ML20056F229
| ML20056F229 | |
| Person / Time | |
|---|---|
| Issue date: | 07/08/1993 |
| From: | Jordan E Committee To Review Generic Requirements |
| To: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| References | |
| NUDOCS 9308260205 | |
| Download: ML20056F229 (25) | |
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UNITED STATES
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July 8, 1993 MEMORANDUM FOR:
James M. Taylor Executive Director for Operations FROM:
Edward L. Jordan, Chairman Committee to Review Generic Requirements
SUBJECT:
MINUTES OF CRGR MEETING NUMBER 240 The Committee to Review Generic Requirements (CRGR) met on Tuesday, May 11, 1993 from 8:00 a.m. to 11:50 p.m.
A list of attendees at the meeting is attached (Enclosure 1). The following items were discussed at the meeting:
1.
The CRGR reviewed a proposed Generic Letter (and related Topical Report Evaluation) regarding "Long-Term Solutions to Thermal-Hydraulic Stability Issues in Boiling Water Reactors".
The Committee recommended in favor of issuing the proposed safety evaluation and generic letter, subject to incorporation of several clarifying changes and circulation of the revised package for a final review by CRGR members prior to issuance. This matter is discussed in Enclosure 2.
2.
The CRGR reviewed proposed Administrative letter 93-01, " Announcing a New Type of NRC Generic Communication".
The Committee recommended in favor of issuing the proposed letter, subject to several clarifying changes (to be coordinated with the CRGR staff).
This matter is discussed in Enclosure 3.
3.
The proposed Generic Letter, " Resolution of Issues Identified in the
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NRC Staff's Evaluation of Shutdown and Low Power Operations", scheduled for consideration by CRGR at this meeting, was withdrawn by the sponsoring NRC program office for further development. This matter will be considered by CRGR at a subsequent meeting (to be announced).
In accordance with the E00's July 18, 1983 directive concerning " Feedback and Closure of CRGR Review", a written response is required from the cognizant office to report agreement or disagreement with the CRGR recommendations in these minutes. The response is to be forwarded to the CRGR Chairman and if there is disagreement with the CRGR recommendations, to the ED0 for decision m; king.
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PDR REVGP NRCCRGR MEETING M O PDR
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t James M. Taylor Questions concerning these meeting minutes should be referred to James H.
Conran (492-9855).
Original Signed bf.
E. L Jordan Edward L. Jordan, Chairman Committee to Review Generic Requirements
Enclosures:
As stated cc:
Commission (5)
SECY J. Lieberman P. Norry D. Williams W. Parler Regional Administrators A. Thadani CRGR Members Distribution:
Central File.
PDR (NRC/CRGR)
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CRGR S/F CRGR C/F S. Treby M. Taylor J. Sniezek D. Ross D. Allison J. Conran R. Emrit B. Grimes G. Marcus R. Jones L. Phillips
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Minutes.240
ATTENDANCE LIST CRGR Meetina No. 240 May 11, 1993 CRGR Members NRC Staff E. Jordan A. Thadani B.J. Youngblood (for G. Arlotto)
R. Jones J. No re L. Phillips J. Partlow (for F. Miraglia)
H. Richings W. Kane B. Grimes B. Sheron S. Bloom R. Kiessel CRGR Staff ara ta J. Conran
- to the Minutes of CRGR Meetina No. 240 Proposed Generic Letter (and Topical Report Safety Evaluation) on " Thermal-Hydraulic Instabilities in Boilina Water Reactors" May 11, 1993 TOPIC A. Thadani (NRR), R. Jones (NRR), and L. Phillips (NRR) presented for CRGR review the proposed Generic Letter, and associated Topical Report Safety Evaluation, on "Long-Term Solutions to Thermal-Hydraulic Instabilities in Boiling Water Reactors. The purpose of the proposed generic letter was to request that each addressee (1) take appropriate actions to augment short-term measures already taken (in accorda1ce with NRC Bulletin 88-07, Supplement 1) to prevent thermal-hydraulic instauilities in the operating BWRs, and (2) submit to the NRC a plan describing the long-term stability solution option selected and the schedule for implementation of any planned modifications to plant protection systems involved.
