ML20039B714

Forwards marked-up Revisions to Committee to Review Generic Requirements Operating Procedures.Comments Should Be Submitted by 811223

ML20039B714
Person / Time
Issue date:	12/21/1981
From:	Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
NUDOCS 8112230462
Download: ML20039B714 (16)

Text

1 l$g DISTRIBUTION VStello DEC 21 1981 TMurley DEDR0GR cf Central File PDR(NRG/CRGR) y%Luis W

MEMORANDikt FOR: Darrell G. Eisenhut, NRR 0

gj Edward L. Jordan, IE p,

Donald B. Mausshardt, NMSS Q

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h,5 Robert M. Bernero, RES OfO

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C1emens J. Heltemes Jr. AE00 2

M fg78g7 Joseph Scinto, ELD t

FROM:

Victor Stello, Jr., Chairman g

)s' Comittee to Review Generic Requirements

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SUBJECT:

REVISIONS TO CRGR OPERATING PROCEDURES A Comission paper on Procedures For Controlling Generic Requirements is in preparation. Enclosed to that paper will be the CRGR Charter and Operating Procedures. Please review the enclosure, which contains

. revisions to the Charter and Operating Procedures discussed by the Comittee, and provide any coments or pmposed changes to Walt Schwink (24342)_ by Decen1ber 23,1981.

Original Signed by, Victor Stell4/

Victor Stello, Jr., Chairman Comittee to Review Generic Requirements

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Enclo'sure:

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NQC FORM 318 (10-80) NRCM O240 ICIAL RECORD COPY

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4 COMMITTEE TO REVIEW GENERIC REQUIREMENTS (CRGR) i 1

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Charter i

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II. Membership g

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Scope '

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IV. Operating Procedures I

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Reporting Requirements O

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.Nov. 13, 1981 12{tygj I.

CHARTER The Comittee to Review Generic Requirements (CRGR) has the responsibility to r'eview and re'comend to the Executive Director for Operations' (E,00) approval or disapproval of requirements to be imposed by, the NRC staff on

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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 eliminate 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 contro.ls should make sure that requirements issued (a) do in fact con-tribute effectively and significantly to the health and safety of the public, and (b) do lead to utilization of both NRC and licensee resources in as optimal a fash,io'n as possible in the overall achievement of protection of public* health and safety.

By having the committee submit recomendations directly to the ED0 for approval, a single agency-wide point of control will be provided.

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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 EDO a statement of the reasons for its recommendation ~.

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statement shall provide a clear indication of the basis for the decision not to apply the requirement to individual reactors or classes of reactors.

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Tools used by the CRGR for scrutiny would be expected to include cost-

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benefit analysis and pr.obabilistic risk assessment where data for its proper use are adequate.

Therefore, to the extent possible, written just2 ifications should be based on these evaluation techniques.

The use of cost tenefit 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.

MEMBERS IP

& Depdy gXWp8% }imgr This Committee shall be chaired by 'Jict:- ?t:", tt: :#, Dir::ter

'>n' n: th:.,.l., fc...~d p;;itier ;f 0:00 for Regional Operations and Generic Requirements, and it shall consist of, in addition to the DEDR0GR, and one individual from.sacA NRR, IE, NMSS, RES, AE0D and ELD, appointed, by the g

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.

TSc f:1 % ing individu;is hcyc L;;n cppointed by th: EDO, ef#erH "e

':Ovader 2,1:01, te le CRG5:

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.i New membars will be appointed by the EDO as the need arises.

If a member cannot att.end a meeting of the CRGR, his Office Director may propose an alternate for the chairman's approval.

It is the responsibility of the alternate member to be fully versed on the agenda items before the Committee.

III.

CRGR SCOPE A.

The CRGR shall consider all proposed new generic requirements to be imposed by the NRC staff on one or mor 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

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applicable to reactor licensees, including technical information required of reac, tor licensees or applicants for reactor licenses or construction permits.

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(ii) All staff papers proposing new proposed rules of the type described in paragraph 1, including Advanced Notices.

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(iii) All propose.d new or revised regulatory guides; all proposed new or revised SRP sections; all proposed new or revised branch l

technical positions; all proposed generic letters; all multiplant orders; show cause orders; all 50.54f letters; all bulletins l

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p and circulars; all USI NUREGS; and all new or revised Standard fieks sad dafs c*llecf:*^ *cS*'U" r*V t'^f '**" Y'M'A * ***

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B.

