ML20054C912
| ML20054C912 | |
| Person / Time | |
|---|---|
| Issue date: | 02/10/1982 |
| From: | Mark King NRC OFFICE OF MANAGEMENT AND PROGRAM ANALYSIS (MPA) |
| To: | Brach B, Norian P, Oklesson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE), Office of Nuclear Reactor Regulation, NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML19219A803 | List: |
| References | |
| FOIA-82-103 NUDOCS 8204220097 | |
| Download: ML20054C912 (2) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION h
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FEB 10 1932 MEMORANDUM FOR:
TMI Action Plan Coordinators FROM:
Michael E. King, MIS Analyst
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Management Information Branch Office of Management and Program Analysis
SUBJECT:
TMI ACTI0t1 PLAtt TRACKIfiG SYSTEM (APTS) -
JAtlUARY UPDATE Enclosed are copies of the TMI action items that pertain to your respective office.
Please review them and make any last-minute changes that need to be factored in. We anticipate issuing the
" street" version of this issue next week.
Please note the following:
1.
Completed and/or subsumed items are not included in this package.
2.
Each item having a request for schedule change pending before the Commission is so notated following " Issues."
Please return the marked-up copies to me at 12704 MtiBB by February 16, 1982.
If you have any questions, please call me on X27039.
Yf EIN
') Michael E. King, MIS Anaisst
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LA Management Information Branch Office of Management and Program Analysis
Enclosure:
TMI Actica Items N
8204220097 820326 PDR FOIA SHOLLY82-103 PDR t
a ETS DISTRIBUTI0ft fiRR
- Paul florian Bill Brach IE RES
- Ed Oklesson AE0D - Fred Hebdon IP*
- Joseph Lafleur OPA
- Frank Ingram ADM
- Peter Goldman I
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r// 2-HOV 0 41981 MEMORANDUM FOR:
Harold R. Denton, Director, NRR
~ Robert B. Minogue, Director, RES Richard C. DeYoung, Director, IE John G. Davis, Director, NMSS Carlyle Michelson, Director, AE0D James R. Shea, Director, IP Daniel J. Donoghue, Director, ADM Howard K. Shapar, Executive Legal Director Joseph J. Fouchard, Director, PA Kenneth E. Perkins, Technical Asst, ED0 FROM:
William J. Dircks Executive Director for Operations
SUBJECT:
TMI ACTION PLAN ITEMS NRR is currently reviewing Priority 1 TMI Action Plan items still in the development phase to reassess both priority and deadlines.
(See. Attachment 1, memo Murley to Distribution dated October 23, 1981.) A similar effort should be carried out by all offices having TMI Action Plan items in the f..
development phase and expanded *to cover all Priority 2 and 3 tasks for which
- s. s resources have been provided in the FY 1982 budget.
Therefore, please review all such development items under your purview and propose revised schedules and changes in priority, including the elimination of items. My memorandum of June 3,1981 (Attachment 2) sets forth the procedure to follow for changing Action Plan schedules. 'is an example of a proposed change justification.
Send your proposed changes to MPA by C.0.B.
November 13, 1981.
MPA will then collate the changes and prepare a Commission paper requesting approval.
William J. Dircks Executive Director for Ope, rations Attachments:
As stated cc w/ attachments:
D. Allison, IE P. Norian, NRRs P. Ting, RES F. Hebdon, AE0D M.
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Contact:
' R. A. Hartfield, MPA 49-27834
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UNITED STATES E"'
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NUCLEAR REGULATORY COMMISSION
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,g October 23, 1981 v
MDiORANDUM FOR:
S. H. Hanauer, Director, Division of Human Factors Safety R. J. Mattson, Director, Division of Systems Integration R. H. Vollmer, Director, Division of Engineering D. G. Eisenhut, Director, Division of Licensing B. K. Snyder, Progra:n Director, TMI Program Office FROM:
T. E. Murley, Director Division of Safety Technology SU3 JECT:
CHANGES IN BASELINE SCHEDULE FOR PRIORITY I TMI ACTION PLAN ITB4S UNDER DEVELOPMENT The status of the Tiil Action Plan items under development was discussed with the Canmission on September 30,1981 (SECY-81-568).