Copies of briefing slides used by the staff to guide the presentations and discussions at this meeting are provided in the Attachment to this Enclosure.
BACKGROUND The package provided for review by CRGR in this matter was transmitted by memorandum, dated April 19, 1993, F. Miraglia to E.L. Jordan; the package contained the following documents:
1.
Draf t Generic Letter (undated), "Long-Term Solutions to Thermal-Hydraulic Instabilities in Boiling Water Reactors";
2.
Enclosure addressing the provisions of CRGR Charter,Section IV.B.
(Contents of Packages Submitted to CRGR);
3.
Draft letter to BWR Owners' Group with attachment:
a.
Enclosure NRR Staff Safety Evaluation Report on "BWR Owners' Group Long-Term Stability Solutions Licensing Methodology, NED0-31960 and Supplement 1";
4.
NRC Contractor Report (ORNL/NRC/LTR-92/15), dated August 1992,
" Licensing Basis for Long-Term Solutions to BWR Stability Proposed by the BWR Owners' Group."
CONCLUSIONS / RECOMMENDATIONS On the basis of its review of this item, including the discussions with the staff at this meeting, the CRGR recommended in favor of issuing the proposed generic letter (and associated Topical Report Safety Evaluation), subject to the following comments and recommended changes (to be coordinated with the CRGR staff):
1 2
1.
The draft letter should be revised to make clearer that the proposed generic letter is requesting upgrading of interim (short-term) corrective actions, as well as information regarding planned long-term plant modifications, to effectively address the problem of thermal-hydraulic instabilities in the operating BWRs.
For example, the statement of " Subject" in the draft letter refers only to "long-term solutions"; explicit reference should be made there also to upgrading of interim corrective actions requested by the proposed letter.
2.
The treatment of issues in the draft generic letter and associated topical report safety evaluation does not make clear enough the relationship of the interim corrective actions already taken by licensees to the augmented interim (short-term) corrective actions requested in the proposed generic letter, or to the long-term solution options described briefly in the topical report safety evaluation and referred to in the proposed generic letter (specifically, with regard to whether or not monitoring capability is needed for detecting in phase and/or out-of-phase oscillations in the short-term vs long-term; and whether or not manual or automatic protective action capability for suppressing oscillations is needed in the short-term vs long-term).
This seems to lerve unclear the question of whether or not some interim (or augmented interim) corrective actions would be acceptable as long-term solutions to the instability problem.
In that specific context, CRGR also expressed concern regarding the possibility of further adding to the burden of reactor operators with manual actions to address thermal-hydraulic instabilities.
The staff should reexamine these aspects of the package, and revise it as needed, to make clear to the affected licensees what is intended with regard to short-term vs long-term monitoring and protective action capability, and to emphasize the need for considering operator burden in developing an appropriate response to this generic letter.
As a particular point in this context, note explicitly the " rise time" for the thermal-hydraulic oscillations of concern, i.e., the time interval in which oscillations would reach an unacceptable amplitude resulting in fuel damage, if protective action to suppress the oscillations was not initiated.
3.
The draft generic letter should be revised to note explicitly that the long-term resolutions referred to in the letter do not consider thermal-hydraulic instabilities in combination with ATWS.
addressed separately by other NRC and BWR Owners' Group activities.That subject 4.
In addition to the preceding, CRGR recommended the following specific changes to the draft package submitted for review:
3 Draft Generic Letter a.
Page 5, under " Requested Actions":
Revise Requested Action 1. to indicate explicitly that the lessons learned from the WNP-2 event should be taken into account in determining whether/what additional interim corrective actions are needed to ensure that factors important to core stability are properly understood and controlled.
c.
Page 6, under " Requested Actions":
Delete Requested Action 3.
(NRC staff review of licensee actions in response will be accomplished by selective audit of submitted responses rather than by region-based inspection reviews.)
