ML20056F184

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Submits NRR Ofc Ltr 701,rev 2,providing Guidance to Staff for Participating in Reviews Conducted by ACRS
ML20056F184
Person / Time
Issue date: 06/08/1993
From: Murley T
Office of Nuclear Reactor Regulation
To:
Office of Nuclear Reactor Regulation
References
NRRL-701, NUDOCS 9308260160
Download: ML20056F184 (19)


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UNITED STATES y'

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June 8, 1993 MEMORANDUM FOR:

All NRR Employees FROM:

Thomad E. Murley, Director Office of Nuclear Reactor Regulation

SUBJECT:

NRR OFFICE LETTER NO. 701, REVISION 2, "NRR PARTICIPATION IN REVIEWS CONDUCTFD BY THE ADVISORY COMMITTEE ON REACTOR SAFEGUARDS" PURPOSE This office letter provides guidance to the NRR staff for participating in reviews conducted by the Advisory Committee on Reactor Safeguards (ACRS).

It defines the responsibilities arad authorities of the cognizant NRR staff and addresses the submittal of documentation to the ACRS, the level of attendance at ACRS meetings, the conduct during the meetings, and the procedures for conducting followup actions after the meetings.

This office letter supersedes Office Letter 701, Revision 1, March 23, 1992.

BACKGROUND The ACRS is a statutory committee created by Congress under the Atomic Energy Act of 1954, as amended, and is subject to U.S.

Nuclear Regulatory Commission regulations set forth in 10 CFR Part 7.

It was established to provide independent technical evaluation of matters related to nuclear acilitics and other nuclear activities.

The ACRS has reviewed applications for construction pernits (cps) and operating licenses (OLs) and has advised the Commission on thase matters.

The ACRS continues to review safety studies, unresolved safety issues, generic issues, the NRC research progran, the safety of existing facilities, the adequacy of proposed safety standards, and other safety-related issues as directed by the Commission.

On its own initiative, the ACRS also reviews issues that it considers significant enough to warrant advice to the Commission, such as the restart of problem plants that have been CONTACT:

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shut down for an extended period.

The ACRS also reviews evolutionary and passive reactor designs for future plants in keeping with the staff's new emphasis on the design certification process specified in 10 CFR Part 52.

NRC Manual Chapter 0111 explains the organization and functions of the ACRS and states that the NRC will provide the r.ecessary staff to support ACRS activities On May 19, 1988, the Executive Director for Operations (EDO) and the ACRS issued a memorandum of enderstanding (MOU) to provide guidance to the NRC staff regarding ACRS participating with the NRC in developing rules, policy matters, and safety-related guidance.

On December 9, 1991, a revised attachment to the MOU was issued which-updated the areas of ACRS interest to include 10 CFR Parts 52, 53, and 54 and deleted Parts 60 and 61. is a copy of the MOU.

I DEFINITIONS Proposed Rule

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A proposed change (either revision or addition) to the Code of l

Federal Reculations (CFR), Title 10 (Energy).

Maior Policy Matter A safety-related issue that must be brought to the attention of the Commission, requires their action before being implemented, or both.

The action normally includes publishing a Commission i

policy statement in the Federal Recister.

Even though these publications convey the policy of the Commission and its staff on certain safety matters, they are not enforceable as regulations.

Safety-Related Guidance Guidance _provided by the staff that specifies acceptable methods of neeting NRC regulations.

However, these methods are not the only ways of meeting the regulations.

The guidance is not a regulaticn (rule) and is not legally binding unless the guidance is included in a legally binding document (license or order).

Examples of safety-related guidance include regulatory guides, the Standard Review Plan, the staff's technical positions, and the resolution of generic and unresolved safety issues.

RESPONSIBILITIES AND AUTHORITIES Director, NRR 1.

Ensures compliance with the EDO-ACRS MOU and assigns the NRR ACRS coordinator.

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2.

Resolves conflicts regarding representation at ACRS meetings for technical issues and policy matters, when such conflicts cannot be resolved by the associate director (s).

3.

Suggests issues for the office to present to the ACRS for review.

4.

Ensures that NRR addresses expeditiously the letters and staff requests of the ACRS, and Commission and EDO directives regarding ACRS activities.

Associate Directors Determine NRR attendance at ACRS full-committee meetings and attend full-committee meetings as necesssry for significant issues.

Director. Procram Manaaement, Policy Development, and Analysis Staff (PMAql 1.

Issues the monthly memorandum to the EDO of proposed topics for ACRS full-committee review.

2.

Recommends to the NRR Office Director to approve or disapprove revisions to this office letter.

3.