At this briefing, a total of 35 Priority I items was identified with NRR having the lead responsi-bility for 15 items.
Most of the itens were in either the yellow status (schedule slip up to 1 year) or red status _..(schedule slip over 1 year).
The Commission was infonned that the schedules for these items were under review, and that new schedules would be established for stxne items.
The re-baselining of the Priority I items under d,evelopment was discussed at the recent management retreat.
It was decided that new schedules would be established within one month for all Priority I items under development.
Accordingly, you are requested to prepare the required infomation for each Priority I item in either yellow or red status.
The items for NRR are identified in Table No.' 1.
The infomation should be provided to this office by November 4,1981 in the fomat specified in the memorandum from W. J. Dircks to the Office Directors, dated June 3,1981 (copies of the fonn are enclosed).
The' Division of Safety Technology will prepare the NRR infomation for transmittal to the EDD.
Items are also identified in Table No.1 for which re-baselining infomation has previously been provided; no further infor-mation is requimd on these items.
Y Thanas E. Murle
- cuor Division of Safety Technology
Enclosures:
As Stated y
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w/ encl osu res H. Denton P. Vineyard p
T. Rehm R. Capra
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F. Schroeder J. Zwolinski D. Verrelli
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. o '* a TABLE NO. 1 PRIORITY I ITEMS UNDER DEVELOPMENT ASSIGNED TO NRR Item Status Division I. A. 2. S Red DHFS I.A.2.6(4)
Yellow DHFS I.A.2.6(6)
Red DHFS I.A.4.1(2)
Yellow DHFS I.B.1.1(2)
Yellow DHFS I.B.1.1(3)
Yellow DHFS I.B.I.1(4)
Red DHFS I.C.1(4)*
Red DSI
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Red DSI II.C.3*
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II.J.3.1 Yellow DHFS II.E.4.4(4)*
Red DSI II.E.4.4(5)*
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- Re-baselining infomation provided.
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U HEMORANDUM FOR:
Office Directors FROM:
William J. Dircks Executive Director for Operations
SUBJECT:
mat!AGEMENT OF THE TMI ACTION PLAN The purpose of this memorandum is to consolidate the guidance on staff activities related to management of the EI Action Plan (NUREG-0660) in response to Recom-mendation 1.b of the Office of Inspector and Auditor's Audit of NRR's Implementa-tion of the TMI Action Plan, dated April 9,1981.
The Action Plan (NUREG-0660) approved by the Comission established priorities, requirements, an'd schedules for the staff as well as for applicants and licensees.
The Comission in approving NUREG-0737 clarified and, to some extent, amended these requirements and schedules.
NUREG-0718, " Licensing Requirements for Pending Appli-cations for Construction Permits and Manufacturing License", further clarified the
] ole of the Action Plan in the licensing process.
Office Directors should follow
..he priorities and schedules established in the Cormtission-approved NUREG's cited
" above.
The Comission it currently considering conversion of selected items of the Action Plan into rulemaking, specifically NUREG-0718 (for pending CP's and Offshore Power applications) and NUREG-0737 (both for OL applications and for operating reactors).
When such rules become final, the schedules contained therein cannot be modified except by further rulemaking or by exemption.
Adherence to schedules for these rules.is especially crit'ical.
Once the regulatory requirements are established from the Action Plan, they must be integrated into the Comission regulations and practices.
Therefore, for tracking purposes, the Action Plan tasks should be considered in two phases:
(1)-those tasks still*in the phase of developing staff technical and regulatory positions (develop-mental), and (2) those tasks which have matured to a stage requiring licensee and applicant implementation.
Status of tasks in the developmental phase will be tracked solely in the Action Plan Tracking System (APTS) which is managed by MPA, with cooperation and support from all of the Program Offices.
The APTS, which is updated quarterly, is the formal system of tracking status, measuring progress, documenting responsibilities, flagging problems for management attention in the developmental stage, and documenting trans-fer of requirements to the cognizant office for implementation.