Draft Topical Report Safety Evaluation d.
Page 6, discussion of acceptability of Options 18 and IC:
Reflecting discussion at the meeting, delete the words "not acceptable" in the first line on the page, and further revise the wording of the sentence to indicate that these options still need to be fully developed by the BWROG and reviewed by the staff before their acceptability can be established.
e.
Pages 5-9, under " Conclusions":
The staff should reexamine use of the word "must" in the statement of NRC staff positions.
f.
Page 10, in the fifth sentence under " Safety Classification":
Replace the words ".. notifying the NRC of.." with the word
" requesting" The Committee requested that the revised package, incorporating changes reflecting the CRGR comments and recommendations above, be circulated to CRGR members for final review prior to issuance of the proposed generic letter and NRC staff safety evaluation.
CRGR REVIEW OF DRAFT GENERIC LETTER AND RELATED TOPICAL REPORT EVALUATION CONCERNING LONG-TERM SOLUTION OF BWR THERMAL-HYDRAULIC ISSUES MAY 11,1993 Prepared By:
Larry Phillips Reactor Systems Branch DSSA/NRR l
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t BWR STABILITY ISSUES Identified by Operating Reactor Experience e Vermont Yankee (Tests)
GL 86-02 Resolution of BWR Stability
- Lasalle-2 (False ATWS)
BWROG Study Initiated to Evaluate
-Stability predictive capability
-Fuel integrity
-ATWS issues
- Vermont Yankee (Oct 1988)
(During Low Power Pump Maintenance)
-Input to administrative restrictions
- WNP-2 (Extreme Power Distributions)
-Input to interim operating restrictions
-Source of abundant data on in-phase & out-of-phase oscillations
I
===.
Background===
(Reported by GE on 10/28/88 under 10 CFR Part 21)
- Thermal margins not sufficient to prevent violation of SAFDL for out-of-phase oscillations.
- NRC issued Bulletin 88-07/S1 on 12/30/1988 approving the BWROG/GE proposed " interim corrective actions" and requesting further development of long-term solutions.
- BWROG/GE issued NEDO-31960 and Supp.1 documenting proposed long-term solutions licensing methodology.
Summary of NRR Requests to CRGR
- CRGR Review of
- Generic letter that requests BWR licensees to implement a long-term stability solution.
- Topical report safety evaluation that approves long term solution options.
- Approval of our SER for immediate release to BWROG, while generic letter proceeds through required public comment process.
- The staff believes that the actions requested to ensure compliance with GDC 10 and 12 are compliance backfits that do not require cost justification.
1
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Root Causes for WNP2 Instability Event The AIT concluded that the 8/15/92 WNP-2 event was caused by two conditions:
- Extremely skewed radial and axial power distributions caused by:
Control rod pattern selected by operator (without significant procedural control).
Core loading that placed highly-reactive (new) fuel in uncontrolled locations.
- A mixed (9x9-9X and 8x8 fuel) core that was not 100% thermohydraulically compatible.
LAPUR calculations indicated that:
- Oscillations could have been out-of-phase
- A more conservative control rod pattern results in DR = 0.3 at same power / flow conditions (8/31 startup measured DR = 0.2) compared to 1.05 for 8/15.
- Mixed core starved flow from high-power channels and contributed to instability.
Full 8x8 core DR = 0.8.
Full 9x9-9X core DR = 0.9.