Determines NRR attendance at ACRS full-committee meetings and attends full-committee meetings as necessary for significant issues.

Division Directors 1.

Ensure that appropriate division personnel understand and follow the guidelines contained in this office letter.

2.

Determine assignments for the representatives of NRR before the ACRS at meetings of its subcommittees and full-committee.

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3.

Coordinate the information supplied to correspondence in response to ACRS letters, and EDO and Commission directives regarding ACRS activities.

4.

Provide information through the NRR ACRS coordinator to the EDO's monthly memorandum of proposed topics for the ACRS full-committee to review.

S.

Review the list of WITS items each month for possible ACRS action on items and provide the NRR ACRS coordinator with a list of Commission papers not stated in the WITS list.

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6.

Attend full-committee meetings regarding topics under their area of responsibility.

7.

Attend subcommittee meetings regarding topics under their area of responsibility as necessary depending on the significance of the issues.

Branch Chiefs /Proiect Directors 1.

Determine if informal requests from the ACRS staff (any requests not made through the EDO's office) should be handled formally.

2.

Approve NRR responses to informal requests other than those that are for statements of fact.

3.

Attend full-committee meetings regarding topics under their responsibility.

4.

Attend subcommittee meetings as necessary depending on the significance of the issues.

5.

Notjfy the ACRS through the cognizant ACRS project engineer conc.trning the availability of documentation, the availability of NRR staff for full-committee and subcommittee meetings, and NRR agreement or disagreement with the topics that the ACRS wants to discuss.

6.

Ensure that the required documents are submitted to the cognizant ACRS project engineer according to the schedules outlined in the MOU.

I Provide information to principal correspondence in response 7.

to the ACRS's letters.

8.

Keep the NRR ACRS coordinator informed about contacts with the ACRS or ACRS staff.

NRR ACRS Coordinator 1.

Provides to the staff, as requested, clarification of and information about the implementation of the EDO-ACRS MOU.

2.

Informs the NRR staff of relevant issues to be discussed by the ACRS and the schedule of agenda items.

3.

Coordinates principal correspondence between NRR, the EDO, and the ACRS.

4.

Prepares information to the EDO's monthly memorandum of proposed topics for the ACRS full-committee to review.

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5.

Attends each ACRS full-committee meeting and prepares a summary of items of interest to NRR for the executive team and NRR management.

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6.

Attends subcommittee meetings determined to be significant to NRR and reports to immediate supervisor the significance of items of interest.

8 7.

Represents NRR at ACRS meetings and presents NRR schedules and positions (when known) to the committee, as requested, when cognizant NRR staff are not present.

8.

Attends meetings and participates in conference calls between NRR and the ACRS staff as necessary.

i BASIC REOUIREMENTS Coordination Responsibilities The. principal NRR contact on the ACRS staff is the cognizant ACRS project engineer.

The cognizant ACRS project engineer arranges subcommittee meetings, prepares a schedule of discussion topics, arranges for the NRC staff to participate in both full-committee and subcommittee meetings, and interacts with the ACRS for these activities.

The NRR ACRS coordinator should be kept informed of these activities by the NRR staff and will provide guidance if needed.

The NRR ACRS coordinator coordinates the preparation of responses to ACRS letters and full-committee followup items.

The NRR ACRS coordinator should be on the distribution list for any ACRS correspondence.

The NRR ACRS coordinator prepares a monthly memorandum to the EDO listing topics to be considered for the ACRS to review for the next three months.

The information is compiled after the responsible division director reviews the WITS list and provides information for the schedules according to the schedule requested by the NRR ACRS coordinator.

Management should list any other papers not initiated in response to an SRM or Commission request and not on the WITS list, and should state whether or not the ACRS should review them.

The EDO-ACRS MOU does nct address informal requests which are not made through the EDO's office.

Informal requests to the NRR staff can be discussed informally by telephone or memorandum.

The responsible branch chief or project director should make the decision to respond informally or to direct the ICRS to make a I

formal request.

To enable the staff to communicate openly and establish good rapport with the ACRS staff, information requests should be responded to informally to the extent possible.

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NRR staff response should be approved by the responsible branch chief or project director if it includes information other than statements of fact.

ACRS Meetina Precaration The MOU between the EDO and the ACRS describes the procedures for providing the ACRS with documentation on proposed and final rules and safety-related guidance.

The staff should normally provide documentation for rules, policy matters, and safety-related guidance to the ACRS at least two weeks before the scheduled subcommittee meeting and at least one month before the full-committee meeting.

If possible, the staff should submit the documentation to the ACRS two months before the full-committee meeting to allow the ACRS time to conduct its review as specified in Sections 2b and 3b of the MOU.