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' Status of tasks in the implementation phase will be reported in your office systems designed to track case-by-case progress (e.g., IE-TMI Tracking System in IE and the Project Action Tracking System, PATS, in NRR), with a brief Requirements being implemented in Construction sumary(entered into APTS.
Review Plan (SRP)perating License (0L) reviews will be part of the Standard Permit CP) and O and nonnal casework activities and will not be specifically
. tracked.
The following actions will be taken in regard to management of the Action Plan:
1.
Office Directors will appoint an Action Plan Coordinator to serve as contact for Action Plan management.
It should be the specific responsi-bility of this individual to coordinate shifts of responsibility for actions internally within your office, or betwe:a offices, and to coor-dinate and exercise quality control on data provided to MPA.
Please inform MPA of the name, mail stop, and extension of this individual.
2.
Changes in the office responsible for an Action Plan item will be documented by memorandum to MPA (copies to program office directors and ELD).
Reassign-ments within an office should also be reported to MPA.
3.
Close out of all completed developmental Action Plan items will be accom-
_N plished by a memorandum to the EDO (copies to program office directors,
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ELD, and MPA).
Include a sumary of work accomplished and a statement clearly stating the nature of follow-up work and to whom the work is assigned and the priority which should be given to it.
4.
Office Directors will assure that major changes (which specifically includes Action Plan items incorporated into rules) to the Action Plan--substantive or schedular--have prior Comission approval.
Proposals for change should be fully justified in a Comission paper (Attachment 1 is a sample format for justifying a major modification).
Minor changes should be brought to the attention of the ED0 at the discretion of the responsible Office Director.
5.
MPA will convene a meeting of Office Action Plan Coordinators quarterly--at a minimum semi-annually--to coincide with publication of the APTS report to review status of items and to verify that an orderly transfer of items from developmental phase to implementation has been made.
Questions of priority should be addressed at this meeting.
A sumary will be provided EDO by MPA, to include recommendations for EDO action where necessary.
(SigteM!illizm !. Ditchs William J. Dircks Executive Director for Operations j
I ittachment:
Justification for Change in TMI Action Plan
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Item: -III3 Systems Interaction Current Status:
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_tiUREG-0GGO Objective:
Consideration given-to improving the " systems-interaction" issue in regulatory requirements.
Requirements'will be developed by NRR for rea,ctor designs dif,fering from the reference facility design {nd the' requirements will be transmitted to licensees and near-term license applicants to implement modifii:ations emanating from the systems interaction study.
A Regulatory Guide will be developed by SD providing the NRC position on the application of systems interaction methodology.
2.
Revised Objectiv6:
Consideration given to issuing a regulatory requirement that systems interaction reviews be performed on dperating reactors and LWR designs for common-cause failures that could jeopardize independent systems needed t6 perform basic safety functions.
Regulatory guidance will be developed to provide the fiRC position on the performance of systems inteiaction reviews.
3.
tiUREG-0660 Scope:
Coordinate and expand ongoing staff work on systems interaction (USI A-17) to incorporate it into' an integrated plan for addressing the broader question of-system reliability in conjunction with i
IREP and other efforts.
(1) 'A fault-tree method was developed by Sandia under contract to tiRC an'd is being applied to a reference plant.
This technique addresses systems interactions that could compromise the subcriticality function, the shutdown cooling function, or the integrity of the reactor coolant pressure f
boundary.
(2) iault-tree interaction methodology wi,11 be extended to generalized fault-trees.
(3) Require-ments and procedures will be developed for broad-s,cale applications of the systems interaction methodology.
(4)
A plan is being prepared to implement a two-part approach to an ACRS recommended systems interaction study of' Indian Point 3.
(5) _ Another type of systems interaction study will be performed on the Diablo Canyon docket for the overall effects' on safety system function of failure of nonseismic equipment, components, and, structures. :(6)
Upon completion of tasks 4 and 5, the lessons learned will be factored into decisions g
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Revised Scope:
Coordinate and expand ' ongoing programs' ud systems ' interactions.into an integrated prog,.
addressing the reliability of.the basic safety functions.
