ML20040E209
| ML20040E209 | |
| Person / Time | |
|---|---|
| Issue date: | 11/11/1981 |
| From: | Kerr W, Mark J, Seiss C Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| Shared Package | |
| ML20040E208 | List: |
| References | |
| ACRS-1923, NUDOCS 8202030292 | |
| Download: ML20040E209 (8) | |
Text
Meeting Date:
11/11/81 Date Issued:
12/4/81 Date Ctrtified: 12/10/81, gj?
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/0 0 N ' pg ') 3 MIt4UTES 05 ACRS PROCEDURES SUBCOTi!TTEE MEETING 1
NOVEMBER 11, 1981 Puroose: This meetinn was scheduled to discuss the following items:
- 1) Scope of ACRS activities
!!) Nature / conduct of ACRS activities III) Management /nrioritization of ACRS activities regarding generic matters Participants (Room 1010-H)
J. C. Mark, Chairman C. P. Siess, Mem5er W. Kerr, Menher R. F. Fralay, Executive Director, ACRS Discussion I) Scope of ACRS activities NSOC Recommendations NSOC has recommended that nonmandatory review by the ACRS should be implemented so that the Committee can concentrate on more indepth reviews of selected safety issues and can audit NRC Staff perfor-mance.
It appears that nonnandatory review is not likely to pass this Congress.
To make its project reviews more effective, however, the Committee should spend less time (e.g., limit to 2-3 hrs per meeting) on a project which has previously been reviewed and ap-proved by the ACRS, and should concentrate on matters identified by the Subcommittee as those needing full Committee attention (e.g.,
emergency plans, competence of operatinq organization, etc.).
In order for the Subcommittee review to be more responsive to the interests / concerns of individual members, however, additional time should be spent during full Committee discussion of anticipated Subcommittee activity so that members can identify areas of inter-est/ concern for examination during the Subcommittee reviews. This would preclude the need for extended discussion of such items during full Committee meetings unless the Subcommittee considered it nec-essary to pursue the matter at the Committee level. Members would be encouraged to rely on the report of the Subcommittee in these areas rather than conducting their own detailed inquiry.
In addi-tion, Subcommittee Chairmen should be encouraged to identify and examine items of substantive safety concern during Subcommittee reviews taking into account the specific concerns of their fellow members.
8202030292 811210
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1923 PDR
PROPOSED MINUTES OF PROCEDURES i SUBC01MITTEE MEETING The need for the Committee to perform a OA function regarding staff activities, as proposed by NSOC, was discussed briefly.
This is already done in many respects on an "ex-officio" basis.
In some cases, however, leadership at the head end of the process or aufdance during the process may be more approoriate than QA which comes at the end of the process of project re-view /rulemaking, etc.
Since approximately 1.5 major projects per month can be expected over the next 3 years with possible peaks of 2-3, better manage-ment of generic activities as well as more effective project re-views will be needed.
Additional comments / suggestions reqarding the conduct and mananement of Committee activities are included under Items II and III.
Heed for additional NRC Advisory Committees Additional NRC Advisory Committees to deal with Radiolocical Effects and/or Radwaste Waste Management / Disposal may be ao-propriate since few ACRS members are expert in this area and heavy reliance must be placed on consultants.
It was agreed that further thoucht is needed before making such a recommeda-tion.
It was also agreed, however, that the Committee should not becona involved in any additiora1 areas of review (e.g.,
fuel fabrication) without giving the natter serious thought.
II) Nature / conduct of ACRS activities More effective use must be made of Subcommittee activity as noted in I, above.
tiore time should be devoted to discussing items with the NRC Staff technical reviewers rather than the applicant or the NRC oroject mananer so that significant technical issues can be ad-dressed.
l Too much time and attention are being devoted to the list of unresolved issues identified by the Staff and, more recently the concerns of intervenors, than items of high risk poten-tial.
The Subcommittee should identify and concentrate on the significant issues needing attention.
Use of Subcommittees l
A better definition is needed of Subcommittee authority with respect to such items as:
approval of proposed staff plans to take interim action (e.g.,
approve publication of items for public comment).
Promul gation of a proposed final rule would be reviewed by the full Ct7mittee, i
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4 PROPOSED tilNUTES OF PROCEDURES ;
SUBC0ttITTEE MEETING provide comments to the NRC Staff regarding prooosed actions which do not require full Committee renort.
It was proposed, for ex-ample, that in some cases the Committee could he asked only to en-dorse the transmittal of Subcommittee reports as Subcommittee com-ments without the need for full Committee review of the specific matter and development of Committee comments.