Submittals are to be made by memorandum to the cognizant ACRS project engineer.

Predecisional documents to be transmitted to the ACRS should be marked appropriately.

Every transmittal letter or memorandum must include a statement indicating whether or not transmitted material may be released to the general public.

The attachment to the MOU lists the areas of the regulations in which ACRS participation can be expected.

The following describes the times in the development process at which the ACRS would likely conduct its review.

1.

NRC Rules and Policy Matters The ACRS has two opportunities to review most NRC rules and policy matters.

The ACRS may review a rule or policy matter before it is submitted to the Commission for approval to issue for public comment.

The ACRS may also review it before it is submitted to the Commission for implementation.

Both of these opportunities usually occur before the review l

by the Committee to Review Generic Requirements (CRGR).

These reviews normally allow sufficient time for the ACRS to provide comments to the Commission.

The staff should send 20 copies of the rule or major policy matter to the ACRS at each of these two stages.

The staff should also send five copies to the ACRS for information at each of the stages of development described in Section 2 of the MOU.

2.

Safety-Related Guidange The ACRS normally provides comments on safety-related guidance after the CRGR reviews it and before it is issued for public comments.

The ACRS also provides comments following the public comment period after CRGR review (if

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any) and before the NRC issues the final version.

The staff should send 20 copies of the safety-related guidance to the ACRS at each of these two stages.

The staff should send five copies to the ACRS for information at each of the stages of development. described in Section 3 of the MOU.

3.

Generic Communications SECY-92-224 describes the r evised process the staff uses to inform the Commission of its intent to issue a generic communication in which the staff states a new position or seeks additional licensee commitments.

When the generic communication package is ready for CRGR review, the staff will forward it also to the ACRS.

After CRGR review and a briefing of the ACRS if one is requested, the staff will provide an opportunity for public comment.

If significant revisions result from the public comments, the staff will prepare a request for a meeting with CRGR to discuss the revisions to the generic communication.

When the staff sends the request to CRGR, it also will inform the ACRS of the anticipated staff action.

The staff's process for issuing urgent generic communications is described in SECY-92-338.

As discussed in the SECY, CRGR will review urgent communications either before or after they are issued.

The staff should inform the ACRS of the staff's action when the package is sent to CRGR for review.

Attendance at ACRS Meetinos 1.

General Issues Responsible technical and project personnel and managenent should be present for the entire portion of the full-committee or subcommittee meetings that involve their project or technical area.

The associate director or division director needs to attend full-committee meetings regarding topics under their responsibility and may need to attend subcommittee meetings if warranted by the significance of the issues involved.

Similarly, the NRR ACRS coordinhtor must attend all portions of full-committee meetings that address NRR issues and all portions of selected subcommittee meetings that are considered significant by the NRR ACRS coordinator and JUU1 management.

1 Branch chiefs / project directors should ensure that attendance at ACRS meetings is coordinated with the NRR ACRS

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coordinator.

The NRR ACRS coordinator should ensure that NRR's interests are represented in matters involving the ACRS.

2.

Plant Specific Issues The project manager and technical staff required to support technical discussions should attend both subcommittee and full-committee meetings for plant-specific issues.

The project director and technical branch chiefs must attend full-committee meetings and may be required to attend subcommittee meetings, depending on the significance of the issues involved.

The associate director or division director needs to attend full-committee meetings regarding topics or plants under their responsibility and may need to attend subcommittee meetings if warranted by the significance of the. issues involved.

The project manager and the branch chief, Events Assessment Branch (EAB) must attend both full-committee and subcommittee meetings during which the ACRS reviews the events or experience at the applicable operating reactor.

Technical personnel in the EAB will attend as determined by the branch chief.

Other technical support personnel will attend ACRS meetings as requested by the EAB, depending on the significance of the issues involved.

Other project personnel such as the assistant division director or project director must attend full-committee discussions during which the ACRS will likely make recommendations that may significantly affect pending licensing actions.

3.

Other Issues The ACRS also reviews unresolved safety issues, generic issues, proposed and final rulemaking, regulatory guides, the research budget, and security and safeguards issues.

The document under review may have been prepared by other offices, but an NRR project directorate or branch has usually helped develop the item or items under review.

Each branch chief / project director must inform the NRR ACRS coordinator of the divicion personnel who are involved with an item as it approaches ACRS review.

At least one NRR representative should attend ACRS reviews of issues sponsored by other offices.

The preferred staff members are those identified by the branch chief / project director as helping to develop the item or items under review.