ACRS-WNP2:9/17/92 l
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Generic Letter Requested Actions 1 - Review Adequacy ofInterim Corrective Actions (ICA) Within 60 Days and Upgrade as Needed
- Manual scram when pumps not operating (only BWR-2 plants are exempt)
- Stability consideration in reload core design
- Power / flow exclusion boundaries
- Stability consideration during power maneuvers
- On-line monitoring capability (thermal limits and power distribution)
- Stability monitors
- Appropriate stability operating limits v
Generic Letter Requested Actions (continued)
I 2 - Develop and Submit Long-Term Stability Plan by 1/31/94
- Description and schedule for long-term solution implementation
- Any of the solutions approved in the SER for NEDO-31960 and Suppl.1 is acceptable
- Address proposed near-term and long-term technical specification modifications 3 - Licensees Should Document the Adequacy of Their Stability Training Programs, Procedures, and Associated Core Monitoring Instrumentation, to Ensure that SAFDL Are Not Violated until Long-Term Solution Is Implemented
E Generic Letter Reporting Requirements:
1 i
l 1 - Within 60 Days i
i
- Inform the NRC of Plans and Status with i
Respect to Requested Actions
- Inform the NRC of Reasons for not Taking a Requested Action and a Description and Schedule for Completion of Any Proposed Substitute Action 2 - Inform the NRC Within 30 Days of Completion of a Requested Action or a Substitute Action and Verify its Completion or Implementation I
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Safety Evaluation Report:
Solution Options
- I : Exclusion. Region
- I-B : Same as I-A, but scram may be bypassed with a stability monitor.
- I-C : Protective action taken if (1) operating inside exclusion region and (2) small APRM oscillation is detected.
- I-D : A few small-core plants with tight inlet orifice have reduced likelihood of out-of-phase oscillations.
Flow-biased scram and administrative action provide protection.
- III : New Class 1E computerized system o III-A : Digital replacements of APRM amplifier cards
Safety Evaluation Report:
Conclusions
- Proposed exclusion region calculational methodology is acceptable.
- Treatment of uncertainties is acceptable to define j
initial conditions, oscillation contours, and Option II evaluations.
- Option I-A is acceptable for any BWR type:
- Reload confirmation procedures needed.
- Operational restrictions must be consistent with exclusion region setpoints calculations.
- Options I-B and I-C not acceptable because of lack 1
of developed detail / interest.
l
- Option I-D still under review. Will depend on detailed calculations for lead plants (Duane Arnold
& Vermont Yankee)
Safety Evaluation Report:
Conclusions (cont) i
- Option II is an acceptable long term solution in BWR/2s.
i
- Options III and III-A are acceptable solutions:
- All three algorithms (NEDO-31960) must be l
used.
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- Validity of setpoints demonstrated by analysis.
- Bypass region must be defined in tech specs.
- Requirements for minimum operable number of LPRM and groupings in NEDO 31960 are acceptable.
- A review procedure must be established to assure that LUA do not induce single channel instabilities.
i Safety Evaluation Report-
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Use of Non-Class 1E Flow Signal
- Recirculation drive flow channel must comply with IEEE standard 279 as a minimum o Single failure
- Channel independence
- Capability for test and calibration
- The staff will review hardware design details in a plant specific bases.
- In general, proposed design is acceptable, but may require modifications for some plants.
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- to the Minutes of CRGR Meetina No. 240 Proposed Administrative Letter 93-01.
" Announcino a New Tyoe of NRC Generic Communications" i
May 11, 1993 1
TOPIC
- 8. Grimes (NRR) and G. Marcus (NRR) presented for CRGR review proposed Administrative Letter 93-01, " Announcing a New Type of NRC Generic Communi-cations".
The purpose of this letter is to establish a new type of generic communications vehicle for transmitting to power reactor information of a
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purely administrative nature, or to request from licensees on a voluntary basis information to assist NRC in the performance of its regulatory functions.
The background documents listed below were used by the staff to guide the presentations and discussions at the meeting; copies of those documents are provided in the Attachment, i
BACKGROUND The package provided for review by CRGR in this matter was transmitted by memorandum, dated April 16, 1993, F. Miraglia to E.L. Jordan; the package contained the following documents:
- 1. -
Draft Administrative Letter 93-01 (undated),
" Announcing a New Type of Generic Communication";
- 2. -
" Types of Generic Communications".
CONCLUSIONS / RECOMMENDATIONS On the basis of its review of this item, including the discussions with the staff at this meeting, the CRGR recommended in favor of issuing the proposed bulletin, subject to the following changes (to be coordinated with the CRGR staff):
1.
