ML20050C602

Use of Insp Data in Licensing Process

ML20050C602
Person / Time
Issue date:	04/18/1977
From:	Office of Nuclear Reactor Regulation
To:
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ML20050C595	List: ML20050C594 ML20050C596 ML20050C602
References
FOIA-81-478 NUDOCS 8204090147
Download: ML20050C602 (18)

Text

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m i;;y PROGRAM PLAN USE OF INSPECTION DATA IN THE LICENSING F.90 CESS Office of Nuclear Reactor Regulation c-April 18, 1977 (i

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9 USE OF INSPECTION DATA IN THE LICENSING PROCESS Table of Contents y

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INTRODUCTION 1

PATHS OF INFORMATION FROM THE OFFICE OF INSPECTION AND ENFORCEMENT 2

USE OF DATA AND INFORMATION 7

Operations Phase 8

Basic Information Feedback 9

Rapid Reporting Feedback 10 a

Transfer of Lead Responsibility 11 Pre-Operation Phases 16 SUDMART 18

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ATTAC191ENTS - DOR Memorandus No.,2 - DOR Hemorandus No. 4

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r-INTRODUCTION The Commission requested as a follow-up action to the FY1978 budget development that a program plan be. developed "to establish and implement procedures for using inspection data in the licensing 1

process." This document is the response to that request.

Effective liaison exists between the Offices of Inspection and i

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Enforcement (IE) and Nuclear Reactor Regulation (NRR).

Frequent I

meetings on both technical issues and policy issues are held between IE Headquarters and NRR personnel.

Coordination meetings are held at least monthly between senior IE Headquarters and NRR staff members.

These meetings relate to both daily occurring work items and methods to Lmprove the overlapping inspection and enforcement and licensing functions. They provide primary means for a continuing assessment of the effectiveness of the required interfacing between IE and NRR.

This progran plan is a summary of the procedures used to assess and apply information and data received from IE.

The information is used in frameworks established ?. chin NRn. Ho new management methods or procedures are proposed.

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The reorganization o,f NMR in January 1976 provided changes that enhancedsubstantiallythefocalpointsdithintheOfficeforusing information and data from various sources. Since that tLme further structuring hea been made within the Divisions of NRR to further align work scheduling and intra-divisional responsibilitica.

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2 PATHS OF INFORMATION FROM THE OFFICE OF INSPECTION AND ENFORCEMENT Several routes of consunication have been established between IE and NRR.

Non-routine information received orally from licensees and other sources is evaluated by IE and that of significance is transmitted to NRR. Written information of both a non-routine and a routine nature is also analyzed by IE and, if deemed appropriate, NRR is advised of the evaluation.

NRR also receives copies of all written information from the licensees as well as IE inspection and investigation reports.

Figure 1 outlines this process of collection-asses went-transmission of information used by IE.

Inspection reports (Block A in Figure 1) serve as one of the primary detailed feedback mechanisms between IE and NRR. They are received routinely by NRR for information and appropriate action.

Rapid reporting (Block B in Figure 1) to Regional Offices is required of licensees for non-routine or off-normal events. These reporting re-quirements stem from License Conditions. Technical Specifications, or the regulations. The compilation in Regulatory Guide 10.1 identifies these requirements.

Events of particular interest to NRR for which immediate

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reporting to Regional Offices la required incluje those reportable occur-rences and special interest' events noted in RegJlatory Guide 1.16, con-struction deficiencies (10 CFR 50.55e), and incidents (10 CFR 20.403).

Such information, which is required to be received by the Regional Office within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the event is transmitted to NRR by one or more of the following three pathet u

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Information received by telephone by IE' Headquarters, if deemed appropriate, is relayed by telephone to NRR.

2.

With the sanction of IE Headquarters a Preliminary Notification may be published.

3 copies of Daily Reports prepared by each Regional Office are transmitted to NRR by IE Headquarters.

These reports contain all significant rapid-reported items received by the Regional Offices.

Following the evaluation of an event, IE may determine that an inmediate site inspection or investigation is appropriate.

For lesser significant events tha initial investigation and follow-up may be deferred to a routine IE inspection.

Copies of all IE inspection and investi-gation reports (Block A) are sent to NRR.

As outlined on sheet 2 of Figure 1, licensee reports and IE inspection reports are reviewed concurrently in the cognizant Regional Office and IE Headquarters.

Licensee reports include those related to both non-routine events and routine events.