If these staff members are not available, the NRR ACRS coordinator should either attend or determine if NRR attendance is warranted.

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Conduct Durino ACRS Meetinos ACRS full-committee and subcommittee meetings are normally open to the public, although some meetings are closed for discussion of proprietary, national security, or internal ACRS information.

Therefore, representatives of the nuclear industry and members of the public will normally attend.

Discussion of controlled, internal documents, including predecisional documents, at open ACRS meetings by the NRR staff must have prior approval of the NRR Office Director.

If a member of the NRC staff determines that it is necessary to clarify an opinion or a misconception expressed by an ACRS member, the staff member should clarify the issue in a brief, forthright manner, avoiding a prolonged, argumentative discussion.

The NRC staff may be asked a question to which it does not immediately have an answer.

Also, an ACRS member may state an opinion in a manner that appears to be a question for the staff.

If a staff member is not sure of the response to a question or comment posed by the ACRS or its staff, the staff member should clearly state the uncertainty and offer to provide the answer at a later date.

This action will prevent the NRC staff from providing inaccurate or misleading information to the ACRS.

Finally, if a staff member must speculate or offer a professional opinion, the staff member should clearly state that the response is speculation or an opinion. provides additional guidance for the staff's presentations at ACRS meetings.

Follow-Un Actions After Meetinos The ACRS staff prepares detailed, official meeting minutes of every ACRS meeting.

The ACRS also publishes a transcript of the meeting and provides it to the NRR ACRS coordinator.

1.

Full-Committee Meetinas Within two weeks of a full-committee meeting, the ACRS issues its letters resulting from the meeting.

The letters come to the NRR mailroom under the EDO Principal Correspondence Control System (green ticket items).

The NRR ACRS coordinator distributes the green ticket items to the appropriate division and assists the responsible division to decide whether or not a response is appropriate.

If no response is necessary, the NRR ACRS coordinator will inform the ACRS Executive Director and the NRR mailroom.

However, a response from the EDO to the ACRS is normally required and

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All NRR Employees 10 is due for the EDO's signature approximately two weeks from the date of receipt of the ACRS letter in the EDO's office.

The responsible branch should prepare the responses.

The responsible division should address NRR agreements for future meetings or for providing information and should provide these agreements to the NRR ACRS coordinator.

When the response to ACRS follow-up items promises a date by which the information will be provided, the information should be prepared and transmitted to the ACRS Executive Director from an NRR Division Director.

Project managers should ensure that letters issued by the full-committee pertaining to nuclear reactor facilities are sent to the licensee or applicant, the individuals on the service list, and the NRC and local public document rooms.

The NRR ACRS coordinator will issue a summary of selected topics discussed at the meeting, along with the letters issued by the Committee as a result of that meeting.

The summary, issued three to four weeks after the meeting, is sent to the executive team with copies to NRR branch chiefs and above.

2.

Subcommittee Meetinos Commitments and agreements made at subcommittee meetings are handled in a less formal manner.

Following a subcommittee meeting, commitments or agreements should be discussed with the responsible ACRS project engineer to obtain any necessary clarification.

Information promised during a subcommittee meeting should be forwarded directly to the responsible ACRS project engineer.

l Project managers should issue meeting summaries within 15 work days after the ACRS subcommittee meetings pertaining to nuclear reactor facilities.

These summaries should state the ACRS action items that require followup actions by the staff and should be accompanied by the materials distributed at the meeting.

Copies of these summaries should be sent to the licensee or applicant, the individuals on the service list, and the NRR ACRS coordinator, and should be placed in the NRC and local public document rooms.

Meetinos with the Advisory Committee on Nuclear Waste occasionally the NRR staff will need to brief or attend meetings of the Advisory Committee on Nuclear Waste (ACNW).

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procedures for the ACRS should also be followed for reviews performed by the ACNW.

l-l EFFECTIVE DATE This office letter is effective immediately.

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Thomas E. Murley, Director Office of Nuclear Reactor Regulation Enclosures 1.

Memorandum of Understanding 2.

Guidelines for ACRS meeting preparation cc:

J. Taylor, EDO 17 G 21 l

J.

Sniezek, EDO 17 G 21

^ T. Martin, RI

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Ebneter, RII J. Martin, RIII J. Milhoan, RIV R. Faulkenberry, RV M. Taylor, EDO 17 G 21 SECY, 16 G 15 i

OGC, 15 B 18 ACRS i

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O issuee M., - i, e MEMORANDUM 0F UNDERSTANDING PARTIES:

Advisory Comittee on Reactor Safeguards (ACRS)

ACRS i

Chaiman Nuclear Regulatory Comission Staff - Executive Director for Operations 4

SUBJECT:

ACRSPARTICIPATIONINTHEDEVELOPMEN{0FNRCRULES, POLICY MATTERS. AND SAFETY-RELATED GUIDANCE The purpose of this memorandum is to establish procedures for ACRS i

participation in the development of NRC rules, policy matters, and safety-related guidance. at a sufficiently early stage to pemit con-J structive interaction during fomulation of these matters.

