shall consist of, in addition to the DEDROGR, j
one individual from each NRR, IE, NMSS, RES, AE0D and ELD, appointed by the l
Executive Director for Operations. The Office of the DEDR0GR will provide staff support.
The Generic Requirements Review Committee may use several non-NRC persons as consultants in special technical areas.
The following individuals have been appointed by the EDO, effective November 2,1981, to the CRGR:
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Robert M. Bernero, RES i
Darrell Eisenhut, NRR Clemens J. Heltemes, Jr., AE00 4
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Nov.13,' 1981
- Edward L. Jordan, IE Donald B. Mausshardt, NMSS Joseph Scinto, ELD New members will be appointed by the EDO as the need arises.
If a member cannot attend a meeting of the CRGR, his Office Director may propose ar, alternate for the chairman's approval.
It is the responsibility of the alternate member to be fully versed on the agenda items before the Comittee.
III.
CRGR SCOPE A.
The CRGR shall consider all proposed new generic requirements to be imposed by the NRC staff on one or more classes of reactors.
These include:
(i) All staff papers which propose the adoption of final rules or policy statements affecting 10 CFR Parts 20, 50, 51, 55,100 or modifying any other rule so as to affect technical requirements applicable to reactor licensees, including technical information required of reactor licensees or applicants for reactor licenses or construction permits.
(ii) All staff papers proposing new proposed rules of the type describrd in paragraph 1, including Advanced Notices.
(iii) All proposed new or revised regulatory guides; all proposed new or revised SRP sections; all proposed new or revised branch technical positions; all proposed gen'eric letters; all multiplant orders; show cause orders; all 50.54f letters; all bulletins :
Nov. 13,1981
. and circulars; all USI NUREGS; and all new or revised Standard Tech. Specs.
B.
The CRGR shall consider all cps., OLs, approvals of PDAs and FDAs, minutes of conferences with owners groups, licensees or vendors, staff approvais of topical reports, information notices, and all other documents, hetters or communicati6ns which are represented to reflect or interpret NRC staff positions, unless such documents refer only to previously approved requirements or staff positions,* for example:
(1) only positions or interpretations which are contained in regu-lations, policy statements, proposed regulations, regulatory guides, the Standard Review Plan, branch technical positions, generic letters, orders, topical approvals, PDAs, FDAs, licenses and license amendments which have been promulgated prior to Novemher 12, 1981, or which had :.cen used in the review of at least three facilities (including amendments) prior to November 12, 1981. Any document or communication of this t'ype shall cite and accurately state the position as reflected in a previously promulgated regulation, order, Regulatory Guide, SRP, etc.
(ii) only positions after that date which have been approved by CRGR.
- It is expected that the Offices will develop internal procedures to ensure that the documents and communicatior.s referenced above will contain only previously approved requirements or staff positions.
Nog 13,1981 C.
For those rare instances where it is judged that an emergency action is needed to protect the health and safety of the public, no review by the CRGR is necessary.
However, the Chairman should be notified by the office originating the action.
These emergency action requirements will be reported to the Comittee forinformation and will be included in the report to the Commission.
D.
For each proposed requirement not requiring immediate action, the proposing office is to identify the requirement as either Category 1 or 2.
Category 1 requirements are those which.the proposing office rates as urgent to overcotle a safety problem requiring immeciate resolution or to comply with a legal requirement for immediate or near term compliance.
Category 1 items are expected to be infrequent and few in number, and they are to be routinely approved or otherwise dealt with within 2 working di;/s of receipt of the CRGR.
If the appropriateness of designation as Category 1 is questioned by the Chairman and if the question is not resolved within the 2 working-day limit, the proposed requirement is to be forwarded by the Chairman to the ED0 for decision.
Category 2 requirements are those which do not meet the criteria for designation as Category 1.
These are to be scrutinized carefully by the CRGR on the basis of written justification, which must be submitted by the proposing office along with the proposed requirements. 'Upon notice to the members of the CRGR, and without objection, the Chairman may exempt any Category 2 proposal from review on the grounds that he concludes that it involves only an insigificant effect on the NRC staff and on licensees.
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Nov.13,1981
- E.
The DEDROGR shall compile and ma'intain a. list of projected generic requirements. based on input.from the NRC Offices. The CRGR shall re-ceive an early briefing from the Offices 'on the proposed new generic requirements before the staff has developed the requirements and held
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discussions with the ACRS.
F.
The CRGR 'sh'all be consulted on the proposed backfit policy to be developed by DEDR0GR staff.
G.
The CRGR shall be consulted on.the proposed plan to control consnunica-4 tions with licensees, which is to be developed by DEDROGR staff.
H.
The CRGR may be consulted on any issue : deemed appropriate by the Chairnen.
IV. CRGR OPERATING PROCEDURES A.
Meeting Notices Meetings will generally be held at regular intervals and will be scheduled well in advance. Meeting Notices will generally be issued l
by the Chairman 2 weeks in advance of each meeting, except for Category 1 items, with background rnaterial on each item to be con-I sidered by the Conunittee.
B.
Contents of Packages Submi,tted to CRGR Each package submitted to the CRGR.for review shall include ten copies of the fo11cwing infonnation:
(i) The proposed generic requirement as it is proposed to be sent 9
out to licensees.
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- t (ii) Draft staff papers for underlying staff documents supporting the requirements.
(A copy of all naterials referenced in the document shall be made available upon request to the DEDROGR staff. Any committee member may request DEDR0GR staff to obtain a copy of any referenced material for his use.)