Re9erts of non-routine eveM;c include those items requiring rapid reporting (Block B) by telephone, telegraph, and facsimile notes, as well as written reports (Block *' in Fi ure 1).

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reports of routine ergnts include startup reports, in.;ervice inspection reports, containment it,tk rate test reports, and summaries of accumulated i

data such as annual operating reports.

The joint assessment by the region and IE Headquarters may result in the publication of an IE Circular or bulletin.

These documents are of generic nature, directed to a class of licensees (BWR or fdR, CP or OL), and address

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subjects of potential safety significance. They may request informa-tion from licensees (Bulletin) cn* provide information to licensees (Circular). Draft versions of these documents are transmitted to the cognizant NRR Divisions for review and comment prior to issue.

In some instances, information received by licensee replies to Bulletins may form the basis for a Transfer of Lead Responsibility from IE to NRR for for consideration of modifications to licensee conditions.

In other in-stances, Bulletins may be issued to obtain further information, to assist NRR in evaluating a previously issued Transfer of Lead Responsibility.

Such transfers are executed with NRR concurrence when it is agreed that one or more of the following is applicable to a particular problem or event:

1.

An unreviewed safety issue; 2.

Exemption from a regulation; 3

Significant change in modes of facility operation; 4.

Change to Technical Specifications; or, Technicalconsiderationsbeyondtb7scopeofIEstaff 5

normal activities.

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Summarily, IE provides the foi swing basic paths for information to NRR:

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Inspection Reports 2.

Telephone calls 3

Preliminary Notifications 4.

Daily Reports 5.

Circulars and Bulletins 6.

Transfers of Lead Responsibility.

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5-sheet 1 cf 2 IA Routine IE Inspection m

Inspections A

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Investigations l

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Action to sheet 2 Determines Need for Immediate Site Inspection i

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Rapid Reporting Non-Routine to to sheet 2 t

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Events IE Regional Office v

1' ir 3r Daily Recommends Telecen to Reports to IE IE Headquarters Headquarters (option) t Preliminary llotification Telecon to NRR (option)

Finura 1 - IE DATA ACQLlISITION PROCESS l

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= i USE OF DATA AND INFORMATION FROM THE OFFICE OF INSPECTION AND ENFORCEMENT Six basic methods of communicating inforsation from IE to NRR were outlined in the previous section. The responsible Division of NRR to which information is primarily directed is determined by the phase of the IE inspection program from which the data is derived.

An outline of the five-phase inspection program is presented below.

1.

fre-Construction Permit Phase - This effort is applicable to each nuclear power plant from the time formal notification is given to the NRC of the utility's intent to build a nuclear unit until a construction permit (CP) is issued.

The basic purpose is to ensure that the required Quality Assurance (QA) program is effectively implemented for activities related to the preparation of the Preliminary Safety Analysis Report (PSAR), and the design, procurement, and construction of safety-related structures, systems, and components.

This phase also includes, if apprc-priate, inspection activities related to Limited Work Authorizations (LWA).

2.

Construction Phase - This inspection phase assures that all safety-related site preparations and construction activities meet agency requiresents and licensee commitments.

3 Pre-Ocerationni festina and Ooerational Precaredness Phaai - This phase becomes effective about 18 months before issuance of the operating 11-conse (OL). The purpose of this program is to verify that pre-operational tests for systesa, subeystems, and components related to safety are planned and conducted; and that the results of these tests demonstrate that the plant is ready for operation.

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Startun_Testina Phase - This inspection effort becomes effective about 6 months before issuance of the OL and continues until about one month after the facility reaches full power status. The purpose of these inspections is to verify that systems and components important to safety are tested under operating and transient conditions to demon-a atrate the design requirements Laposed by the NRC.

5.

Orerations Phase - These inspections become effective when an OL cr fuel loading authorization has been issued.

The purpose is to deter-eine whether or not the licensee's management program is effective in assuring the facility is being operated safely and in confor=ance with regulatory requirements.

Operations Phase The Division of Operating Reactors (DOR) assumes the responsibility within the NRR for a nuclear plant at the time of significant power licensing.

The Liceasing Project Manager. Division of Project Management (DPM) retains the responsibility for the plant during the early stages of the Operations Phase inspections by IE, and say in oorjunction with the succeeding Operating Reactors Project Manager (ORPH) manage changes to the Technical Specifications or other license amendments, until formal transfer of the plant from 0FM to DO R.

