ML20058K100

Informs Commission of Status of Implementation of Recommendations by NRR Mgt Guidance Team

ML20058K100
Person / Time
Issue date:	08/30/1989
From:	Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:
References
SECY-89-268, NUDOCS 8909060352
Download: ML20058K100 (169)

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{{#Wiki_filter:- eeeee:c..r .c, og pp em ,). q,- O r . ll l W e4 :, 's I %,..... / August 30, 1959 -POLICY ISSUE SECY-89-268 informat. ion) For: The Corrnissione From: James M. Taylor Acting Executive Director for Operations

Subject:

RECOMMENDATIONS OF THE NRR MANAGEMENT GUIDANCE TEAM

Purpose:

To inform the Contiission on the status of implementation of recommentations by the NRR Managenent Guidance Team. Feference: Memorandur, for the Commission fcom Y. Stello, June 9, 1989 " Operating Reactor Licensing Actions and Technical Specifications Improvements." Bac kground: Reducing the size and age of the inventory of licensing actions has been a continuing challer.ce to NRR management for many years. In the early 1980's the nurber of new issues being opened far exceeded the ndeber being closed such that the inventory increased to over 5,000 actions. Although this is no longer the case and the inventory has been significantly reduced over the last few years, many of the older issues had not been completed. In 1987, NRR instituted a prioritizatien system based on safety significance for dealing with licensing actions and other activitics requiring staff resources. While effective in focusing NRR's reduced staff resources on safety-significant isnTs, the prioritizaticr. system causEc the age of low-priority licensing actions to increase. Discussion: To address this issue, the Director of NRR initiated certain efforts, one of which was the creation of the Management Guidance Team (MGT). Its charter was to review license amendments (a subset of licensing actions) over two years cid, take appropriate actions to reduce the license amendment backlog, and develop recomendations to manage the inventory in the future. The MGT first set out to reduce the existing backlog of older license amendment requests through a concentrated three-month 0000 \\ Cone G. M. Holatan, NRR

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• 'The Compissioners i effort from April to June,1989. As a result of this effort, 937 of the license amendments greater than two years old have been completed. The remaining 7% are on well-defined paths to resolution in the near future and NRR management will monitor the progress en those actions to ensure their tiscely completion.

l It should be noted, however, that there still is a backlog of 'other licensing actions" and that efforts on multiplant action (MPA) reviews are continuing as discussed in the above reference. l Next, based on the findings r,ade during the effcrt to reduce the backlog of olcer license arr.endments, the MGT developed recorrendations for improvements in intnecement control, workload tracking, and staff review guidance to more effectively manage the workload inventory in the future. These recorr:endations also address the backleg of "other licensing actions." The tearr's detaileo recomerdations are summarized in Section 6 of the MGT report (Enclosure 1). KRP management has completed its renew of the reccrrmendations and has directed the staff to begin implerentation of 19 of the 21 specific recommendaticns. lists the specific reccrrrrendations and the imple-nuntion approach to be taken for each of them. The general approach will be te inccrporate the recorrendations cn staff review guidance into hRR Office Letter No. E04, "Procecures and Responsibil1 ties for License Amendment Reviews" by St.pt ember 30, 1989. The recorscenced improverrents in tracking ar.c control will be incorrorated into L'ISP (WorHcad Inforsterion and Seteduling Progrer) in tk long term. Short-terr., sclutions are being impler+nted admir,1stratively by elimintring procedural obstecies. For exertple, the multiplicity of input vehicles that were previously used to update the main (RITS) datebase hes been elluireted, leaving only one. Such short-term efforts will res nd to a number of the MGT recommendations. l Maneprent oversicht of licuising actions will be improved by reans of increased atterition by NRF line n.anagerxnt through a prescribec' series of management meetings with the technical review and project management staffs. Pertinent data produced prcrptly by WISP will be usec at these meetings to guide and cirect the staff in reaching early decisiens on all licensing actions. J i i i l I

'The Cornissioners - i When these reconnendations have been fully irplemented over the next several months, we believe we can brirag the licensing actions inventory under control, in accordance with the reconnended gocl. /, s J rres M. Tay ~ r cting Executive Director for Operations Er closures: 1. MGT Report 2. Implernentaticn of MGT Recorr,endations DISTRIBUTION: Commissioners OGC OIG GPA PIGIONAL OFFICES FDO ACRS ACUW ASLBP ASLAP SECY i 3 1 I

"l jg Enclosura 1 UNITE 3 STATES '-8 9,A NUCLEAR REGULATORY COMMISSION ,g wAsmaTow,c. c. rosca %...../ June 29, 1989 MEMORANDUM FOR: Thcrnas E. Nurley, Director Office of Nuclear Reactor Regulation THRU: James G. Partlow ) Associate Director for Projects ( Office of Nuclear Reactor Regulation FRCM: The Management Guidance Team

SUBJECT:

MANAGEMENT GUIDANCE TEAM

SUMMARY

REPCRT Attached is the sunnary report of the efforts of the Management Guidance Team. As directed in the Team's charter, a short-term effort has been conducted which has resulted in the completion of 93% of the license amendment backlog. It should be noted, however, that there still is a backlog of "other licensing actions." Based on the findings made during the license amencment backlog reduction effort, the Team has developed recomendations for improvements in management control, workload tracking, and staff review guidance to more effectively ~ manage the workload inventory in the future, including a means to deal with the backlog of "other licensing actions." The detailed recocraendations are sumarized in Section 6.of the report. The Team'woul'd like to express its appreciation for the efforts of the Project Managers, technical staff, Section Leaders, Branch Chiefs, and Project Directors who promptly and thoroughly responded to the Team's requests and directions. The Team also 'ishes to express its sincerest appreciation for the valuable w assistance of Ed Reis from the Office of General Counsel. Mr. Reis not only provided legal views, but alto actively contributed to the Team's efforts. ~ W N AhS"W Gary M. Hola an, Chaiman - uanes E. Richardson A.Nysk Qk [, Christopher I. Grimes Charles E. Rnssi h. Gus C-Lainas Ashok C. Thadani Atn ment: MGT Sunnary Report 4 64% 13 4 "

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.r s-I CONTENTS 1. INTRODUCTION i i 2. MANAGEMENT GUIDANCE TEAM PROCESS AND FINDINGS f i 3. ROOT CAUSE OF INVENTORY BUILDUP AND RESOURCE NEEDS 3.1 Backlog Causes 3.2 Resource Implications i 4. NATURE OF 'OTHER" ACTIONS i i 5. FUTURE INVENTORY CONTROL RECOMMENDATIONS 5.1 Backlog Inventory l' 5.2. Inventory Goals 5.3 Management Attention 5.4 Procedural Controls for the Review of Licensing Actions 5.5 NRR Priority System 5.6 Future Tracking System Requirements 5.7 Submittal Guidance 3 5.8 Review Guidance 6. SUMARY CONCLUSIONS ~ ~ i I i 1 [ 4 I e s,

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r - 4 h APPENDICES A. Management Guidance Team Charter 8. Final Backlog Reduction Status Report C. MPA Closure Plans-f D. Proposed Revision to the NRR Priority System l E. WI5/ Tracking System F. Sample "Interia" Tracking Systen G. Certification Process for TS Improvements H. Documentation Guidance and Examples I. Procedures and Responsib111 ties for License Amendments, Proposed NRR Office Letter No. 804 I s o I 4 i e i e t 9 y.. , ;,,,_g._y _ .-.,.:..,....x.,,.

.4 y o 1. INTRODUCTION The Mariagement Guidance Team (MGT) was created by the Director of the Office of Nuclear Reactor Regulation (NRR) to review license amendments over two years old, take appropriate actions to reduce the license amendment backlog, and develop reconnendations to manage the license amendment inventory in the future. The purpose of this report is to present the results of the MGT's review of the existing license amendment backlog and the MGT's recoceendations for the handling and maintenance of the licensing action inventory in the future. On March 3,1989, during the NRR Management Meeting Dr. Murley discussed the problem of the " sediment" of old licensing actions wh'ich has accumulated over the years. To deal with this problem. Dr. Murley created the MGT, designated the.aembers of the team, and directed that the team prepare a charter to address the backlog of license amendment requests. The scope of this activity was defined as those license amendment requests over two years old. The composition of the MGT.was specifically designed to include broad experience in both technical review and project management; the designated members of the MGT are: Gary Holahan, Chair Chris Grimes Gus Lainas Jim Richardson Ernie Rosst Ashok Thadani ~ Ed Reis (OGC representative to the MGT) In a memorandum from Chaiman Zech to the EDO, dated March 6,1989, the Connission expressed its concerns regarding the timeliness, inventory and resource demands of reactor licensing actions. Further, the Chairman directed that a review of'this matter be conducted and identified specific requirements which had a direct bearing on the. scope of the MGT's effort. The Chairman i made it clear that the focus of this effort "is a reasonable expectation of both l l .. - %....d.. , ?...

U the public and our licensees that al.1 matters submitted to this agency in accordance with our regulations would be reviewed thoroughly and acted upon by the staff in a reasonable period of time." Accordingly, the MGT developed a charter which would achieve the objectives established by the Director of MRR and satisfy the requirements set forth by the Commission. The MGT's charter is presented in Appendix A to this report. Briefly, the charter provides for: 1. a s'hort-tens effort to reduce the existing backlog of license amendment requests over two years old through a concentrated three-month effort (target completion - June 1,1989) directed by the MGT, with the approval of any significant resource reallocations by the Executive Team, and 2. based on a review of the experience from the short-tem effort, the types of other actions in the licensing action inventory, and the plans for closure of the multiplant actions, the MGT would develop recommendations for the scope and depth of reviews, acceptable size of the inventory, and management control procedures for licensing actions iri the future. To this end, tha MGT issued instructicns to the NRR staff to prepare information related to the nature of the issues associated with the license amendment backlog and the resource impacts associated with the completion of those actions. The MGT then met with each of the Project Directorates and Technical Branches and specified the actierts to be taken to complete the license amend-ments in the backlog. The MGT met three times a week during the short-tem effort and monitored progress on the completion of the backlog with weekly status reports. Concurrently, the MGT reviewed the activities associated' with the closure of the multi-plant and generic actions, the types of other actions in the licensing inventory, and information concerning various tracking systems, to provide a thorough basis for its recomendations. As a result of its efforts, which are described in more detail in Section 2, the MGT has satisfied the objectives set out in its charter, as follows: .- ;-m w: ;.y:,,..r ~ -..... :.. ~ ;.., .-44

The license amendment backlog, of items greater than two years old, has essentially been eliminated (93% complete during the three-month effort); any remaining license amendments over two years old are on a well-defined course to completion. The MGT's final status report on the short-term effort is presented in Appendix B to this report. The nature of the population of "other licensing actions" (i.e., those actions not directly related to license amendments) has been defined, and the attributes of similar efforts to manage licensing activities have been investigated. Recoccendations have been developed for inventory goals, management controls, and process improvements which, when implemented, would maintain the " licensing action" inventory in the future. l Section 2 of this report describes the process the MGT employed to reduce the license amendment inventory and the significant findings from that effort. Section 3 discusses institutional characteristics which tend to foster the growth of a backlog and the resource implications of the iicensing action inventory. Section 4 describes the nature of the "other licensing actions," different from the license acenchent requests involved in the MGT's short-tem effort, and presents recorcendations for reducing the backlog in that inventory. Section 5 of this report presents the MGT's recocmendations for completing and controlling licensing actions in the future. Finally, Section 6 presents the MGT's overall conclusions concerning the licensing action inventory. 2. MANAGEMENT GUIDANCE TEAM PROCESS As in similar past efforts, the MGT initially found it necessary to capture the license amendment inventory on separate database to identify, control and track the actions required to reduce the backlog. While infomation associated with the license amedment backlog is available on several of the NRC's computer tracking systems, there isn't one system with all of the necessary infomation and flexibility to monitor and direct the completion of the license amendment backlog. Consequently, the MGT created a database of the license amendment 3-9 e

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inventory, segregated the amendments that constituted the backlog over two years old, and sent the listing to the Project Directors (PDs) and Branch Chiefs (BCs) to validate the extent of the backlog and obtain additional information related to the timing and resources necessary for the completion of those actions. The MET then met with the PDs and BCs to review the status of each license amendment action and the nature of the effort required to complete the action. The specific infomation the PDs and BCs were asked to provide and discuss for each action included: 1.

Background:

The nature of the issue and need for the amendment. I 2. Safety Significance: High, medium, low, or unknown. 3. Proposed Resolution Path: Accept, deny, require (order) more than the licensee proposed, eliminate where necessary (e.g., based on TS split), or require alternative action. 4. Relationship to Other Plants: Proposed action: consistent, less demanding, or more demanding. 5. Relationship to TS Improvements Program: Maintained or removed in the ~ TS " split report" (i.e., the office policy on required content of technical specifications). 6. Relationship to STS: Proposed resolu' tion consistent, requires less, or requires more. 7. Resource impact: Technical expertise available or needed. 8. Proposed Activities to be Deferred to Make Resources Available: Based on guidance. - 9. Schedule: Initiation and cornpletion. 4 m $M$g j %* W esf$ S eg - 4 6$ e qG49W yp g-p@ %ge*W E gg F g M*"# W$ Dg8 m. q ad' 4 T" .g M "NM

4 s, i During the initial meetings with the PDs and BCs, the MGT provided direction or obtained commitments by which nearly all of the license amendments would be completed by the end of the short-term effort (June 1,1989). The effort required to complete these actions generally fell into the following categories.: Review Cor:pletion Many of these cases were issues of relatively low priority and the reviews were not previously begun or completed because of their low priority. At the direction of the MGT, project and technical staff resources were made available to complete these reviews. Withdrawals These cases included those for which the licensee's original request was incomplete, out-of.-date, or of such low priority to the licensee that they were not actively supporting the review. For these cases, the Project Manager was instructed to offer the licensee an opportunity to voluntarily withdraw the application. In the event that the licensee would not voluntarily withdraw the application, the Project Manager was instructed to send a letter rejecting the application. A standard rejection letter (included in Appendix I) was constructed to aid the affected Project Managers. Issues Related to Generic Activities ' These cases included those for which the licensee's request was related to an NRC generic issus (e.g., inservice tasting) or standard technical specification activity (e.g., TS' " split report" issues) for which the staff or licensee was delaying action until a generic solution was achieved. In those cases where a constructive action could be taken now, the MGT directed that the action proceed in advance of the generic solution. For the remaining cases, the Project Manager was instructed to request that the application be withdrawn.. as discussed above, since no constructive 3 review could be undertaken for these cases.. o

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c Recuests Differino from NRC Guidelines These cases included those for which the licensee's request differed from - that in the STS or generic guidance. As a result, an ongoing dialogue had developed to negotiate a compromise. Naturally, those negotiations were time consuming because the NRC staff wanted a result more like the standard and the licensee wanted a result reflecting their " unique" circumstances. In cases where it could be reasonably ec%cluded that circumstances were unique and the request was technically acceptable, then the request was approved. Otherwise, the licensee was to be informed that we are prepared to order that the standard be imposed. There was considerable debate on this point. While some of the cases clearly warranted an crder and were supportable from both a safety and policy perspective (e.g., improvements to the reliability of reactor trip breakers), in other cases an order did not appear warranted on safety grounds. While some PMs and PDs felt the staff should continue the negotiations in cases of lesser safety signifi-cance, the MGT directed that affirmative action be taken to resolve these issues. Substantial Efforts which Should Continue In a very few cases, the %T identified specific license amendment actions which would not and snould not be compisted by the Jur.e 1,1989 gesl. , l These cases usually involve a significant effort that was well along and the remaining activity was well planned for a timely conclusion. For example, the STS conversion for Turkey Point is scheduled for completion in the fall of 1989. In addition, orie issue in hearing and the Full-Ters Operating License conversions for Dresden, Palisades, San Onofre, and Oyster Creek could not reasonably be completed in three months. A total of 13 actions out of 286 license amendments were identified for which resolution could not reasonably be expected before June 1. 1989. It is reasonable to expect that there will always be a few cases requiring a substantial effort that may not be completed within the inventory goals set for other items. The cocnitments and schedules the NGT obtained during the initial meetings were incorporated into the database so that the MGT could monitor the staff's. <,.s 4,

progress during implementation. A report form was created which would readily [ depict progress by highlighting the periods during which technical review and project management were supposed to be active for each action, and a sumary graph

• depicting the overall completion in relation to the goal (see Appendix B).

During the period that the MGT monitored implementation of the short-ters backlog reduction activities, the MGT also met with the staff working on related activities to share experience and obtain a broader' perspective for the long-tene recomendations. These meetings included the projects, staff working on the ccepletion of multiplant actions (See Appendix C) and the status of implementation of T14I Action Plan items, and the generic communica-tions staff working on bulletins and generic letters development and closecut. The MGT generally found that all of these efforts shared comon themes. The MGT also had an inventory assembled of the "other licensing actions" to under-stand the nature of that inventory (see Section 4). After reflecting on these activities, the MGT arrived at the following findings: Acceptance reviews have not been conducted for incoming applications. Many of the staff have been willing to review any application submitted, ' wit'hout regard for the quality or need of the application. Similarly, the staff has been reluctant to take action on applications that licensees have allowed to remain dormant for long periods. Licensees occasionally submit improved computer codes and new procedures that require a substantial review eff' ort. However, when these applications push the state-of-the-art too far, they might be more properly categorized as research projects. While licensees should not be discouraged from pro-posing such improvements that can benefit the whole industry.the staff should not be expected to complete these issues in the same time and effort as a license amendment. i Adequate tracking and management review of the licensing action inventory with regard to age, priorities, and resource allocation has not been perfomed. Management does not have a consolidated and accurate database of all of the pending licensing actions. -7

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• Guidelines do not exist'which explain the appropriate differences in the scope and depth of review, and the associated documentation, for the various kinds of licensing actions and other regulatory reviews; The' j

staff, for simplicity, often applies the level of review and documentation j associated with a license amendment to all regulatory activities. The staff often conducts "de novo" reviews on each application and issue. f While precedents are often used, they are not used consistently or l effectively. t Efficiency of the review process, and the timeliness of staff actions, could be enhanced through the increased use of standard forms and' checklists, including acceptance checklists, standard rejection letters, ) required legal findings, and review checklists, and examples of. scope and. -i depth for various types of reviews. Guidelines are not clear with respect to the proper use of the STS-and l the SRP,as standards for accepted practica. The staff has not adequately j encouraged conformance with those standa'rds. Moreover, when it has been j ~ necessary for public health and safety, the staff has been reluctant to l order conformance even when the licensee has not demonstrated that its alternative to those standards is justified. Considerable effort is often. expended by the staff in reviewing unique applications. Standardi:ation of the ra,b prscass can save :::ecite.4RC staff and licenses resources, ~j ~ speed the resolution of issues, and reduce the likelihood of ineffective ~..; resolution. A plan needs to be developed to effectively and efficiently' reduce the backlog of "other licensing actions" in the inventory in a reasonable ~ period of time. However, that effort could substantially hamper other safety-significant staff activities (i.e., resolution of multiplant ~ actions and operational safety initiatives) if it were scheduled too aggressively. O i 4 f i 8-b i-3:.. c,.. .r

9 g 6 3. ROOT CAUSE OF INVENTORY BUILDUP AND RESOURCE NEEDS 3.1 Inventory Buildup The overall inventory of " licensing actions" is the result of NRC initiatives ~ following the THI-2 accident, other events in the early 1980's, and licensee initiatives associated with proposed plant cr procedure modifications. In the early 1980's, the number of new issues being opened far exceeded the number being closed, such that the inventory increased to over 5000 actions. Although the inventory has been reduced over the last few years, many of the oldest issues have not been completed. In 1987, NRR instituted a prioritization system, based on safety significance, for dealing with " licensing actions" and other activities requiring staff resources. While the prioritization system has been effective in focusing NRR's reduced staff resources on safety-significant issues, it has exacerbated the problem for low-priority, aging licensing actions. The prioritization system did not recognize the indirect significance of inaction on old issues; inaction can and has reflected ~ poorly on NRRs credibility 'as an organization which has its activities under control. A number of other elements have contributed to the inventory of old licensing actions. These include: A review style characterized by excessive necotiation rather than decisiveness. This style is a carry-over from the CP/0L review style when the nature and schedule of the r'eview permitted negotiations (i.e., open licensing issues did not need to be closed because they could be imposed as a license condition). A lack of management attention to the nature and age of the licensing action inventory. Because the prioritization system worked well for the high-priority actions, management did not anticipate the formation of the low-priority " sediment" or the adverse impact it w'ould have. An inability of some staff and first-line managers to $ake decisiens or to get managemen' tvolved to provide guidance and direction. :

= y ~~ y ~j 4 A lack of clear policy on the acceptability of ' deviations and exceptions from NRC standards and generic guidance. A general reluctance by the staff to use strong actions (orders which offer hearing rights or formal denials) on low priority issues because they have lower safety significance. A lack of an adequate tracking system to identify and manage the natum, distribution, and age of lice.nsing actions. The lack cf licensee pressure for approval for lower priority actions. l .i The NRC issued guidar.ca to'the industry in Generic Letters 83-20 and 88-20 ~i on integrated implementation schedules and integrated safety assessments.- j While the intent of this policy was to encourage licensees to prioritize implementation of plant modifications based on safety significance, in f practice this policy has tended to inhibit the resolution of issues with -l lesser safety significance because, at least in some cases, the licensees-l t have deferred not only the implementation of corrective action, but also o the decision on the action to take to resolve the issue. This is parti-cularly true for issues with a low perceived safety significance where the l licensees are inclined to leave the issue open in light of the possibility l of that the resolution of other issues could affect the most efficient action to resolve the deferred issue. This phenomenon was directly responsible for at least one issue in the backlog. In addition, the-staff's review of a licensee's integrated schedule to implement actions-is itself a licensing action which accounted for a few of the items in the backlog (Brunswick, North Anna, and San Onofre). Consequently, the MGT finds that NRR reconsideration and revision of the integrated schedule policy is needed so as to be consistent with-the licensing action inventory policy ultimately adop N from our-recommendations. 10 - b e 4, 9- .g,

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4 None of the elements' contributing to the backlog of licensing actions con-stitutes an " institutional impediment' which cannot be effectively resolved by internal guidance and procedures and resource adjustments. Each of these elements and the associated reconnendations are addressed in this report, av follows: Major Cause: Recoceendation Report Section Low priority Increase priority with age. 5.3 and resources. Other causes: Poor tracking Implement interim tracking system 5.6 until WISP implementation complete. Review style. Issue new guidance. 5.8 Management attention. Increase management attention. 5.3 Poor decision making. Increase management attention 5.3 No policy on Develop policy. ~ 5.8 deviation from NRC standards. Reluctance to use Issue new guidance 5.8 orders and denials Lack of licensee No action required. attention Integrate schedules Consider strengthening 5.8. early decision making 3.2 Resource Implications In order to develop conclusions and recommendations on the subject of resource implications, the MGT ' reviewed the list of "other licensing actions" (non-license amenaments) other new initiatives (such as the TS improvement program), NRR resources allocated for licensing actions, the use of contractor support, the validity of using labor rates for resource projections, and the potential savings associated with the MGT reconnendations in other areas (such as a shortened review process via early decision making).

