ML20041C595
| ML20041C595 | |
| Person / Time | |
|---|---|
| Issue date: | 02/18/1982 |
| From: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML19291F701 | List: |
| References | |
| NUDOCS 8203020367 | |
| Download: ML20041C595 (5) | |
Text
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FEB 181982 1
l MEMORANDUM FOR: William J. Dircks Executive Director for Operations FROM:
Victor Stello, Jr., Chairman Comittee to Review Generic Requirements t
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SUBJECT:
HINUTES OF CRGR MEETING #7 1
The Comittee to Review Greaeric Requirements met on Wednesday, February 3, 1982 from 9:00a.m. to 3:00 p.m.
A continuation of the meeting to further discuss item (3) below, was held on Wednesday, February 10, 1982 from 9:00a.m. to 11:00a.m. A list of the attendees are enclosed. The actions of the Comittee are described below:
1.
NRR (Hanauer) described the status of their activities in prioritizing Generic Safety Issues, including TMI Action Plan items under development.
The Comittee noted the progress in these activities and suggested that subsequent briefings would be appropriate to keep CRGR informed concerning NRR's actions to incorporate prioritization into their plans for dealing with the Generic Safety Issues.
2.
In conducting the survey of mechanisms for comunicating new regirements to licensees, the OEDROGR staff noted that new requirements were apparently being imposed by means of frequent changes to the Standard Technical Specifications (STS) in a manner that was not adequately controlled.
In his briefing on this subject, Dr. Hanuaer stated that NRR recognized the pmblem and he described draft office procedures designed to limit the frequency of changes to the generic STS and to better control the case-specific application of the generic STS.
Mr. Novak of NRR discussed the practice of changing Tech Specs on Operating Reactors, noting that the staff frequently imposed parts of the latest version of the Standard Tech Specs on licensees applying l
for license amendments. The Comittee suggested that NRR develop and l
implement office procedures to control the retrofit of current STS on l
operating reactors licensed to earlier Tech Specs.
l 3.
At the request of the EDO, the Comittee reviewed the proposed final rule concerning documentation of differences from the current Standard Review Plan (SECY 81-648). HRR (E. Case and C. Grimes) briefed the Comittee on the background of the proposed rule and NRR's estimates of the costs and safety benefits.
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William J. Dircks The primary safety benefit identified by NRR was that the staff would be able to focus its review on the differences from the SRP and spend less time searching for the differences. Consequently, resources could then be concentrated on the evaluation of the specific differences from the SRP criteria, rather than independently reviewing the SAR in order to identify such differences.
It was noted that an audit review of the descriptive SAR material would still be required to provide confidence that the licensee's identification of differences from SRP criteria was complete and accurate and to develop a proper understanding of the design.
Further, it was acknowledged that in a theoretical sense, the staff would only have to audit the identification of differences, but in a practical se
, it would be necessary for the staff to detemine that each difference was acceptable because of the need to make and defend the necessary staff findings and because any identified difference in an acceptable SAR would set a precedent for other applications.
Although NRR was unable to quantify the safety benefit associated with the proposed rule, they believed that the concentrated evaluation effort would be more likely to identify design deficienties and, thus, could enhance the overall safety of the plant. While acknowledging that this might have a potential for some safety benefit, the Comittee tried to get specific examples of matters that might have had significant safety improvement, had the proposed rule been in place.
It was hard to identify specific examples where the audit reviews now being conducted have proved inadequate with regard to safety and, consequently, where important safety matters embodied in the SRP criteria were being missed or improperly addressed by the applicant and by the staff. Thus, it was difficult to obtain a sense of the degree, if any, f specific safety improvement that may result from the roposed rule.
With regard to the costs in terms of manpower required to implement the l
proposed rule, there were wide divergences between estimates by the NRR l
staff and by industry. Based on discussions with industry representatives, NRR estimated that it would require about 10 licensee staff-years per l
plant to comply with the rule and an additional one to two staff years i
per application required on the part of NRC. The Atomic Industrial Forum estimated that it would require about 10 licensee staff-years to identify and describe differences from the SRP, but that the manpower needed to justify and defend the differences could be an additional 30 or more i
staff-years per plant during the OL review. NRR disagreed with this estimate on the basis that much of the work of identifying and justifying differences from the SRP is part of the nomal OL review process.
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r William J. Dircks NRR believed that the effort was only that of documentation and that no substantial efforts to justify each difference were needed. On the other hand, the industry believed that the SRP contains numerous acceptance criteria that allow subjective interpretation by the staff, and thus, while the staff may know the specific intention, purpose and scope of each criterion, the industry would have to conservatively identify all potential differences and to present analysis sufficient to justify how the pmposed alternative is acceptable for each difference no matter how trivial. Further, the AIF was concerned that essentially all project documentation such as drawings, specifications, analyses, contracts, letters, etc. would have to be specifically reviewed in the context of the rule to assure all differences are properly identified, described and justified.