Essentially all of the information and data received from IE during this inspection phase is directed to the Division of Operrting Reactors.

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xa 9-Ranie Information Feedback - Inspection reports serve as one of the primary detailed feedback sechanises between IE and DOR. They are re-ceived routinely by the ORPM for information and appropriate action.

Additional information may be obtained by the ORPM from the IE Head-quarters contacts or the regional inspectors. The ORPM and his super-visor have the responsibility to consult with specialists in Operational Technology on issues appearing in inspection reports that may suggest licensing action.

Additionally, in the areas of environmental monitoring, radiological accident analysis, radiation protection, and waste treatment methods and plant effluents the Environmental Evaluation Branch of Oper-ational Technology conducts continuing assessments of inspection reports.

Addit'onal information or data required by these specialists may be ob-tained th ough the ORPM from the IE Headquarters contacts, the inspectors,

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DOR project managers and technical specialists also review all LERs. The reviews by ORPMs pertain to assigned cperating facilities; whereas reviews by specialists in Operational Technology relate to affected disciplines and plant equipment assignments. Any requirement for follow-up information stemming from these reports is accommodated by the ORPM. This review of event reports serves as a means to keep DOR stalf informed of plant operations and provides a means for ob-serving trendt in equipment and process cerformance, radiological releases, and human errors. Such assessments, which may result from the review of' inspection reports and licensee event summaries, provide naJaible bases for discussiot,s with IL that may lead to special inspection emphasis, enforcement, or licens!ng actions.

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- r Racid Reoortinn Feedback - Information reported rapidly by IE includes telephone calls to cognizant DOR personnel. These calls are general y made to the ORPM by the IE Headquarters contacts or by IE regional in-spectors. They are made at the option of IE when it is believed that a significant safety issue may be involved or when an event may be of y-high public interest.

If deemed appropriate by IE a call may also be made t1 the responsible branch chief, the Assistant Director for Operating Reactors (ADOR), or to the Office of the Director, DOR. Ordinarily, p

the disnosition of the information rests with the ORPM and the cognizant ORPM branch chief. The ORPM may call the Regional Inspector of the affected region, cognizant Headquarters Personnel, or the licensee for additional details concerning the event. On occasion IE uay re-quest through the ORPM aid from the Assistant Director for Operational f

n Technology on these rapidly reported events. Oa such issues the t

Director, DOR is immediately informed.

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Preliminary Notifications published by IE are also an information vehicle. They serve primarily as a written means of prompt dissemination L: 31 of information to the Commissioners and other NRC management on matters of high potential interest to the NRC or the public.

These notifications are sent to the Director, NRR, and are available immediately for infor=a-s tion to the Director, and the Assistant Directors, DOR.

Daily Reports peblished by each IE Regional Office are forwarded by IE Headquarters to the Director, DOR. These reports contain summaries of prise events for which rapid reporting may be required.

Ihese reports contain the first information received related to significant events which are subsequently published as Licensee Event Reports (LER).

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Subsequent follow-up, if deemed desirable by the Director, DOR may be conducted by the ORPM through the IE Regional Office, IE Head-quarters, or directly with the licensee.

Transfer of Lead Reseensibility - A transfer of lead responsibility to DOR will in most cases involve substantial technical assessment cf the concern and perhaps licensing actions.

The concern may be related tc a specific plant or it may be " generic" in nature, i.e.,

applicabic to several plants. Depending upon the scope of the concern, the assigned ORPM may conduct the evaluation, or may require assistance from Opera-tional Technology.

Figure 2 outlines the work process related to major technical 1

assessments which require technical specialists.

The ORPM performs two basic functions to initiate work on such issues.

First, a recuest

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for technical assistance is prepared and discussed with cognizant branch chiefs of Ope ational Technology.

The ORPM, under the supervision of his branch chief, determines the priJary and supporting technical dis-ciplines required to conduct the evaluation.

The assigned section leader or other senior staff member of the Operational Technology branch providing primary review effort may serve as the technical coordinator for the specific ~. issue. Review specialists are assigned from other technology branches as required. Jacondly, the ORPM as-scaes the lead role in preparing letters to the affected licensees requesting additional informat ion or analyses, if required.

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f inquiries are coordinated with the assigned technical reviewers and r

other affected supervisors of Operational Technology, as well as with project management supervision.

