ML20039E401
| ML20039E401 | |
| Person / Time | |
|---|---|
| Issue date: | 01/06/1982 |
| From: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| 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 |
| Shared Package | |
| ML20039E402 | List: |
| References | |
| NUDOCS 8201070241 | |
| Download: ML20039E401 (14) | |
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!!EMORANDUM FOR: Darrell G. Eisenhut, NRR
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Edward L. Jordan, IE g
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Donald B. Mausshardt, NMSS T
Robert M. Bernero, RES Clemens J. Heltemes, Jr., AEOD
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Joseph Scinto, ELD
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FROM:
Victor Stello, Jr., Chairnan
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Committee to Review Generic Requirements
SUBJECT:
CRGR MEETING NUMBER 5 -- DATE CHANGE FINAL CRGR CHARTER AND OPERATING PROCEDURES The date of the subject meeting has been changed from Thursday, January 7, 1932, from 1-5 pm in Room 6507 f tNBB to Wednesday, January 13,1982, from 1-5 pm in Room 6507 ftNBB. The agenda is unchanged.
The enclosed copy of the CRGR Charter and Operating Procedures, modified as appropriate to include each CRGR nember's recent comments, is forwarded for ratification by each member.
Formal ratification should be forwarded to Walt Schwink by January 7,1982.
Original signed by
. Victor Stenaf Victor Stello, Jr., Chairman Committee to Review Generic Requirements
Enclosure:
CRGR Charter and Operating Procedures cc w/o encl:
Office Directors T. Rehm Distribution:
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NRC rORM 318 (10-80) NRCM 024o OFFICIAL RECORD COPY usceo is,i-sa>9eo
December 30.-1981 o
1 COMMITTEE TO REVIEW GENERIC REQUIREMENTS (CRGR) b I.
Charter t.
.II.
Membership-1 l
III.
Scope-IV.
Operating Procedures V.
Reporting Requirements f
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I.
CHARTER Ths Committee to Review Generic Requirements (CRGR) has the responsibility to review and recommend 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 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 controls should make sure that requirements issued (a) do in fact contribute 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 fashion as possible in the overall achievement of protection of public health a'nd safety. By having the Committee submit recommendations directly to the EDO for approval, a single agency-wide point of control will be provided.
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 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 probab~ilistic risk assessment where data for its proper use are adequate. Therefore, to the extent possible, written justifications.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 prinrity or those which might be dropped entirely.
'r 1 II. MEMBERSHIP
.f This. Commi.ttee shall be chaired by the Deputy Executive Director for Regional Operations and Generic Requirements (DEDROGR), and it
'shall consist of, in addition to the DEDROGR, one individual each frem NRR,cIE, NMSS, RES', AE0D and ELD, appointed by the Executive Director for Operations. The Office of the DEDROGR will provide staff support.
The Committee may use several non-NRC persons as consultants in special technical areas.
In a memorandum dated October 29,1981 (Attachment 1), the EDO appointed six members to the CRGR.
4 New members will be appointed by.the EDO as the need arisesi If a membe.r cannot attend a meeting of the CRGR, his Office Director may
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- propose an alternate for the Chairman's approval.
It is the responsibility of the alternate member to be fully versed on the r
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 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.
t (ii)
All staff papers proposing new or revised rules of the type described in paragraph (i), including Advanced Notices.
(iii)
All proposed new or revised regulatory guides; all proposed new or revised Standard Review Plan (SRp) sections;.all proposed new or revised branch technical positions; all proposed generic letters; all multiplant orders; show cause orders; all 50.54f letters; all I
bulletins and circulars; all USI NUREGs; and all new
. or revised Standard Technical Specifications.
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s B.
The CRGR shall consider all licenses, license amendments, approvals of Preliminary Design Approvals (PDAs) and Final Design Approvals (FDAs), minutes of conferences with owners groups, licensees 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:
(1) only positions or interpretations which are contained in regulations, policy statements, 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 November 12, 198.1. Any document or communication of this type 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.
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
- lt 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.
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These emergency action requirements will be reported to the' Committee for information and will be included in the
-1 report to the Commission.
D.
For each proposed requirement not requiring emergency 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 overcome a safety problem j
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 by 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 forward'ed by the Chairman to the E00 for decision.
Category 2 requirements are those which do not meet the criteria for designation as Category 1.
Thase are to be scrutinized l
carefully by the CRGR on the basis of written justification, which must be submitted by the proposing Office along with the i
proposed requirements. Upon notice to the members of the CRGR, l
and without objection, the Chairman may exempt any Category 2 i
proposal from review on the grounds that he concludes that it l
involves only an insignificant effect on the NRC staff and on
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licensees.