The Committee supported the concept of establishing a new generic communications vehicle for transmitting or requesting information of a purely administrative nature.
TheAdministrativeLetter(AL)shouldnot be used, however, to transmit any information of a technical nature, i.e., involving or relating to the evaluation of technical safety issues.
Two specific examples of types of information that should be excluded from handling via Als (which might have been envisioned initially by the staff as appropriate subjects for future Als) were identified by CRGR: (a) information concerning resolution of an unresolved safety issue not result in any recomme(USI) or generic safety issue (GSI) that does ndation for new requirement (s), NRC staff position (s), or 50.54(f) information request)s); and (2) NUREG reports
2 that document the results of NRC sponsored studies and contain recom-mendations that are not approved NRC staff positions (e.g., AE0D technical reports). After discussing these examples of excluded information for ALs, it was agreed that. in the initial implementation of this new generic communications vehicle, for some reasonable trial period (e.g., six months to one year), consultation between NRR and the CRGR staff would be appropriate in the development and before final issuance of proposed ALs, to ensure that there is mutual understanding of the exclusion criteria.
2.
CRGR recommended the following specific modifications to the draf t package submitted for review:
Draft Administrative Letter a.
Page 1, under " Addressees":
Use instead the standard language referring to ".. holders of 1
operating licenses.." (i.e., delete the reference to " licensed operators".
b.
Page 1, 2nd and 3rd sentences under " Purpose":
Revise to read as follows:
)
"This administrative letter does not transmit or imply any new or changed requirements or NRC staff positions.
No specific action or written response is required."
[ Note: Licensees may be requested to provide voluntarily information of a strictly administrative nature; but no licensee response is to be required (e.g., under 10 CFR 50.54(f)) by an AL.]
c.
Page 2, subitem 1.a:
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Revise to read as follows:
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" Administrative procedure changes relating to implementation of the regulations or NRC staff positions."
d.
Page 2, in subitem 4:
Insert the word " purely" or " strictly" preceding the words
".. administrative nature."
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Page 1, in the liword " safety" atunder " Bu the conforming a
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e.
Replace the Page 1, in the 9t val" with "endorseof the draft h line tion word "approG neric Letter" secon the page in f.
Replace thechange in the " eext-to-last MakeEnclosure.
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3 Dra ft Enclosure 2 ("Defini tions..")
[ Note: Enclosure 2 was not intended to be included as a part of the proposed Administrative Letter, so it was not reviewed by CRGR for that purpose.
The following comments were offered for the purpose of improving clarity for any intended use of this information internally by the NRC staff.]
Page 1, in the lith line under " Generic Communications":
e.
Replace the word " safety" at the end of the line with " relevant".
f.
Page 1, in the 9th line under " Bulletin":
Replace the word " approval" with " endorsement". Make a conforming change in the " Generic Letter" section of the draft Enclosure.
g.
Page 1, in the next-to-last line on the page:
Replace the word "should" with "may".
Make a conforming change in the " Generic Letter" section of the draft Enclosure.
h.
Page 2, under " Generic tetter":
Revise the last sentence in that section to reflect, in accordance with Commission policy, that the language of a generic letter should be structured so as not to directly cr coercively solicit licensee commitments.
Licensee response to a generic letter may be required in accordance with the provisions of 10 CFR 50.54 and licensees may be requested to indicate in their responses (f);
"whether or not" they intend to implement actions requested in the generic letter.
A licensee commitment may or may not result from such a request.
Page 3, under " Administrative Letter":
e.
Conforming changes should be made in draft Enclosure 2 to incorporate the changes (to the draft Administrative Letter) recommended in 2.b, 2.c, and 2.d above.
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UNITED STATES
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i NUCLEAR REGULATORY COMMISSION W ASHINGTON, D. C. 20555 f
April 16, 1993 MEMORANDUM FOR:
Edward L. Jordan, Chairman Committee to Review Generic Requirements FROM:
Frank J. Miraglia, Deputy Director Office of Nuclear Reactor Regulation
SUBJECT:
PROPOSED ADMINISTRATIVE LETTER 93-01, " ANNOUNCING A NEW TYPE OF NRC GENERIC COMMUNICATION" The Office of Nuclear Reactor Regulation (NRR) is proposing the establishment of a new type of generic communication -- namely administrative letters.