4 The following have been agreed upon to facilitate ACRS participation in matters of the type noted above when they are within the purview of the ACRS:

1.

GENERAL a.

Areas of ACRS interest (see attachment) will be identified on behalf of the ACRS by the ACRS Executive Director.

- b.

The NRC Staff will be responsible for ensuring that ACRS coments regardjng nuclear safety rules, major nuclear safety policy matters, and safety-related guidance under development by the NRC Staff are obtained and taken into account at appropriate stages in the development process of these items.

This function will nomally be the responsibility of the cognizant NRC Staff office.

An NRC contact to coordinate these activities will be assigned in every major staff program office.

i c.

The ACR$ staff engineer supporting the ACRS Regulatory Activi-a ties Subcomittee will serve as the ACRS contact for the i

I subject matters.

The NRC contact in the responsible staff office will be the coordinator in the NRC Staff.

d.

ACR$ coments will be forwarded to the EDO or to the Comis-l sion, as appropriate, with copies to the cognizant staff office (NRC contact). The NRC contact will ensure that copies Isafety-related evidence weludes Regulatory Svides. Standard 4teview Plans.* Branch Technical Positions. Generic Issues, and Unresolved Safety Issues.

2A major policy matter is a safety-related issue that must be brought to the attention of the Commissioners and/or requires their action before being implemented.

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are provided to appropriate NRC Staff offices and the EDO will assure consideration of ACRS coments by the NRC Staff.

Comission papers, if any, will address ACRS coments, includ-ing those not endorsed by the staff.

In those instances in which a rule, major policy matter, or safety-related guidance is considered predecisional and is not e.

othenvise a matter which is exempt from the open meeting requirements of the Federal Advirory Coenittee Act, appropri-ate NRC Staff will participate in open ACRS subcomittee or full comittee meetings considered necessary to such reviews.

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In those cases where discussioc of controlled internal docu-ments, including Predecisional Documents, is required during an open meeting, approval of the cognizant Office Director or Regional Administrator shall be obtained, consistent with applicable procedures (e.g.,

Bulletin No. 3203-25, dated Februsry 9,1988, Section C, Paragraph 2.b.) by the office transmitting the document to ACRS for its consideration.

Documents transmitted to the ACR$ wMeh are considered to be predecisional will be identified as such either by appropriate marking or in an accompanying' transmittal letter so that they may be protected in accordance with the provisions of the Freedom of Information Act.

When deviations from procedures of tMs Memorandum of Under-f.

standing are unavoidable, they may be altered consistent with the needs of the ACRS/E00 Staff or, as appropriate, in those cases where the ACRS is participating directly in a related rulemaking hearing as outlined in 10 CFR 2.809, such changes should be autually agreed on by the ED0 and the ACRS Executive Director.

PROCEDURES FOR DEALING WITH MRC RULES AND POLICY MATTERS 2.

When a proposed rule.'or a major policy matter. in an area of ACRS interest is under consideration by the NRC Staff for a.

eventual transmission to the Commission, the ACR$ should be informed of the anticipated NRC Staff action when the basic requirements are being formulated and an opportunity for ACRS discussion should be provided.

This may be achieved by the NRC contact / project engineer providing ACR$ with copies of the pertinent task initiatLon fors (after user office endorsement)

Any written reaction by or other relevant office documents.

the ACR$ on the need for, scope, and direction.of the proposed task will be considered and responded to by the EDO.

Normally ACRS comments on a rule or major policy setter will b.

be provided at the following two stages:

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Prior to submittal to the Comission for action regarding publication of a proposed rule or major policy matter for public coment, a hearing, or other action, as appropri-ate. This would normally occur before CRGR review.

l prior to submittal to the Comission for action regarding i

implementation of the final rule or major policy matter unless no substantive revisions are made by the staff in This preparing the matter for final Comission action.

period would normally occur after the public coment and/or after completion of a related hearing and before CRGR review.

The cognizant NRC Staff office (NRC contact / project engineer) will ensure that schedules for the development of a specific rule or a major policy matter include sufficient time (nor-mally about two months) for ACRS review prior to submittal to 4

CRGR/EDO, at both stages.