There is a current inventory of approximately 3400 " licensing actions,' with a projected total for the end of FY 1989 of approximately 3200. (Note that this figure includes many items which may be redefined as something other than a " licensing action," as discussed in Section 4 of this rep' ort.) To reduce the inventory to an amount approximating the annual incoming number of actions, the inventory would need to be reduced to approximately 25 actions per plant per year (i.e., 25 x 112 = 2800) depending on the definition of the scope of the inventory; this would constitute a reduction of approximately 600 actions from the number now pending. Based on the " labor rate" experienced during the first half of FY 1989 (i.e.,100 technical staff FTE plus 49 project manager / engineer FTE and an annualized rate of 2514 actions = 0.06 FTE per action), the addi-tional 600 actions would appear to require 36 FTE. However, a full 36 FTE increase would probably not be needed, based on the expected increase in efficiency associated with early decision making, the elimination of some items, and on extensive use of the new guidance on the format and content of SERs (see Section 5.8). The increase in resources currently allocated for this activity for FY 1990 in the Five Year Plan is 24 FTE (i.e.,124 FTE for FY 1990 versus 100 FTE for FY 1989). This resource level appears adequate to handle "the FY 1990 workload, including completion of the additional 600 actions to bring the inventory to an acceptable level. In addition, by concentratin'g efforts on those actions greater than two years old, the total inventory can be significantly reduced in age as well as in nwrter. By the end of FY 1990, the total inventory can be brought to a level conforming to the age distribution goals proposed in Section 5.2 of this report. In FY 1991 and beyond, the resources for this activity would become approximately 112 FT'E for the technical staff and 49 FTE for the project r.anager/ engineer staff to handle the projected 2800 actions per year. If the MGT recocnendations relative to management involvement, improved tracking, and staff review guidance are adopted, these resource estimates for FY 1991 and beyond should be reevaluated in about six months. 4 d

.l i For the purpose of this discussion, and particularly the use of an. average of 25 actions per plant, as discussed above, we have assumed that the scope of the inventory would encompass " licensing actions" and "multiplant actions" as they are defined in Section 4 of this report, and all of those items we have designated as " regulatory tasks" in that section. If the MGT's re-commended definitions for " licensing action" is adopted, approximately 5 actions per plant, out of the average 25, would be categorited as " regulatory tasks" and would be counted, tracked, and budgeted separately. k'e believe that the latter category should be handled differently, particularly with rtgard to resource allocation. It should be noted that these resource estimates do not reflect the additional effort associated with the TS improvement program or with license extensions beyond 40 years. The technical staff level of 112 FTE cited above appears to be accoccodated by the resources allocated in tne latest draft of the Five Year Plan. In our review of the resources available for " licensing actions," it has become clear that the projection of resource-needs t'hrough the use of labor rates ~ (i.e., average FTE per licensing action) is not reliable. A minor change in the assumed labor rate will make an important change in the projected allocation of resources. In the past, significant changes in actual' labor rates have occurred, due to changes in the types of actions under review and changes in ranagement pressures to get actions completed. Three alternative approaches for dealing with resource projections have been studied. First, the concept of labor rate's could be abandoned and NRR could simply budget at an arbitrary level (for example, 100 or 124 FTE) regardless of the expected or desired number of licensing actions. This would apply more pressure to the staff to complete the actions more efficiently (i.e., at a lower " labor rate") when more licensing actions were being added to the inventory. Second, a " standard" labor rate (e.g., 0.05 FTE/ action) could be applied each time budget and resource estimates are needed. This would lead to fluctuations 13 - b .....s.. s

4 ' in the resources allocated to this activity to meet tne goals on inventory size and age distribution. In many cases, these resource needs would depend l cn the types of issues and on management guidance on the depth of review. A third alternative Wuld be to develop a more realistic labor rate to be j assigned to various types of licensing actions. Resource estimates would then be based on estimates of the type as well as the number of incoming actions and on specific labor rates assigned for each type of action. This approach would also establish standards and goals for the efficiency needed in reviewing the actions. Although the third alternative would require more study and would further complicate the resource estimate activities, it would ultimately provide the most accurate and useful resource projections and is consistent with MGT's other redomendations for tighter tracking and management control. Therefore, the MGT recomends that this approach be pursued. 4. NATURE OF "0THER" ACTIONS The first task for this effort was to clearly define the components currently counted in the "other licensing action" category. Based on a separate dat' abase of actions developed like that for the license amendaents, we found that the major divisions are listed as 2.206 petitions and the Director's Decisions, exemptions to the regulations, reliefs from the regulations, support to the regional offices under Task Interface Agrerwnts (TIAs) or assistance to other offices, and letters / memoranda. The letters / memoranda grouping represents actions dich may result in a safety evalu~ation or letter to the licensee or NRC. internal documentation concerning some technical or administrative issue for a particular plant. An audit review using plants in Regions I and II as a representative sample produced the following results: the combination uf petitions, Director's Decisions, and TIA (assistance to other offices) combined represent about 4 percent of the inventory of "other licensing actions." Exemptions and reliefs from the regulations represent roughly 32 percent of the' inventory. Letters and memoranda represent the remaining 64 percent of the inventory. In - tm .,.p..,..n =- + -. .m ~,

4 this inventory, a small percentage (roughly 14 percent) is designated for project manager review, and a large percentage (roughly 45 percent) of the total inventory is over two years old. Consequently, we expect that these actions will be harder to complete than the amendments and they historically have taken longer. Several reconnendations have been derived from these findings, as follows: The NRC needs a better definition of a " licensing action." The MGT recomends that the following three categories be applied for all licensing work activities, as sumarized on Table 1. i 1. A licensino action should be defined as an action directly related to a facility which would -if granted, have an effect on the licenn, such as (a) amendments to the Technical Specifications, (b) the review of licensee submittals on unreviewed safety questions, (c) license conditions, (d) exemptions to the regulations, (e) orders, and (f) reliefs allowed by the regulations. All licensing actions should be covered by the same timeliness goals, namely, those recormnended in Section 5.2 of this report. 2. A multiplant action should be defined as an action to resolve a generic issue which has been approved for imposition. Generally, these are actions related to a response to a generic letter or bulletin. ~ Multiplant actions should be identified separately in the tracking system (see Section 5.6) and should have separate timeliness goals from those for licensing actions. 3. All remaining licensing activities in the work inventory should be designated as reculatory tasks. These actions include (a) priority i correspondence, (b) WITS items (c) technical responses to regional requests (TIAs), (d) Director's Decisions under 2.206, (e) inspection activities, and (f) event follow-up. l l 15 - 4 k < a ..s-

e l ~ i The regulatory tasks should also be identified separately in the tracking system (see Section 5.6). These actions should continue to be monitored by their individual scheduling requirements and do not need separate timeliness goals. Priority correspondence Lnd WITS items are scheduled by the EDO, Director's Decisions are norreally required to be completed within 90 days of acknowledgement of ) receipt of the petition, schedules for event follow-up and the ~ development of bulletins and gener1c letters are dictated by the significance of the event, and schedules for regional-related i activities are scheduled according to their safety significance. While the schedules for these actions should be realistic and adhered l to, they should not be as strict as the schedules for licensing and multiplant actions. Consideration should be given to excluding these actions from SIMS and allowing for more informal methods of f closure (i.e., not necesssrily backed by fonnal correspondence), A plan is needed to reduce the backlos' of "other licensing actions.' This plan should generally consist of (IT establishment of an overall objective to reduce the total inventory to the desired level during FY 1990; (2) identification of all of the actions in this category; ~ (3) 1oading this information into the interim tracking system discussed in Section 5.6 of this report; (4) establishing reasonable completion ^ schedules for individual actions, based on input from the Project Directors and Branch Chiefs, with line management oversight and approval through a series of meetings like those conducted by the MGT; and (5) having the normal line managers r'sponsible for monitoring progress e toward the completion of these actions and taking appropriate action to correct delinquencies. All licensing actions, as defined above, should be supported by a I Safety Evaluation Report following the review guidance recomended in Section 5.8 of this report. Technical evaluations for multiplant actions and regulatory tasks should include the level of detail appropriate for the action. 16 - e g p g -4 e9% e_se o P_

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.. _ _..3 4 } ) + . The ET tested the category and type ' codes presented in Table 1 by applying ~ them to a random sample of 180 actions from the "other licensing actions" i database. The results indicated that, for a total. inventory of..about 3400'_ l actions, about 900 actions (27t) are luensing actions, about 1900(565) j are multiplant actions, and about 600 actions (171) are regulatory tasks. These results suggest that the " average" plant, with about 25 total-actions. I would have approximately 7 licensing actions, about 14 multiplant actions,. l and about 4 actions which constitute regulatory tasks. ~t The MGT recommends that, to assure the effectiveness of these category t and type codes, an effort should be undertaken to reconcile these codes with the Program Accomplishment (PA) codes used by IRM for resource tracking. While many of the PA codes are currently consistent with our proposal, some l of the plant-specific PA codes should be adjusted. .i N O e O r l l i .t l r I + l i l l' e l i. [ ] - ' s

4 Table 1 CATEGORY AND TYPE CODES FOR LICENSING ACTIVITIES l Code Category &M LICENSING ACTIONS LA Amendments (including License Conditions and License Extensions) LR Reliefs LE Exemptions LO Orders MULTIPLANT ACTIONS MB Bulletins MG Generic Letters (including NUREG-0737) MR New Regulations NO Other Multiplant Activities (including MPA clean-up) . REGULATORY TASKS RC Controlled Correspondence (including WITS and ticketed items) RD 2.206 Petitions and Directors Decisions RE Event Followup RR TIA Reviews (Regional support) RI Inspections RG Other Regulatory Tasks (including 50.59 reviews, improvement programs, USAR reviews, environmental monitoring reviews, topical report reviews not specifically related to a license amendment, and safeguard reviews. NOTES: Although we have categorized license extensions beyond 40 years with license amencments, NRR management may want to consider a separate type of code for this activity in the future. We also envision that the IPE reviews would be categorized with generic letters (MG). Both of these activities will likely involve a substantial resource burden in the future. Conversely. USAR and environmental monitoring reviews do not involve a substantial effort, if any effort, thus we have included them under the "other" type of Regulatory Task. In addition, it should be understood that management briefings and the broad " support to others" that are not TIAs constitute " overhead" and, as such, should be accounted for in the Program Accomplishment codes like travel, training, and enforcement. f e e i,

s ~ ~ \\ a 5. FUTURE INVENTORY CONTROL REC 0leENDATIONS 5.1 Backlog Inventory The MGT's effort to reduce old license amendments has demonstrated that close management attention will be required in order to ensure that licensing actions are completed in a timely fashion. This section of the report discusses specific areas important to improving management controls over the timely completion of licensing actions. These areas include goals for the size and age distribution of the NRC " licensing action inventory" and for each distinct subset of the total inventory of tracked itests; the use of a line management team to focus more attention on the timely completion of licensing actions; improvements in procedural controls for accepting, prioritizing, reviewing, and closing licensing actions; interim and future tracking system requirements; improvements in submittal guidance for licensees; and improvements in review guidance for the NRR staff. Clear goals have not been provided to the staff concerning what is acceptable and unacceptable with respect 'to either the s'ize or age distribution of the backlog. The current priority system and its use have resulted in a number of licensing actions with low safety priority being allcwed to accumulate indef1-nitely. High safety priority items receive attention at the expense of the low safety priority items regardless of the age of the low priority items. Establishing goals for the inventory and providing clear policy to project managers and technical reviewers on actions which should be taken as licensing actions age are necessary to prevent a sig'nificant and unacceptable backlog. Furthermore, continued management attention is necessary to ensure that the policies for processing actions is consistently followed. A significant problem causing the buildup of the backlog has been related to continual exchanges between the NRC staff and licensees concerning what is acceptable for rcolution of an action. In particular. the use of generic guidanca has not always resulted in the efficiencies desired because of.a,n unwillingness on the.part of licensees to adopt the generic guidance or to provide a plant-unique reason for an alternate solution. In the past, the NRC staff was willing to continue a protracted dialogue with licensees rather.

a 4 than obtain a definitive resolution of the issue. Management attention on. aging licensing actions can ensure that prompt decisions are made to obtain closure (see Section 5.3). The systems used to track the age, status, and resources for the completion of licensing actions must be such that problems are made visible to management (see Section 5.6). Guidance on what constitutes an acceptable licensing action submittal, both in terms of femat and content, can reduce the need to request additional infsrma-tion from or to have extended dialogue with the licensee (see Section 5.7). This could significantly shorten the review time for actions. Improvements in procedural controls for accepting, prioritizing, reviewing, and closing licensing actions will both improve the timeliness and reduce the resources required to complete licensing actions (see Sections 5.4 and 5.8). 5.2 Inventory Goals Broad goals must ba set which can be applied on a plant specific level in an achievable and realistic manner. NRR should internally establish the following goals and provide management attention to ens'ure they are attained consistent i with the resource allocation principles discussed'in Section 3.2 of this report 4 and the inventory characteristics discussed in Section 4. The MGT recomends the following age distribution for Licensing Actions, as defined in Section 4 and as measured from the date of an acceptable submittal. l 1. 80% less than 1 year old 2. g5% less than 2 years old 3. None more than 3 years old 1 The MGT also considered a number of alternative goals for Multiplant Actions. lihile we believe that the Multiplant Actions should have a similar goal ' structure to that we've recommended for Licensing Actions, we believe that the periods probably should be longer but we did not have sufficient k'nowledge about the multiplant action inventory to make an infomed recomenda-tion on these goals. Consequently, we recommend that NRR deveJop goals for the Multiplant Actions after the MPA Closure Plans have been completed, and that NRR solicit the views of the technical managers on these goals before they are promulgated as office policy. ' }

i The NRR office policy on all timeliness goals should also recognize, however, that there are special cases. Some of these cases should be categorically excluded from these general goals. Special cases may arise for which NRC l management may approve a review schedule longer than three years. In any t event, the policy should allow for management approval of schedules and plans which deviate from these goals. 5.3 Management Attention t The MGT was established to address the current backlog during a three month period. In the future, the MGT's functions should be assumed by the NRR line managers. There will be a continuing need for line managers to routinely monitor the efficiency and effectiveness of the review process. The NGT reconnends that, under the direction of the Associate Director for Projects, a group of these line managers, and a representative from OGC, meet regularly to review the status of licensing activities in such a way as to resolve both generic and plant specific issues affecting the workload in NRR. At these meetings, any licensing action or mul'iplant action more than 18 t months old, any Priority "1" action more than 6 months old, and' any action for which there is disagreement among the staff should be discussed. A written summary of the licensing action and issues should be provided; this should eventually be done through WISP (see Section 5.6). The specific information which should be provided is the same as that provided to the MGT during the short-tens effort (March to June 1989) as described.in Section 2. The responsible Project Director, Project Manager. Technical Review Branch Chief and Technical Reviewer should attend the meeting prepared to discuss each action. Conmitments aod datas should be clearly understood by all participants and tracked. The schedules for discussion of each licensing action should be such that those involved only need to attend the meeting for the time their issue is to be discussed. The licensees should be informed promptly when actions are approaching the point share additional management attention is called for. Subsequently, periooic meetings between senior NRR projects management and senior licensee. e

v management (above the routine licensing manager) should be held for plants with licensing actions requiring management attention. This will ensure high visibility of aging licensing actions within the licen ee's management. 5.4 Procedural Controls for the Review of Licensing Actions Improvements in procedural controls for accepting, prioritizing, reviewing, and closing licensing actions can both improve the timeliness and reduce the resources required to cociplete these actions. Controls for accepting licensing actions should verify that submit +als are in the proper fnrmat and contain the information necessary for an efficient NRC review. The prioriti- . zation process needs to be augmented to address not only the safety significance of actions, as is the case new, but also their age. This aspect is discussed in Section 5.5 and a proposed revision to the NRR guidance is included in Appendix D. Guidance should also be developed as to when an issue should be raised to management (see Section 5.3) for the resolution of disagreements among NRC staff organizations or between the NRC and the licensee. Project managers and technical reviewers should be provided~ with guidance on ] the actions to take to avoid leaving TACs open while lengthy resubmittals are being prepared by licensees, where lengthy dialogue with the licensee persists (not converging toward clesure), or when the action becomes dormant for other reasons. For example, project managers and technical reviewers should be given instructions, as follows: The staff should reject licensee requests for amendments not conforming to NRC generic guidance (e.g., Standard Technical Specifications) when, on request, the licenses fails to adequately justify that there is a plant-unique reason not to follow the generic guidance (see also f Section 5.7 concerning submittal acceptance reviews). NRR managers should be tasked to assure that generic guidance is clearly stated. Nevertheless, the staff should also be provided a means to recommend clarifications or changes to generic guidance when warranted. ] 7- ..7-i

4 .o ~ i When a licensee's submittal is unacceptable or the licensee is otherwise unresponsive to an NRC initiative and some action is necessary for public health and safety, the staff should promptly prepare an order requiring the action. The staff should reject licensee requests for amendments that a Ticensee allows to remain dormant for 90 days, unless some action is necessary for public health and safety. Where there is such need, the staff should promptly order the appropriate action be taken as discussed above. These instructions were used by the MGT during the short-term backlog reduction effort, and examples of these actions are included in Appendix I. 5.5 NRR Priority System The NRR priority system should be revised to raise priorities consistent with completing the licensing actions on a time scale consistent with the backlog goals. Any licensing. action more than 18 months old or multiplant action ~ more than 30 months old should be raised to a Priority "2" (the appropriate threshold for multiplant actions may be revised when their goals are set). The tracking system should differentiate between schedule priority and safety prio-ity for items raised in pricrity solely for maintenance et the inventory goalt, for the purpose of management review of the inventory and resource allocation. Appendix D presents a proposed revision to the NRR office policy on prioriti-zation which would achieve this end. 5.5 Future Tracking System Requirements The MGT's efforts to' reduce the license amendment backlog has clearly demon-strated that modifications are nece"ary to our past practices of assigning, monitoring, and tracking work and product assignments. Priorities and resources should be adjusted, as necessary, to maintain the inventory within established goals. A tracking system needs to ensure management attention to actions over 18 months old., ? 7' F* +-*f "TM' 9 Dere

4 In order to prevent the future growth of such an accumulation of old actions, a significant upgrade will be necessary to our various tracking systems. Indeed, the existence of a single unified tracking and monitoring system is necessary to provide the necessary management control and oversight of all staff task assignments. It was intended that the WISP system, currently in development, would form the nucleus of such a unified management control system. Appendix E provides an overview of the expected WISP capabilities. Since no direct operating experi-ence has been gained on the WISP system, at this time, it is not possible to specifically identify any enhancements needed for implacentation in the full system. The MGT has identified some functional requirements for WISP in this report. Further, we would recomend that the WISP staff work closely with the projects and technical managers to ensure that needed capability is provided in the co=plete system. Based on the experience gained during the short-tenn amendment backlog reductioni the MGT has developed a proposed scope and set of system fea'tures which should be included in the tracking system. These details are described in the following paragraphs and are summarized in Table 2. In addition, the MGT recomends that, until WISP is fully operational _, an " interim" tracking system be used for monitoring completion and resources. To that end, the MGT has developed an " interim" system, as shown in Appendix F, and we recomend that NRR implement this system. ~ The interim tracking system generally has,'and ultir.ately the WISP system should have, the following capabilities: All technical staff and project manager activities (i.e., tasks or TACs) ~ must be identified for tracking purposes. The system needs to be capable i of associating these tasks!at the branch and Project Directorate level. Individual TACs must be created in all cases :.are a staff product is called for. While the current systems use TAC codes for licensing actions. many other items are identified and tracked by an alternate means in broader overhead categories. The tracking system we recomend must be. a ..m,,4 ; ~ ~ '* .,o

e flexible enough to contain all assignments. Work category and subcategory codes need to be developed in more extensive detail than that we have proposed in Section 4. Future detail would be geared to the PD and BC level, and would track each of the process steps: acceptance, prioriti-zation, technical review, documentation. OGC review, concurrence, and issuance. Some examples of assignment types would be: TIA development, license exemption actions, orders or bulletins, long term event follow-up and part 21 followup activities, region assistance, inspection support, ticket responses (see Section 4 discussion of "other licensing actions"). Tracking codes also need to be assigned and utilized to account for management support activities which traditionally have been charged to overhead type categories. With the accountability we recocrnend for NRR line management, it is important that we be able to identify resource impacts arising from critical short turnaround r quests at the Office, EDO, and Comission levels. WISP should include these categories to allow identification of resource expenditures at the individual request level (see Section 3.2 recocmendations for resource estimates). One of the most important functions of a future tracking system would be to prevent the formation of a new backlog. Historically, we have been effective in dealing with higher priority items (NRR priority 1 and 2). Problems often develop, however, over lower priority issues. While they initially are assigned completion dates, they continuously get delayed to accomodate newly developing priority 1 and 2 actions. It is essential that the tracking system provide a schedule history field accompanied by a coment field shewing each s..hedule' change with an accompanying justi-fication of the higher priority work that supplanted it. While this is not currently envisioned for WISP, preliminary discussions with the WISP staff indicate that it can be provided. A late-date flag system needs to be implemented as part of the complete WISP system. In addition to management control at the Section Chief level for weekly due dates, an upper level flag system also needs to be provided which will identify actions approaching a specified critical age. This =ay be 18 months for licensing actions, other periods for differant work activities. To maintain a low backlog, it must be recogni:ed that. l ~ l s

94 ~ Table 2 REVIEW PROCESS & TRACKING SYSTEM REQUIREMENTS Applicable to Interim Tracking System and WISP - r } Data Fields System Characteristics 1. Plant All active TACs by number Name Unit Docket Flags for management reports: Age (total resident time) l

• NSSS Vendor & type
• Containment type Slip (passedduedate)
• 0L Date Perforisance (unsat status) 2.

TAC Number' Late start Title Program Activity Number l Connants j 3. Prcdect Directorate Project Manager Region (ImpliedbyPD) Status Codes 4. Review Group A - active Key (primary / secondary group) P - planned

• Reviewer C - complete
• Section 5 - satisfactory 5.

Activity U - unsatisfactory Action Category D - delinquent i Action Type Review Category j Priority

• Performance Calculations 6.

Initiation Date Due date change history 7. Acceptance Review Quality (see flag) .i AR Start Date AR Due Date AR Complete Date

• Procedures 8.

Technical Review TR Planned Start Data Data consistency TR Actual Start Date PA consistency RAILIssue Date Performance audits RAI Response Due Date Controlled access RAI Response Complete Management controls TR Due Date 9. Action Completion Completion Due Date CompleteAcceptable(CA) CompleteWithdrawn(CW) Complete Deny (CD) Complete Order (CD)

• Eventual capabilities recomended for WISP, not included in interim tracking system.

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v v-w a priorfty 3 or 4 task nearing this flag age will have to be assigned a Priority 2 to get the necessary resources (see Section 5.5). The reassignment of priority could be entered manually into WISP after a management review, or even automated by the code. This assignment of priority can be justified on a policy basis but, in some instances, not on a public safety basis. This policy needs to be recognized and accepted by the NRC management. We anticipate that development of the specific features for the future WISP tracking system will be an evolutionary process. The WISP prototype testing is just now starting. As management summary reports are generated and utilized, enhancements needed to meet the goals identified above can be specified. We believe that enhancements to deal with the above issues can eventually be incorporated into the complete term WISP system. As the system becomes more capable (through an interactive process) it will hopefully supplement or supplant the summary reporting in the NRR Whitebook. 5.7 Submittal Guidance The staff should be given a detailed acceptance criteria for licensee sub-mittals.. The guidance should address two formats: one for responses to NRC initiatives and the second for licensee initiatives. The use of standard formatting will facilitate the initial staff review of a submittal with regard to the submittal completeness. For submittals respondino to staff initiatives, the standard format needs to highlight the following information: Identification of the formal staff document to which the licensee is res ponding. A statemen' sf the requirement as it appears in the staff's initiating documen'ts. Reference to all previous formal communications on the requirement. l l 27 - l l

m ~ A statement of the criteria which the licensee has applied to assess compliance with the staff's requirements and the basis for the criteria. A discussion of how the licensee's actions meet the criteria identified above. A discussion of deviations free splicit staff generic guidance. The discussion should include plant-unique design features or other circum-stances which warrant the deviation from staff guidance, the sensitivity of the significant hazards considerations to each deviation and all deviations as a whole. It should also specifically address compensating actions taken to provide an equivalent level of safety. For submittals initiated by the licensee, the standard format needs to highlight the following information: A statement of the licensee's request which explicitly identifies the existing conditions and the proposed changes. A discussion of the safety considerations related to the request in order of their significance and the impact of the proposed changes for each modification. Explicit statement of wny the proposed changes are being requested. This should include safety and operational considerations. An explicit discussion of each of the'significant hazards consideration factors for each of the changes requested. Explicit statement of the criteria (for example, regulations, regulatory guides, codes, and/or standards) used by the licensee to determine the acceptability of the proposed changes, and the basis for tnse criteria. In addition, technical specification change requests should explicitly state , whether or not the proposed changes adopt standard technical specifications and consistency with NRC guidance on technical specifications improvement. + =3 +.