As described in the enclosed (Enclosure 1) proposed Administrative Letter 93-01,
" Announcing a New Type of NRC Generic Communication," an administrative letter is defined as a type of generic communication issued to:
1.
Inform addressees of any of the following:
Administrative procedure changes being made to implement new a.
regulations
\\
b.
The issuance of a topical report evaluation or a NUREG-type document that does not contain a new or revised staff position and is not appropriate for inclusion in either a generic letter or an information notice Changes in NRC internal procedures or organizations c.
2.
Request submittal of voluntary information of an administrative nature which will assist the NRC in the performance of its function.
3.
Announce events of interest such as workshops or Regulatory Information Conferences.
1 4
Other purposes of a strictly administrative nature.
This definition of an administrative letter comes from the current working draf t of NRC Inspection Manual Chapter 0720, " Nuclear Regulatory Commission Generic Communications Regarding Nuclear Reactor Issues."
The draft manual chapter definitions of all four types of generic communications are contained in Enclosure 2.
The currently effective Manual Chapter 0720, "NRC Bulletins and Information Notices," does not define generic letters or administrative letters.
CONTACTS: Gail H. Marcus, NRR 504-2837 Richard J. Kiessel, NRR 504-2840 A WacA -cn / f.
En c nc 3
l Edward L. Jordan 1 An administrative letter will not convey or imply new requirements or be used l
to transmit new interpretations of regulations.
Therefore, an addressee response to the NRC will not be required and CRGR review and approval, issuance of a Federal Reaister notification, and preparation of a Commission information paper also are not required.
However, an Office of Management and Budget Paperwork Reduction Act clearance would be required when the administrative letter requested voluntary submittal of administrative information.
l l
In essence, administrative letters would be developed and issued in essentially the same manner as information notices are currently handled.
As with information notices, the issuing office would be responsible for ensuring that the administrative letters did not contain any new requirements.
l NRR is recommending this new typa of generic communication to reduce the burden on both the NRC staff and licensees which is associated with the issuance of generic letters which have as their primary purpose the transmittal of administrative information.
Further background and rationale are provided in the body of the enclosed proposed administrative letter.
l Should you desire, the Director, Division of Operating Reactor Support, is prepared to meet with the CRGR to discuss this new type of generic i
communication.
In the absence of such a request, NRR ir.tends to proceed with issuance of Administrative Letter 93-01 after informing the Commission, via an information paper, of this new type of generic communication.
i I
The Office of Nuclear Materials Safety and Safeguards has no objections to initiating this new type of generic communication.
NRR will make available to NMSS the administrative letter system in a similar fashion as is now done for information notices.
The Office of the General Counsel has no legal objections to the use of this new type of generic communications.
Brian K. Grimes, Director, Division of Operating Reactor Support, is sponsoring the issuance of Administrative Letter 93-01.
1
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l
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Frank J. Miraglia, Deputy Director i
Office of Nuclear Reactor Regulation
Enclosures:
1.
Proposed Administrative Letter 93-01, l
" Announcing a New Type of Generic Communications" i
2.
Generic Communication l
l
l I
UNITED STATES i
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NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION i
l WASHINGTON, D.C.
20555 April xx, 1993 1
NRC ADMINISTRATIVE LETTER 93-01: ANN 0UNCING A NEW TYPE-0F NRC GENERIC COMMUNICATION All NRC licensees except licensed operators PurDose The U.S. Nuclear Regulatory Commission (NRC) is issuing this administrative l
letter to inform addressees of this new type of NRC generic communication.
This administrative letter does not transmit or imply new requirements or interpretations of regulations. Therefore, suggestions contained in this administrative letter are not NRC requirements, and no specific action or written response is required.