(iii) A brief description of each of the steps anticipated that licensees must carry out in order to complete the requirements; e.g.,
Are there separate short-term and long-term requirements?
Is it the definitive, comprehensive position on the subject or is it the first of a series of requirements to be issued in the future?
How does this requirement affect other requirements? Does this requirement mean that other items or systems or prior analyses need to be reassessed?
Is it only computation? Or does it require or may it entail engineering design of a new system or modification of any existing sys,tems?
What plant conditions are needed to install, conduct preoperational tests and declare operable?
Is plant shutdown necessary? How long?
Does design need NRC approval?
Does it' require new equipment? Is it available for purchase in sufficient quantity by all affected licensees or must such equipment be designed? What is tiie lead time for availability?
May it be used upon installation or does it need staff approval before use? Does it need tech. spec. changes before use?
Nov.13,1981
' (iv) Identification of the category of reactors to which the generic requirement is to apply (that is, whether it is to apply to new plants only, new OLs only, OLs after a certain date, OLs before a certain date, all Ols, all plants under construction, all plants, all water reactors, all PWRs only, some vendor types, some vintage
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. types such as BWR 6 and 4, jet pump and nonjet pump plants, etc.
(v)
For each such category:
A risk reduction assessment performed using a data base and methodology commonly accepted within NRC (for example, similar to that outlined in SECY '81-513).
An assessment of costs to NRC; an assessment of costs to licensees, including resulting occupational dose increase or decrease, added plant and operational complexity, as well as total financial costs.
Consistent with the first two items above, provide the basis for requiring or permitting implementation by a given da'te or on a particular schedule.
Any other suggested implementation schedule and the basis there-for.
This should include sufficient information to demonstrate that the schedule is realistic and provides sufficient time for indepth engineering, evaluation, design, procurement,-installation, testing, development of operating procedures, and training of operators.
Schedule for staff actions involved in completion of requirement (based on hypothesized effective date of approval).
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_g.
Prioritization of the proposed requirement considered in light of all other safety related activities under way at all affected facilities. This prioritization shall be based upon the guidance and direction provided from time-to-time by DEDROGR. Until such time as such advice is provided, each proposing office shall use its best technical judgment and explain the basis therefor.
For proposed requirements involving reports and/or record keeping, an assessment of whether such reporting or record keeping is the best means of implementation and the appropriate degree of formality and detail to be imposed.
To the extent that the category contains plans of different types or vintages, the items listed above shall be provided _for each type and vintage, or justification shall be provided demonstrating that the analysis o.f each item is valid for all types and vintages covered.
(31) Each proposed requirement shall contain the sponsoring office's position as to whether the requirement implements existing regulations or goes beyond-them.
(vii) The proposed method of implementation along with the concurrence (and any.coments)'of OELD on the method proposed.
(viii)
Information needed to obtain OMB clearance under the Paperwork l
Re. duction Act.
C.
DEDROGR Staff Review DEDROGR staff shall review the package for completeness.
I f.incompl ete,
the package shall be returned by DEDROGR to originating office with reasons
Nov. 13, 1981
.- for inco.'aleteness. Prior notice to committee not.aeeded; however, at each meeting of the Committee, DEDROGR staff shall report on rejected packages.
If a package is complete, it shall be scheduled for CRGR consideration; however, scheduling priorities shall be at the discretion of the.
Chai rman.
All requests for particular scheduling shall be made to the C051rman not to the Committee The R0GR staff may obtain factual information from industry and con-sultants on such proposals, particu'larly with respect to cost of implementation, realistic schedule for implementation, and effect of carrying out the proposed work on the ability of licensees to safely and efficiently carry out the full range of. safety related activities at each facility.
D.
CRGR Meeting Minutes l
At each meeting, for each package scheduled for discussion, the sponsoring l
l office chall attend to respond to comments and questions. The DEDR0GR l
staff shall present a brief analysis of the package. A reasonable amount of time, within the discretion of the Chairman, shall be permitted for discussion of each item by Conmittee members. At the conclusion of discussion, each Committee member shall summarize his po'sition.
Minutes cf the meeting, including minutes of the discussion, shall be maintained and the position of each member as summarized by that member shall be accurately recorded.
Nov.13,1981 Minutes shall be circulated to all members within 3-working days after the meetings, and each member shall have the opportunity to cu.nment in writing on such minutes. All such comments received within 5-working days shall be maintained as part of the minutes of the meeting.
Based on consideration of the comments of the Committee enembers, the Chairman shall reccmmend to EDO approval, disapproval, modification, or conditioning of each recommendation for generic requirements con-sidered by the Committee, as well as the method of implementation of such requirements and appropriate scheduling for sucn implementation, which shall give considerati.on to the ability of licensees to safely and efficiently carry out the entire range of safety related activities at each facility.
Copies of the Chairman's recommendation, and ED0 approval, disapproval, or other action shall be provided to Cognittee members. -
E.
Record Keeping System The DEDROGR staff will maintain an archival system far keeping records of all packages submitted to DEDROGR, actions by the staff, summary.
minutes of CRGR consideration of each package, recommendations by the Chairman, and decisions by EDO.
V.
REPORTING SYSTEM The DEDR0GR staff shall prepare a report to be submitted by the ED0 to the Commission each month. The report will provide a brief summary of the number packages received, the number returned, a summ'ary of those considered by the CRGR, the decision by the EDO on each proposed requirement, and the number '
- Nov,.13,1981 1t.
I of packages yet to be considered by the CRGR. Committee members will be on 4
j distribution for these repcrts.
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