4 activities (see discussion of the certification process for TS improvements in Appendix G). If not, a discussion of how the proposed specification differs from the STS should be provided, and a justification for not adopting the STS. Techni' cal Specification change requests should include a discussion of the overall purpose of the specification even if only a subpart is being modified. Until such detailed guidance can be developed, the general guidance provided in Appendix I to this report should suffice. 5.8 Review Guidance The staff reviews are performed in three major steps. The first is an acceptance review by the Project Manager based solely on fonnat. Licensees should be required to use a standardized fomat, as discussed in Section 5.7, for all submittals. Submittals aeviating from the format should be subjected to an acceptance review by the project and technical staff based upon an identification by the 1.icensee of the primary safety considerations which need ^ to be addressed in the proposal. A brief review should suffice in most cases to determine whether or not the licensee has focused on the appropriate concerns. If not, the submittal should be rejected. Second, once a submittal has been accepted for review, it should be prioritized and scheduled in accordance with established NRR procedures (see Section 5.5 regarding comments on the NRR Priority System). Third, with regard to the review process itself, every effort should be made to minimize resource expenditure, while maintaining the quality of the technical reviews, by the following: Clearly identify what action is being requested and what decision must be made. This is a combined projects and tschnical staff responsibility. Focus the review and the SER on the primary safety considerations identified by the licensee (and agreed to by the staff in the submittal acceptance). The scope and depth of review should then be established - d O wa

4 between the reviewer and his/her supervisor at the time the review assignment is made and the review schedule is set. In establishing the scope and depth of review for a given action, reviewers and supervisors should consider the following elements: (1) safety significance of the issue, (2) technical complexity of the issue, (3) degree of innovation in the proposal, (4) extent of deviation from accepted codes and standards, (5) prior staff and licensee experience on similar issues, (6) the general quality of the licensee's engineering and licensing support organizations, (7) the use of confinnatory tests, and (8) the licensee's use of independent audits. During the review, the line managers should monitor the conduct of the review to assure the scope is sufficient but not excessive, and to assure timely management decisions to prevent the review from stalling. Develop guidance that clearly explains how the staff is to use generic guidance (including SRP, STS, and generic letters) and when deviations from that guidance should be permitted. ^ Maximize use of prior reviews. For example, changes which adopt standard technical specifications or adopt approved Owners' Group solutions, or simply apply previously approved calculational methods should generally involve minimal review time. Focus resource expenditures in accordance with the safety significance of the request and the past performance of the licensees. PRA insights and SALP assessments can help focus resources on problem areas. General plant design strengths and weaknesses', as discussed in " Final Report on Plant Design Features" (mecerandum from Ashok Thadani to multiple addressees, dated April 26,1989) should be used to assess the safety significance of issues based on design strengths and weaknesses. The SALP assessments should be used to assess process weaknesses. Require confirmatory tests or coccit:nents to codes and standards in place of reviewing detailed analyses. =

n.x -

~ ~-

4 Develop specific criteria to eliminate the need for reviews in routine areas. For example, SRXB is developing criteria and procedures to allow the use of modified fuel designs without prior staff approval. The safety evaluation report (SER) constitutes the product of the staff's review effort. As such, the SER provides the documented evidence of the staff's review. The staff's SERs should be held to quality and consistency requirements so as to further enhance the efficiency and effectiveness of the review process. At this point, we should distinguish between the SER which supports a license amendment and those "avaluations" which form the basis for closure of the "other licensing actions." The content of the two kinas of reports is not necessarily the same. The SER supporting a license amendment is part of a legal document and must be i able to withstand the scrutiny of a court or hearing board. The purpose of the OGC review of a license amendment is to assure that the staff actions comply with law and regulations. Therefore, the SER must clearly demonstrate a reasoning leading to the conclusion in plain, clear language. Absent such explicit reasoning, the conclusions would appear to be arb'itrary and capricious. It is also important to understand the following legal distinctions when preparing SERs: While conformity to the SRP, STS, or other generic guidance does not, of itself, prove that & preposal is consistent with the law and regulations, conformance with those standards, in the absence of any contrary indication, may be accepted as meeting the law ano regulations. When a licensee's proposal deviates from the SRP..STS, or other generic guidance, the burden is on the licensee to prove that its proposal meets all of the requirements of the law and the regulations. While the staff may ultimately find the licensee's proposal acceptable, more technical details are needed in the evaluation because there is less generic basis to refer to. e 31 - . ~. - - .....,;n.

4 ~ Conversely, the evaluation supporting " regulatory tasks," as defined in i Section 4 of this report, does not necessarily have to meet these legal standards. Nevertheless, they should also clearly demonstrate a reasoning leading to the conclusion in plain, clear langu&ge. The only substantive difference between the two are minor points of form and content. To clarify this matter, Appendix H provides form and content guides for SERs and other evaluations, and examples of good reports. In addition, staff documents should minfaize repetition of infonsation provided in the licensee's submittal. References to specific pages of the licensee's submittal should be used for clarity. This can considerably shorten and clarify many SERs. We expect that this guidance should improve the quality and consistency of the reviews, reduce the number of comments from OGC on license amendments, and minimize the potential for issues later " resurrecting" because of poor docu-mentation of the staff's review efforts. In a related matter, the technical input for SERs and other evaluations are normally transmitted to the Project Directors by memoranda. The memoranda provide a means to track completion of the technical work. However, the current style of these memoranda appears to vary greatly, as do the form and content of the reports they transmit. The technical branches should use the standard form memorandum p' resented in Appendix H and focus the enclosure on the " evaluation" section of the SER or other evaluations. The transmittal memorandum should only discuss specific issues that should be noted by the Project Director: Review status and open items Specific conditions or actions required for acceptability Any future actions required Proprietary information included in the SER or evaluations Policy implications requiring management attention The transmittal memorandum should not contain any extraneous or backgrouhd information, nor should it conclude that a review is " complete" when the text of the evaluation identifies additional actions that have to be taken. 32 - O o p m. a n, e

e; ~ -l .i Many of the foregoing recossendations and guidance currently exist in a; variety of forms, including the Project Manager Handbook. Office LetteN the . Standard Review Plan, and various memoranda. However,'the MGT believes that (1) the guidance is scattered in too many different forms and (2) it is not i routinely used. Further, the MGT believes that there is insufficient' accountability for the quality of the work as it is reflected in the staff j SERs and other products. Consequently, the MGT recommends that: All of the NRC staff's review guidance, including process and documentation. l requirements, should be consolidated into one' document. Consideration-should also be given to the elimination of the NRR Office Letters and the PM Handbook in favor of an NRR Manual which includes all of the. f guidance to the NRR staff. l NRR should adopt a quality assurance program, including the managerial-i and administrative controls to be used to assure thorough technical evaluations, prompt decision making, and clear and concise communication. Specifically, technical staff should be accountable for the technical. sufficiency of the evaluations, the Project Manager should be account-I able for the clarity and style of the documentation, line managers should j 1 be accountable for the quality and timeliness of the decision-making,- and the Project Directors should serve affirmatively in the role of I quality control to assure that the staff's' documentation is acceptable - before it is issued for concurrence. Further, NRR should conduct audits of both issued and pending actions to assure that these responsioilities j i are being satisfied. Other reconnendations the MGT considered for optietzing review resources in the l future are: I Develop a centralized database summarizing technical specification I positions -(case histories) sorted by TS uction. This would promote. consistency in staff reviews, as well as expedite them. Currently, OTSB ~ maint.ains a collection of TS positions, referred to as the.STS Background Books, and Inspection Manual 9900 contains'many of the TS positions. Similarly, the. project managers initiated an effort to' collect Category 2

i l

0

~' 4 9 L. evaluations as examples for future reviews. Consolidation and automation' of these efforts would substantially improve their potential usefulness. Routinely, review and revise the standard review plan to focus on areas of current interest and importance. 6. SIM4ARY CONCLUSIONS The Management Guidance Team has taken action to eliminate the backlog of pending license amendments greater than two years old. At the time of this report 93% of these actions have been completed and the balance are on well-defined paths to completion in the near future. However, there is still a backlog of other actions which need to be addressed. As a result of this effort, and after careful review of related licensing activities and the other actions, the team has developed recommendations for licensing action inventory goals, management controls, and process improvements which, when implemented, would maintain the licensing action inventory in the ~ future. These recommendations are susunarized as follows: - IMPROYEMENTS IN MANAGEMENT OVERSIGHT Section Reconnendation 5.3 ' NRR line management should routinely review the status of all licensing activities to assure that appropriate actions are taken and decisions are prompt. 5.2 Licensing action inventory goals should be established as follows: 80% less than one year old, 95% less than two years old, and no actions over three years old. 5,eparate goals should be established for multiplant actions 'after the completion of the MPA Closure Plans. However, the inventory goals should allow for senior management approval of case-specific alterna-tive goals. For example, the inventory goals would not neces-sarily inclu'de future " license extension" or TS improvement cases..

4 .04 IMPROVEMENTS IN MANAGEMENT' 0VERSIGHT (continued) Section Recoemendation .c 3.1 The current policy on integrated schedules, in Generic Letters 1 83-20 and 88-20 should be revised to be consistant with the . t backlog policy and be reissued. l l 3.2 NRR should develop and utilize a type-specific labor rate for resource estimates in the future. 1 4. NRR should develop a plan for the review of the "other" actions,. including the identification of the items requiring actions. addition of these actions to the interim tracking ' system, and I l assignment of the appropriate resources and schedules to be applied to complete a targeted set of these actions in FY 1990.. l Thereafter, the line managers sPould monitor progress on the j implementation of this plan. 4. NRR should continue to schedule and monitor priority } correspondence. WITS, TIAs, event follow-up,'etc., in accordance with existing practices. This workload, however, still needs j to be included in the tracking systeur and considered in the overall resource impacts. - r 5.3 NRR should establish periodic meetings between senior NRR- ~ management and the licensee's management when licensing actions ~ i; on the licensee's actions require management attention. j 5.5 NRR should revise the priority system to raise priority for action's over 18 months old. [ 'f i ? t ) 4 j

• 4 TRACKING AND CONTROL IMPROVEMENTS i

Section Recommendation 5.6 NRR management should conduct routine tracking and periodic management review of all licensing actions. NRR should develop l an interim and long-term consolidated database of all licensing activities. WISP should be adopted as NRR's long-tens tool for all tracking and resource planning activities. 4. NRR should adopt clear definitions for the categories and types of licensing activities, as defined on Table 1 in Section 4. Consideration should be given to excluding i " regulatory tasks" from SIMS and allowing informal closure i methods. t 4. A " licensing action" should be defined as an action requiring a response issued by NRR which affects the licensee. Other licensing activities should be' categori:ed 'as "multiplant actions" and " regulatory tasks," along with appropriate type classifications for each of these three categories. The standardization of these terms and proper classification will improve resource tracking. 5.6 The WISP staff should work closely with the NRR managers to assure that the tracking system has all of the necessary capabilities for management centrol of licensing actions. Ultimately, as experience is gained in the use of WISP, it may supplement or replace the NRR White Book. 5.6 The tracking system should hr.ve the following functional requirements: monitor all tasks at the BC/PD level TACs for j ~ all staff products, track each process step, provide tracking ) codes for management support activities, provide schedule history data and comments for schedule slips (see Table 2 in Section 5.6). '

TRACKING AND CONTROL IMPROYEMENTS (continued) Section Recommendations 5.6 The tracking system should provide flags which would automatically generate managenet reports highlighting actions which are appr6 aching established age goals, have passed due dates, or have reported performance problems. STAFF REVIEW GUIDANCE IMPROYEMENTS i Section Recommendations 5.4 The NRR staff should be given clear guidance on the handling 5.7 of licensee submittals, including the use of standard forms 5.8 and chec.klists. The scope and depth of review should be established and' controlled by ' he line managers, consistent t with the safety significance and complexity of the issues and i resource allocations. NRR should also clarify the role of generic guidance (for example, the SRP, STS, and generic' letters) and encourage the staff to require conformance with those standards, unless there is a justifiable, plant-specific safety reason to differ. 5.4 The project manager should ~ reject submittals that do not conform to the requirements specified in Appendix I. The staff should be given guidance on how to promptly respond to non-conforming submittals; prepare an Order, if necessary for public health and safety, requiring appropriate action within a timeframe con-sistent with inventory goals; or, recommend changes in the generic guidance the submittal is being judged against, if necessary to obtain an acceptable submittal. . e e A 9 a _ = + -4 w g g a ,ame.+ =e e ea e

m t .e i j STAFF REVIEW GUIDANCE' IMPROVEMENTS (continued) .i Section' Recommendations -l l c r i 5.4 The project. manager should reject any request the licensee-allows to remain dorinant, or prepare an Order, if necessary for publ'ic health and safety, to require whatever action is i necessary. l 5.7 NRR should adopt review guidance for submittal acceptance c reviews, which specify project manager and technical review - j responsibilities. 5.8 NRR should adopt standard formats and content for SERs and other evaluations. 5.8 Possible future improvements which would improve the l efficiency and effectiveness of the review';irocess are (1) ~ 1 a TS case history database and (2) a routine update of the SRP to focus on areas of current interest to safety. i 5.8 NRR should consolidate all of the Office Guidance into a single manual and require that the staff use that guidance. t e -j _ _., _ _,_ _ _... :., r ' 1

_ 4 O q O O 9 e p APPENDIX A MANAGB4ENT GUIDANCE TEAM CHARTER O e O e e e e l 1 ... ee .....e. m

t CHARTER ~ FOR THE LICENSING ACTION MANAGEMENT GUIDANCE TEAM I. OVERVIEW. l A number of old license amendments have accumulated because of their Iow priority and consequent NRC inattention. To effectively eliminate the old work backlog of Technical Specification License Ameneents and establish .i management controls to control the licensing action inventory in the future, the Director of the Office of Nuclear Reactor Regulation has formed a ManagementGuidanceTeam(MGT),withthefollowingmembership: i Gary Holahan, Chairman [ t Gus Lainas l f Charles Rossi Ashok Thadani ~ James Richardson 7 Chris Grimes i ~ ~ [ The broad purpose of the MGT is to revtew those Technical Specification -l license amendment changes that are more than two years old for all operating f reactors ~(including TVA plants); deterzine what actions are recuired to .) cocplete those actions; implement actions in a concentrated short-ters effort -j to substantially reduce the license amendment backlog; and develop guidance l and procedures to control the licensing action inventory in the future. This l effort will not include Multi-Plant Actions (MPAs), which are being resolved in a parallel effort. However, the MGT will also consider other licensing l actions, which do not involve license amendments, to clearly characterize the ] nature of these issues; to develop improved definitions, categories and -l tracking; and to determine whether a similar or combined effort should be i directed toward reducing this ba:klog. ~ i The MGT's efforts are intended to be accomplished during a three-month i concentrated effort. During this period, special measures will be taken, as reccomended by the MGT and approved by the Executive Team, to allocate the - resources necessary to accceplish this charter. The MGT will report on its l progress to the Executive Team each week. The detailed plans to accos911sh this charter are discussed below and have been developed on the basis of a June 1, 1989 completion date. i i . :...,,.n

s z-i i The Management Guidance Team will coordinate its activities with those individuals responsible for related tasks such as resolution of MPAs, guidance i on Technical Specification Improvement Program reviews and WISP development. 6 i I i 1 9 l e 4 + 4 e o e -~ .a.m.,~ -~ ~se rsee;*sm; m - - ~..

4 ~ e II. SHORT TERM EFFORT TO COMPLETE LICENSING AMENDMENTS GREATER THAN TWO YEARS 0LD The MET will provide guidance and direction the effort to complete all licensing, amendments greater than 2 years old. A total of approximately 300 items (which would have been 2 years old by June 1,1989) will be addressed. The distribution of these items among the projects and Technical groups is shown in Enclosures I and 2. The first task of the group has been to identify the specific efforts that are needed to complete these actions.- This backlog could be a result of a lack of review priority, need for additional information from licensees, legal issues and other considerations. The Management Guidance Team will a) issue guidance to each technical branch to develop an action plan for the completion of all relevant amendments, b) meet with each branch to discuss the plan and to provide guidance and direction with respect to technical issue resolution, priorities, resources and other impacts, and c) conduct at least one followup meeting to access progress. Th'e MGT will meet with all Project Directors on March 10, 198g to provide general guidance and direction. Enclosure 3 presents the schedule for meetings on the short-ters activities. In its meetings with'the technical review branches and project managers, the Management Guidance Team will analyze and determine the specific reasons for the past delays in resolving the issues and will determine if additional resources, re-priorit12ations (e.g., deferred work) or reduced scope and depth of the review ~ would resolve the issue. In order to provide additional resources, certain on-going work may be deferred within the branches responsible for the licensing actions. - As part of the plan to complete the old licensing actions by June 1, 1989, each Branch Chief will identify to the Management Guidance Team what work will be deferred. Work areas to be considered for deferral could include: support to enforcement actions ; advance reactor reviews (particularly the Westinghouse AP600 license ability review

participation in maintenance team inspections; travel not related to events; and some training. Deferral of major programs will be discussed with the ET before implementation.

e e ~ ~ ^ ' ^ "

The need for additional resources will also be considered. These resources may be available in DRIS, DLPQ, DOEAand PMAS. These groups will be asked to identify to the MGT the individuals who could be made available for reducing the backlog and their areas of expertise. The potential for reducing the scope and depth of the reviews will also.be addressed on an issue by issue basis during the three month effort. The technical branches will be requested to consider a reduced scope and depth of review based on safety significance, regulatory requireeents and providing reasonable assurance of public health and safety. They will also be requested to consider the guidance provided in the Technical Specification improvement program to avoid adding technical specifications which would later be eliminated. It will be emphasized that only reasonable assurance needs to be provided and ~ that trivial issues rust be avoided. The experience gained in this effect will be very helpful in developing generic guidance for future long tern licensing action management. III. LONG TERM PLAN FOR LICENSING ACTION MANAGEMENT i Based on the experience the team gains in its item by item review and disposition of the Technical Specification amendments greater than 2 years old, guidance will be developed for the scope and depth of review of items in the future. This guidance will consider the safety priority "of the issue, the regulatory mandate for the issue, the guidance in the T/S improvement program, the age of the issue, and the sources of the action (e.g., requested by licensee, request by MRC). i fromtheexperiencegainedinthiseffort,fromareviewoftheplansforclosing multiplant action iters, and from a review of the types of other issues in the current inventory, goals will be established for the inventory of actions per plant and the age distribution (a's a starting point, the team will use the guidance discussed at the NRR r.anagement meeting; 30 items per plant with 80% less than 1 year old; 95t Tess than 2 years old; no items greater than 3 years old). )

4 ,t Management control procedures will be recoemended for review and disposition of licensing actions as they age to ensure that the inventory goals are being met. This will include guidance to project managers for screening incoming actions with the view towards promptly returning items which are not safety significant, not complete, or not in accordance with NRC policy. The team will also recommend management controls to be included in the NRC plan and tracking systems. This would include the use of WISP to identify items when they attain a specific age or exceed pre-established goals. The benefits of using additional resources (particularly contract dollars) to meet the long term inventory goals will also be identified. Each of these long term issues will be addressed in a final report to be completed t by June 1, 1989. i i .l t t t N ..... -..... _. ~ - _ _.

4 O a ~ EMCLOSURE 1 S DISTRIBUTION BY PROJECT DIRECTORATE OF TECHNICAL SPECIFICATION LICENSING AMENDMENTS GREATER THAN 2 YEARS OLD* 3 TOTAL PN REVIEW TECH STAFF REVIEW-I-1 23 13 '10 1-2 34 19 15 1-3 12 7 5 1-4 13 10 3 II-1 17 11 6 II-2 26 11 15 II-3 34 18 16 III-1 33 19 14 _,III-2 17 2 15 III-3 20 7 13 IV 15 10 5 Y 27 13 14 271 140 131

• Data en TVA plants not yet included.

i b F 4 4 -4 -,,n...... c,,..

r.. -.,..

o. j ENCLOSURE 2 ) DISTRIBUTION BY LEAD TECHNICAL BRANCH OF TECHNICAL SPECIFICATION LICENSING AMENDMENTS GREATER THAN 2 YEARS CLD BRANCH TECHNICALISSUk3 ECEB 5 EMEB 6 EMTB 4 ESGB 3 SELB 12 SICB 25 SPLS 31 SRXB 24 PRPB '6 + I LHFB 2 LPEB 3 OTSB 2 ^ RSGB 3 1 RII 5 (to be returned to NRR) RV 1 (to be returned to NRR) PM's 140 t

• Data on TVA plants not yet included.

