ML20045E837

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Provides Commission W/Current Status & Update of Schedule for Completing Guidance Documents Describing non-power Reactor Licensing Process as Discussed in SECY-91-160
ML20045E837
Person / Time
Issue date: 06/28/1993
From: Taylor J
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:
References
SECY-93-182, NUDOCS 9307060119
Download: ML20045E837 (3)


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POLICY ISSUE June 28, 1993 SECY-93-182 (Information)

FOR:

The Commissioners FROM:

James M. Taylor Executive Director for Operations

SUBJECT:

STATUS OF THE PROGRAM FOR PRODUCING GUIDANCE DOCUMENTS FOR THE NON-POWER REACTOR LICENSING PROCESS PURPOSE:

To provide the current status and update of the schedule for completing guidance documents describing the non-power reactor (NPR) licensing process, as discussed in SECY-91-160. The Commission directed the staff to prepare these guidance documents by a staff requirements memorandum (SRM) of April 11, 1991.

SUMMARY

Significant progress has been made on the effort to develop guidance documents for the NPR licensing process. Because of a shortage of qualified contractor personnel with NPR knowledge and experience in regulation, operations, and safety analysis, the original schedule, which called for a completed document issued for public comment by April 1993, has been extended by an estimated 18 months.

BACKGROUND:

The SRM of April 11, 1991, directed the staff to prepare a NUREG document or other form of guidance that (1) identifies the regulations that apply to NPRs, (2) provides direction to licensees on all aspects of the NPR licensing process, and (3) describes procedures that the staff will use when reviewing ai, application for a license.

SECY-91-160 responded to the SRM and identified the following three tasks:

(1) develop NPR regulatory guidance, (2) consider selective changes to regulations, and (3) consider electronic updates. A program and schedule for completing these tasks was issued in SECY-91-160.

NOTE:

TO BE MADE PUBLICLY AVAILABLE l

IN 10 WORKING DAYS FROM THE CONTACT:

DATE OF THIS PAPER A. Adams, Jr., ONDD/NRR 504-1127 lob I

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The Commissioners DISCUSSION:

Task 1:

Develop NPR Regulatory Guidance The staff is developing and will publish guidance that (1) identifies the regulations that apply to NPRs, (2) provides direction to licensees on all aspects of the NPR licensing process, and (3) describes procedures that the staff will use when reviewing an application for a license.

The staff is preparing two NUREG documents, a " Format and Content for Applications for the Licensing of Non-Power Reactors" (format and content) to provide licensing guidance to applicants and licensees and " Safety Analysi; i

Report Review Plan and Acceptance Criteria" (SRP) to provide guidance to the staff.

The two documents are being prepared together.

The original schedule for these documents has been extended by a shortage of people who are knowledgeable in NPR safety analysis, operations, and regulation.

This project requires a unique combination of background and skills which includes experience in operation and safety analysis of an NRC regulated NPR and experience equivalent to an NRC NPR Project Manager or an NRC contractor performing safety evaluations of NPRs.

The contractor for this effort, Idaho National Engineering Laboratory (INEL), had three employees (two full time and one half time) who had the knowledge and experience to work on this effort. This regulatory guidance document effort was in addition to the normal INEL NPR licensing work load. During the peri' of the contract, one full-time employee resigned and another retired (unexpectedly) affecting the schedule for developing the regulatory guidance document.

INEL nas been actively seeking replacements, but available people who meet the requirements are not currently available for full-time employment.

INEL, using a part-time subcontractor and the half-time employee, has revised its schedule to complete their effort.

This is reflected in our revised completion date.

The staff originally proposed to offer guidance that identifies which regulations apply to NPRs as a database.

After careful consideration, the staff is proposing to include this guidance as an appendix to the format and content and review plan guidance.

The staff anticipates that this information will not require frequent updating and will be of greater utility to NPR licensees if appended to the guidance.

The initial review of 10 CFR Part 50 is complete and the other parts of the regulations will be reviewed and issued subsequently.

Appropriate NPR American Nuclear Society (ANS) standards and NRC regulatory guides are referenced in the NPR guidance documents being prepared by the staff.

Task 2:

Consider Selective Changes to Regulations During the development of the guidance discussed in Task 1 above, the staff considered the impact of regulations on NPRs and the need for corrections or changes.

No problems were identified in the regulations that, at this time, would require a rulemaking effort.

O The Commissioners The NRR staff has been reviewing proposed rulemakings to ensure that, if the rules are appliable to NPRs, they appropriately consider NPR needs and do not inadvertently have a negative affect on NPRs.

Task 3:

Consider Electronic Updates The staff considered electronic updates of the guidance documents.

The staff determined that it will infrequently need to update the guidance documents and that offering these documents in electronic format does not give any distinct advantage over published copies.

Offering the regulations that apply to NPRs in the form of a database was discussed in Task I above.

CONCLUSION:

A complete set of guidance documents for licensee comment will be ready by October 30, 1994.

Nine chapters will be completed by the end of 1993 and the remaining 10 chapters by October 30, 1994.

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$es lor xecutive irector for Operations DISTRIBUTION:

Ccamnissioners OGC OCAA OIG OPP REGIONAL OFFICES EDO SECY