In addition. ACR$ will have the option of reviewing a specific c.

document during the period allowed for public coment and at such other times as considered appropriate by the cognizant ACRS. subcomittee.

Under such circumstances, the NRC Staff (NRC contact / project engineer) will be infomed as early as possible of anticipated ACRS full comittee and pubcomittee activities and will establish a schedule which allows the time to the degree practicable, required for the ACRS input.

d.

Twenty copies of a rule or major policy matter will be pro-vided to the ACR$ for review by the NRC contact / project engineer at the stages identified in 2.b.,

above with a

memorandum addressed to the ACRS Executive Director requesting ACRS review and also including a proposed schedule for review and publication, as appropriate. The ACRS Executive Director 4.

will keep the ED0 informed of the schedule for ACRS comments /

recommendations.

When sending a rule or major policy matter to the ACRS for review, the Staff office involved (NRC contact / project engi-neer) will ensure that the ACRS is provided with a copy of other related documents such as differing judgments on techni-cal issues among the RRC 5taff, public comments, NRC Staff's resolution of public coments (if any), ar.d related CRGR o

settingsinutas(ifany),etc.

Five copies of a rule or major policy matter will also be e.

provided to the ACR$ for infomation by the NRC contact /

' project engineer at the foHowing stages, with a memorandum addressed to the Executive Director, ACR$. indicating that they are sent to ACRS for infomation:

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When a proposed rule or major policy matter is sent to other NRC offices by the originating office for final review and coment.

After incorporation of CRGR coments on a proposed ru7e or a policy matter, when it is sent to the Comission for approval to be published as a Federal Register Notice for public coment.;

After approval by the Com.ission, when a proposed rule or a policy matter is sent to be published as a Federal Register Notice for public coment.

After CRRR review of a proposed final rule or a policy matter subsequent to the public coment period.'when it is sent to the Comission for approval for implementa-tion.

Final document, when it is sent to be published as an effective document.

3.

PRDCEDURES FOR DEALING WITH $ATETY-RELATED GUIDANCE CE.G., REGU-

.ATORY GulDES, STANDARD REVlEW PLANS. BRANCH TECHNICA PO5ITION5, iEhERIC 155UE5. AhD UhRE50LV ED 5AFElY 155UE5)

When the NRC Staff is considering the development of new a.

guidance or modifications (e.g.,. revision, cancellation, and/or substitution) of existing guidance in areas of. ACRS interest, the ACRS should be informed promptly of the antic-(pated staff action and be afforded an opportunity to cosinent early in the process. - This may be achieved by the NRC con-tact / project engineer providing ACR$ with copies of such documents as the pertinent task initiation form (after user office endorsement) or other relevant office documents.

Any written reaction by the ACR$ on the need for, scope, and direction of the proposed task should be considered and responded to by the EDO.

b.

Noma 11y. ACR$ comments on safety-related guidance ~will be 1

provided at the following stages:

After CRGR review, if any, and prior to issuance for

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public comment.

Subsequent to the public connent period and after CR6R veview, if any, and prior to issuing the final version for industry and/or NRC Staff use.

When developing schedules for safety-related guidance, the cognizant NRC staff office (NRC contact / project engineer) will

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ensure that such schedules include sufficient time (nortally abouttwomonths)fortheACRSreview.

In addition, ACRS will have the option of reviewing a specific c.

dosument associated with safety-related guidance during the J

public comment period, if any, and at such other times as may be considered appropriate by the cognizant ACRS subcomittee.

Under such circumstances, the NRC Staff (NRC contact / project engineer) will be informed of anticipated ACR$ full comittee and subcomittee activities as early as possible to enable them to provide the necessary time, to the degree practicable, required for the ACRS input.

d.

Twenty copies of pertinent documents dealing with safety-related guidance will be provided by the NRC contact / project engineer to the ACR$ for review at the stages identified in 3.b., above, with a memorandum addressed to the ACRS Executive Director requesting ACR$ review and also including a proposed schedule for review and publication, as appropriate. The ACRS Executive Director will keep the EDO informed of the schedule for ACRS connents/recomendations.

When sending p'roposed safety-related guidance to the ACRS for review, the staff office involved (NRC contact / project engi-neer) will ensure that the ACRS is trovided with a copy of other related documents, as appropriate, such as differing judgments on technical issues among the NRC Staff, public coments, NRC Staff's resolution of public comments, related i

CRGR meeting minutes, etc.

Five copies of pertinent safety-related guidance documents e.

will also be provided to the ACRS for information by the NRC contact / project engineer at the following stages with a semorandum addressed to the Executive Dire: tor. ACRS. indicat-ing that they are sent to ACR$ for information:

When a proposed safety-related guidance is sent to other NRC offices by the originating office for final review and comment.