The CRGR shall consider all cps, OLs, approvals of PDt., _ad FDAs, minutes of conferences with owners groups, license'es or vendors, staff approvals of topical reports, information notices, and all other

' documents, letters or communications which are represented to reflect or interpret NRC staff positions, unless. such documents refer only to previously approved requirements or staff positions,* for example:

(i) only positions or interpretations which are contained in regu-lations, policy statements, proposed regulations, regulatory

- guides, the Standard Review Plan, branch technical positions, generic ge Yo,indivigv..t planfr er.provals, P_DA(, FDAs,d ;

ers orders, topical ap licenses

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.and license amendmentMhich have been promulgated prior to

' Noveinber 12,198 r wh'ch ha been sed the ev' w f at]

f efst 4ree f cili ies incl, ding afnendmg ts) p for to i

over er 12,198 y document or communication of this type shall cite and Jccurately 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 communications referenced above will contain only previously approved requirements or staff positions.

Noy 13,1981 IL{ltltt 5-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 notif_ied by.the office originating the action. These_ emergency actipn requirements will-be report'ed to the Committee forinformation and will be inclu~ded 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.

Ca.tegory 1 requirements are those which.the proposing office rates as urgent to overcome a safety problem requiring immediate 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 days 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 beforwarded by the Chairman to the EDO for decision.

Category 2 requirements are those which do not meet the criteria for designation as Category 1.

Thesearetobescrutinizedcarefulkyby 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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E.

The DEDROGR shall compile and maintain 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 discussions with the ACRS.,

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The CRGR shall be consuited on the proposed backfit policy to be developed by DEDR0GR staff.

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[he.CRGR shall be consulted on the propo. sed ' plan to control communica-tions with licensees, which is to be developed by DEDROGR staff.

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The CRGR may be consulted on any issue deemed appropriate by the Chairman.

IV. CRGR OPERATING PROCEDURES A.

Meeting No'tices Meetings will generally be held at regular intervals and will be scheduled well in advance.

Meeting Notices will generally be iswd by the. Chairman ~ 2 wqeks in advance of each meeting, except for availdle.

Category 1 items, with background material on each item to be con-4 sidered by the Comittee.

B.

Contents of Packages Submitted to CRGR Each package submitted to the CRGR for review shall ' include ten copies of the following information:

(i) The proposed generic requirement as it is proposed to be sent l

out to licensees.

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(ii) Draft staff papers for underlying staff documents supporting the requirements.'

(A copy of ~all materials referenced in the document ~

shal.1 b'e.made available upon request to the DEDROGR staff. Any

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committee member may request DEDROGR staff to o,btain 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 ne'ed 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 systems?

What plant coriditions 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 the lead ti.? for availability?

May it be used upon installation er does it net.d staff approval

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before use? Does it need tech. spec. changes before use7 Y+%

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O/ISfst (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 cnly, some vendor types, some vintage types such as BWR 6 and 4, jet pung and nonjet pump plants, etc.

(v)

For each such category:

A risk reduction assessment performed using a data base and methodology commonly accepted w.ithin 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 t'otal financial costs.

Consistent with the first two items above, provide the basis for requiring or permitting implementation by a given date or on a particular schedule.

Any other suggested inplementation schedule and the basis there-

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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 traiiling of operators.

Schedule for staff actions involved in completion of requirement (based ~ on hypothesized effective date of approval).

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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 bh DEDilbGR. dntil 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 exten't that the category cont $ ins 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 of each item is valid for all types and vintages covered.

(.vi) 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.

Repladory calyrit twMiciedio SO*55 +Ae-(viii) Jrf;c= tion n;;ded to et.t;in C"3':ic;r=: =hr the Papemork order.Iu91 Reduction ' Act, 'H e E'$"l"S*rY Flexibility' Act a ed Eyscutin C.

DEDROGR Staff Review DEDROGR staff shall review the package for completeness.

If incomplete, the package shall be returned by DEDR0GR to originating office with reasons 6

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Nov.13,1981 Iff tlgl-for incompleteness. Prior notice to committee not needed; however, at

. each meeting of the Committee, DEDROGR staff shall report on rejected packages.