It was noted that sone Subcommittees already exercise such authority on an "ex-officio" basis in some areas and it works quite well.
Use of consultants The manner by which the Committee makes use of consultants was discussed.
It was noted that several senior ACRS consultants are considered the equivalent of ACRS members in the conduct of Sub-committee meetings.
Assigning them to ACRS Working Groups along with other experts (e.g., selected members of the NRC Staff, ACRS Fellows, etc.) might be a useful way to supplement Subcommittee activity.
Such an arrangement was used in the preparation of ACRS report on Reactor Pressure Vessel Intearity (1971) and worked well.
All members of the task force would have equal rights including the right to vote regarding decisions of the groun. This would require a decree of colleaiality in their conclusions rather than divergent and sometimes conflicting reconmendations/ opinions with which the Committee and NRC Staff must deal.
The Subcommittee members concluded that ACRS use of consultants at the discretion of the Subcommittee chairman as is now done, is appro-priate.
Meetings with Commissioners It was noted that Chairman Palladino has asked that ACRS meetings l
j once aqain be scheduled with the Commission rather than the Chair-man.
This will be implemented.
Use of ACRS meetings with the Commissioners as an opportunity to present a convincinq case regarding the basis for ACRS views, the degree of concern, etc. was discussed.
Concern was expressed by Dr. Kerr regarding the adversary relation-ship such briefings might create with the NRC Staff.
He suggested I
that implementation of ACRS recommendations are in large part dele-gated to the Staff by the Commission, and it should therefore be left to the NRC Staff to interface with the Commissioners, as ap-l propriate.
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PROPOSED MINUTES OF PROCEDilRES !
SUBCOMMITTEE MEETING Dr. Siess expressed his belief that it was not appropriate for a collegial body to designate a member (or selected members) to speak on behalf of the Committee except on rare occasions (e.g., Con-gressional testimony). A collegial body must express its views in written form even though it may be cumbersome.
Improved ACRS reports, reolies may be aooropriate, if considered necessary to provide additional information to the Commissioners regarding Committee recommendations. Written replies to Commission questions can and has also been used as a mechanism to address their concerns /
questions.
Items identified for discussion with the Commissioners by the ACRS should be limited to items of substantive concern to Con-mittee members.
In the past some items discussed have lacked a notable level of enthusiasm by the Committee members.
Preparation of ACRS reports Subcommittee members endorsed the attached Guide for content / scope of ACRS Project Reports.
Distribution of documents to ACRS members Subcommittee members endorsed a proposal to terminate distribution of project related Category B documents received after the Commit-tee's CP review has been comoleted and before the OL review has begun (e.g., reports regarding construction deficiencies, etc.).
These documents represent approximately 40% of the 1200 Category B reports distributed selectively by the ACRS Office each month.
A more selective distribution of Category B documents, received after the OL review, was endorsed. The ACRS staff will review the selective distribution list consistent with these suggestions (e.o., documents related to technical specification changes, amendments, environmental qualification of equipment, etc. have little interest while LER's, P90's, SECY's, etc. are of consider-l able interest).
l III) Management /Prioritization of ACRS Generic. Activity Several alternates were discussed for improved management of the Committee's generic activities including:
" Established" Generic Items (e.g., those on the NRC/ACRS list of generic items)
(a) The ACRS Generic Items Subconmittee will assign generic items to topical subcommittees bearing in mind the importance of the iten, workload of the topical subcommittee, etc.
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PROPOSED *11NUTES OF PROCEDURES I SUBC&tMITTEE MEETING (b) ACRS topical Subcommittees will select from the list of Es-tablished Generic Items (EGI's) those items they consider of high priority.
(c) The Generic Items Subcommittee will provide oversight of gen-eric matters handling those itens it is competent to deal with and assigning others to topical Subcommittees at ap-propriate in much the same manner as the ACRS Subconnittee on Requlatory Activities provides oversight regarding proposed rules and regulatory guides.
(d) The ACRS Executive Director will assign priorities for generic work.
The Subcommittee members endorsed Alternate C.
In this connection the Generic Items Subconnittee should work up e list of priorities for those items that are already established generic issues, e.g., USI's, Task Action Plan Items of priority A, B, and C.,
etc.
Newly / proposed potential generic items (e.g., proposed by individual XCR5 menbers, etc.)
(a) Topical Subcommittees would be expected to conduct a prelimi-nary evaluation of potential generic items raised by ACRS mem-bers, etc. and report to the ACRS regarding their disposition (e.g., pass on to the NRC Staff for action, take no further action hecause of low risk-reduction potential, etc.).