When it is sent to be publish &d as a Federal Register Notice for public comment.

e When it is sent to be published as a final document for industry and/or NRC Staff use.

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Executive Directo r Operations May 6,1988 (Date)

William Kerr, chaire.an Advisory Comittee on Reactor Safeguards

Attachment:

Areas of ACRS Interest l

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o XIVISED October 7, 1991 December 4 1991 Attachment to NOU of Menerandun of Understandine 1.a.

Areas of ACRS Interest Per Ited ACRS Participation in the Develeenant of NRC Ruleg, and safety-Related cuidance Poliev Matters, For purposes of implementing the NOU noted above, the ACRS has identified the following areas of interest which consist of safety-related rules, propos'ad rule changes, or appendices in the areas Policy matters and regulatory guidance which impact noted below.

on safety considerations in these areas are also of interest.

Standards for Protection Against Radiation e

Part 20 Reporting of Defects and Noncompliance e

Part 21 Domestic Licensing of Production and Utilization e

Part 50 Facilities Early Site Permits; Standard Design Certifica-e Part 52 tions; and combined Licenses for ca.laar Power Plants Criteria and Procedures for Determining the Part 53 Adequacy of Available Spent Nuclear Puel Storage Capacity Nuclear Powar Plant License Renewal e

Part 54 Operators' Licensas e

Part 55 Domestic Licensing of special Nuclear Material e

Part 70 Licensing Sequirements for the Independent e

Part 72 Storage of Spent Nuciaar Puoi and Eigh-Level Radioactive Waste Physical Protection of Plants and Natarials o

Part 73 e

Part 100 - Reactor Site Criteria With respect to new Parts to 10 CFR that impact on safety-reinted matters, the ACRS should be providad an opportunity for review and osmaant.

Regarding proposed abanges, or appendizes to Part 3, ' Rules of for Domestic Licensing Proceedings, er Part 51, Practice etnvironmental Protection Regulations for Domestic Licensing and alated Regulatory Functions," Which tapact on safety-related aspects of the regulatory process (e.g., limits on the scope or

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2 nature of the safety review process), the ACRS also has an interest to a degree that copies should be provided for information.

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All NRR Employees l

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GUIDELINES FOR STAFF PRESENTATIONS AT ACRS MEETINGS i

1.

DISTRIBUTED MATERIALS AND SLIDES organize the information on slides using bullets and short sentences.

Simple charts, diagrams, and cross sections help convey concapts.

Limit the information on each slide.

Presenters should keep i

slides and handouts from being "too busy" and difficult to distinguish, especially at the back of the room.

1 Include the following information on the standard cover sheet:

subject; date; presenter's name, title, division, and branch; presenter's telephone number; and whether it is a subcommittee or full-committee meeting (Attachment 1 is an example).

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Sequentially number the slides for ease of reference.

l Do not use color transparencies.

Use a large type face, as illustrated in Attachment 2.

Standard size type (10 pitch) should be avoided.

The use of the orator typeface or a reasonable facsimile would be better suited for such presentations.

Include one or two blank lines between sentences to improve the appearance.

Provide 30 copies for subcommittee meetings.

i Provide 40 copies for full-committee meetings.

i Provide copies to the cognizant ACRS project engineer at the meeting for distribution.

Material distributed at the meeting cannot be treated informally since it will be included in the transcript.

l If more than one person will be speaking on a topic, only one package of material should be distributed at the beginning.

This minimizes the shuffling of material in l

between presentations.

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2.

PRESENTATIONS Each presenter should allow one-half of the allotted time for ACRS questions and discussion.

Before speaking, each presenter or member of the audience should state his or her name and affiliation for the. court

reporter, t

Presenters should summarize the background history of the issue under consideration by emphasizing only important i

events.

Chronologies of the regulatory history of the issue should be included in the presentation package for information but should not be discussed line-by-line unless the Committee or its consultants have specific questions on the background of the issue.

Presenters should not read their slides verbatim; rather they should discuss the important points that they.wish to enphasize to the Committee.

t Presenters should be prepared during the course of their presentation to summarize some of their prepared presentation in the interest of meeting the Committee's time-schedule.