Backaround Review of the 460 generic letters issued since March 1979 indicates that 203 (approximately 44 percent) simply forwarded information to the addressees i
i that, in most cases, was not directly related to nuclear reactor safety, safeguards, or environmental issues.
Examples of the most recent generic letters of this type are:
I Generic Letter (GL) 93-02, "NRC Public Workshop on Commercial Grade Procurement and Dedication" GL 92-09, " Limited Particination by NRC in the IAEA International
=
Nuclear Event Scale" l
GL 92-07, " Office of Nuclear Reactor Regulation Reorganization" GL 92-05, "NRC Workshop on the Systematic Assessment of Licensee
=
Performance (SALP) Program" In addition, a number of generic letters have requested the voluntary submittal of administrative information. A specific example of this is GL 92-06, " Operator Licensing National Examination Schedule," and its annual predecessors which asked addressees to revise their previous estimates of the i
I number of candidates to be tested during future fiscal years.
Discussion NRC expects each licensee to evaluate each generic communicat. ion for applica-bility to its own facility.
Even though a generic letter that transmits only administrative information to addressees should be quickly processed, the fact that it is called a generic letter may place an unnecessary tarden on systems designed to evaluate safety information.
l l
l
AL 93-01 April XX, 1993 Page 2 of 2 In view of the above, a new type of generic communication, called an administrative letter, will be issued from time to time.
Specifically, an administrative letter is defined as a type of generic communication issued to:
1.
Inform addressees of any of the following:
Administrative procedure changes being made to implement new a.
regulations b.
The issuance of a topical report evaluation or a NUREG-type document that does not contain a new or revised staff position and is not appropriate for inclusion in either a generic letter or an information notice Changes in NRC internal procedures or organizations c.
i 2.
Request submittal of voluntary information of an administrative nature l
that will assist the NRC in the performance of its function.
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3.
Announce events of interest such as workshops or regulatory information l
l conferences.
4.
Other purposes of a strictly administrative nature.
This administrative letter requires no specific action or written response.
If you have any questions about this letter, please contact one of the people l
listed below, the appropriate Office of Nuclear Reactor Regulation project manager, or the appropriate regional office, l
i Brian K. Grimes, Director Division of Operating Reactor Support Office of Nuclear Reactor Regulation Contacts:
Gail H. Marcus, NRR (301) 504-2837 Richard J. Kiessel, NRR (301) 504-2840 Kevin M. Ramsey, NMSS (301) 504-2534 l
i TYPES OF GENERIC COMMUNICATION 1.
Generic Communication A transmittal to one or more classes of licensees.
Identical communications addressed separately to individual licensees should also be considered as generic communications.
There are four general types of such communications:
bulletins, generic letters, information notices, and administrative letters.
The enforcement aspects of bulletins, generic letters, and information notices are discussed in 10 CFR Part 2, Appendix C, Section V.H, "Related Administrative Actions."
In addition to the affected licensees, copies of generic communications are also sent to nuclear industry manufacturers, suppliers, service groups, and regulatory organizations to broadly disseminate information to those whose safety activities it may affect.
Any NRC office may propose a generic communication on issues within its technical purview. However, the Office of Nuclear Material Safety and Safeguards (NMSS) and the Office of Nuclear Reactor Regulation (NRR) retain ultimate responsibility for issuing such documents, NMSS for matters regarding materials or fuel cycle issues and NRR for matters regarding nuclear reactor issues.
If the subject matter pertains to both reactor and materials or fuel cycle issues, it may be signed by both offices or issued as separate generic communications.
2.
Bulletin A type of generic communication that transmits information to, requests specified action' by, and requires a written response in accordance with 10 CFR 50.54(f) from addressees regarding matters of safety, safeguards, or environmental significance.
The addressees may i
be asked to take actions by a specified time.
Bulletins, in general, do not request continuing actions.
Normally, before issuing a bulletin, the staff will obtain review and endorsement of the bulletin by the Committee to Review Generic Requirements (CRGR), publish the bulletin in the Federal Reoister along with a request for comments from interested parties, and inform the Commission via information paper of the staff's intent to issue the bulletin.