--~.....,..2

._ q 4' a ENCLOSURE 3 i l MEETING SCHEDULE FOR LICENSING ACTIONS j MANAGEMENT GUIDANCE TEAM l 1 DATE ACTION r i 3/9 Guidance meno to Technical staff Branch Chiefs 3/10 Guidance meeting with ads, PDs............ -(140 issues) f i 3/15 EngineeringBranches(ECEB,EMEB,ENTB,ESGB) ....'(18. issues)' 3/17 Radiation Protection Branch (PRP8).......... (6 issues) Human Factors Branch (LHFB)..............- (2 issues) I Perforinance EvaTua*,'on & QA Branch (LPEB)....... (3 issues)L l Technical Specifications Branch (OTSB)........ (2 issues)l ~ SafeguardsBranch(R$GB)...............(3 issues) 3/20 Systems Review Branches (SELB, SICS)......... (37 issues) t f 3/22 Plant Systems Branch (SPLB).......... '.... (31 issues) 4 3/24 Reactor Systems Branch ($RX'8)............(24 issues) .i 4/89 PD Followup meeting, as necessary 1 1 l i ,..........-.,.,.. ~. ....,. ~ ... ~

M P e s O O 6 e 9 0 APPENDIX B MANAGEMENT GUIDANCE TEAM -t FINAL BACKLOG REDUCTION STATUS REPORT P t i + 1 r Y 5 e i i e .[ s + 4 e, =, WY is

• • e 9

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1, B AC KL.OG REDUCTION

SUMMARY

l License Amendment Backlog-es "~ Assignments:- i DRP ~56% 3

• ~

DRSP 41% "~ ADSP 3% I 15 - N se - 2 38 N3 2 14 NL NS 3-1 321 Na N3 t' S' A 2 11 g23 cesseen 15 3; suas g g assa,e The figure above depicts the distribution of the' license amendment backlog between the projects organizations and indicates the extent of I completion at the end of the short-term reduction effort (6/15/89). Those actions schdeuled to be completed after June 1999 are so scheduled with the &pproval of the MGT. The figure below depicts the the review 1 efforts required to complete the 'sacklog actions between the technical i branches. I Back1Dg Techni.ual Review i 4 n. Assignments: "~ Projects 65% SAD 247 3 8-EAD S% l REP 2% -t j LPQ - 27. j RIS 1% ~ OSA'

17. '

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[ \\ UNITE 3 STATES 8 NUCLEAR REGULATORY COMMISSION B wAswearow.o. c.nosas t ~ DWT EEMORANDUN FOR: Frank J. Miraglia, Associate Director for l Inspection and Technical Assessment Dennis M. Crutchfield, Associate Director i for Special Projects James G. Partlow, Associate Director for Projects Frank P. Gillespie, Director Program Management, Policy Development and Analysis Staff FRGE: Thomas E. Nurley, Director Office cf Nuclear Reactor Regulation l

SUBJECT:

PRIORITY RANKING SYSTEM FOR REVIEW EFFORTS - REVISION i 2 l l This revisten, Revision i (2) to the NRR work priority ranking system, which was issued was originally on April 29, 1988, ano reissued as Revision 1 on March 24, 1989, provides guidance on how work-eegoests-from-ether-Gif4ees shouid-be-pr4er444eed-ser-aetien,--Gemments-en-the-proposed-Rev4s4en-i-were se44e4ted-from-the-k'RE-34v4s4 ens-en-weli-as-liMS3 -REiv-AEGG,-and-GEP-the - 5 pr4 mary-Gif4ees-from-wh4th-hRR-rese4ves-work-eetoests,--The-eenuments-reeefves. were-4psegrated-inte-this-revis4en, the priority of licensing actions should be changed as their residence time within the NRC increases. SubstLntive changes to the previous version are delineated by vertical lines in the right margins. To allow more effective management of our technical resources, a uniform work pricrity ranking system scheme is being used through NRR. This ranking system 1 uses a priority hierarchy which will be used my maragement to establish completion schedules and staff assignn.ents. While the priority ranking system was ceveloped for use in the licensing action process, it encompasses most expected activities, so that work requests are considered within the broad scope of all resource demands. ~ Both Projects (ADP) and Technical (ADT) will apply the enclosed priority system. [ Projects will inoicate the appropriate priority on all work requests transmitting new work to the technical branches. Although work maintained for review within Projects nomally does not require a work recuest, the PM shall prioritize all ( work efforts. The Project Manager Report (PMR) will be modified so that the i PM can indicate the appropriate priority code for all licensing actions. This f new prioritization schece is required for all work in NRR. j t Werk originatics in Offices other than NRR will be received by the responsible NRR interf ace organization (see External Interfaces Section, "NRR Panagement l anc Operatient Folicies" and Table 1 telow). The priority of the work will -t be detemined by the interface organizatice using the examnles proviced in i l ,..... c,.,.... -........ . ~ .. n. ..a w, n. :.

s

• Multiple iddressees 2

In those cases in which the NRR interface organization is the Program Management, Policy Development and Analysis Staff (PMAS), the work will be performed within PMAS to the extent practicable (notwithstanding the priority examples given in Enclosure 1) in order to minimize the adverse resource impact on the NRR line organizations. Iterations with the line organizations ~ will be limited to only those that are necessary to complete the work. PMAS will obtain the concurrence of the line organization as appropriate for work originating in Offices other than NRR which it performs. If it is impractical or inappropriate for the work to be performed in PMAS, PMAS will work with the appropriate line organization in delineating the scope of work to be complet e sy that organization and, using the examples provided in Enclosure 1 its pnority. TABLE 1 i EXAMPLES OF NRR WCRK ORIGINATING IN OTHER OFFICES NRR Originating Interfacing Subject Office Greanization Events assessments AE00 DOEA Diagnostic inspections AEOD DRIS Perfornance indicator program AEOD DLP0 Overall coordination RES RTSB Advanced LWRS RES ORSP Safeguards NMSS DRIS Waste issues NMSS PTSB Dry spent fuel storage NMSS PTSB Power reactor decomissioning NMSS DRSP ~ The NRR Allegation Review Board will also utilize the priority ranking system. ~ In. accercance witt. NRR Office Letter 1003, " Management cf Allegaticns," dated July 1, 1988, the Board is responsible for the assignment of allegations tc NRR organizations and for approval of specific allegation resolution plans to be implemented by those organizations. Basis for Rankino Scheme The prioritizec scheme utilizes safety significance, operational impact, Comission statutory responsibilities, and residence time within the NRC in assigning priority. The ranking scheme defines four categories which are described generally below, along with a corresponding resource allocation. delitientes specific examples of work which fall. into each category. It should be noted that the examples contained in Enclosure are part of a living document, The Executive Team will periodically provide c action, either verbally or in writir,g, to the Division Directors concerning relative work priorities which will scrersede the examples in Ecclosure 1. Additionally, management ray declare a set priority for actior.s on a single plant, if desired, due to unusual circumstances.at the plant. 4 a

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• Multiple. Addressees 3

'~ Management's initiative to control the backlog (age distribution) of licensing actions focuses attention on lower priority issues by raising the priority to Priority 2 after they have been within the NRC for 18 months. Also, low priority work may temporarily be assigned a higher priority at management's discretion to ensure schedules are achieved. ~Fer-enemplev-managementa -4n444ative-te s reduce-the-baskieg-of-44eens4ng-ae44 ens-feemsee-e44ent4en-en-lower-priee44y ~ issues-and-efiest4vely-ra4ses-thefr-pr4er44y-to-a-h4gher-leve4, Finally, in establishing priorities, consideration should be given to the licensees' -l assessment of their needs for their various requested actions and the resident l inspector'/ regional offices' views on those needs. For example, clarification. i of the intent of technical specifications could be important in ensuring the exact intent or meanino of the technical specification is set. PRIORITY 1: Significant safety concerns which require imediate action or l response to issues which have demonstrated very high risk significance-Actions needed to prevent plant shutdown, allow restart or .{ prevent significant derate, when required action could not have been anticipated in a more timly manner by utility or vendor. ] ~i Issues where inrediate actions needed for compliance with statutory and judicial requirements or Comission directives. Includes such activities.as response to court orders ED0/ Congressional. tickets,. support for. hearings, ar.d response to 2.206 petitions. Resource Allecation for Priority 1 j Imediate resources will be allocated. Short response jobs will be accomodated as rapidly as possible. PRIORITY 2: Significart safety issues which require near-term staff evaluation, j Activities reeded to determine the safety sigr.ificance/ generic significance of an operating event. j Actions needed to support cbntinued plant operation or evaluation of necessary modifications or enhancements. Plant-specific resolution of very significant generic topics which have been identified as matters of high-risk significance. j Topical Report reviews which will have extensive application in i the short-to-mfo term, and whose application results in a significant safety benefit. Licensing reviews where SER preparation is needed within 6 months to prevent' impact on CP, OL, PDA, or FDA issuance. Licensing actiers having a residence time (i.e., age from initiation of review) or 16 months or more, p g e.... _. g,._ m,. A._ ; g.

~ Multilple Addressees 4 Resource Allocation for Priority 2 The assignments will receive sufficient resources of ADT personnel and contractors to complete the issue in a timely manner, consistent with the demands of priority 1 assignments. Generally, the. review schedule will result in a review period from 3 to 6 months, though longer schedules may be necessary for tasks involving ignificant licensee / vendor interaction. PRIORITY 3: Important issues (potentially of moderate safety significance) which require staff action over the long term. Support for generic issue resolution and multiplant actions. Topical report reviews which will have wide referenceability to the short-to-mid term and for which an application offers operational or economic benefit. Technical Specification changes not needed to correct a safety problem or support continued plant operation or prevent derate. Long-term license reviews, including naval and non-power reactor evaluations. Resource Allocations for Priority 3 Technical resources will be allocated consistent with the ' demands of priority ~ 1 and 2 tasks. Schedule slippages may occur due to development of higher priority assignments, but will be minimized via use of contractors and Regional res ou rces,. The review schedule typically will be 4 months or longer. PRIORITY 4: Issues not directly impacting plant safety. Acministrative tech spec changes. Topical report reviews with limited referenceability er safety hanefit. Acticns on generic and conf'irmatory items with relatively low safety impact. Resource Allocation for Priority 4 ADT technical branches will schedule resources es available from the demands of priority 1, 2, and 2 assignments. Review senedules by technical branches ' will typically be 6 months or longer on priority 4 assignments as the work will be utilized to acconecdate available slots of reviewer time. Schedule slippages will likely occur on priority 4 assignments due to requirements of higher priority work, but repeated rescheduling should be minimized to the extent prcctical. Priority 4 items should be completed within 18 months of receipt by the NRC. It is envisioned that because of the little safet) significar:ce associateo with priority 4 items, the scope and depth of review effort shoulc be minimized. Periodically, management will review priority 4 f tems to cetermine if the work effort should be continued or eliminated. l e a bsw -w m n r1.en m. %wm A h.* 2 .*n gen _ u

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e .~ APPENDIX C MPA CLOSURE PLANS In order to provide better coordination of multiplant activities (MPAs), lead project managers (PMs) were assigned to existing MPAs on October 30, 1987. New MPAs are automatically assigned lead PMs by the MPA management program. However, the program still required better focus, as some closecut plans had long schedules. In December 1988, briefings were made to the Executive Team for selected MPAs. The purpose of these meetings was to present examples of new and innovative methods to close MPAs in a safe manner. These MPAs were to provide examples of closecut methods which could then be applied to the remaining MPA inventory. Basically, five potential closecut bins were developed as follows: 1. Management to better focus the scope and depth of the NRC review based on the issue's overall priority. 2. The NRC will accept licensee certification that actions are completed satisfactorily with' inspection followup on an audit basis. 3. The NRC will accept owners group results with audit followup, as appropriate. 4. The NRC will discontinue review efferts based on new developments, or the low safety significance of the effort. 5. The NRC will continue the review in the nonnal process, with increased management attention to ensure an efficient closecut. Following the December 1988 briefings, each review branch developed closecut plans for their remaining MPAs by February 1,1989. The amendment blitz program has delayed some of the closecut programs but improvements in the MPA closecut program are occurring. C-1

..4 r For future MPAs. the NRC will closely define the scope and depth of the review L effort before issuing the generic requirements. Closecut methodologies listed above will be considered. Ir. particular, more dependence will be placed en f licensee certification and use of prompt enforcement, where appropriate. Addf tionally, where negotiations are not succa'ssful in resolving staff safety concerns expeditiously, senior management concurrence will be obtained in j issuing orders, as necessary. h f 6 e a l j 9 s f C-2 9 O

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a O 4 ' 4 4 g 4 4 s D P e O 1 a APPENDIX D. PROPOSED REVISION TO THE i NRR PRIORITY SYSTEM I f J e O e 6 a 9 4 I l 4 h m. .,.,........,........ ~.. ~ -.. - -.s ;,

V 1 \\ Multiple Addressees 5 i Use of Risk Assessment Insichts in Determination of Safety Importance As a general rule, the safety significance of an issue should be guided by an assessment of its risk significance. Issues which affect components or systems that are involved with major accident scenarios should be considered as an appropriate high safety priority. A prime example would be problems associated with the station batteries or diesel generators, since station blackout accidents have been identified as major contributors to public risk at a number of sites. In a similar sense, issues related to containment integrity would be likely candidates for high priority since containment bypass accidents also contribute significantly to public risk. 8dentification of components and systems involved as safety or nonsafety is not alone sufficient justification for assignment of priorities, as is clearly evidenced by the problems of the ICS (nonsafety) at B&W plants. Effects on important support systems n.ust be carefully consicered. Significant contrib-utors to initiating events.that may result in challenges to the plant need to have an appropriate high priority. In the future, guidance will be provided on the determination of risk signif1cance based on past PRA studies. Prior to this, necessary guida' ice be obtained from the responsible ADT Branch Chief or Assistart Director. Xmolementation of Procram Each new work request being transmitted to the technical branches will have the appropriate prioriti:ation category identified by the PM and concurred in by the Project Director as indicated by appropriate initials on the work request form (Enclosure 2). While the above priority descriptions are meant to provide a general framework, Enclosure 1 identifies examples of specific actions which fall within each category. is to be the new standard Work Request form. It has been modified to allow a space to indicate the priority being recuested as well as the basis for the priority. Each assignment should be given a priority designation, and this should be indicated on the assignment form. In justifying priority assignments, the specific example from Enclosure 1 should be cited, if feasible. The more general guicance abeve can be of asristance where an issue is not explicitly incicated in Enclosure 1. The technical review branch management will retain a copy and return the original work request form within 5 working days either agreeing to the proposed completion cate, or for cases where the technical review Branch Chief disagrees with the priority assignment or schedule, the appropriate Project Director will be contacted to ciscuss the issue. If resolution of priority anc schedule cannot be reached, the issue should be elevated to the Assistant Director level. For work assignments which are completed by multiple branches, the PM wil. coordinate the assignment to assure that a uniform priority determination is agreed upon by cli review branches. Brcnch-specific schedules will, cf course, be controlled by competing workloads within the Branch. ~ . % w.n . _,,.,,., w.,.. n, : n.,,. a.,

l e- -l Multiple Address:es 6 For review of multiplant actions (MPAs), priorities and review schedules will j be detemined by the designated lead reviewer and lead Project Manager. The use if work request-forms is not necessary for individual plants within an MPA. The lead reviewer will ensure that a. uniform priority is established when multiple l review branches are necessary for a given MPA. The lead Project Manager will work with the individual plant Project Managers to' insure that the appropriate-1 review priority is entered for all plants in the RITS/PMR data base for their i assigned MPAs. Unique design features or special circumstances at certain plants 1 may result in non-uniform review review priorities within a specific MPA. l The prioritization scheme is not meant to be a rigid framework. Some assignments may not fall within the categories described. Allocation of resources, however, will be guided by the principles inherent in our prioritization process. This is, issues of greatest safety significance and operational impact will be prioritized high, as well as those areas which the Commission has identifico as of importance. In the near future, our computerized licensing acticn tracking systems will be modified to include the prioritization scheme to allow management monitoring of the, program. Modifications to Schedules The following procedure will be used to document modifications to schedules or j priorities for all plant-specific work requests under review by the technical l ) branches. This includes the backlog of work in process-before this program i was implemented. The plant PM is to be kept informed of any necessary schedular or priority adjustments prior to th'e expiration'of the original negotiated schedule. If the changes are due to competing priorities of other 'I work assigned to the technical review branch, the reviewer will route a - revised work reouest through his/her management to the PM. Before.the request 1 is routed for concurrence, the PM and the reviewer should informally negotiate the schedule. If an acceptable alternative cannot be negotiated, the issue shall be elevated for higher level management review. If the changes are due to reasons under control of the PM or licensee, the PM will initiate the transmittal of a reviseo work request to document the change. In addition. the PM will initiate the transtnittal of a revised work request to document l the change of a licensing action priority to Priority 2 when the licensing 2 I action has been within the NRC for 18 months. For minor schedule slippages of no more than approximately 1 month, the' PM may detemine that transmittal of a revised work request is unnecessary if he/she has received timely j notification of an acceptable schedule change from the assigned reviewer and reviewer's management. Project Managers and ADT staff should make all possible efforts to establish realistic schedules so that multiple schedule i changes are avoided. 1 For multiplant issues, schecule and priority discussions should be held between i the lead PM and lead reviewer. The lead FM is responsible for informing plant-specific project managers of schedule or priority changes in e. timely 7 manner so they c;n update their PMR appropriately. Cuarterly, the leac PM and lead reviewer will issue a sumary report of their multiplant activities. e J

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U ~ Mul'tiple Addressees 7 ADP Review Projects has assumed review responsibility for some amencment applications and. other action items requiring review. Depending upon the issue and the expertise of the individual, review by a PM may be appropriate for issues of all priorities. However, if a review branch has a considerable workload of pricrity 1 and 2 items, it should re-evaluate its priority 3 and 4 commitments to detennine if they can not be adequately reviewed by Projects. The procedure for determining if Projects will conduct a review is provided in a memorandum dated September 4, 1987 from Frank J. Miraglia and Richard W. Starostecki. Before a PM ccmmences a review, he/she should receive concurrence from technical branch n.anagement that Projects can conduct the review. To properly support this program, the review Branch Chief will normally provide concurrence and/or comments within 10 working days of receipt of the amendment package. Reoional Resources Where feasible, technical reviews will be considered for assignment to the Regions. Either the PM or technical branch can request a regional review. However, the letter transmitting the work request tu the Region will be signed by the appropriate ADP Assistant Director (who will be responsible for coor-dinating the total work assignec to the Regicn) and have the concurrence of the associated technical Branch Ch.ief. If it is. initially decided that the PM will conduct a particular review and tten later the PM cecides to transmit the work to the Regicn, concurrence by the technical Branch Chief on the transmittal letter is not requirec but tne Branch Chief is to receive a copy of the transmittal letter fer information purposes. However, all final amendment packages cr safety evaluations sent to the licersee, where the review was not concucted by the NRR technical branches, will include the appropriate technical Branch Chief on cer.currence. The purpose of this procedure is to ensure that the technical branches are ecgnizant of all efforts in their area of technical expertise. Thomas E. Murley, Director Office of Nuclear Reactor Regulation

Enclosures:

1. Examples of Actions / Issues 2. Work Request Form I cc: All NRR Staff e 9 e p - & a.....,., - :. -., r.. - M. m.....,. :.... z. ,.. ;. -w,~r -,. ~ r w.

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4 EhCLOSURE 1 EXAMPLES OF ACTIONS / ISSUES WITHIN EACH pRIORITIZATION CATEGORY priority I - HIGH PRIORITY, IMMEDIATE ACTIONS / ISSUES 1. Operating plant safety assessments of very high significance inc'luding: a. event analysis of a serious operating incident b. B&W plant reassessment c. Part 21 reports cf high safety significance 2. Bulletin development 3. 10 CFR 50.54(f) letter development 4 Team inspection (AIT/IIT/OSTI/Special Inspection) support 5. Activities directly related te problem plant restart decisions 6. Emergency Technical Specificaticn reviews where necessity could not have been anticipateo in a more timely manner. 7. Equipment modifications required to ensure continued safe operation if there is a significant safety ccncern, such as ATWS modifications 8. Exemption requests necessary to allow restart or to prevent unnecessary reactor shutcown or significance derating of operating plants 9. ED0/Cengressionel ticket items 10. Support for court and Licensing Board hearing and response to inter-rogatories and 2.206 petitions ~ 11. Incident Response Center Suppcrt 12. Technical support for Temporary Waivers of Compliance or Safety ~ Evaluations Reports for license amendments for actions to prevent unnecessary reactor shutdowns or startup delays or significant derating of the plant, if such action would potentially have a safety impact 13. ACRS/Comission Briefings

14. Technical Support for orders or 50.54(f) letters consistent with safety significance 15.

kesolution of inspection or RER. team findings with high safety or safeguards significance f;CTE: Items such as 2, a, 9,11,13, and 15 do not necessarily dnycive ADP assignment or tracking, but are included for perspective on work priority. s -y

- u 2 Priority 2 - HIGH PRIORITY, SHORT-TERM ACTIONS / ISSUES 1. Safety Evaluations Reports and Technical Specifications for NTOL activities 2. Safety evaluations necessary for restart support event assessment 3. Evaluation of changes required as a result of operating events, inspection findings, and significant Part 21 reports 4. Reviews of responses to 10 CFR 50.54(f) letter / bulletins, if potentially safety significant 5. Assistance to Regions (of safety significant) including: a. Inspection team support b. Consultation c. Tast. Interface Agreements 6. BWR piping degradation and repair reviews and evaluations 7. Erosion / corrosion evaluations 8. Major safety, emergency planning, or safeguards issues 9. Radiological reviews for new or unique major modifications or equipment repairs

10. Technical Specification Improvement Program

11. Standard plant reviews

12. Reload reviews which result in Technical Specification changes, which are necessary to assure no reduction in safety margins i

13. Multiplant issues of hign safety significance 14 Emergency Operating Procedure heviews from a plant-specific perspective

15. Support for enforcement acticn other than orders Emergency Operating Procedure Reviews from a vendor perspective 16.

17. Review of proposed resolution (prioritization) of USIs and GSIs

18. Licensing actions residing with the NRC for 18 months or' longer

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.y 3 1.. Priority 3 - MODERATE PRIORITY, LONG-TERM ACTIONS / ISSUES L Licensee Qualification to perform Plant Safety Analyses l 2. GDC-4 leak-before-break reviews j 3. Multiplant actions not priority 2 1 4.- Surveillance program review 5. BWR IGSCC long-tenn program review 6. BWR feedwater nor:le cracking, long-term program revisions 7. Vent and purge valve operability 8. Non-power reactor issues, if safety significant 9. Vital equipment and vital area reviews 10. Changes necessary to satisfy order, license conditions or regulations l affecting numerous plants if change has moderate safety significance

11. Spent fuel pool expansion reviews not meeting priority 1 or 2 requirements 12.

Piping as-built / design nori-conformance reviews 13. Participation in ASME, ANSI, ar.d IEEE Code and Standards activities

14. Code' Topical Report reviews which are recuired to demonstrate compliance with the regulaticnc, or provide operating flexibility / economic benefit.

l and are expected to have wide reference ability Examples: 4 a. Codes necessary to support cross-venoor reload b. Haccam Neck conversion to zirct.loy clad fuel c. LOCA models for UPI plants -l i

15. Safety-significant problems _with Offsite Dose Calculations Manual (ODCM) n or Radiological Effluent Technical Specifications (RETS)

16. Decoccissioning efforts j

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17. Regulatory Guide 1.97 Reviews j

18. naam generator replacement 1

19. Waste issues 1

1 20. FTOL issues

21. Long-term follow up of events which are not of high safety significance

~ j j c.,,, y.K.,,,,,,, y ._,,., w g y.,,_.,y. .. u : 4..-: w.- ,,-1;s. g.s f.,,.y

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22. Support on high priority generic issues

13. Severe accident policy implementation

24. Proposed regulatory changes

25. Review and evaluation of containment integrity issues

26. Pressurized Thermal Shock review and evaluation j

27. Significant control room habitability issues 1

28. Seismic hazard characterization

29. Advanced reactor plant reviews l

30. Inservice inspection ano testing program implementation and relief l recuests not affecting continued operations or restart l

31. Hycrogen Control Reviews l

3I. Plant license renewal effort related to lead plant reviews l Priority 4 - LOW PRICRITY ACTIONS / ISSUES i k Issues not included above, including 1. Technical Specification relief requests that are in essence " relief" from-current requirements (exclucing those that involve unnecessary reactor shutdowns er plant derating) l 2. B&W thermal hydraulics tssting l 3; Pcwer upgrade propcsals 4, Plant license renewals l ^ S. Changes in cere operating limits Jor.1 to increase margin and not i associated with the Technical Specification Improvement Program [ 6. Increased surveillance intervals, unless safety benefit 7. Larger acceptable operating bands for equipment needed only to provide operational flexibility i 1 8. Code reviews which are needed only to improve operating flexibility j i 9. Turbine z.issile reviews i

10. ASMS Code case reviews for ors 3

11. Review of effluent reports i }

m e.m s.~r ~~ m. - c,-ru m.,,-% c. %,+,gw..r,-~,a&.re n.ma.mW }

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WL@li8LLCN Date Prepared i Requested Target Date WDRK REQUEST TD: . Branch Chief. Branch ) THRU: . Director, PD FRDM: , Project Manager, PD Mail $too TAC / TITLE: 1 Description of Review Requested Priority:' Rases for Prior ty: Please indicate your acceptance of the Work Recuest and Target Cate by Signature and Assigreent of Reviewer (s). Wort Package should be retained by reviewer (s). 1 Priority Detamination Acceptable: Yes No Alternative Priority Target Date Acceptable:' Yes No Alternative Target Date: .ssigned Reviewr(s) Phone Phone Section Chief Signature Cate Branch Chief Signature Date Return to plant PM within 5 working days of receipt if a n vision to previously approved schedule: } W4u corolation date .or New priority Raason for revision Section Chief Approval: tranch Chief Approval: ' Review schedules for the 4 priority categories are nomally: Priority 1 !amediate assignnent of resources Priority 2 Eear tem action Priority 3 Long tem action Priority 4 Resource dependent action e 9 ~ ~ J.,- .C.1 ,..T,...,'.~,, s.

o 4 j APPENDIX E i WISP TRACKING SYSTEM Workload Information and Scheduling Program System Objectives Although progress has been made in improving the management of specific programs, such as the license amendment backlog and multiplant actions, a need exists for better workload management, office-wide accountability, and improved oversight of program performance throughout NRR. Accordingly, NRR has initiated the development of the Workload Information and Scheduling Program (WISP). The program will be fully implemented this calendar year and will provide a single source of all NRR workload information and scheduling, and will be accessible to and used by all levels of management from the first-line supervisor to the Office Director. Two key goals will be achieved through the implementation of this program. First, NRR will achieve better efficiencies through improved management, control, and oversight of workload. Second, NRR will be better able to realign workloads and resources by focusing on the best means to satisfy safety priorities. From a workload management perspective. WISP will enable the first-line ~ supervisor to better control the scope and depth. of the technical reviews consistent with safety priorities, and to develop and communicate realistic ~ schedules that are linked to estimated staff time and resource availability. Because WISP will account for all workload's at each organizational level, it will facilitate the monitoring of assignments, pricrities, and staffing. An automatic resource-leveling feature will facilitate balancing workloads and resources, and the rapid assessment of the impact of new assignments on existing priorities. WISP will provide the project manager with direct access to ail actions and safety issues for his/her plant, along with a schedule of technical inputs needed from others to close out specific actions. Through use of the program, NRR management will cause enhanced. visibility and accountability of workloads and resources, as well as improved oversight of program performance. E-1 m. a,. 4eeu m.-..e...,*%. w. _ k e e J.. *, w, s.. v.e. s - .,.. w :.g.. %... a- .a.= seam.um .y, m M

~ 1 From a safety perspective, WISP will enable each level of NRR management to focus on how staff time is being allocated to all safety priorities within the context of-total workload. Through this visibility, better management decisions can be made on how to best realign workload and resources, with a-clear focus on safety. This system will automatically elevate visibility .j of older actions to preclude the " sediment" from recurring.: l Oversight will be provided so as to provide an ongoing assessment of program perforsance, quality control of data, and assistance to first-line supervisors and managers in estimating work, setting goals, maintaining priorities, and scheduling. Assistance will also be provided in assessing workload impacts j and identifying opportunities for improvements and efficiencies. r l t 1 t n b e ' I E-2 ....,_......,,.,,_......,,.;.m.,.,_,,.,..._., ,. _,... _.m. %,,.,x..