IE is provided copies of thesJ re-quests for information and may be requested by DOR to perform additional l

plant investigations, or other tasks related to data collection and inter-regional coordination.

k During this time frame it is the responsibility of all D0R personnel assigned to the specific project to enter their assignment rnd projected completion date with supervisory concurrence into the Technical Assistance Control System (TACS).

Future iterations on projected completion dates for each review assignment may be required.

l The TACS is a computer-based work scheduling and accounting program that is updated weekly.

The ORPM serves a lead role in 1) obtaining infor=ation as ex-peditiously as possible from licensees, 2) compiling the licensee's informatien and data for re.ily reference and use by the technical review team, 3) advising the assigned technical reviewers of general programmatic, legal, and other requirements that may ultimately affect the implecentation of the resolution of the issue, 4) providing required interfacing with IE, and 5) continuously assessing technical review progress and recommending to all affected parties needed schedular adjusteents.

It is the responsibility of the assigned technical coordinator to coordinate all technical review aspects of the issue.

He inter-faces with the project manager.

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. At the option of the assigned technical coordinator contractual assistance may be obtained for those aspects of tne problem requiring resources not otherwise available. The contractual assistance is generally H

acquired through existing arrangements with national laboratories.

In some cases special assistance is obtained through new contracts er by retaining private consultants.

Early during the information and data collection phase or during the evaluation prccess a feedback memorandum is prepared on each lead transfer subject that appears to De significant to the licensing process.

i These memoranda are coordinated with the Office of the Director, DOR and are transmitted to other Division Directors of the NRR for considera-tion in licensing reviews.

This procedure is outlined in D0R !!e=orandum No. 2, " Feedback of Information and Data from Operating Reactors to Licensing Reviews," July 6, 1976. is a copy of this DOR

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management directive.

1 During the evaluation of a Transfer of Lead Responsibility item it I

may be determined that no significant safety or environmental issue is I

involved.

However, in these instances the information may be of general interest to senior management within NRR.

In these cases, a synopsis of these events is provided as cutlined in DOR Memorandum No. 4,

" General Information from Operating Reactors," October 8,1976.

Enclo-sure 2 is a copy of this DOR management directive.

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s Typically, resolution of problems stemming from Transfers of Lead Responsibility include one of the following:

1.

A new safety requirement that must be approved by the Regulatory Requirements Review Committee with subsequent changes to Technical Specifications; 2.

Changes to Technical Specifications - under existing requirements; 3

Plant Modifications; 4

Changes to Plant Procedores or Operating Modes; or, 5.

No action required.

t The current status of a lead transfer ites may be obtained by IE or other interested parties from the assigned ORPM. Status may also be determined by reference to the Status Summary Report - Pink Book which is updated bimonthly. A written statement of the final resolution of each issue is also sent to IE.

i Other operational concerns or issues arising that are related to operating reactors are also managed as outlined in Figure 2.

These issues are more likely to be generic. These concerns may be identified by one or more of the following means:

1.

Issues originating from staff safety reviews; 2.

Issues raised b'y the ACR3; x

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New NRC regulatiods; 4

Safety issues raised 'by nuclear vendors; 5.

Issues identified by licensees; or, 6.

Operating information from fo$eign reactors.

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. Pre-Operation Phases From the standpoint of NRR, information feedback from IE during the entire period prior to actual plant operation is treated as a single, pre-operations phase.

During this period a Licensing Project Manager (LPM), Division of Project Management (DPM), is assigned responsibility for safety aspects of the nuclear plant, while an Environmental Project Manager (EPM). Division of Site Safety and Environmental Analysis (DSE),

is assigned responsibility for environmental aspects of the nuclear plant.

During this period, inspection reports serve as one of the primary detailed forms of feedback between IE and NRR.

They are received routinely by the LPH and EPM for information and appropriate action.

Additional information may be obtained by the LPH or EPM from IE Head-quarters contacts or regional inspectors. The project managers have the responsibility to consult with appropriate technical specialists l

in the Division of Systems Safety (DSS), the Division of Site Safety i

and Environmental Analysis (DSE), or within DPM on issues appearing in inspection reports that may have an impact on the licensing process.

Feedback from IE to NRR during the period prior to plant opera-tion may take several forms and is noted by several milestones during the licensing process On receipt of an application for a CP, an NRR pre-docketing re-view is conducted to determine whether the application is sufficier.tly complete to warrant docksting. Concurrent with this review, IE performs specific inspections and provides to DPM written findings on whether the applicant's QA program is being suffiolently implemented to warrant docketing.

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