In an attempt to reconcile the differences in the resource estimates provided to the CRGR, a meeting was convened with the DEDROGR staff, NRR and industry representatives. While some progress was made daring the meeting, it was decided that a further analysis would be made of a recently completed review for which it was estimated that approximately 60% of the SRP was used during the audit review process. Based on this analysis, the AIF staff estimated that an additional resource comitment of about 41 staff-years would be required to implement the rule. For the plants listed in Enclosures 1 and 2 of SECY 81-648 this estimte could require the efforts of hundreds of industry safety staff during the year after implementation of the rule. Based on the results of the NRC survey reported in NUREG 0839 and the vacancy rates (7-24%)
currently existing in the industry, it is expected that a significant adverse resource impact would result.
Attempting to balance costs and benefits on an individual case-by-case basis suggests the rule would not be cost beneficial.* Furthermore, considering the balance on an industry-wide basis, the Comittee believed that the potential exists for a negative impact on safety because the resource needs approaching the magnitude projected for imposing this rule would detract from current safety programs imposed as a result of the THI follow-up activities.
Based on this review, the Comittee reached the following conclusions:
a.
No clear safety benefits have been articulated for the proposed rul e.
Principally due to a lack of recognizable safety benefits.
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William J. Dircks b.
The industry resources needed to comply with the rule would probably fall in the higher part of the 10-40 staff-year per plant estimate range.
c.
Implementation of the rule would adversely impact other ongoing priority safety work and could thereby have an adverse impact on overall nuclear safety.
In view of these conclusions, the Comittee recomended that the EDO pn> pose to the Comission that the rule not be adopted.
During the Comittee discussions, it was pointed out that the rule, as pnposed in SECY 81-648, has an internal inconsistency with respect to second units, which the paper asserts are uncontested.
This is incorrect for most of the second units identified in of SECY 81-648. Nine units are currently part of contested proceedings, and their inclusion in the rule can affect the contested hearings. The paper idicated that a principal goal in the proposed rule was to assure that the licensing process, including the hearing boards, would not be on the critical path. The inclusion of contested units under subparagraph (f)(1)(b) would be inconsistent with this goal. The Comittee noted that this inconsistency would have to be reconciled in any event.
4.
The Comittee met with the Directors of NRR and IE to discuss resolution of the Emergency Response Facility issues. Mr. Denton (NRR) concurred with the January 29, 1982 draft of the Emergency Response requirements prepared by the DEDR0GR staff. Mr. DeYoung (IE) asked for additional time to review the draft document. The following day, Mr. DeYoung con-curred in the proposed document with suggestions for editorial improve-ments.
The Comittee agreed to recommend to the E00 that he concur in the adoption by the Directors of NRR and IE of the proposed Emergency Response Requirements and instruct the Director of NRR to irr.plement them.
Victor Stello, Jr., Chairman Comittee to Review Generic Requirements
Enclosure:
DISTRIBUTION List of Attendees VStello W. Schwink TMurley DEDROGR cf Central File PDR (NRG/CRGR)
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CRGR MEETING NUMBER 7 l
Attendance (2-3-82)
CRGR Members i
Vic Stello Ed Jordan K. Goller (Rep. R. Bernero)
Jack Heltemes Don Mausshardt Darrell Eisenhut Joe Scinto Others Walt Schwink Steve Hanauer Frank Schroeder Warren Minners Mal Ernst Tom Murley John Austin Tom Cox Mat Taylor P. McKee Tom Novak P. Wagner ~
Ed Case Chris Grimes Steve Stern
' Don Skovholt Tom Rehm Chris Grimes T. Gibbon Harold Denton Richard DeYoung EXECUTIVE SESSION ON 2-10-82 (Followup discussions on Doucmentation of SRP Differences - References Mtg. #7) c I
Others CRGR Members Tom Murley V. Stello Walt Schwink Joe Scinto Tom Cox Bob Bernero Beth Hayden Jack Heltemes Mat Taylor Bob Purple (Rep. D. Eisenhut)
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February 19, 1982 MEMORANDUM FOR: Victor Stello, Jr., Chairman Committee to Review Generic Requirements FROM:
Joseph Scinto, Deputy Director Hearing Division, OELD
SUBJECT:
MINUTES OF CRGR MEETING #7 I have the following comments on the subject minutes.
The minutes with respect to item 3, the SRP rule, do not reflect the discus-sions concerning the potential for limiting the proposed rule to facilities whose FSAR has not yet been prepared.
For these facilities, there was some discussion that the costs, in tenns of manpower, might be substantially less than those discussed with AIF and those based on the recently completed review; there might also be benefits not directly related to safety, such as procedural benefits in hearings, etc.
In the absence of information with respect to the benefit or cost of the rule, if limited to plants whose FSAR had not yet been prepared, the Committee did not attempt to reach a conclu-sion on the matter of a limited version of the proposed rule. Nonetheless,
I think the minutes should reflect this discussion.
The minutes with respect to item 4 should more clearly state that the proposed Emergency Response requirements which have been adopted by the Office Directors (and which we are recommending that the ED0 concur in) are those attached to Mr. Stello's February 11,1982 memorandum.
The January 29, 1982 draft referred to in the ?rior paragraph was generally accepted in principle with various comments which were incorporated in the Februa ry 11, 1982 draft. The February 11, 1982 draft is the draft sent to the CRGR for review and that is the draft which the Office Directors should have adopted.
[ s Josliph Scinto, Deputy Director Hearing Division, OELD cc:
R. Bernero
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D. Eisenhut J. Heltemes E. Jordan D. Mausshardt T. Murley W (b~
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