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4 e d + e e APPENDIX G CERTIFICATICN PROCESS FOR TS IMPROVEMENTS 9 9 e e e O 0 e O b e 4 e I ,] k [ gk) O F 'f *@ HgyM g g g

m e ' MEMORANDlM FOR: Frank J. Miraglia, Associate Director for Inspection and Technical Assessment, NRR James 8. Partlow, Associate Director for Projects NRR FROM: Charles E. Rossi., Dimetor - i Division of Operational Events Assessment, NRR Steven A. Varga, Director i Division of Reactor Projects ~- I/II, NRR

SUBJECT:

FOLLOWUP ACTIONS FROM MARCH 1989 NRR MANAGEMENT ' l MEETING [ FrankGillespie'smemorandumofMarch7,1989assignedSteveYarha'andmyself a followup action from the March 1989 NRR Management Meeting. j "Varqa/Rossi. Consider what we want licensees converting to. sTs to accress and/or certify in their applications-in order ' to minimize resource impacts" l Enclosed is an outline of our recommendations for this followup action. We are prepared to discuss these recomendations with you at your convenience. l Odginal 5?fd BY Charles E. Rossi, Director - Odginal sp6d By j Division of Operational Events Assessments, NRR Steven A. Yarga, Director Division of Reactor Projects - I/II, NRR

Enclosure:

As stated cc:- Distribution .i D. Crutchfield GT55 R/F l L. Shao DOEA R/F B. Grimes \\ Central. Files F. Congel M ERossi 1 J. Roe EJButcher F. Gillespie JACalvo G. Holahan WDLanning i 8.'Liaw RLEmch C. Grimes SAVarga CHBerlinger .J CSchulten +

• SEE PREVIOUS PAGE FOR CCNCURRENCE (ROSSf-VARGA/MIRAGLI A-PARTLOW)
• TSB:00EA:NRR *TSB:DCEA:NRR. 'C:TSB:00EA:NRR 'PD4:NRR D

- R CSchulten REmch' EJButcher JAcalvo Va a-05/2/89 05/2/89 05/4/89 05/4/89 0Sg89 0 p9 W ue---~.--....ce..-~,.........-...~,.,,,,......-..-e...,~~..--~,

y e j ~ 2 ? g-o - Based on thiAicensee's pre-certification our review could concentrate on differences identified in the STS markup: - We could focus on differences identified in the STS mark-up with confidence that no necessary TS requirements are missing, and - We could identify TS certified to be identical to the STS and existing TS values,~e.g. setpoints, for which only spot check reviews are necessary. o Based on the licensee's pre-certification we could support the following NRR l SER findings without significant review effort: - All current TS requirements are maintained either in 'the conversion f j TS or relocation documents. - For TS which are pre-certified. NRR staff could approve those TS.in j a SER using an audit to verify the accuracy of the pre-certification, o A final certification at the end of the conversion TS review would ensure (1) that the conversion to the STS is consistent with the FSAR, the SER and the l as-built plant and (2) that the plant-specific values are identical to existing TS values. hECESSARY NRR SAFETY EVA1.UAT10N REPORT FINDINGS The conversion TS mest the requirements 10 CFR 50.36, 50.36a and 50.40. o All current plant TS requirements are either in the conversion TS or o relocation documents. The co'nversion TS are consistent with the new STS format, the updated FSAR, o the SER and the as-built plant, and (1) they are acceptable because the TS requirements are the same as the new STS* which is applicable to their plant design, and -i plant-specific values are identical to the current plant TS values, or (2) the TS recuirements are different from the new STS, but are acceptable based on judgement,against the four criteria in the " Key Implementation Issues", and against guidance in the " Split Report

• for plant specific relocation.

l 1 j Updated 10 CFR 50.59 program is in place, o The staff finds the locations and change controls for relocated TS o requirements acceptable. i o The conversion TS are consistent with the plant specific conditions in the l ~ line item improvement generic letters and 6cpical report approval letters. i i

• The new 5T5 will be Topical Reports whose approval will be documented by a staff Safety Evaluation Report.

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4 4 6 e e ? I e APPENDIX H DOCUMENTATION GUIDANCE AND EXAMPLES e e 4 l h l 1 1 I i i e l i O e O h O.'

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u SAFETY EVALUATION REPORT FORM CONTENT GUIDE e INTRODUCTION [ ] WHAT action has the licensee requested? [ ] WHY has the licensee requested the action? [] WHEN was the action requested? [] Note ALL related licensee correspondence (see References). [] Are there any related NRC activities? EVALUATION [ ] What are the SPECIFIC applicable CRITERIA ? [] What INFORMATION was gathered to conduct the review? -[ ] HOW was the review performed? [ ] Is there any other pertinent information? [ ] In what way does the requested action satisfy the applicable REGULATORY REQUIREMENTS and STANDARDS? See sample finding on the following page. ENV IRONMENTAL - CONSIDERATIONS [] The required environmental impact finding should always be presented in an SER supporting a license amendment. If you cannot make this finding then there is more work to do. See standard finding on the following page. CONCLUSION [ ] Briefly reiterate the requested action, the Staff conclusion, and the manner by which the proposal satisfies the applicable regulatory requirement. [ ] Include the overall findings required by law. See sample finding on the following page. REFERENCES [] All applicable uti l ity correspondenc e. [ ] Applicable FSAR sections. ~ [] Applicable regulatory requirements and guidance. [ ] Applicable industry standards and guides. e 9 a ]y#$e _'4Y "" d p (4k e8'

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0~ ' SAMPLE SER FINDINGS EvaluationQ o Thestaf$hasreviewedthe proposed changes and concludes that the revised TS 3.6.E and 4.6.Er and the associated bases incorporate the recossended procedures of IE Balletin 80-07 for improved monitoring of. jet pump per formance. These procedures were approved by the staff base on MURES/CR-3032, Appendix 0 CHovesker 1964). In addition, the installation of 1sproved Jet pump hold down beams, during the 1988 refueling outage provides r added assurance that Jet pump failu.res will not occur. Therefore, the staff finds the proposed changes acceptabit. Environmental finding: The staff has determined that this amendsent involves no significant increase in the amounts, and no significant change in the t ypes, o f any ef fluents that say be released offsite, and that there is no signi ficant increase in individual or casalative occupational radiation exposure. The Cassission has previously issued a proposed finding that the avendment involves no significant hazards considerations and there has been no public consent on such finding. Accordingl yr the amendment seets the eligibility criteria for categorical exclusion set forth in 10 CFR 31.22Cc)C9). P ursuant to 10 CFR 31.22(b), no environmental impact statement or environmental assesssent.need ~ be prepared in connection with the issuance of this asendment. Conclusion finding: As described in the foregoing evaluation, the staff has reviewed the licensee's design nodifications and the associated proposed Technical Speci fication changes related to the service mater systes and intake canal inventory sanagenent. Based on this review, the staff concludes that the service water systes and intake canal design sodifications will satisty the revised design basis and the applicable regalatory requirements, as follows General Design Criterion C00C) 2, with respect to protection of the cooling water systes against earthquakes and tornadosy GDC 44, nith respect to the adegancy of the cooling water systen for normal and accident conditons, redundanc y, capability to isolate non~ essential

systems, components and

piping, and con formance with Regulatory Guide 1.27 with respect to the reliabilit y o f the ultimate heat sink to sitigate an accident at one unit and safel y shutdown other units at the same site; design p'ovisions to permit inservice GDC 43, as it relates to r

testing o f cooling unter systems and equipsent; and SDC 46, as it relates to ~ design provisions to permit operational and functional testing of the cooling unter systems and equipsent. ,, - ~ -,. ..e.....

~. SAMPLE SER FINDINGS CONTINUED The staff further concludos that the proposed Technical Specifications are more conservative than current specifications and are consistent with the design noo'ifications and revised design basis. Therefore, the staff finds the proposed design nodifications and Technical Specification changes acceptable. ~ Based on the considerations discussed above the staff finds r that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed nenneer (2) plant operation will be conducted in compliance with the Consission's regulations, and (3) issuance of the amendment will not be inimical to the conson defense and security or health and safety of the public, i s ~ - u. ~. ..-c. ..--.v. - ~ *.. ..a ~- - .. ~. - - s ...,...,.a. ......-z

v EVALUATION REPORTS FOR OTHER ACTIONS FORM CONTENT GUIDE INTRODUCTION [] WHAT issue or event is being addressed? [I WHY is the evaluation necessary? [] WHEN did the issue arise or the event occur? [] Are there any related issues or activities? i EVALUATION [] What are the SFECIFIC applicable CRITERIA ? [] What INFORMATION was gathered to conduct the review? [ ] -HOW was the review performed? [] Is there any other pertinent information? i [] In what way does the conclusion satisfy the applicable STANDARDS and CRITERIA? i See sample evaluation on the following page. r CONCLUSION i [] Briefly reiterate the issue and Staff conel'usion, including the overcll manner by which the conclusion satisfies the applicable regulatory requirements. See sample conclusion on the following page. ~ 1 REFERENCES .l i l [ ] Applicable reports and correspondence. [ ] Applicable FSAR sections. [ ] Applicable regulatory requirements and guidance. [] Applicable industry standards and guides. ~. v e i )

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4 SAPTPLE EVALUATION FINDINGS + Evaluation: The staff finds the licenser's approach for determining systen and nozzle flourates ecceptable beca*1se it is generally based on applicable test data. The af fect of a single through-wall crack in the Oyster Creek Ho, 2 core sray sparger has previously been evaluated by the staff (Reference X). In that evalaation, the staff concluded that crack leakage would have a negligible effect on the distribution of flow among nozzles. Since the original crack was discovered in 1978, three additional crack indications have been identified. In determining the crack leakage flow, the licenser has treated these indications as through-wall c'rac ks. All crack leakage flon is treated in the analysis as a net loss in available core spray flow. The staff co ncl udes that this is a conservative approach and is, therefore, acceptable.

== Conclusion:== Based on the staff's revien of TU Electric's progran descriptions, the inspection and audit of the associated Comanche Peak

Response

Tras and Corrective Action Progras activities, and consideration of public consents, the staff concludes that the TU Electric progress provide the necessary seans to (1) identify design and construction deficiencies that could affect safe operation o f. the

plant, (2) design and l

implement appropriate corrective actions to resolve those deficiencies in accordance with' the applicabir regulatory requirements and licensing consitsents, and (3) conduct these activities in accordance with the requirements of 10 CFR 50, appendix B, so as to ensure ef fective sanagement controls for all aspects of these activities. On this

basis, the staff concludes that, subject to the conditions 1 denti fied in th2s evaluation, Revision 4 to the CPRT Progran Plan and ths CAP Plan are acceptable.

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FORWARDING MEMORANDUM + FOR TECHNICAL EVALUATIONS I lt . MEMORANDUM FOR: Project Director i FROM: Branch Chief t i

SUBJECT:

DESCRIPTION OF ACTION (TAC ' NO.) Plant Name: Utility: Docket: Directorates Review Branch: TAC: l Review Status: The opening paragraph should briefly describe the nature of the action j and reference all utility correspondence reviewed in relation to the l cetion, if that is not otherwise done somewhere in the ev-sluation. l -The content of the memorandum should be limited to a discussion of: [ ] Conditions of acceptability. [ ] Open review issues. [ ] Future or other actions required. 1 [ ] Proprietary information in the evaluation. [ ] Policy issues requirihg management a t t e n t i on'., ) [] Any other matters that should be brought to the PD* s att ention. If there.are none, say so. l Branch Chief

Contact:

Reviewer, Phone.

Enclosures:

l. Evaluation 2. SALP Input cc: Project Manager Division Directors ~ Assistant Directors 1 Section Chief i i i e e i,** -f & M.at,F4 % TN %'.?

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APR's 41st M MMANDLSI POR:- Robert.A. Capre, Director Project Directorate I-1 Division of Reactor Projects-1/II FR131: Scott Netherry. Chief Instrismentation & Control Systems Branch Division of Engineering & Systems Technology $UBJECT: INDIAN POINT STATION, UNIT 2. ATid$ RULE (10 CFR 50.82) (TACNO.59103) 1 Plant Name: Indian Point Station. Unit 2 l Utility: Consolidated Edison Company of New York, Inc. Docket No.: 50-247 i TAC Mo.: 59103' I Licensing Status: ON Resp. PO: I-1 i Revier Branch: SICI Review Status:- Closed - Subject to resolution of Technical-Specification requirements issue Thepurposeofthismemorandumistoforwardtheenclosed(Enclosure 1)safets evaluation report associated with the proposed implementation of the ATWS Rula (10 CR 50.82) requirements as related to the Indian Point Station, Unit 2. l The staff has concluded that, pending the final resolution of the. technical specification issue, the ATW5 design proposed by the licensee is in compliance j witfr the ATW5 Rule requirements of 10 CR 50.62, paragraph (c)(1). Further.- i the staff's conclusion is based on the successful completion of certain noted human-factcrs engineering reviars and satisfactory completion of isolation i device testing by the licensee. Refer to the enclosed evaluation for i details on the subject ATW5 design. i i provides the SALP input related to the staff's review of this subject. Scott Newberry, Chief Instrumentation & Control Systems Branch Division of Engineering & Systems Technology ~Encicsure: As stated cc c/ enclosure:

8. Boger A. Thadani A. Nolan (EG&G)

O. Neighbors D. Lynca I

Contact:

L. Tran (SICS / DEST), 20783. e 7 .~. ~, l~,- ?- --~~--m%-~~'" ' " * ~ ~ " " ^ " ~ -.. a ~ :-v. m.< - ._.n,,..,...

~ { Rj } s l t .i $AFETY EVALUATION REPORT l INDIAN POINT STATION. UNIT 2 i COMPLIANCE WITH ATWS RULE 10 CFR 50.62 DOCKET NO: 50-247 -i i 1.0 LNTR000rTION j i on July 26, 1984, the Code of Federal Regulations (CFR) was amended to include. l Section 10 CFR 50.62. " Requirements for Reduction of Risk from Anticipated i Transients Without Scram (ATW5) Events for Light-Water-cooled Nuclear Power-i Plants * (known as the ATWS Rule). The requirements of Section 10 CFR 50.62 f apply to all commercial light-water-cooled nuclear power plants. l t q An ATW5 is an anticipated operational occurrence (such as loss of feedwater, _l loss of condenser vacuus, or loss of offsite power) that is accompanied by a j failure of the Reactor Trip System (RTS) to shut down the reactor. The ATW5 -l Rule requires specific improvements in the design and operation of commercial l nuclear power facilities to reduce the probability of failure to shut down the i reactor following anticipated transients and to sitigate the consequences of an ATWS event. l n f Paragraph (c)(1) of 10 CFR 50.62 specifies the basic ATWS mitigation systan requirements for Westinghouse plants. Equipment, diverse from the RTS, is j required to initiate the auxiliary feedwater- (AFW) system and a turbine trip [ 1 a for ATW5 events. In response to paragrapa (c)(1), the Westinghouse Owners i Emup (WCG) developed a set of conceptual ATWS mitigating system actuation i circuitry (AMSAC) designs generic to Westinghouse plants. WOG_ issued Westinghouse Topical Report WCAP-10858, "AMSAC Generic Design Package," which j provided information-on the various M tinghouse designs. j The ~ staff reviewed WCAP-10858 and issued a safety evaluation of the subject f topical report on July 7, 1986 (Ref. 1). In this safety evaluation the [ t O .f C.. ,j ...T -. L.4.. w' ' ~~ ' d * * *' W " a w m e- .s m.-e. ~..v ..vn~o-- ~ * = vm v~. w~-7 : ~--~v~~. .1' ' W'~+' " * ' ~ v

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.l 2 staff concluded that the generic designs presented in idCAP-10858 adequately J. meet the requirements of 10 CFR 50.62. The approved version of the idCAP is labeled IdCAP-10858-P-A. During the course of the staff's review of the proposed AMSAC design, the 1d06 issued Addendum 1 to idCAP-10858-P-A by letter dated February 26, 1987- ~ (Ref.2). This Addendum changed the setpoint of the C-20 AMSAC permissive signal from 705 reactor power to 405 power. On August 3, 1987, the 180G issued Revision 1 to idCAP-10858-P-A (Ref. 3), which incorporated Addendum 1 changes and provided details on changes associated with a new variable timer and the C-20 time delay. For those plants selecting either the t feedwater flow or the feedwater pump / valve status logic option, a variable l delay timer is to be incorporated into the AMSAC actuation logics. The variable time delay will be fiiverse to reactor power and will approximate the time that the steam generabr takes to boil dawn to the low-law level ^ setpoint upon a-loss of sein feedwater (MFW) from any given reactor power level between 405 and 1005 power. The time delay on the C-20 rnasive signal for all logics will be lengthened to incorporate the s w a time that the, steam generator takes to boil down to' the low-low level setpoirit upon a loss of MFW with the reactor operating at 405 power. The staff-considers the Revision 1 changes to be acceptable. Paragraph (c)(6) of the ATWS Rule requires that detailed information to demonstrate compliance with the requirements be submitted to the Director. Office of Nuclear Reactor Regulation (NRR). In accordance with paragraph l (c)(6) of the ATWS Rule, Consolidated Edison Company of New York, Inc. l (Coned)(licensee)providedinformationby1~etterdatedJanuary 16, 1987 (Ref.4). The letter forwarded the detailed design description of the ATWS l mitigating systne actuation circuitry proposed for installation at the l Indian Point Station, Unit 2. l t 8eginning in July 1987, the staff held several conference calls with the i i licensee to discuss the AMSAC design. As a result of these conference calls, the licensee responded to the staff concerns by letters dated November 2, 1987 l (Raf. 5) and September 16, 1988 (Ref. 6). t ~ eaa g = 0 e e sof yng g

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2.0. REVIEW CRITERIA The systmas and equipment required by 10 CFR 50.62 do not have to meet all of the stringent requirements normally applied to safety-related squ'ipment. However, .the equipment required by the ATWS Rule should be of sufficient quality and reliability to perform its intended function while minimizing the potantial for transients that may challenge the safety systems, e.g., inadvertent scrams. The following review criteria were used to evaluate the licensee's submittals: 1. The ATVS Rule, 10 CFR 50.62. 2. " Considerations Regarding Systems and Equipment Criteria," published in the Federal Register. Volume 49, No. 124, dated June 26, 1984 3. Generic Letter 85-06. " Quality Assurance Guidance for ATWS Equipment That Is Not Safety Related." 4. Safety Evaluation of WCAP-10858 (Ref.1). 5. WCAP-108SS-7-A, Revision 1 (Ref. 3). I 3.0 DISCUSSION AND EVALUATION To datamine that conditions indicative of an A1VS event are present, the licensee has elected to implement the WCAP-10858-P-A AMSAC design associated with monitoring the, steam generator water level and activating the AMSAC when the water level is below the low-low setpoint established for the reactor protection systra (RPS). The AMSAC setpoint will be set between 5% and 8% of the narrow range span (NRS). The steen generator low-low level setpoint for the RPS is set at 8% of MRS. This setpoint coordination will ensure that in the event of a steam generator low water level excursion the RPS will generate a protective signal before AMSAC actuation. This AMSAC design does not use a C-20 permissive signal and thus will be amed at all reactor power levels. ) Omission of the C-20 perisissive is discussed further in Itan 6. below. i o a j -~s ~ n .c- _s.~- rv a..

e-4- ~ 3-Many details and interfaces associated with the isolamentation of the final AMSAC design arv of a plant-specific nature. In its safety evaluation of [ ifCAP-10858, the staff identified 14 key elements that require resolution'for I each plant design. The following paragraphs provide a discussion on the licensee's compliance with respect to each of the plant-specific elements. s 1. Diversity 1 t i The plant design should include adequate diversity between the AMSAC equipment and the existing Reactor Protection System (RPS) equipment. Reasonable equipment diversity, to the extent practicable, is required to minimize the potential for common-cause failures. The licensee has provided information to confirm that the AMSAC logic circuits will be diverse from the logic circuits of the RPS in the [ 4 areas of design, equipment, and manufacturing. idhere similar types,of r components are used, such as relays, the AMSAC will utilize a relay of a different make and manufacturer. 2. Logic Power Supplies i Logic power supplies need not be Class 1E, but must be capable of performing I the required design function upon a loss of offsite power. The logic power must come from a power source that is independent from the RPS power supplies. i The licensee has provided information verifying that the logic power supplies l selected for the Indian Point 2 AMSAC Iogic circuits will provide the maximum available independence from the RPS power supplies. The AMSAC will be potered from redundant Class IE power supplies which.will be independent of. the RPS and capable of operating upon a loss of offsite power. i 3. Safety-Related Interface + The implementation of the ATids Rule shall be such that the existing RPS i continues to meet all applicable safety criteria. e i i l O .g y$ 8 f [*.. D ) ,[, e~9 S $ [*g 8 p 1 *W =dp*, f g,

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i ~ 'The proposed ANSAC design interfaces at its input with the existirq Class IE j ~ circuits et the steam generator level instruentation. At its output, the l ANSAC will interface with the Class 1E circuits of the plant's AFW pumps and the steam generator's sampling and blowdown isolation valves. Connections with these Class IE cirtuits will be made through the use of approved Class ? 1E isolation devices. The licensee has confirmed to the staff that the' existing safety-related criteria that are in effect at'the plant will 1 continue to be met after the implementation of AMSAC (i.e., the AP$ will j continue to perfors its safety functions without interference from AMSAC). Refer to Item 9 for further discussion on this issue. j 4. Quality Assurance The licensee is required to provide information regarding compliance with j Generic Letter (GL) 85-06, " Quality Assurance for ATWS Equipment That Isy Not Safety Related." i i i The criteria of the MRC quality assurance guidance (GL 85-06) were reviewed i by the licensee. The licensee state'd thati the quality assurance practices at the Indian Point Station 2, as applicable to nonsafety-relatM AMSAC 'l equipment, comply, as a minimum, with the guidance of GL 85-06. 5. Maintenance Bypasses Information showing how maintenance at power is accomplished should be provided. In addition, maintenance bypass indications should be incorporated into the continuous indication of bypass status in the contro1 room. The licensee provided information showing how saintenance will be' j accomplished at power. The staff was informed that swintenance at power will be performed by inhibiting the operation of AMSAC's output relays, which will blocx the output signal and, thus, prevent it from reaching the final actuation devices. The continuous indication of hypass status 1 0 5 1 e 4 e 7 '^ N '" W

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6-will be provided in the main control room through the use of status lights ~ and annunciation. It is the staff's understanding that the licensee will conduct a himan-factors review of the subject indication consistent with the plant's control room design process. 6. Operatino Bypasses The operating bypasses should be indicated continuously in the control room. The independence of the C-20 penrissive signal should be eddressed. As discussed earlier, the licensee has stated that there are no operating bypasses in the proposed Indian Point 2 /MSAC design, with the exception of maintenance and testing. The AMSAC system will be armed at all reactor power levels. With the RPS steam generator icw-level setpoint set higher than that of the AMSAC, a steam generator low-level transient will generaite a reactor trip signal before AMSAC can generate its actuation signal. Ar AMSAC~ generated trip signal at all power level will appear no different than the already existing reactor trip signal initiation and, thus, is consistent with the existing design basis' of the plant'. 7. Means for Svpasses The means for bypassing shall be accomplished by using a permanently installed, human-factored, bypass switch or similar device. Disallowed methods for bypassing mentioned in the guidance should not be used. The licensee's response stated that bypassing AMSAC during testing and maintenance wi,11 be perfonned through the use of a permanently installed control switch. The disallowed methods for bypassing such as lifting leads, pulling fuses, blocking relays, or tripping breakers will not be used. It is the staff's understanding that the licensee will conduct a human-factors review of the bypass controls consistent with the plant's detailed control roos design process. 4 9 e n _. ~.,.. ;.i. _.._.. _ m.

y. v y. 8. Manue1' initiation. i Manual initiation capability of the AMSAC mitigation function must-be j provided. ] The licensee discussed how manual turbine tMp and auxiliary feedwater i ~ actuation are accomplished by the operator. In summary, the operator can use existing manual controls located in the control room to perform a l i turbine tMp and to start au::111ary feedwater flow should it be necessary. i Thus, no additional manual initiation capability will be required as a' i result of installing the AMSAC equipment. l i ~ i 9. Electrical Independence From Existino Reactor Protection System i l ITAi rara is required from the sensor output to the final actuation j device, at which point nonsafety-related circuits eust be isolated from i safety-related circuits by qualified Class 1E isolators. l The licensee discussed how" electMeal independence isto be achieved. The proposed design requires isolation between the non-Class 1E AMSAC and the Class IE circuits associated with the steam generator (SG) f level input signals and the AMSAC output signals to the AFW pumps. j t The licenses has infonned the staff that the required isolation will be achieved using electrical isolation devices that have been qualified and l tasted to Class IE electMeal equipment requirements.. In addition,. the l ~ isolators will be qualification tested as described in Appendix A to the staff's safety, evaluation (Ref. 1). The data and information required by Appendix.A is to be compiled by the. licensee and should be available for. s review duM ng a subsequent site. audit in accordance with Temporary Instruction 2500/20 (Ref. 7). The implementation of the AMSAC design - I will be consistent with the electrical. separation criteria established for the plant during original plant licensing. q e j j ~-- og $6g 9 9 e +et.# Ma.,e * $ g h.>" 4 W * **' M f#* i AP 9 9 NE##f N M O 8

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10. Physical Separation From Existing Reactor Protection System The impiamentation of the ATVS mitigating system must be such that the separation criteria applied to the existing RPS are not violated.