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frRR-STAFF PRESENTATION TO THE ACRS I

SUBJECT:

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4 DATE:

PRESENTER:

PRESENTER'S TITLE / BRANCH /DIV:

l PRESENTER'S NRC TEL. NO.:

i SUBCOMMITTEE:

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t STAFF POSITION ON VENDOR SUBMITTALS O-VARIATIONS IN LEVEL OF ADVANCED TECHNOLOGY AMONG VENDORS IN PROPOSED CONTROL ROOMS FOR EVOLUTIONARY DESIGNS LEVEL OF DETAll PROVIDED BY GE, CE, TO DATE, INSUFFICIENT TO MAKE SAFETY DETERMINATION USE OF DESIGN ACCEPTANCE CRITERIA 4

MANY OPEN ISSUES FO'R SPECIFIC CONTROL ROOM DESIGN GE AND CE ARE SPECIFYING PROTOTYPING g

IN THEIR CONTROL ROOM DEVELOPMENT PROCESS N

n SECY 91-272 (10) m l

STAFF POSITION ON VENDOR

. SUBMITTALS (CONT'D?

E AP-600, PASSIVE DESIGN NOT YET SUBMITTED E USING MORE ADVANCED CONTROL ROOM DESIGN THAN GE & CE W GENERALLY AGREES WITH EPRI R.D. & STAFF ON MAN-MACHINE INTERFACE DEVELOPMENT

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OPERATOR ROLE IN CONTROL ROOM OF PASSIVE PLANTS MAY BE DIFFERENT FROM EVOLUTIONARY PLANTS EXTENSIVE MAN-IN-THE-LOOP TESTING + FULLY O

a FUNCTIONING PROTOTYPE NEEDED 9

SEGY 91-272 (11)

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O All NRR Employees June 8, 1993 procedures for the ACRS should also be followed for reviews performed by the ACNW.

EFFECTIVE DhTE This office letter is effective immediately.

original signed by i

Thomas E.

Murley, Director Office of Nuclear Reactor Regulation

Enclosures:

1.

Memorandum of Understanding 2.

Guidelines for ACRS meeting preparation cc:

J.

Taylor, EDO 17 G 21 DISTRIBUTION:

J.

Sniezek, EDO 17 G 21 Central files NRC PDR T. Murley T. Martin, RI R. Ingram (Orig. +5)

F. Miraglia S.

Ebneter, RII ILPB R/F J.

Martin R*:1 -

H. Pastis i

J-Milhoan, RIV A. Vietti-Cook i

R. Faulkenberr v RV M. Slosson M. Taylor, EDO 17 G 21 A. Gody SECY 16 G 15 D. Crutchfield OGC 15 B 18 R. Wessman J. Partlow ACRS W. Russell

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All NRR Employees necessary clarification.

Information promised during a subcommittee meeting'should be forwarded directly to the i

responsible ACRS project engineer.

l Project managers should issue meeting summaries within 15 work days after the ACRS subcommittee meetings pertaining to i

nuclear reactor facilities.

These summaries should state the ACRS action items that require followup actions by the staff and should be accompanied by the materials distributed

. 1 at the meeting.

Copies of these summaries should be sent to J

the licensee or applicant, the individuals on the service i

list, and the NRR ACRS coordinator, and should be placed in the NRC and local public document rooms.

Meetinos with the Advisory Committee on Nuclear Waste occasionally the NRR staff will need to brief or attend meetings of the Advisory Committee on Nuclear Waste (ACNW).

The procedures for the ACRS should also be followed for reviews-performed by the ACNW.

EFFECTIVE DATE This office letter is effective immediately.

Thomas E. Murley, Director Office of Nuclear Reactor Regulation i

Enclosures:

1.

Memorandum of Understanding 2.

Guidelines for ACRS meeting preparation cc:

J. Taylor, EDO 17 G 21 J.

Sniezek, EDO 17 G 21 J

T. Martin, RI S.

Ebneter, RII A. Davis, RIII IL S

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g All NRR Employees q) June 8,1993 q) procedures for the ACRS should alsc be followed for reviews performed by the ACNW.

EFFECTIVE DATE This office letter is effective immediately.

original signed by Thomas E.

Murley, Director Office of Nuclear Reactor Regulation

Enclosures:

1.

Memorandum of Understanding 2.

Guidelines for ACRS meeting preparation ec:

J.

Taylor, EDO 17 G 21 DISTRIBUTION:

J.

Sniezek, EDO 17 G 21 Central Files NRC PDR T. Murley T. Martin, RI R. Ingram (Orig. +5)

F. Miraglia S.

Ebneter, RII ILPB R/F J.

Martin, En L H. Pastis J.

Milhoan, RIV A. Vietti-Cook R. Faulkenberry RV M. Slosson M. Taylor, EDO 17 G 21 A. Gody SECY 16 G 15 D. Crutchfield OGC 15 B 18 R. Wessman J. Partlow ACRS W. Russell

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See previous concurrence