If a packo3

complete, it shall be schedule,d,for CRGR consideration; however, scheduling priorities shall be at the discretion of'the.

Chhi man.

All requests for particular scheduling shall be made to the Chairman not to the Committee The ROGR staff may obtain factual infomation from industry and con-sultants on such proposals, particu'larly with respect to cost of implementation, realistic schedule for imple.nor.tation, 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

. activ,ities at each facility.

D.

CRGR Meeting Minutes At each meeting, for each package scheduled for discussion, the sponsoring i

office shall attend to respond to comments and questions. The DEDROGR staff shall present a brief analysis of the package.

A' reasonable amount of time, within the disetetion of the Chaiman, shall be pemitted for discussion of each item by Committee members. At the conclusion of discussion, each Committe'e member shall summarize his position.

Minutes of.the meeting, including minutes of the discussion, shall be maintained an'd the position of each member as summarized by that member shall be accurately recorded.

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Ninutes shall be circulated to all members within 3-working days after the meetings, and each member shall have the opportunity to coment in writing on soch minutes. All such comments received within 5-working days shall be maintained as part of the minute. of the meeting.

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Chima, shall recommend to,ED0 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 such implementation, which shall give consideration to the ability of licensees to safely and efficiently carry out the entire range of safety related activities at committee's each facility.

Copies of the Chi.ma': recommendation, and ED0 approval, disapproval, or other action shall be provided to Committee members. -

E.

Record Keeping System ov.e At ht 15; The DEDROGR staff will

"t:f an archival system for keeping records l

of all packages submitted to DEDROGR, actions by the staff, summary i

minutes of CRGR consideration of each package, recommendations by the Co.,yftee l

_ m m, and decisions by EDO.

i V.

REPORTING SYSTEM

.The DEDR0GR staff shall prepare a report to be submitted by the EDO to the Commission each month. The report will provide a brief sumary of the number

' packages received, the number returned, a summary of those considered by the CRGR, the decision by the EDO on each proposed requirement, and the number '

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of packages yet to be considered by the CRGR.

C:mm ttee members will be on distribution for these reports.

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NUCLEAR REGULATORY COMMisSICrM

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October 29,J1981 MEtORANDUM FOR:

Darrell G.' Eisenhut, NRR' Edward L'. Jordan, IE '

Donald B. MaQsshardt, NMSS '

Robert M. Bernero, RES'

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Clemens J. Heltemes, Jr., AEOD' Joseph S:into, ELD' FROM:

-Williamd.Dircks Executive Director for Operations '

SUBJECT:

PPOINTMENTS-TO C0!NITTEE TO REVIEW GENERIC REQUIREMENTS '(CRGR)

On' October 16, 1981, Chairman Palladino announced a reorganization of NRC staff activities.

The objectives are to improve our control over require-

.ments imposed on NRC licensees and focus the priorities of the agency and the nuclear industry on those reg'uirements having the greatest safety f'"

significance.

The imchanism established to accomplish this.is a new

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Comittee to Review Generic Reqairements which' will be chaired by the new Deputy Executive Director for Regionai Operations and Gener,ic Require-ments.

The Chairman has' directed me to appoint members to the Comittee from the Offices of NRR, IE, NMSS, RES, AEOD and ELD.

.I am appoi:iting, by this memorandud, the following individuals to the Comittee:

Darrell Eisenhut, NRR Edward L. Jordan, IE. '

Donald B.-Mausshardt, NMSS.

Robert M. Eernero, RES.

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' Cle:5 ens J. He].temes, Jr., AEOD

' Joseph Scinto, ELD

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I consider the 'r.esponsibil.ities assigned by the Chairman to' the new Comittee to be the key to. effectively controlling new requirements and assuring their safety significance.

It is essential that your comitment to and participation 3

.in the work of. the~ Ccmittee match the job,at hand?

i It is expected that a meeting of the Comittee will be heli in the near future to develop the procedures which will be followed for the Comittee's work.

.A. &.

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William J. Dircks Executive' Director for Operations cc:

See attached list

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- October 29, 1981 cc:

Harold Denton, Director, NRR -

Richard DeYoung, Director, IE John Davis, Director,.NMSS.

Robert Minogue, Director, 'RES Caryle Michelson,-Director, AEOD o

Howard Shapar, Executive Legal Director Victor Stello, Jr., Deputy Executive Director ROGR,,

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