The licensee stated that the AMSAC circuitry will be physically separated from the RPS circuitry. In addition, the ATWS equipment cabinets will be located so that there will be no interaction with the protaction system cabinets. The licensee also stated that the RPS design will continue (subsequent to the implementation of AMSAC) to meet the electrical separation criteria originally established for the Indian Point 2 Station during initial plant licensing, as discussed in Section 7.2.4 and Section 8.2.2 of the updated FSAR. 11. Environmental Qualification ~ The plant-specific submittal should address the environmental qualification of ATVS equipment for anticipated operational occurrences. The licensee stated that MSAC mitigation equipment will be located in areas of the plant that are considered to be a mild environment. The licensee also stated that the equipment will be designed to operate in the environment for anticipated operational occurrences that might occur associated with the respective ecuipment locations.

12. Testability at Power Measures to test the ATWS aitigating systas before installation, as well as periodically, are to be established. Testing e.ay be perfonned with the system in the bypass mode. Testing from the input sensor through the final actuation device should be perfonned with the plant shut down.

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' The licensee stated that a complate end-to-end test of the AMSAC system. including the AMSAC outputs through the final actuation devices..will be perfomed during each refueling outage. With the plant at power, ti.e systas can be tested with the AMSAC outputs bypassed. This bypass w!11 be accomplished through the use of a permanently installed bypass switch which negates-the need to lift leads, pull fuses, trip breakers, or physically block relays. The testing of the MSAC logic will be performed with one of the two AMSAC logic circuits bypassed. The other logic circuit will remain operable to perfom its sitigating function. These tests will verify analog, channel accuracy, setpoint (histable trip) accuracy, and coincidence logic operation including operation and accuracy of all timers. Tha at power testing will be performed on a quarterly basis. Plant procedures will be used when testing the AMSAC circuitry and the AMSAC outputs. These procedures will ensure that AMSAC is returned to service when testing is complete. j It is the staff's understanding that the licensee will conduct a human-factors review of the controls and indications used for tasting purposes ~ that is consistent with the plant's detailed control room design process.

13. Completion of Miticative Action

~ The licensee is required to verify that (1) the protective action, once initiated, goes to completion and (2) the subsecuent return to operation requires deliberate operator action. l The licensee responded that the AMSAC system design will be such that MSAC action will be consistent with the circuitry of the auxiliary feed-watar and turbine trip control systems. Once initiated, the design will l ensur1r that protective action goes to completion. Following completion of the sitigative action, deliberate operator action will then be required to return the actuated devices to normal operation. e 4 h 6 = . ~. -.... .... ~..

l l

14. Technical Soecifications j

The plaet-specific submittal should address technical specification ~ requirements.for AMSAC. The licenses responded stating that no technical specification action is proposed with resWct to the AMSAC and that normal adeinistrative controls are sufficient to ensure AMSAC operability, l t The equipment required by the ATWS Rule to reduce the risk associated with j an ATWS event must be designed to perform its functions in a reliable manner. I A method. acceptable to the staff for demonstrating that the equipment. satisfies l the reliability requirements of the ATWS Rule is to provide limiting conditions. for operation and surveillance requirements in the technical specifications. 1 In its Interim Commission Policy Statament of Technical Specification l Improvements for Nuclear Power Plants [52 Federal Resister 3788 February 6, ~ j 1987], the Commiission established a specific set of objective criteria for-l determining whic.h regulatory requirementi and operating restrictions should bs i included in technical specifications. The staff is presently reviewing ATWS requiements to criteria in this Policy Sta' ament to determine whether and.to t what extent technical specifications are appropriate. Accordingly, this aspect of the staff review remains open pending completion of, and subject to the results of, the staff's further review. The staff will provide guidance i regarding the technical specification requirements for AMSAC at a later date. 1 ~

4.0 CONCLUSION

I The staff concludes, based on the above discussion and pending resolution of the technical specification issue, that the AMSAC design proposed by' Consolidated Edison Company of New York, Inc. for the Indian Point Station,- ) Unit 2, is acceptable and is in compliance with the ATWS Rule,10 CFR 50.62. - 1 paragraph (c)(1). the staff's conclusion is further subject to the sucessfull' completion of cartain noted human ' factors engineering reviews and to the satisfactory completion of isolation device qualification testing;to which the licensee has committed. It is the staff's position that the AMSAC should ~ m g %F'." _EQ $? S h49 d'M OPCh mEh $ 45,3 $,h W fg M s,, Supe Nm W..Mh4 Dr94-OrN N* A q J,, k Ry 'h .A i yd _ ] _ Y b-8IW-'- 4-d

m-y 9 q ' not'be declared opera,1onci prt r to the s:ccessful qualification of the l 1 solation devices in accordance with Appendix A'to the staff's safety evaluation (Ref.1). Until staff review is completed regarding the use of technical specifications for ATWS requirements, the licensee should continue with the scheduled installation and implementation (planned operation) of the ATWS design utilizing administratively controlled procedures.

5.0 REFERENCES

1. Lattar, C E. Rossi (NRC) to L. D. Butterfield (WOG), " Acceptance for Referencing of Licensing Topical Report." July 7, 1986. 2. Latter, R. A. Newton (WOG) to J. Lyons (MRC), " Westinghouse Owners Group Addendum 1 to WCAP-10858-P-A and WCAP-11233-A: AMSAC Generic Design Package,' February 26, 1987. 3. Latter, R. A. Newton (WOG) to J. Lyons (NRC) " Westinghouse Owners Group Transmittal of Topical Report, WCAP-10858-P-A, Revision 1 AMSAC Generic Design Package," August 3,1987. 4. Latter, J. A. Basile (Coned) to U. S. NRC, " Response to NRC's SER Plant Specific AMSAC Design," January 16, 1987. 5. Latter, M. Selman (Coned) to U.S. NRC; " Response to NRC Questions on the AMSAC and,SAS/SPOS Submittals," November 2,1987. 6. Letter, S. 8. Bram (Coned) to U.S. NRC, "ATWS Mitigation System Actuation Circuitry (MSAC)," September 16, 1988. 7. Temporary InstrNetion 2500/20, " Inspection *. Dettermine Compliance with ATWS Rule 10 CTR 50.62,* Feburary 9, 1987. ~ 4 s

4 EnCLosunE 2-4 SYSTEMATIC A55ESSMENT OF LICENSEE PERFORMANCE j t = l \\ FACILITY NAME: Indian' Point Station, Unit 2 i $UPMARY OF REVIEW / INSPECTION ACTIVITIES 'the SICS has reviewed the ATW5 desiqn submitted by the Consolidated Edison Company of New York Inc..for insta' lation at the Indian Point Station, Unit 2 and has concluded that, pending the final resolution of the technical specification issue, the ATWS design Rule (10CFR50.62 Paragraph (c) (1)) proposed.is in compliance with the ATW5 requirements. The staff's conclusion is based on the successful completion of certain noted human factors engineering reviews and satisfactory completion of isolation device testing by the licensee. NARRATIVE DISCUSSION OF LICENSEE PERFORMANCE - FUNCTIONAL AREA Throughout the review process, it appeared ~ that the staff's review policies were adequately understood by the licensee. There was evidence of prior planning of priority issues and' that decisions' were usually made at the proper management level. There was an occasional repetition of' events required to resolve various issues. The approaches taken by the licensee to resolve the-issue were tacfmi~cally sound and thorough. The resolutions were timely. I ) Author: L. Tran i ) ~ ~ Date: 04/06/89 .h i 1 ....:......L.. ....n., . i a - -- - i .. <- " ~ - i ~.~~..~--+,~:-.--v

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Deciht Res. '50-200 1 and so-ass. 1 1 MEMDRANDL55 art 8erkow, Director I ect Directorate II-2 1 Division of Reactor Projects I/II j FROM: John W. Craig, Chief Plant Sy. stems Branch Division of Engineering and Systems Technology SUSJECT: SAFETT EVALUATION FOR PROPOSED TECHRICAL $PECIFICATIONS AND DESIGN MODIFICATIONS RELATED TO THE SERVICE WATER SYSTEM AT SURAY, UNITS 1 AND 2 (TAC N05. 72811 AND 72812) Plant Name: Surry Power Station, Units 1 and 2 Licensee: Virginia Electric Power Company Review Status: Corglete j In accordance with TAC Nos. 72811 and 72812, the Plant Systems Branch ($PLE) has reviewed Virginia Electric and Power Company's (the licensee) March 27, 1989 subsittal proposing Technical Specification changes related to the ~ service water (SW) system at Surry, Units 1 and 2. The proposed technical l specification changes are based on a reanalysis of the design basis for the e. i ttake canal water level-requirements and modifications to the intalie canal 1evel actuation system. The March 27, 198g submittal also addressed a number of design modifications related to preventing the intake canal inventory from. being inadvertently depleted due to a single failure and assuring. operability of the component cooling water (CCW) system heat exchangers. i -3PLF has reviewed the design modifications and proposed technical specification j changes and concludes that they are acceptable. The bases for this conclusion are.provided-in the enclosed (Enclosure 1) evaluation. i Our SALP input is provided in Enclosure 2. We consider our efforts on TAC i -l Nos. 72811 and 72812 to be complete. Oh6nsi stened W John W. Craig, Chief Plant Systems Branch Division of Engineering and Systems Technology l

Enclosures:

i As stated cc w/ enclosures:

8. Buckley

.l CONTACT: W. LeFave X20862 I j j i ~. ) ....-.......m,..

~ l n ? SAFET[hALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATIONl PLANT SYSTEMS BRANCH SAFETY EYALUATION FOR PROPOSED TECHNICAL SPECIFICATIONS AND DESIGN JDIFICATIONS RELATED TO THE SERVICE WATER SYSTEM-SURAY POWER STATION, UNITS 1 AND 2 DOCKET N05. 50-280 AND 50-281 t ~ t

1.0 INTRODUCTION

The service water (SW) system at Surry, Units 1 and 2, is unique when compared to.the SW s Rather than emergency service j water (25W)ystems at most nuclear power plants. system pumps forcing flow throu! gravity feed from a high level intake canal (HLIC)gers, flow is induced via system and other safety-related system heat exchan which~fs' required to have a-l certain level of water to provide adequate head in order to meet minimum flow requireaants. However, the inventory in the intake canal is not sufficient to j meet long ters cooling requirements, and, therefore, three diesel-driven ESW pumps (actually makeup pumps) are provided to replenish-the canal inventory'14 l circulating water system (CWS)peration, canal inventory is meintained by t an emergency. During normal o y flow through the main condensers is also gravity flow from the intake canal.. l The ESW and C3W pumps take suction from the James River. As a resukt of a Safety System Functional Inspection ($3FI)-during the weeks of September 12 and September 26, 1988, the NRC staff identified several concerns regarding the operability of the SW system that were directly related to the unique Surry SW system design. Following the identification of these l concerns, the licensee reevaluated the design basis for the SW system particularly with respect to HCIL inventory control and management following l apostulateddesignbasisaccident(DBA). As a result of this reevaluation, l the licensee, by letter dated March 27, 1989, identified design. modifications 1 and proposed technical specification changes necessary to correct deficiencies

• l The following evaluation found during the SSFI and followup reevaluation.

addresses the design modifications and proposed technical specification changes identified in the licensee's March 27, 1989 submittal. I l 2.0 EVALUATION-t The licenses has proposed three sodifications to the plant Technical I Specifications. The'se changes will: 1. Raise the minimum required HLIC level from eighteen feet to twenty-three i

feet, 2.

Increase the requirement from two to three ESU pumps to be operable with provisions for limited duration maintenance outages, and j e 3. Provide operability and surveillance requirements for the new safety-related HLIC level actuation system. j } . >,. A.. .m.,_

, -t-aW TheproposedTectinicalSpecification(TS)changesareaccompaniedbydesign modifications which include new vacuum breakers to prevent reverse siphoning 1 at the new, higher canal level (23 feet), addition of a safety-related canal Tow level actuation system, repowering the circulating water system valves to assure isolation in the event of an emergency diesel generator failure, installation of manual vacuum breaker valves on the discharge tunnel to break prime and hence conserve inventory, and installation of CCW heat exchanger SW flow instrumentation to allow throttling during a D8A. 1. The licensee's reevaluation identified six basic deficiencies which precipitated the-proposed T3 chances, design modifications and associated 1 changes to station procedures as follows. The first deficiency was related to MLIC level drawdown durjng a DBA due to a single failure. The DBA is assumed to be a loss of coolant accident (LOCA) and a loss of off-site power (LOOP). Possible single failure problems i included an ESW pump failure, emergency diesel generator failure, and a failure to close of any one of the isolation valves to heat exchangers not essential.. l for post.CSA heat removal. To resolve this. issue, emergency operating procedures (EOPs) were revised for operation of ESW pumps and SW heat exchangers, and to require manual confirmation / action for closing specific SW isolation valves. Design modifications were also made to repower the CWS isolation valves, as required, to at least one CMS inlet or outlet valve for each 4 ' condenser waterbox in order to ensure isolation following any single failure. In addition, to allow. time for operator action, the TS have 3een revised (proposed TS change) to raise the minimum intake canal level from 18 feet to j L 23 feet. 4 The second deficiency noted was' reliance on nonsafety-related signals for the main condenser and service water isolation valves. To resolve this concern, a j safety-related canal low level actuation and indication system was installed ~ to provide safety-related signals to the system isolation valves and to provide safety-related canal level instrumentation..T3 changes were also i t proposed to add operability and surveillance requirements for the new safety-j related instrumentation. j A third deficiency identified was the potential for inadequate ESW supply heat removal (g a 08A in one unit with cooldown of the other unit or residualRi (makeup) durin i time interval following shutdown based on decay heat production). To resolve i this problem. T5 changes were proposed to require three E3W pumps to be operable with two units at power and with'one unit at power when heat loads from the spent fuel pool and a shutdown unit are equal to or greater than than 25 million BTU /hr. Present T3 only require the operability of two ESW pumps. t A fourth deficiency identified was the potential for the CWS pump discharge. l lines to siphon back to the James. River on loss of the CWS pumps. The present design contains a passive vacuum breaker designed to prevent siphoning below a canal level of 19 feet which is consistent with the present T3 of 18. feet. l ~ s However, in order to be consistent with the proposed 75 of 23 feet, new passive vacuum breakers have been installed to assure a reverse siphon will not be present for canal levels less than or equal to 23 feet. The new vacuum breaker is located dust above the 23 foot level. 1 i a' ..r., .. <,.-~.3 .- c. r---. g a.ns,,. ..es. ,z.s ~r sv.auru-.s.nca men.nen rm r mm~ p

[ 3.- . The fifth deficiency identified by the licensee was the capability of the service water sjitas to meet the requirements of Appendix R to 10. CFR Part 50 reparding safeeshiitdown following a-fire. The current Appendix A analysis j al ons for fetteser of the CWS isolatfon valves to close followed by operator action. However*, a method for breaking condenser vacuum under full flow conditions is not addressed in the current design. The resolution of this defic ~iency involves the installation of vacuum breakers on the condenser water i boxes.- The vacuum breakers will have pneumatic remote and local capability. The remote control stations are roovired in the event of a fire in the turbine I building, and are located to a fire area that is appropriately separated from the turbine building by a fire well in accordance with Appendix A criteria. Thestathandfinalanfordeficienhcondition. identified by the licensee involves CCW heat exchanger operability in a degrade The SW system side of the heat exchangers is subject to significant microfouling and macrofoulin'g phenomena. l The possibility of reduced perforniance of the heat exchangers must be accounted ~ for in the design basis by application of appropriate fouling factors to both the SW and CCW modes of the heat exchangers. The resolution of this concern involves a combination of design modifications, procedural changes and periodic testing as follows: I i 1. The installation of differential pressure instrumentation on the SW side i of the heat exchangers. 2. The installation of discharge tunnel vacuum breakers to conserve HLIC 2 inventor These are safety-related valves (y for use in the CCW heat exchangers.aanually operated) which may have to ' after a DBA if the discharge tunnel self-prising action'is not already 1 broken. 3. The implementation of a periodic test to asasure combined CWS and SWS { isolation valve leakage and a periodic test to measure CCW heat exchanger operability. The leakage test is required to demonstrate that valve leakage (HCIL inventory loss) is less than that assused in canal inventcry analysis following a DBA. The frequency of CCW heat exenanger operability testing will be fairly high initially, with subsequent reduction if I substantiated until a appropriate continuous frequency for the Surry - i plant is established. A number of other potential design and operating deficiencies were identifid by the licensee, which were related to the ESW pumps and punohouse. Appropriate action has been taken by the licesnee to correct these potential deficiencies, These actions include design modifications, maintenance and testing procedural c changes and additional instrumentation. These changes and modifications are conservative in nature and should make the ESW pumps more reliable. The licensee has proposed two TS changes to TS 3.14 " Circulating and Service i Water Systems." The first is to increase the minimum required NCIL to support. l s:rvice water neat exchanger flow by allowing for automatic and operator l action times to isolate nonessential SW system flowpaths. The second proposed-change to 13 3.IA requires three operable. ESW pumps for HCIL askeup for long tent accident mitigation. Both of these proposed ~ changes are more" conservative than the original TS and are required. to meet the design basis-of the SWS as reanalyzed by the licensee. The revised design basis includes the most 1 titing DBA coupled with any single active failure. i . l l . _ _.... _. ~... i

~ l j 'AthirdT3changirevisesbothT33.7and4.1relatedtotheengineeredsafety. features (E3F) instrumentation setpoints, action requirements and testing frequencies. These T3 changes are required to be consistent with the i design modifications which included.a safety-related intake canal level- ) instrumentation and actuation system. The setpoints are consistent with the-revised design basis and proposed changes to TS 3.14. The action statements. i and testing frequencies are consistent with those for other ESF instrumentation in the Surry plant Technical Specifications. l The licensee has also revised the Bases Section of the plant T5 to be consistent with the progosed T3 changes and design modifications.. The design modifications described above are considered by the staff to be I safety improvements, and provide added assurance that adequate canal inventory will be available and maintained to cope with the worst case DBA coupled with: any single active failure. These modifications improve the SW system post-accident capability for both the short and long term. l

3.0 CONCLUSION

T l As described above, the staff has reviewed and evaluated the licensee's designr i modifications and associated proposed Techn 421 Specification changes relatodi to the service water system and high level intake canal inventory management. Based on its review, the staff concludes that the service water system and ~ intake canal design modifications will ensure that the revised design basis j is satisfied and meet the following staff criteria-P 'I. General Design Criterion (GDC) 2. " Design Bases for Protection Against Natural Phenomena," as it relates to protection of the cooling water system against earthquakes and tornt Joes. ' 2. GDC 44, " Cooling Water," as it relates to providing adequate cooling requirements under both normal and accident conditions, suitable j redundancy, and the capability to isolate nonessential systems, components or piping if required; and P.egulatory Guide 1.27, " Ultimate i Heat Sinks for Nuclear Power Plants," as it relates to prevision for . lj l a reliable long term source of cooling. water to mitigate an accident l in one unit and ensure a safe cold shutdown of the other unit. ( 3. SDC 45, ' Inspection of Cooling Water Systems," as it relates to provisions to permit inservice inspection of safety-related cooling } water system components and equipment. 3 l 4 EDC 46, " Testing of Cooling Water Systems," as it relates to design l provisions to permit operational functional testing ~of safety-related L cooling water system ca yonents and equipment. j The staff further concludes that the proposed Technical Specification changes ] are more (onservative than the current, specifications and are consistent i l- .with the design modifications and revised design basis analyses.sThe staff, therefore, concludes that the design modifications and proposed Technical } i l Specification changes are acceptable. i l l 1: .j ?,~-n....... ..m-. -., < w n -,--. .-._.-...a.