The staff can issue an immediately effective bulletin without obtaining prior review and endorsement of the bulletin by the CRGR or issuing a Federal Reoister notification.
However, the staff normally provides a l
copy of the immediately effective bulletin in advance to the CRGR Chairman for affirmation of the program office determination that the bulletin should be issued without prior CRGR review.
' If an addressee declines to perform an action requested in a bulletin or generic letter, a staff evaluation is apprupriate to determine whether a requirement for action should be imposed by an order.
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3.
Genesic Letter A type of generic cc m unication that:
Requests that analyses be performed or descriptions of proposed a.
corrective actions be submitted regarding matters of safety, safeguards,orenvironmentalsignificance.
The addressees may be asked to accomplish the actions and report their completion b -
letter with or without prior NRC approval of the action.
Information relating to these analyses may be requested on a voluntary basis or in accordt.qce with 10 CFR 50.54(f). Usually, this type of generic letter requests new or revised licensee comitments or other continuing actions.
b.
Requests or provides the opportunity to addressees to submit revised technical specifications.
Requests addressees to submit technical information which NRC c.
needs to perform its function.
d.
Provides staff technical or policy positions not previously comunicated or broadly understood.
Solicits participation in voluntary pilot programs.
e.
i Normally, before issuing a generic letter, the staff will obtain review and endorsement of the generic letter by the CRGR, publish the generic letter in the Federal Reaister along with' a request for comments from interested parties, and inform the Comission via an information paper of the staff's intent to issue the generic letter.
The staff can issue an imediately effective generic letter without obtaining prior review and endorsement of the generic letter by CRGR or issuing a Federal Reaister notification.
However, the staff normally t
provides a copy of the immediately effective generic letter in advance to the CRGR Chairman for affirmation of the program office determination that the generic letter should be issued without prior CRGR review.
4.
Information Notice A type of generic communication issued to addressees to provide information regarding safety, safeguards, or environmental issues.
Information notices are normally used to bring significant recently identified safety, security, or environmental information to the attention of licensees.
Addressees are expected to review the information for applicability to their facilities and consider actions, as appropriate, to avoid similar problems.
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An information notice is written so as not to convey or imply new requirements or transmit new interpretations of regulations and so as not to require or request specific actions.
Therefore, an addressee 2
response to NRC is not required and CRGR review and endorsement, issuance of a Federal Reaister notification, preparation of a Commission information paper, and OMB clearance are not required.
In some cases, the staff may also issue a bulletin or generic letter after performing additional evaluation.
5.
Administrative Letter A type of generic communication issued to:
Inform addressees of any of the following:
a.
i.
Administrative procedure changes being made to implement new regulations ii.
The issuance of a topical report evaluation or a NUREG-type document that does not contain a new or revised staff position and is not appropriate for inclusion in either a generic letter or an information notice iii.
Changes in NRC internal procedures or organizations b.
Request submittal of voluntary information of an administrative nature which will assist the NRC in the performance of its function.
Announce events of interest such as workshops or Regulatory c.
Information Conferences.
d.
Other purposes of a strictly administrative nature.
An administrative letter is written so as not to convey or imply new requirements or transmit new interpretations of regulations and so as
.not to require or recommend specific actions.
With the exception of requesting submittal of voluntary information, an administrative letter may not request specific actions either. Therefore, an addressee response to the NRC is not ree"4 red and CRGR review and endorsement, issuance of a Federal Reais', acc^i1 cation, and preparation of a Commission information pap >
are no required.
However, an OMB clearance is required wheo.
- rd submittal of administrative information.an.s 'ative letter requests voluntary i
2 NMSS _ information notices may contain suggestions for Because of backfit requirements applicable to reactor licensees, good practices.
NRR information notices may not contain suggestions or recommendations; where suggestions or recommendations are appropriate, other forms of generic communications must be used and CRGR must ba consulted.
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