(1)
Resolve USI A'-17 and conclude the Sandia 7
methodologyLdevelopment.
(2)
Evaluate-the seismic-initiator,, systems interaction study on Diablo Canyon
.1/2.
(3')
Evaluate the s'eismic-initiator, systems interaction study on San Onofre 2/3.
(4)' Evaluate the ACRS-recomended systems interaction study on Indian Point 3.
(5)
Issue interim guidance to provide the
-NRC position on 'the performance of systems interaction reviews on selected plants.
(6)
Perform and evaluate the(systems interaction reviews on the selecte'd plants.: (7)
Issue regulatory requirements and guidance regarding'the performance of systems interaction reviews on a broad scale..
5 NUREG-0660 Scheilule:,
Milestone Date 06/00/80. A-17 procedures developed for broad application of the systems-interaction methodology developed by Sandia 08/00/80 Issue requirements for modifications emanating from the A-17 studies' 12/00/80 Issue draft Regulatory Guide 8
06/00/81 Regulatory Guide, becomes effective 6.
Revised Schedulei l
I Date Milestone Status 10/00/80 SSER issued evaluating Diablo Canyon study ~
Complete,
01 / 00/ 81 State-of-the-Art reports issued evaluating feasible methodology for systems Compl ete intera' tion including A-17 methodology c
04/07/81 SSER issued evaluating San Onofre study Complete
.12/00/81 Interim guidance issues for reviews of selected plants Projected 09/30/82 SER issued evaluating Indian Point 3 study i
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10/00/82 Issue regulatory requirements and. guidance regarding systems interaction Projected 03/00/83 SER issued evaluating reviews of selected plants Projected 9
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ilVREo-0GGO Resources :
's FY 80 - 3.9 pmy and $360,000 FY 81 -
.1 pmy and $ 12,000 Revised Resources;:
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FY 80 - 4.0 pmy 'and $250,000
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FY 81 - 2.0 pmy,and $394,000 FY 82 - 3.0 pmy and $510,000 FY 8'3 - 1.0 pmy 6nd $180,000 FY 84 - 0.1 pmy hnd $ 60,000 9.
Impact / Assessment if Additional Resources were Applied; (1)
If another person were added to the II.C.3 effort, the addition would contribute more to the scope of the reviews rather than accelerate the schedule.
(2)
Most of the methodology development and plant reviews" are being performed under Technical Assistance and additional funds could accelerate those parts 8
of the reviews p6rformed under contract but would not accelerate the work being'done by the utilities.
The schedule can be rget provided that the requested budget for systems interactions is not reduced.
.i 10 Explanation of Rdvised Scope / Schedule:
(1)
ACRS rev,iew of Sandia methodology (A-17) led to the recognitio of a deficiency in the fault-tree-only methodology, to illustrate the' feasibility of identifying actual, systems interaction occurrences.
(2)
The state-of-the-art review concluded that no single method presently exists in a form that can be used for an adequate systems interaction review.
The interim guidance must define a program combining the applicable methods.
Thus, the original schedule is infeasible considering the current understanding of:the complexity of systems interaction and the deficiencies in the curren.t methodologies.
(3)
There is very little fiRC and industry experience on systejns interaction reviews, thus reviews of selected w
c plants ahe essential prior to fiRC issuance of a rather'uccailed requirem:nt to perform systems.interacb.'.
.I' reviews en a broa'd scale.
(4). The Systems Interaction Branch was dissolved May 3,1981 and two people were transferred to RRAB/ DST to perform the program for NRR.
(5)
PASNY incurred a six-months delay-in submittirig their. systems interaction program because of delays in~the selection of a contractor.
l.
Related Work. in NUREG-0660:. In addition to the systems interaction program, there are several items within tWREG-0660 that qIust be coordinated with II.C.3.
Primarily, the selection of the plants for the systems interaction reviews must be synchronized with ~ continuation of IREP. plants (II.C.2) now called ilREP.
Because systems interaction reviews will include non-safety-grade systems, the efforts of II.C.3 will be coordinated with those of itbm II.F.5.
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