Ecc1::stre 2 k f SPLS SALP INPUT Plant Name: Surry Power Station, Units 1 and 2 SER

Subject:

Safety Evaluation for Proposed Technical Specifications and Design Modifications Related to the Service Water System TAC Nos.: 72811 and 72812 Summary of Review / Inspection' Activities SPLS reviewed the licensee's March 27, 1989 submittal which included technical specification changes ano design modifications to the service water system and intake canal. These changes / modifications were precipitated by staff. concerns related to the service water system which were identified during an SSFI. Narrative Discussion of Licensee Performance - Functional Area i As a result of t?,w staff's SSFI, the licensee performed a reanalysis fo the design basis for the service water system. As a result of.this reanalysis, i . tha licensee identified a' number of deficiencies in addition to the concerns = identified by the staff's SSFI. The reanalysis, as described in the licensee's submittal, was very thorough, and resulted in a number of technical specification changes and design modifications. The licensee's submittal was very clear and detailed and reevired no further inforestion' for the staff to complete its review. The information provided was very well organized and showed an excellent understanding of the system operation and of the concorris i identified by the staff during the SSFI.. The licensee's response resolved the staff concern' and was consistant with applicable requirements. s q Author: W. LaFave I i Date: April 24, 1989 I l e a a d.' ) t J 1 i I ~ -*Sm* + w.e e 4#4> .a.-e .. F

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EXAMPLt 3 q [* 't MODEL 5AFETY EVALUATION REPONT Underscored blank spaces are to be filled i'n with the applicable informa - tion. The-information identified in brackets should be used as applicable j on a plant-specific basis. i i SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR RESULATION RELATED TO AMENDMENT NO. TO FACILITY OPERATINE LICDtSE. NFP. AND AMENCHENT NO. T T FACILITY OPERATING LICENSE NFP- ~ ~ [UTILITYNAME]50-DOCKET N05. 50-AND [ PLANT NAME], WIT 5'l AN T2 / INTacoucT1oM By letter dated _ 1989, [ utility name (the licensee) proposed changes totheTechnicalspec1TTe,ations(TS)for[ plan]tname]. The proposed change re-1 moves the provision of Specification [4.0.2] that ifmits the combined time in-terval for three consecutive surveillances to less than 3.25 times the speci-t fied interval. Guidance on this proposed change to T3 was provided to all. power-reactor licer.aees and applicants by Generic Letter 89 _, dated _,1989. EVALUA LON 5pscification 4.0.2 includes the provision that allows a surveillance interval b to be extended by 25 percent of the specified time interval. This extension i 'provides flexibility for scheduling tpe performance of surveillances and to i permit consideration of plant operating conditions that may not be suitahle for conducting a surveillance at the specified time interval. Such operating con-citions include transient plant operation er oneotng surveillance or.mainte-nance activities. Specification 4.0.2 further limits the allowance for extend-j ing surveillance intervals by requiring that the combined time interval for any three consecutive surveillances not exceed 3.25 times the specified time inter- ,i val. The purpose of thi extended repeatedly as as provision is to assure that surveillances are not i v> operational convenience to provide an overall 1 increase in the survAillence interval. Exp;riencehasshownthatthe18-monthsurveillanceinterval,withtheprovi-sica to extend it by 25 percent, is usually sufficient to accommodate normal variations in the length of a fuel cycle. However, the NRC staff has routinely granted reouests for one-time exceptions to the 3.25 limit on extending refuel-ing surveillances because the risk to safety is low in contrast to the altern-ative of a forced shutdown to perform these surveillances. Therefore, the 3.25 i licitation on extending surveillances has not been a practical limit on the use-of the 25-percent allowance for extending surveillances that are perforined on a i refueling ou*. age basis. +! 't Extcading surveillance. intervals during plant operation can also result in a { benefit to safety when a scheduled surveillance is due at a time that is not i suitable for conducting the surveillance. This may occur when transient plant. operating conditions exist or when safety systems are out of service for main-tenance or other surveillance activities. In such cases, the benefit to safety of extending a surveillance interval would exceed any safety benefit derived by j ^ m 'A*^~^^ - - =*'t*~ ,y,,,e.-

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a7sv limitist thiuse of the 25-percent allowance to extend. a surveillance. ~ t Further1more, th:re is the administrative burden associated with tracking the - i use of~ the 25-percent allowance to ensure ccupliance with the 3.25 limit. l In view of tirese findings, the staff concluded that Specification 4.0.2 should. be changed to remove the 3.25 11mit for all surveillances because its removal. i will have an overall positive effect on safety. The guidance provided in Generic Letter 89-included the following change to this specification and 1 removes the 3.251 Tait on three consecutive surveillances with the following statement. j ~ i '4.0.2 Eack Surveillance Requirement shall be performed withhi the I specified surveillance interval with a maximum allowable extension not to exceed 25 percent of the specified surveillance interval." In addition, the Bases of this specificat' a were updated to reflect this change l and noted that it is not the intent of the allowance for extending surveillance l intervals that it be used repeatedly merely as an operational convenience to t extend surveillance intervals beyond that specified. l ~ ',The licenses has proposed changes to Specification 4.0.2 that are consistent with the guidance provided in Generic Letter 89-basis of its review of this matter, the staff fi H s, as noted above. On the that the above change (s] to the TS for (plant name) Unit (s) _ is(are] acceptable. ENVIR0fe' ENTAL CCH5IDERATION t These amendments involve changes to the use of the facility components located withirr the restricted area as defined in 10 CFR Part 20. The Staff has deter-mined that the amendments involve no significant increase in the amounts and no significant changes in the types of any effluents that may be released offsite { and that there is no significant increase in individual or cumulative occupa t tional exposure. The staff has determined that the amendments involve no significant-hazards consideration, and there hasebeen no public connent on such j finding. Accordirgly,-the amendments meet the eli categorical exclusioryseT for*.h in 10 CFR 51.22(c)gibility criteria for (9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental. assessment need be prepared in econection with the issuance of these amendments. i CCHCLUSICH l i The Caecission's determinations that the amendments involve no significant-hazards consideration, which were published in the Federal Register (52 FR 7)public ccanirits were recafved, and the State ofThe Commis on ,1989. i have any corzents. did not On the b& sis of the considerations discussed above, the staff concludes that (1) there t reasonable assurance that the health and safet of the public will be conducted in compliance with the Corzission's reg issuance of t'hese amendments will not be inimical to the cosmon defe r security or to the health and safety of the public. 1 k i i i ~ .-,-..,%-v,.#,,,,J..-....~-e..c.~...-.f,;.- A+-...-.,#,, ....n~-~w. .e.

3.. 4 .5 Prfacipal Contributors: Thomas G. Dun 3fng. OT38/D0EA N MW Oated: 1989 e O e 0 e f 4 4 9 9 e 8 9 e O 4 4 e O e 4 4 e e e O a 's

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u 4 APPENDIX I PROCEDURES AND RESPONSIBILITIES FOR LICEllSE AMENDMENTS, PROPOSED NRR OFFICE LETTER NO. 804 b e 9 e 4 t f I i e i 1 w.

F NUCLEAR REEULATORY COMMISSIOft a usensestam, a, c.aums (a,.. a MEMORANDtM FORY All NRR Employees Ulh FRtN: Thomas E. Murley, Director II O-Office of Nucisar Reactor Regulation

SUBJECT:

NRR OFyrICE LETTER NO. 804 - PROCEDURES Ale RESPONSIBILITIES POR LICENSE AMENtNENT REVIEWS I PURPOSE This office letter establishes a centralized instruction to proc'ess license amendment applications within NRR. It provides a screening process to deter-mine technical completeness of the application as well as a procedure to ' detemine lead review responsibility within NRR. While this office letter is-primarily directed at amaneont application reviews, the principals involved are to be applied when detemining lead NRR review responsibility for other i technical issues received from the licensees. This office letter supersedes all previously issued memoranda on this subject. BACXEEILNG l On September 4,1987. Frank J. Miraglia, Associate Director for Projects, and Richard W. Starostocki. Associate Director for: Inspection 4.nd Technical Assessment. issued a memorandus, " Project Manager Review Responsibility." The memoranous established a femal procedure by which project managers (PMs) would b3 authorized and expected to conduct selected amendment application reviews. By authorizing the PMs to conduct some reviews, typically for the less technically complex issues, the technical staff would have more time to devote to the more i safety-significant issues. Overall, the process has proven to be a more i efficient use of staff resources. Several amplifying samoranda were issued to provide guidance in selected areas. By memorandum dated August 11, 1988, Steven A. Yarga, Director, Division of Reactor Projects - Regions I and II, issued the results of an audit of the i i program to Frank J. Miraglia, Associate Director for Projects. The audit i concluded that the program should continue with several recommended changes. i This office letter condenses all of the previous mesoranouns into one central-ized instruction and feslaments appropriate changes to better focus previous guidance. It also provides new guidance in selected areas,-particularly in reference to Category I ameneent applications. - RESPONSIBILITIES AND AUTHORITIES e The Associate Director fr-Prp.iects and the Associate Director 'for Inspection and Technical Assessment are responsible for ensuring that their staffs adhere to the procedures delineated in the enclosure to this office. letter. However, project directors and branch chiefs are responsible for overseeing the MRR review process and ensuring that it is effective and afficient. CCNTACT: Ni N 1' ,.~,,,_w .. - - -. ~. - - - - - - ~. - ~ = ~ ~ ~ ' - ~ ~ ~ ~ ~ ~ ~ ' " ~ ~ ' " " " " ' " ~ ' ~

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~ - All NRR Employees 2-BASIC REOUTRD8ENTS The assigned PM for each plant is responsible for implementing the enclosed procedure for each' amendment application received. For technical-reviews not involving a licensa. amendment, an initial consultation should still be con-ducted with the associated branch chiefs to determine lead review responsi- ~ bility. Branch chiefs or their section chiefs are responsible for educating PNs.on specific review guidance to ensure agency-wide consistency in approach. i EFFECTIVE DATE l This office letter is effective inmediately. Thomas E. Murley, Director Office of Nuclear Reactor Regulation

Enclosure:

Procedure for Processing License Amendment Applications i ec: V. Ste1To, EDO M. Taylor. DEDO D. Crutchfield. ADSP (70) J. Amenta. IRN W. Russell, R-I S. Ebneter. R-II A. Davis, R-III R. Martin, R-IV J. Martin, R-V SECT J. Bartlett, OGC (83) NRC POR i f i e j 8 86 *** *eA*

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'4 PROCEDURE FOR PROCESSING LICENSE AMENOMENT' APPLICATIONS- ~ + NRR 0FFICE LETTER No. 804 l Plannine the Technical Review ~ Most Itcensing amendment applications are initially processed by the-NRR. ] project manager (PM) assigned to the specific plant. One exception to this generalization is amendment applications related to safeguards; these are-discussed separately in NRR Office Letter No. 801, " Procedures and Responsi-bilities for Safeguards Reviews *.* If an amen dent application is received that does not involve safeguards issues, the PM must perform several functions including: l t (1) Obtaining a technical assignment control (TAC) number to assist in 4 tracking resources expended to conduct the review. i (2) Initially screening the application for technical completeness and classifying the application as Category I, Category II, or Category III. l (The categories are discussed below.). (3) Evaluating the application to deterwine if significant hazards considera-tions are involved. [ Barring conflicting assignments, the three actions listed above should be completed within about 20 working days after the PM has received the amend-l ment application. l .t TAC Assionment i A technical assignment control (TAC) nud er is obtained from the NRC Regulatory Information Tracking System (RITS) using procedures contained in NRC Office Letter No. 27. This office letter is currently. under revision due to recent changes in the RITS, structure and will be published under the'300 series of the - - 'f new NRR Office Letter numbering system. Assistance in obtaining a TAC number l can be obtained frem the Planning, Piogram, and Management Support Branch (PMSB). l l t f ENCL 05URE

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y ~ Procedum for Processing Licats3 Ame:dnent App'ications Initial Screenino and Cateoorization Guidance for screening amendment applications is contained in Attachment 1. Amendments that are technically inadequate are classified as Category I. The PM may o'r any not involve the technical branches in this screening process, depending on the specific amendment application. Based on several factors, the ameneont is placed into one of three categories as follows: Definition for Category i The overall review indicates that the amendnent application is inade-quately justified. The PM will prepare a letter to the licensee docu-menting the reasons why the package is inadequate and stating the corrective action necessary before resubmittal. The rejection letter is to describe general areas that are either omitted or inadeouately addressed in the licensee's submittal. This is not a re,iection of the ' substance of the licensee's amendment application, no.r is it a request for additional information concerning some small technical aspect of the application, but it is a rejection of the adequacy of the amendment appli-cation to support the request for an amendment. If substantial questions i are raised which the NRC staff believes must be answered on the docket l-before an agency finding can be made, the amendment roovest is to be classified as Category I and the licensee informed, by letter, what must be corrected before resubmittal. i For multiplant activities (MPAs) or plant-specific itans that are an outgrowth of NRC initiated actions, a request for a proposed resubmittal l date should be included in the letter sent to the licensee. When-this l occurs, the TAC manber should be kept open. If the licensee appears uncocoerative, the issue should be raised to senior NRC management for consideration of a possible order to resolve our concerns. l l 2 ....-,-.e.o. 4 .-..,..-......-..-.~.=**.w=.e +..*-e%'*. + L

Procedure for Processing . License Asemhent Applications e For' plant-specific requests which are not an outgrowth of an MPA or other NRC initiated action, the review is to be closed in accordance with the procedures of Attachment 2. Basically, the licensee may withdraw the-Muest, either verbally or in writing, or will be given a designated time to correct the deficiencies (typically 60 days). If the ifcensee does not correct the deficiencies within the specified time, the amendment will be denied. A licensee may choose to submit a new applica-tion at any point in the future once the discrepancies are corrected. A Category I classification is a tool by which the PM can improve the lice ~nsee's applications. If a licensee repeatedly has amendment applica-tions classified as Category I, such performance should be reflected in the SALP appraisal. ~ Definition for Cateoorv II Initial consultation with;the technical branch (es) indicates that the

• licensee's anemhant application has adequate technical justification to conclude that no detailed specialist review is necessary. The PM will be assigned lead review responsibility. The PM will write the safety evalua-

.f tion and prepare the final amendment' package simultaneously. Normally, these amendment applications easily sat,isfy the requirements for "no ,l significant ha:ards' considerations

• criteria contained in the regulations 10 CFR 50.91 and 10 CFR 50.92 (discussed below).

~ j When the PM is assigned the review, the involved technical' branch chief (s)' i must specifically state if they are to be on final concurrence for the amendment application. It is anticipated that proper initial coordination will reduce the need for subsecuent technical branch concurrence of PM i reviews. However, the appropriate technical branch chief (s) should be on ) internal distribution for all license amendment applications that are t issued in their area of expertise. d 3 e .**P'*- sP em 9p1 -* g f pt*.r* 4 < ar.e+r etee *

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Procedure'for. Processing License Amendment App'ications If the PM conducts the review and the technical branch chief.does not specifically request to be put on concurrence, the appropriate project i director has the option, after reviewing tho' final safety evaluation-(SE), of requesting technical branch concurrence. When the PM conducts the review and the technical branch is on final f concurrence, the branch chief should. conduct his/her concurrence review expeditiously. If the branch chief believes the PM's review lacks an important element, he/she should give the review back to the PM with instruction for corrections. l l Note: For this procedure, the resources available in the regicas are not considered part of the technical branches. Therefore, if the only other i input to an SE, besides from the PM, comes from a region, that particular review is still considered, a Category II review. i Definition for Catecory III - l i The amendment requires a detailed specialist review.. The PM will route. j a work request to the technical brar.ches with a negotiated schedule and { priority. All contact with the licensee will be through the PM. Ther SE will be formally transferred by the reviewer to the PM via a memorandum I signed b'y the branch chief or other appropriate individuals as.' delegated by the branch chief. Additionally the SE should be transmitted via 5520 (or other electronic asil system in use by the MRC) from the technical f branch to the secretary in the appropriate prefect directorate for use in } preparing the final amendment package. The PN will prepare and issue the formal amendment or denial as appropriate. l Concerning the technical review of licensee submittals, the PM must, f,n, n 3 ,a,,],], cases, consult initially with the appropriata technical branch (es) i 4t either the branch chief lev'el or section chief level for all amendment applications that will be either Category II or Category III. This required i 4 i 4 i l ... _. _............... ~... _. _. s __:........ _ _..i ....__...~..u...-u.cr...-

~ e .Prgedure for Processing. .,1 cense Amendment App'ications consultation has several purposes. First, it infoms the technical branches of licensing activities in their area of expertise. Second, it allows for a dialogue between the PM and technical management to detamine who will conduct the review and its overall priority compared to other assignments. If the technical branches are to conduct the review, the PM will prepare and route a work reouest fom for signature. If the PM is assigned the review effort, this consultation period serves to educate or update the PM on current review guidelines and policy in the given subject area to ensure agency consistency in approach. The ultimate decision as to the categorization of a review effort will be made by Projects with the consultation of the technical branches. Recognizing that the technical competence of the NRC rests with the technical branches, strong emphasis mst be placed on the expertise and desires of the review branches. The sa.iority of the categori:ation decisions should be the result of a mutual agreement between the PM and Branch Chief or Section Chief. If a mutual decision cannot be reached, the PM is to raise the issue to his/her Project Director (PD), who will discuss the review effort with the Branch Chief. The PD serves as the arbitrator. If the review branch insists on doing the revic'.: in a reasonable schedule with no slippages, the review shculd be done by the branch. If the review branch cannot agree to a reasonable schedule and the PK has the technical eJeartise to do the review, the effort should be given to Projects. In such cases, the review branch will be put on concurrence for the final safety evaluation. Rarely should the need arise to appeal the P0's decision. But if the technical staff. desires to appeal the PD's decision, it will be done through the nomal Project management chain and involve the equivalent technical management organization. Public Wotice and Sienificant Mazards Considerations t The Public Notice requirements are contained in 10 CFR 50.91 and 50.92. The PM is responsible for preparing the appropriate notice under 10 CFR 50.91 for all amendment applications. The basic procedures for evaluating no significant G 5 +..

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Procedure for Processiny - License Amendzent App'ications 7 hazards consideration (NSHC) are contained in other instructions (specifically DLOP 228 which will be published as a separate office letter). For Category II' or Category III amendment applications, the PM will evaluate the NSHC in accordance with normal OLOP 228 procedures (or other office letter when issued). The NSHC evaluation is independent from the deterwihation of lead review responsibility. If an MSHC finding can be readily' determined on the basis of the licensee's application, the appropriate finding shall be made and pubished in the Federal Register biweekly notice or as an individual notice. Final Processino of the Amendment Application Once a safety evaluation is either received from the technical staff or prepared [ by the PM, the FM is responsible for assembling the package in the required format for issuance to the licensee. When format euestions arise, the PM should consult with their assigned licensing assistant (LA). The final amendment package will, at a minimum, contain the concurrence of the PM, the LA, the Project Director, and OGC..The PM should plan on OGC requiring a ~ minimum of 5 working days and possibly more for their concurrence. Additionally, the package may contain the concurrence, depending upon the circumstances, of the appropriate technical branch chief. In unusual circumstances, the Project Director may require additional concurrence from other members of the NRC staff. V If at any time in the process, a request for a hearing is received, the PM shall consult with OGC before processing the amendment packag2. The technical review should corrtinue unless the PM receives other guidance from OGC. If the NRC elects not to make an NSHC finding, an environmental assessment per 10 CFR 50.21 must be prepared by the PM and published in the Federal Resister prior to issuance of 'the amendnent. The PM may need assistance from the technical branches in preparing this assessment. e 6 i g egyM S, %S9 M-%glo ;u* 9 M* bM * * *

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Prxedure for Processing ~' l ~ License Amendment App 1ications l I If the NRC elects to make a proposed MSHC finding,10 CR 51.22 would allow the staff to declare that amen h nt application a categorical exclusion regarding. i an environmental assessment. This is the normal practice. However,10 CR 51.21 does state that the Casutission may, in special circumstances, prepare an j environmental assessment on an action covered by a categorical exclusion. I If a decision is reached to deny an amendment application based on its technical l merit,,the procedures of Attachment 2 shall be followed. l I t Attachments: Guidance for License Amenament Application j Pre-Approved Fonnat for Amendment Denials r and Withdrawals l 1 i I l I ne l c i l _n.. ~.. - --,, n. -;,-,....,.._g..w. .,..,.~.,,.,...., '. 7 ..4 .... - e :- - ..se-,---..,... i e

q i GUIDANCE FOR LICENSE AMENOMENT APPLICATIONS .i The following guidance highlights important key elements. that should normally be contained in a licerise amendment application. It is provided'to assist - Project Managers in their initial screening ~ process. The guidance is not an interpretation or substitute for conforming with the legal requirements of the j regulations, nor does the guidance itself constitute an absolute requirement. I Key elements in an amendment application include those listed below: l 1. Description of the Amen eent The amendment application should include a description of the content of the l ~ current license condition or technical specification being changed, including j specific identification of the condition or specification (e.g., paragraph 2.C(B), ' Emergency Preparedness," or Technical Specification 3/4.2.4, "DNSR MARGIN'). i i The amenoment application should include a description of the proposed change. including a discussion of how it relates to plant equipment and/or operating ] procedures and whether it is a temporary or permanent change. This should i include a discussion of the effect of the change on the purpose of the j technical specification or license condition involved. l The amendment application should include e discussion on why the change is i being requested (see additional guidance below for exigent or emergency requests). The amendment application should include an itemized list of the specific changes to the license / technical specifications and final camera-ready pages of l the license and/or technical sper'fications that reflect the ' requested change. - 1 I Attachment I '-o. ., ~... -. .-.. >- ~ ~ ~ ~ - - ~. * ~,. - - ~. - c~- '. ~~~ -* -n.-.-~.

' evidence for License- , R j Amendment Applicatioes j l \\ 2. Licensine Basis i The amendment application should specify the current licensing basis that is I . pertinent to the change (e.g., codes, standards, regulatory guides, or Standard ) Review Plan (SRP) sections). L The amendeont application should provide a safety analysis that supports the ~ change requested. It should include technical informationr in sufficient detail .I to enable the NRC. staff to make an independent assessment regarding the con-tinued validity of the conclusions in the final safety analysis report (FSAR) I or updated safety analysis report (USAR)-(updated per 10 CR 50.71(e)). It should contain a discussion of the analytical methods used, including the input parameters in support of the proposed changes. The discussion also should i state whether the methods are different from those previously used and whether l the methods have been previously reviewed and approved by the staff. An evaluation should also be provided for aministrative changes to demonstrate-l that the changes do not have an adverse effect on safety., e i If the licensee concludes that their amendment application contains potential significant hazards considerations, the amenennt application must contain l t sufficient information so that the Commission can prepare an environmental l assessment, an environmental impact statement, or justify a categorical exclusion per 10 CR 51.21. If the NRC staff elects not to make a proposed j NSMC finding per 10 CR 50.91, the licensee may have to provide additional-l environmental information so that the NRC staff can make an environmental finding per 10 CR 51.21.. I 3. Sfonificant Hazards Consideration Assessment In addressing the standards for determining whether the amendment involves a significant hazards consideration, the application must include the information below in sufficient detail for the staff to make a finding on this issue. l -2 [ t I i s*A g..e F

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u-1 Guidance for License Amendment Applications ~ \\ Standard 1. involve a Sionificant increase in the probability'er Consecuences of an Accident Previously Evaluated The amendment application should identify the applicable accidents that were previously evaluated (i.e., those that currently form the licensing j basis for the plant) and involve the areas of proposed change. The discussion should focus on how these accidents are affected by the proposed change and whether the change involves a significant increase in probability or consequence of those previously evaluated accidents. If the proposed change does not affect any previously evaluated accidents, the reasons for this conclusion should be stated. Standard 2 - Creste the Possibility of a New or DiMerent Kind of Accident from Any Accident previously Evaluated The amendment application should make clear whether a new or different type of accident is involved. Amendment applications involving changes in eeufpment, plant operations, and such' eight create'the possibility ef a different kind of accident. An accident for which an evaluation hat not been submitted on the docket and reviewed by the staff is considered new or different. There should be careful focus on this issue, especially if the discussion of the first standard above asserts that the change does not involve any previously evaluated accidents. Standard 3. Involve a $[enificant Reduction in a Marcin of Safety ~ The amendment application should indicate whether, based on the analyses of record and/or the uisting limits of the technical specifications, the margin of safety will be significantly reduced. This includes changes to safety limits, limiting safety systas setting (LSSS), limiting conditions for operation (1.C0), and acceptance critaria for and frequency of surveil-lance tasting. Such a consideration should be based on the margin of safety established or implicit in the FSAR or any other licensee coneitments, the safety evaluation report (SER) and its supplements, and the Bases of s 3 Attactment 1 y, ym.: q y m me n - v~~ p -p ~ ~ gn ..* * ~. > ;

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Amendeont Applications ~ - i record in the Technical Specifications. A significant reduction in margin ] can be involved even if the results of new' analyses are within acceptance -l criteria. l 4 Acclication Fee l t i Provide fee payment in accordance with 10 CR Part 170. '[ i 5. Additional Information for Exieent or Emergency License Amendment Recuests i If necessary, the NRC will process an amendment application on an expedited [ schedule. An amargency situation exists when failure to act in a timely way j would result in derating or shutdown of a nuclear power plant or'in preventing - f either resumption of operation or of increase in power output up to the plant's licensed power level (see 50 CR 50.91(a)(5)). Exigent circumstances. exist j when a licensee and the Commission must act ouickly and time does not permit j the commrission' to pubTish a' Federal Recister notice allowing 30 days for. public comments (see 10 CR 50.91(a)(6)). The Cameiss' ion expects licensees to apply for license amendments on a timely basis. Although the Cossnission recognizes that unusual situations may arise, i licensees are not to create an emergency in order to take advantage of.the _l emergency provisions. When a request is made for emergency or exigent action on a license amendiment application, other information should be supplied in [ addition to. that identified above. This additional information should be f l submitted in a timely manner and in sufficient detail for the ' staff to evaluate l l the request for exigent or emergency treatment. The Ifconses should follow the I i guidance provided below. For a request for emergency treatment, provide justification that timely' I action is reovired to prevent an unnecessary dorating or shutdown of the plant or to allow resumption of operation or an increase in power output up to the plant's licensed power level. l l i i -4 1