(b) The ACRS Generic Items Subcommittee would cenduct a preliminary evaluation of proposed / generic items and, witn the Committee's concurrence, proceed with further action (e.g., refer to the NRC Staff for action, assign to a topical ACRS Subcommittee for action, etc.).
The Subcommittee members endorsed Alternate (b).
Attachment:
Guide for Preparation of ACRS Reports -
Content / Format / Scope of ACRS Project Reports dtd 11/12/81
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UNITED STATES l/*
NUCLEAR REGULATORY COMMISSION g
il ADVISORY COMMITTEE ON REACTOR SAFEGUARDS e
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,f WASHINGTON, D. C. 20555 p
GUIDE FOR PREPARATION OF ACRS REPORTS CONTENT / FORMAT / SCOPE OF ACRS PROJECT REPORTS ACRS reports on specific projects should deal with the project being con-sidered and recomendations regarding areas needing resolution should ad-dress the priority, specific items of concprn, and degree of ACRS partici-pation in resolution as noted below. Matters of a generic nature should be addressed as they apply to the project being reviewed but project re-ports should not be the vehicle for making generic recommendations to the Comission. Generic matters normally should be handled in a separate report which addresses not only the nature of the concern but also its degree of applicability to specific types or classes of reactors and, if possible, a target date for its resolution and implementation on a generic basis.
Distinction Between " Recommendations" and " Suggestions" In preparing its reports the Comittee should take into account the difference between a recomendation and a suggestion as follows:
Recommendations - the Comittee desires / expects that they will be carried out on the time scale and to the degree defined in the body of the report.
Suggestions - may or may not be carried out by the staff / applicant i
based on their own good judgment. A suggestion would be an exhorta-l tion to good practice but not the equivalent of a recommendation.
The Committee could, for example, suggest that an applicant continue to work on an issue or continue to contribute to the resolution of an issue (e.g., by support of EPRI or an Owner's Group activities) and incorporate such improvements as may be forthcoming when and if they develop. This would not be considered a licensing condition, however.
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Concluding Paragraph 1
1 The concluding paragraph in the Comittee's report will address the need to resolve recomendations in the body of the report as follows:
"The Comittee believes that if recomendations noted above are resolved l
as indicated [1] and subject to satisfactory completion of construction [2]
i and preoperational testing, there is reasonable assurance that the Dreyfus Nuclear Plant can be operated at power levels up to 3500 MW(t) without un-i due risk to the health and safety of the public."
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Notes:
[1] The recommendations in the body of the report should address three aspects as follows:
A) Timing / Priority for resolution Before a license is issued - a major issue which will determine if the basic plant can be built / operated safely.
Before fuel is loaded - an issue with consequences from an in-advertent criticality that are not acceptable.
Before power operation is permitted - an issue with consequences from an accident with limited F.P. inventory which are not ac-ceptable.
Before the first refueling (first year of power operation) -
an item of some concen that must be resolved within a reason-able period of time.
When NRC TMI-2 Action Plan (NUREG-0660 and NUREG-0737),
item XX-XXX has been resolved / implemented When proposed NRC Rule (or Regulatory Guide) XX-XXX has been implemented.
When NRC Task Action Plan Item XX-XXX has been completed.
B) Specific action being recommended (e.g., is a plant change needed or is further study needed)
ACRS recommends that system (or plant) design (or operational /
inspection / testing) changes should be incorporated to... -
a problem does exist and ACRS believes it should be fixed by a change in plant design, operation, etc., with the priority noted in A), above.
ACRS recommends (further) consideration of - a problem may exist and, if it does, needs resolution with the priority noted in A), above. Further study / evaluation is needed to determine if a problem does or does not exist and an appro-priate fix. The Committee should indicate if the study is to be done by the NRC Staff and/or the applicant.
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t 4 C) Degree of ACRS Involvement ACRS plans / desires to review the prooosal - should be re-ferred to the ACRS for review with tne priority noted in A),
above.
ACRS desires to be kept informed - ACRS should be informed of resolution in writing. This will provide an opportunity for the Committee to take whatever action appears appropriate.
should be resolved so it is satisfactory to the NRC Staff -
ACRS will rely on staff for resolution. ACRS will be informed of resolution by Supplemental SER and related Category B docu-ments.
[2] The list of items in the concluding paragraph that need to be completed before operation have traditionally been limited to " completion of construction and preoperational testing" since these are areas in which the Committee relies on I&E to make a determination after the ACRS review has been completed.
It was agreed during the 252nd ACRS meeting that this list can/should be ex-panded to include any other substantive items which will be completed fol-lowing the Committee's review (e.g., staffing of a nuclear plant) depending on the specific situation at the particular plant under consideration.
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