ML20041C634
| ML20041C634 | |
| Person / Time | |
|---|---|
| Issue date: | 02/26/1982 |
| From: | Jordan E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML19291F701 | List: |
| References | |
| NUDOCS 8203020401 | |
| Download: ML20041C634 (4) | |
Text
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NUCLEAR REGULATORY COMMISSION a
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WASHINGTON, D. C. 20555
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FEB 2 61982 MEMORANDUM FOR: Victor Stello, Jr., Chairman Committee to Review Generic Requirements FROM:
Edward L. Jordan, Director Division of Engineering & Quality Assurance, IE
SUBJECT:
MINUTES OF CRGR MEETING #7 My comments related to the subject minutes are directed toward the final version of the Committee's recommendation on Emergency Response Capability which was transmitted by your memo dated February 11,1982.
My comments do not affect my position of endorsement expressed during the February 3,1982 meeting. The comments are intended as further improvements to a complex document which has the potential for far-reaching impact on the NRC staff and industry actions on Emergency Response. A brief explanation of the purpose or reason for each proposed modification and a comparative text revision is provided in the enclosure.
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ordan, Director Divisi of Engineering and Qual y Assurance Office of Inspection and Enforcement
Enclosure:
Proposed Modification to Emergency Response Capability cc w/ enclosure:
R. C. DeYoung, IE B. K. Grimes, IE D. G. Eisenhut, NRR D. B. Mausshardt, NMSS R. M. Bernero, RES C. J. Heltemes, AE0D J. Scinto, ELD E. B. Blackwood, DEDROGR egg 3gg[gh g
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Enclosure Proposed Modification to' Emergency Response Capability 1.
The wording of the policy statement may diminish the value of REG Guides and NUREG reports as a side effect of removing the ratchet effect. The following rewording is provided:
- p. 3 The following NUREG documents are to be used as information or guidance only, and the Regulatory Guides are to be con-sidered as guidance or as an acceptable a-pessible approach.
to meeting formal requirements. Under-no-efreumstanses-should The items by virtue of their inclusion in these documents shall not be misconstrued as requirements to be levied on licensees or as inflexible criteria to be used by NRC staff reviewers.
2.
Item 4.d., page 4 may be misunderstood to argue against centralizing functions for the SPDS. A preferable wording is as.follows:
- p. 4 Acquisition, processing, and management of data for SPDS, control room improvements, and emergency response facilities should be coordinated but-need-net-be and centralized + 'to' the
. extent practical.
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3.
While I fully support the proposed function of negotiating " reasonable and achievable" schedules by agreement between the NRC. Program Manager and each individual licensee, the boundary conditions for such agreements should be provided by the responsible NRC program office.
I propose the following modifications to make that provision:
- p. 2 When the basic requirements for emergency response capabilities and facilities are finalized, they should be transmitted to licensees by a generic letter from NRR, promulgated to NRC staff, and be appropriately incorporated as regulatory requirements (e.g.,
in the Standard Review Plan or by regulation or Order, as needed).
The letter to licensees should request that licensees submit a proposed schedule for completing actions to comply with the basic requirements. Each licensee's proposed schedules would then be reviewed by the assigned NRC Project Manager, who would discuss the subject with the licensee using general implementation goals of the NRC program office and mutually agree on schedules and completion dates. The implementation dates would then be forma-lized into an enforceable document.
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- p. 5 5.
General implementation oonis'should be provided by the responsible NRC program office. Specific implementation f
. plans and reasonable, achievable schedules should be i
established defined by a'greement between the NRC Project i
Manager and each individual licensee. The NRC office responsible for implementing each requirement should develop procedures identifying the following:
- p. 5 6.
The NRC Project Manager for each nuclear power plant is assigned schedule coordination pregram-management respon-sibility for NRC staff actions associated with implementing emergency response initiatives.
The NRC Project Manager is the principal contact for the licensee regarding these-initiatives.
- p. 8 Integration Although prompt implementation of an SPDS is a desired goal, the schedule for implementation should be based on the licensee's judgment as to overall integration of SPDS, control room design review, and development'of symptom-oriented emergency operating procedures, as well as the general implementation goals provided by the NRC program office.
For this reason, licensees should develop and propose a schedule for im)lementation of all three items.
If reasonable, this schedule s1ould be accepted by NRC.
p.12 Integration Although prompt implementation of an SPDS with other aspects of control room design review to follow is a desired goal, schedules for implementa_ tion should be based on the licensee's judgment as to overall integration of SPOS, control room design review, and development of upgraded emergency operating' procedures, as well as the general implementation goals of the NRC program BTfice.
For this reason, licensees should develop and propose a schedule for implementation of all three items.
If reasonable,' this schedule should be accepted by NRC.
4 The description of indicators, equipment and circuitry as being of " reliable design" needs a little more explanation.
I recommend describing the i
instrument quality as control grade as stated in the' proposed revision:
p.13, item 2.b.
The indicators and associated circuitry shall be of reliable design equivalent to control grade but need not meet Class lE, single-failure or seismic quali-fication requirements.
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r i p.13, item 3.b.
The EOF data indications and associated circuitry I
shall be of reliable-design (control grade) but need not meet Class lE, single-failure or seismic qualification requirements.
5.
The environmental control and radiological protection required in the TSC should be expressed more precisely:
p.19 4.
Environmentally controlled to provide normal room air temperature, humidity and cleanliness + appropriate for
' personnel 'and equipment.
p.19 5.
Provided with radiological protection and monitoring equipment necessary to assure-that-radiatien-expesure te-any-persen-werking-in-the-TSE-weuld-net-exeeed-5-Fem w hol e - be dyre r -it s, e q u i v a l e n t-te - a ny-pa r t-e f-t h e - be dy, fe ret h e -d u ratie n-e fe th e-a e e 4d e n t - meet radiological
'hapitability~ requirements of the control room under accident conditions as described in GDC 19, SRP 6.4.
6.
The " current plant records" needed in the TSC and EOF should emphasize drawings, schematics and diagrams as follows:
- p. 20 8.
Provided with accurate, complete and current plant records (drawings, schematics and diagrams) essential for evaluation l
of the plant under accident emergeney conditions.
- p. 23 7.
Provided with up to date plant records (drawings, schematics, diagrams) procedures, emergency plans and environmental information (such as geophysical data) needed to perform EOF functions.
7.
Since radiation protection is not required in the OSC, provisions for relocation of the functions should be included:
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- p. 21 1.
Located onsite to serve as an assembly point for support i
personnel and to facilitate performance of support functions l
and tasks,'If the OSC is not habitable under accident conditions, emergency plans shall provide for relocation of OSC functions at other onsite locations.
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