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-Asendmint Applications l For a request for exigent treatment, establish that quick action is desirable (1) to avoid the loss of a safety benefit or (2) to provide an increase in safety or reliability, or a significant environmental benefit, t For amargency amendments, the licensee must explain why 2e emergency situation occurred and why this situation could not hhve been avoided. i For exigent amendments, the licensee must explain the exigency and why t it cannot be avoided. e Establish that there is no other viable alternative available or that l the approach chosen is more desirable than alternatives available. l Describe interim concensatory measurea to be imposed, if appropriate. l If temporary relief is being requested, state the required duration, e.g., the scheduled date for returning inoperable components or systems to an operable condition or the scheduled. date for accomplishing required surveillances. t t t =f I i A e 5- - = :. .... =..~=, a. -...z. :. : az -. =.= =,. : :. :==::. .?h ,;.,=.=,=-

m\\ x UNITE 3 s7ATas NUCLEAR REGULATGRY COMMIS*lON j i !~ naammeron, s. c.assus March 27, 1989 1 MEMORANDUM FOR: All NRR/ADP Personnel FROM: Steven.A. Varga j Acting Associate Director for Projects Office of Nuclear Reactor' Regulation

SUBJECT:

LICDSE AM DOMENT INVENTORY REDUCTION - PRE-APPROVED FORMAT FOR AMENDMDIT DENIALS Als WITHDRAWALS Early work by the Management Guidance Team for reducing the licensing action I inventory has shown that staff denial and/or withdrawal of amendments by licensees will. frequently be required. In support of this effort, a number of standardized amendment withdrawal and denial packages have been preparea in - cooperation with OGC. 0GC has concurred on the policy discussed in this memorandum and on the standardized packages which are enclosed for the following cases: i Case 1: License' amendment withdrawn in writing by the licensee. Case 2: License amenement withdrawn orally by the licensee. Case 3: Licensee informed of needed modifications to submittal; 60 days or more has passed anc' submittal has not beeri received; NRC concludes - that docketed amendment request is unacceptable and denies the application. l Case 4:. ' Proposed license amendment denied on a technical basis. f Staff actions for processing Case 1 amendment applications are self-explanatory. For Case 2 situations, the staff's letter confirstng the licensee's oral request for withdrawal vill be sent to the licens~ee. The licensee will be given 10 days after receipt of the letter to notify the staff if they-do not intend to witharaw the application. If no response is received from the licensee within the specified time, a second letter will be sent to the licenses transmitting the Withdrawal Notice which will be published in the Federal Register, q For Case 3 to be applicable, the staff must have informed the licensee orally or in writing regarding what portions of the proposed amenht cause staff concerns. The staff must also have requested that the licensee sodify the docketed request to alleviate these concerns. If 60 days has elapsed since these staff actions were taken and the licensee still has not provided the, requested information (or if the staff gave the licensee a greater aseount of time to respond and that period has expired), a denial shou d, be' issued. t ? CONTACT: I R. Dudley, NRR 492-1355 .i i i . -. ~. -. -........... .. - +. ,..- -... ~... - ;

4 [ All NRA/ADP Pcesonnel ' March 27, 1989 Case 4 is an outright denfal and is applicable whenever the staff does not expect that any modification of the proposed request could result in staff approval of the licensee's application. Case 1, Case 2 and Case 3 packages do not require OGC concurrence before 1ssuance. Case 4 denial packages require prior OGC concurrence. However, OGC has pre-approved the st4ndardized language used in the enclosed packages. t These packages are available on the 5520 system under the document names shown in the Enclosure. 1 L. t rgat, c ssociate Director f r rejects Office of Nuclear Rea r Regulation 1

Enclosure:

As stated cc w/ enclosure: D. Crutchfield, ADSP B. D. Liaw ~ S. Black C. Grimes J. Wilson i 1 l I i e i l l I i 1 i l i f . ~......

_a ENCLO$URE i [ CASE 1] 1 Docket No. 50-5520 DOCUMENT NAME -l [ LICENSEE] i

==Dear

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SUBJECT:

UNIT NO. - WITHDRAWAL OF AN AMENDMENT REQUEST l UAG NO. ) By letter dated , you applied for an amendment to the operating License, No. The proposed change would have noctfieo tne f acility technical specifications pertaining to !ubsequently, by letter dated , you withdrew the amendment request. The Commission has filed the enclosed Notice of Withdrawal of Application for f Amendment to Facility Operating License with the Office of the Federal Register for publication. 1 $1ncarely, t , Project Manager Project Directorata Division of Reactor No7ects I Office of Nuclear Reactor Regulation -1

Enclosure:

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~ [ CASE 1] l 7590-01 ~ ~ UNITED' STATES NUCLEAR REGULATORY CCMISSION-l (LICENSEE) D0CKET W. 50-. l NOTICE OF WITHDRAWAL 0F APPLICATION FOR l AMENDMENT TO FACILITY OPERATING LICENSE The United States Nuclear Regulatory Commissioni(the Comunission) has granted the request of [UTILITYi-(thelicensee)towithdrawits [datel application for proposed amendment to Facility Operating License No. for the , Unit No. _, located in The proposed amendment would have revised the The Commission.has previously issued a Notics of Consideration of Issuance of Amendment published in the FEDERAL REGISTER on (date] L - i FR ). However, by letter dated the licensee withdrew the proposed change. ~ For further details with respect to this action, see the application i for amer.dment dated , and the licensee's letter dated which withdrew the application for license amenoment. The above documents are available for public inspection at the Commission's Public Document Room, 2120 L Street, N.W., Washington, D.C., and the [ LOCAL PUBLIC DOCUMENT A00M1. Dated at Rockville, Maryland this day of l FOR THE NUCLEAR REGULATORY ComISSION + , Project Manager Project Directorate Division of Reactor Projects 0ffice of Nuclear. Reactor Regulation ~ j I * *' ~ w -.r.m.. an nm -*-w --ev= :. ='- = s - ~ ~' -% ~ m 4 * - Y *

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y [ CASE 2] Docket No. 50-5520 DOCUMENT MAME: [ LICENSEE] i e Dear Mr. SUSJECT: UNIT - WITHDRAWAL OF AMENDMENT REQUEST No. ~ ~ (TAGNO. j By letter dated , you submitted Change Request No. to revise applicable specifications to 7 However, your staff subsequently informed the NRC curing a telephone conference that the amendment is no longer requested. Therefore,.your proposed change is considered to be withdrawn. If this. information is not correct, please notify the NRC of your intended actions within 10 days of receipt of this 1stter. We have prepared a proposed Notice of Withdrawal of Application for Amendment to Facility Operating License. Unless you notify us that we are incorrect within 10 days of receipt of this letter, we will file the notice with the Office of the Federal Register for publication. Sincerely", , Project Manager Project Directorate Division of Reactor F Ejects Office of Nuclear Reactor ReguiaTion ec: See next page DISTRIBUTION: I [$AMPLEAMENCMENT5] Office: LA/PD PM/PD P0/PO Surname: Date: / /89 / /89 / /89 i i ~ a..:. :;...,,, w..r r H.n - n em o..+., ~, w s.., .$. ::m,:d?%"5 .n...,,,,,..cu., -.. -. u ~. c, -. n.,.

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~ 7590 01 ~ . UNITED STATES NUCLEAR REGULATORY COMMISSION CLICENSEE1 -i DOCKET No. NOTICE OF WITHORAWAL OF AMElGNENT TO FACILITY OPERATING LICENSE The U. 5.. Nuclear Regulatory Comeission (the Commission) has l granted a request by -(the Itcensee).to withdraw its ~[DATE] a_pplication for an amendment to Facility Operating License No. ( iswed to the licensee for operation of the , Unit No. _, located in Notice of Consideration of l i Issuance of this amendment was published in the FEDERAL REGISTER on [DATE]( FR ). i The purpose of the licensee's amendment request was to revise the Technical Specifications (TS) to f Subsequently the licensee informed the staff that the amendment is l i no longer requested. Thus, the amendment application is considered to be withdrawn by the licensee. j For further details with respect to this action, see (1)' t$e application for amendment dated , and (2) the i staff's letters dated and These documents are available for public inspection at the. l Commission's Public Document Room, the Gelman Building, 2120 L Street, l t N.W., Washington, D.C. and at the [ LOCAL PUBLIC DOCUMENT A00M]. 1 Dated at Rockville, Maryland, 1 .. l FOR THE NUCLEAR REGULATORY Com ISSION i .t , Project Manager Project Directorate. [ Oivision of Reactor EEjects i Office of Nuclear Reactor RegETation l 3 i. ~ :: s......., +----.-. ~- ~

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SUBJECT:

, UNIT MO. _ - WITHDRAWAL OF AMENOMENT REQUEST UAc leo. ) By letter dated ,you applied for an amendment to the [ FACILITY] Operating ucanse, No. Subsequently, during a telephone conference, your staff informed the EC that the proposed amencuent was no longer requestard. By letter. dated , we informed you that the NRC would consider the proposed amencment to De withdrawn unless you notified us within 10 days that our understanding was incorrect. [Sincu the allotted time has passed and you have not responded, we consider the amencuent request withdrawn.] -or- [By luttar dated , you confirmed your intent that the ar,enament request ce witncrawn.J The Commission has filed the enclosed Notice of Withdrawal of Application for Arencuent to Facility Operating License with the Office of the Federal Register for publication. Sincarely. , Project Manager Proaect Directorate DivisionofReactorIHIIsets Office of Nuclear Reactor Regulation

Enclosure:

Notice cc w/ enclosure: See next page DISTRIBlfTION: [SAMPLEAMENCMENT5] Office: LA/PD PM/PO PD/PD Surn=~ : Date: / /89 / /89 / /89 l

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e P [ CASE 3] i 7590-01 4 UNITED STATES NUCLEAR REGULATORY CCM41SSION i [LICENSEEl DOCKET N0. NOTICE OF DENIAL OF AMENONENT TO FACILITY CPERATING LICENSE AND OPPORTUNITY FOR HEARING l The U. S. Nuclear Regulatory Commission (the Commission) has denied a request by . (licensee) for an amendment to Facility j Operating License No, issued to the licenses for operation of [ the . Unit No. _, located in Notice of Consideration of Issuance of this amendment was published in the FEDERAL REGISTER on [0 ATE] ( FR ). The purpose of. the licensee's amendment request was to revise the i Technical Specifications (TS) to The NRC staff has advised the licensee that the proposed amendment-is denied since the licensee.has failed to respond to the Commission's request for additional technical information to support the application. i The licensae was notified of the Commission's denial of the I t proposed change by a letter dated j By [30-QAY DATE], the licensee any demand a hearing with respect to the r denial described above. Any person whose interest any be affected j by this proceeding any file a written petition for leave to intervene. o O Y e 6 I s ......n.... - - - - - ~ ~ ~ - - ~ - ~ ~ * * ~ ~ ~ ' ' - * ' ' ' ' ~ ~ * * ' * ~ ~ ~ ' ' ' ' ' ' ~~~

e e P 2-A request for hearing or petition for leave to intarvene must be filed with the. Secretary of the Connission, U.S. Nuclear Regulatory Consission, Washington, D.C., 20555, Attention: Docketing and Servics 3 ranch, or may be delivered to the Consission's Public Document Room, the Gelman Building, 2120 L Street, N.W. Washington, D.C., by the above date. A copy of any petitions should also be sent to the Office of the General Counsel, U.S. Nuclear Regulatory Commission, Washington, D.C., 20555, and to , attorney for the licensee. For further details with respect to this action, see (1) the application for amendment dated , and (2) the Cosmission's letter to the licensee dated These documents are available for public inspection at the Commission's Public Document Room, the Geir.an Builcing, 2120 L Street, N.W., Washington, D.C., and at the [ LOCAL PUBLIC DOCUMENT ROOM]. A copy of ites (2) may be obtained upon request addressed to the U.S. Nuclear Regulatory Commission, Washington, D.C., 20555, Attantion: Document Control Desk. Dated at Rockville, Maryland, this FOR THE NUCLEAR REGULATORY CDPMISSION ~ , Project Direc+a r Fro;ect Directorate Division of Reactor FBjec+a Office of Nuclear Reactor ReguTation -OR- , Project Manager lif signature authority has been delegated to PM in writing). .. ~. ir.

l r v. l [ CASE 3] . Docket No. 5520 DOCUMENT NAME: i i [ LICENSEE] i I Dear Mr. I 4 $UBJECT: UNIT - DENIAL 0F AMLEMENT REQUEST 8 (TAG ) ~ l ~ Sy letter dated , you submitted Amendment Aequest No. _ to revise applicable technical specifications regarding [In conference calls with the NRC staff, your staff consitted to provide : i further information in a revised submittal to support this amendment request. This revised submittal with further infonnation has nut been received.] l - OR - i .t [We have requested additional inforsation regas aing the proposed change in j -letter ('s) dated-This infonnation has not been received.] Since your currently docketed application is not now supported by sufficient. . technical-information, your recuest for license amendment is denied. A copy of the Notice of Denial of Application for Amendment to be published in the Federal Register, is enclosed for your information. i Sincerely, I , Director l Project Directorate Division of Reactor F Ejects Office of Nuclear Reactor ReguTation

Enclosure:

As stated cc w/ enclosures: See next page DISTRIBUTION:, [ SAMPLE MEN 0MENTS] k ~ Office: LA/PD PM/PD P0/PO ~ ~ ~ Surname: Date: / /89 / /89 / /89 j i w ~~~-_--_-__-_-_-~_._______; m

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O P [ CASE 4] 7590-01 UNITED STATES NUCLEAR REGULATORY CCMMISSION [LICENSEEl DOCKET N0. 50-NOTICE OF DENIAL OF MENDMENT TO FACILITY OPERATING LICENSE AND OPPORTUNITY FOR REARING, The U. S. Nuclear Regulatory Cosmission (the Cosmission) has denied a request by . (licensee) for an amendment to Facility Operating License No. , issued to the Itcenses for operation of the . Unit No. . focated in Motice of Consideration of Issuance of this amendment was published in the FEDERAL REGISTER on [DATE] ( _ FR ). The purpose of the licensee's amendma'nt request was to revise the ~ Technical Specifications (TS) to The NRC staff has concluded that the licensee's request cannot be granted. The Ifcansee was notified of the Cosmission's denial of the proposed change by letter.da+M By the licenseit may demand a hearing with respect to the denial described abcve. Any person whose interest say be affected by this proceeding may file a written petition for leave to intervene. A request for hearing or pet 1 tion for leave to intervene must be filec with the Secretary of the Consission, U. S. Nuclear Regulatory Consissien, Washington, D.C., 20555, Attention: Docketing and Service Branch, or may be - delivered to the Commission's Public Document Room, the Gelman Building, 2120 L Street, N.W., Washington, 0.C., by the above date. O s .~

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r .g. (; v ~> A copy of any petitions should also be sent to the Office of the ~ General Counsel..U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, and to attorney for the licensee. For further dotatis with respect to this action, see (1) the application for amendment dated . and (2) the Commission's letter to the licensee dated These documents are available for public inspection at the Commission's Public Docume'it Room, the Gelman Building, 2120 L Street. N.W., Washington, D.C. and at the [ LOCAL PUBLIC DOCUMENT 200M]. j A copy of Itas (2) any be obtained upon request addressed to the I U.S. Nuclear Regulatory Commission, Washington, D.C., 20555, Attention: [ l Document control Desk. ~ [ Dated at Rockville, Maryland, this FOR THE NUCLEAR REGULATORY CCMISSION { r , Director I Pro,1ect airectorate Division of Reactor T5jects . + 'l Office of Nuclear Reactor Regulation t [ i t s i ~ h + ~ ~ . ~........... -. -.. - .. ~

j i s [CA$E4] Docket No. 50-5520 DOCUMENT NAML: [LICDSEEA00RES$] - Dear Mr.

SUBJECT:

O DIAL 0F AMENOMENT REQUEST No. f (TAC NO. ) By lettsr dated , you submitted Amendment Request No. to revise applicaole tecnnicsl specifications regarding 7 After careful review, the NRC staff has concluded that your request cannot be approved. We have provided the reasons for our conclusion in the related Safety Evaluation. A copy of the Notice of Denial of Amendment to be published in the Federal itegister, is enclosed for your information. Sincerely, ~ , Director Proaect Directorate Division of Reactor T5fects 1 Office of Nuclear Reactor Regulation

Enclosure:

As stated cc w/ enclosures: See next page DISTRIBUTION: [SAMPLEAMEN0MENTS] Office: LA/PD PM/PD OGC PO/PO - Surname: Date: / /89 / /89 / /89 / -/89 (OGC sust approve a dental before issuance]. e e . ~..

o W l 1HPLEMENTATION OF MANAGEMENT GUIDANCE TEAM (MGT) RECOMMENDATIONS 1. NRR line management should routinely review the status of all licensing activities to assure that appropriate actions are taken and decisions l l are prompt. (Section5.3) Action: NRR will institute regular line manage.nent meetings with the technical and project management staff to provide guidance and direction on reaching early decisions on licensing actions. 2. Licensing action inventory goals should be established as follows: 80 percent less than one year old, 95 percent less than two years old, and no actions over three years old. Separate goals should be established for multiplant actions after the completion of the MPA Closure Plans. However, the inventory goals should allow for senior management approval of case-specific alternative goals. For example, the inventory goals would not necessarily include future " license extension" or TS improvement cases. (Section 5.2) Action: The licensing action inventory goals will be incorporated into NRR Office Letter No. 804, " Procedures and Responsibilities for License Amendment-Reviews", and will be monitored and evaluated during NRR management meetings. 3. The current policy on integrated schedules, in Generic Letters 83-20 and 88-20, should be revised to be consistent with the backlog policy and be reissued. (Section 3.1) Action: Guidance on early decision-making in the context of integrated schedules will be included in a revision of NRR Office Letter No. 804, " Procedures and lesponsibilities for License Amendment Reviews." Regular NRR line management reetings between technical and project management staff will ensure that this decision-making guidance is followed. However, it is not necessary to issue further generic cormunication. 4. NRR should dnvelop and utilize a type-specific labor rate for resource estimates in the future. (Section 3.2) Action: This recommendation will not be implemented because developing a more complex system is not deemed to solve the basic problem. Rather, more attention will be devoted to supervisory control of scope and depth of review based on safety significance.

• References refer to appropriate sections of the MGT Report (Enclosure 1).

l

1 k , 5. NRR should develop a plan for the review of the "other" actions including the identification of the items requiring actions, addition of these actions to the interim tracking system, and assignment of the appropriate resources and schedules to be applied to complete a targeted set of these actions in FY 1990. Thereafter, the line managers should monitor progress on the implementation of this plan. (Section4) Action: NRR will include the "other" actions within the scope of the regular line management meetings with the technical and project management staff to guide and direct the staff on reaching early decisions on licensing actions, 6. NRR should continue to schedule and monitor priority correspondence, Work Item Tracking System (WITS) items, Task Interface Agreements (TIAs), event followup, etc., in accordance with existing practices. This workload, however, still needs to be included in the tracking system and considered in the overall resource impacts. (Section4) Action: Existing practice for scheduling and monitoring priority corre-spondence will continue and these actions will be included in the WISP (Workload Information and Scheduling program) system. 7. NRR should establish periodic meetings between senior NRR management and the licensee's management when licensing actions on the licensee's actions require management attention. (Section 5.3) Action: Management meetings with licensees will be planned as the need is perceived by NRR management at the management meetings on licensing actions. 8. NRR should revise the priority system to raise priority for actions over 18 months old. (Section 5.5) Action: The priority of issues more than 18 months old will be raised as appropriate after management review. 9. NRR management should conduct routine tracking and periodic management review of all licensing actions. NRR should develop an interim and long term consolidated database of all licensing activities. WISP should be adopted as NRR's long term tool for all tracking and resource planning activities. (Section 5.6) Action: This recommendation will be implemented through the WISP system in the long term and through the WISP prototype system in the interim.

r-3 ~ 1 10. NRR should adopt clear definitions for the categories and types of licensing activities as defined in Table 1, Section 4 of the MGT Report. Consideration should be given to excluding " regulatory tasks" from Safety Issue Management System (SIMS) and allowing informal closure methods. (Section4) Action: This recommendation will be implemented through the WISP system in the long term and through the WISP prototype system in the interim. It will also be incorporated in NRR Office Letter No. 804.

11. A " licensing action" should be defined as an action requiring a response issued by NRR which affects the license. Other licensing activities should be categorized as "multiplant actions" and " regulatory tasks,"

along with appropriate type classifications for each of these three categories. The standardization of these terms and proper classification will improve resource tracking. (Section4) Action: The following definition of a " licensing action" is being used to implement the intent of this recommendation. This definition is currently being implemented through improved administrative controls and will be used in the WISP system in the long term and through the WISP prototype system in the interim. It will also be incorporated in NRR Office Letter No. 804. A " licensing action" is defined as an action requiring NRC approval before it can be implemented by the licensee, regardless of whether it was requested by the licensee or has as its source a safety issue imposed by the NRC. 12. The WISP staff should work closely w'ith the NRR managers to assure that the trackir.g system has all of the necessary capabilities for management control of licensing actions. Ultimately, as experience is gained in the use of WISP, it may supplement or replace the NRR White Book. (Section 5.6) Action: This activity is already taking place.

13. The tracking system should have the following functional requirements:

monitor all tasks at the BC/PD level, TACs for all staff products, track each process step, provide tracking codes for management support activities, provide schedule history data and comments for schedule slips (see Table 2 in Section 5.6). Action: This recommendation dll be implemented through the WISP system Tii the long term and through the WISP prototype system in the interim. 14. The tracking system should provide flags which would automatically generate management reports highlighting actions which are approaching established age goals, have past due dates, or have reported performance problems. (Section 5.6) Action: This recorrendation will be implemented through the WISP system in the long term and through the WISP prototype system in the interim.

f + , 15. The NRR staff stould be given clear guidance on the handling of licensee submittals incluMng the use of standard forms and checklists. The scope and depth of revity should be established and controlled by the line managers, consistent with the safety significance and complexity of the issues and resource allocations. NRR should also clarify the role of generic guidance (for example, the SRP, STS, and generic letters) and encourage the staff to require conformance with those standards unless there is a justifiable,) plant-specific safety reason to differ. (Sections 5.4, 5.7, 5.8 Action: This recommendation will be incorporated into a revision of NRR Office Letter No. 804, " Procedures and Responsibilities for License Amendment Reviews."

16. The project manager should reject submittals that do not conform to the requirements specified in Appendix I of the MGT Report (Enclosure 1).

The staff should be given guidance on how to promptly respond to non-conforming submittals; prepare an Order, if necessary for public health and safety, requiring appropriate action within a timeframe consistent with inventory goals; or, recommend changes in the generic guidance the submittal is being judged against, if necessary to obtain an acceptable submittal. (Section 5.4) Action; This reconmendation will be incorporated into a revision of NRR Ottice Letter No. 804, " Procedures and Responsibilities for License Amendment Reviews."

17. The project n.anager should reject any request the licensee allows to remain oormant or prepare an Order, if necessary for public health and safety, to require whatever action is necessary.

(Section 5.4) Action: This recommendation will be incorporated into a revision of NRR Office Letter 804 " Procedures and Responsibilities for License Amendment Reviews." l

18. NRR should adopt review guidance for submittal acceptance reviews, which specify project manager and technical review responsibilities.

(Section5.7) Action: This recommendation will be incorporated into a revision of NRR Of fice Letter No. 804, " Procedures and Responsibilitics for License Amendment Reviews."

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19. NRR should adopt standard formats and content for SERs and other evaluations.

(Section5.8) Action: This recommendation will be inco.oorated into a revision of NRR Office Letter No. 804, " Procedures and Respu.isibilities for License Amendment Reviews."

20. Possible future improvements which would improve ti,e efficiency and effectiveness of the review process are (1) a TS case history database and (2) a routine update of the SRP to focus on areas of current interest to safety.

(Section 5.8) Action: This recommendation is on hold because of current resource limitations.

21. NRR should consolidate all of the Office Guidance into a single manual and require that the staff use that guidance.

(Section 5.8) Action: Because of resource limitations, the implementation of this recom-mendation will be limited to developing a comprehensive list of guidance documents for reference. i l f i 4 1 r ? l I e}}