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6-E.
The DEDROGR shall compile and maintain a list of projected generic requirements based on input from the NRC offices. The CRGR will normally receive an early briefing from the Offices on the proposed new generic requirements before.the staff has 1
developed the requirements and held discussions with the ACRS.
F.
The CRGR shall be consulted on the proposed backfit policy to be developed by DEDROGR staff.
G.
The CRGR shall be consulted on.the proposed plan to control communications.wiEn licensees to be developed by DEDROGR staff H.
The CRGR may be consulted on any issue deemed appropriate by a
the Chainnan.
IV.
CRGR OPERATING PROCEDURES A.
Meeting Notices Meetings will generally be held at regular intervals ano will be scheduled wcil in advance.
Meeting notices will generally be issued by the Chairman 2 weeks in advance of each meeting, except for Category 1 items, with available background material on each item to be considered by the Committee.
B.
Contents of Packages Submitted to CRGR Each package subnitted to the CRGR for review shall include ten (10) copies of the following information:
(i)
The proposed generic, requirement as it is proposed to be sent out to licensees.
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. (ii)
Draft staff papers or other underlying staff documents supporting the requirements.
(A copy of all materials referenced in the accument shall be made available upon request to the DEDROGR staff.
Any Committee member.may request DEDROGR staff to obtain a copy of any referenced material for his use.)
(i-i) 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 re-quirements ?
4 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?
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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 conditions are needed to install, conduct preoperational tests and declare operable?
Is plant shutdown necessary? How long?
-8 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 it the lead time for availability?
May it be used upon installation or does it need staff approval before use? Does it need tech. spec.
f changes before use?
(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 ven' dor types, some vintage types such as BWR 6 and 4. jet pump and nonjet pump plants, etc.).
(v)
For each such category of reactor, the following information should be provided:
A risk reduction assessment performed using a data base and methodology commonly accepted within NRC (for example, similar to that outlined in SECY 81-51 3).
An assessment of costs to NRC, an assessment of costs to licensee's, including resulting occupational dose increase or decrease, added plant and operational complexity, and total. financial costs.
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_g_
Consistent with the first two items above, provide the basis for requiring or permitting implementation by a given date or on a particular schedule.
Other acceptable implementation schedules and the basis therefor.
This should include suf'icient l
information to demonstrate that the schedules are realistic and provide 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).
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 advice is provided, each proposing Office shall ute 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 inplementation and the approp. mate degree of formality and detail to be imposed.
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- To the extent that the category contains plants 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 comments) of OELD on the method proposed.
(viii) Regulatory analysis sufficient to address the Paperwork Reduction Act, the Regulatory Flexibility Act and Executive
' Order 12291.
C. DEDROGR Staff Review DEDROGR staff shall review the package for completeness.
If incomplete, the package shall be returned by DEDROGR to the originating Offire with reasons for incompleteness.
Prior notice to the Committee is not needed; however, at each meeting of the Committee, the DEDROGR staff shall report on ryected packages.
If a package is cor@lete, it shall be scheduled for CRGR consideration; however, scheduling pricrities shall be at the discretion of the Chairman.
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the Chairman not to the Cosnittee.
The DEDROGR staff may obtain additional information fr:m' industry and consultants on such proposals, particularly with respect to the cost of implementation, realistic schedule for implementation, and the ability of licesees to safely and efficiently carry out the full range of safety related activities at each facility while implementing the proposed requirement.
D.
CRGR Meeting Minutes At each meeting, for each package scheduled for discussion, the sponsoring Office shall attend to respond to comments an_d questions. The DEDROGR 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 Committee members. At the conclusion of discussion, each Committee member shall summarize his position.
Minutes of the meeting, including minutes of the discussion, shall be' maintained. Minutes shall be circulated to all members within 3-working days after the meeting, and each member shall have the opportunity to comment in writing on the j.
minutes. All comments received within 5-working' days from receipt shall be maintained as part of the minutes of the meeting.
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The Committee shall recommend to the EDO approval, disapproval, modification, or conditioning of each recommendation for generic requirements considered 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 each fa cil ity.
Copies of the Committee's recommendation, and E00's approval, disapproval, or other action shall be provided to Committee members.
E.
Record Keeping System The DEDROGR staff will assure-that there is an archival system for keeping records of all packages submitted to DEDR0GR, actions by the staff, summary minutes of CRGR consideration of each, package, recommendations by the Committee, and decisions by EDO.
V.
REPORTING REQUIREMENTS The DEDROGR staff shall prepars 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 summary of those considered by the CRGR, the decision by the EDO on each proposed requirements, and the number of packages yet to be considered by the CRGR.
Committee members will be on distribution for these reports.