ML20058K413
| ML20058K413 | |
| Person / Time | |
|---|---|
| Issue date: | 11/30/1993 |
| From: | Marcus G Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20058K357 | List: |
| References | |
| NUDOCS 9312150206 | |
| Download: ML20058K413 (2) | |
Text
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7590-01 NUCLEAR REGULATORY COMMISSION Proposed Generic Communication Generic Letter on Availability and Adequacy of Design Bases Information AGENCY: Nuclear Regulatory Commission.
ACTION:
Notice of intent to take no further action on the issuance of the subject generic letter.
SUMMARY
The Nuclear Regulatory Commission (NRC) has decided not to issue the subject generic letter. This decision is discussed in Commission information paper SECY-93-292, dated October 21, 1993 and its associated Staff Requirements Memorandum, dated November 10, 1993 which are available in the public Document Rooms. The proposed generic letter requests power reactor licensees to describe the programs that are implemented or planned to ensure design information for their facilities is correct, accessible, and maintained. A notice of opportunity for public comment on the proposed generic letter was published in the Federal Register on March 24, 1993.
Twenty tv-comments were subsequently received.
Based upon review of these public comments and the available informal Design Document Reconstitution information, the NRC has concluded that it would not significantly benefit the Agency in its licensee oversight functions to issue the proposed generic letter.
The resolution of public comments received is discussed in Commission i
information paper SECY-93-292. Although the proposed generic letter will not 9312150206 931130 PDR I&E HISC PDR
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? be issued, the NRC expects licensees to maintain accurate and accessible design documents and will take whatever measures are necessary to ensure that the licensees have and use design information for their facilities that is correct, appropriately maintained, and accessible.
ADDRESSES: Not applicable.
FOR FURTHER INFORMATION CONTACT:
Eugene Imbro at (301) 504-2967.
Dated at Rockville, Maryland, this 30
- day of M 1993.
FOR THE NUCLEAR REGULATORY COMMISSION
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Gail 11. Marcus, Chief Generic Communications Branch Division of Operating Reactor Support Office of Nuclear Reactor Regulation
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November 10, 1993
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OFFCE OF THE h
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MEMORANDUM TO:
James M. Taylor Executive Director for O stions
~i FROM:
Samuel J. Chilk, Secreta)
SUBJECT:
SECY-93-292 - (Eb NIC leg ER ON THE AVAILABILITY AhD 6 OEQUACY' OF DESIGN BASES -
INFORMATION This is to advise you that the Commission has not objected to the l
staff plans to discontinue all activities related to the issuance of the subject generic letter.
The staff should continue to take whatever measures are necessary to ensure that licensees have accurate and accessible design 1
documents for their plants.
This can be done through the various inspection efforts the staff notes in the paper or alternative approaches that appear necessary through routine oversight.
Contrary to the staff's reasoning, by not issuing the generic
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-letter, licensees could get the impression'that the Commission is j
not committed to ensuring licensees have accurate and accessible design documentation.
Through inspection and followup activities, the staff should clearly communicate the expectation that licensees must maintain accurate and' accessible design documentation for their facilities.
I cc:
The Chairman' 3
Commissioner Rogers Commissioner Remick j
Commissioner de Planque OGC i
OCA OIG Office Directors, Regions, ACRS, ACNW, ASLBP (via E-Mail) 1 SECY NOTE:
THIS SRM AND SECY-93-292 WILL BE MADE PUBLICLY l
AVAILABLE 10 WORKING DAYS FROM THE DATE OF THIS SRM I$ $
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October 21, 1993 SECY-93-292 (NEGATIVE CONSENT)
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The Commissioners FROM:
James M. Taylor Executive Director for Operations
SUBJECT:
GENERIC LETTER ON THE AVAILABILITY AND ADEQUACY OF DESIGN BASES INFORMATION PURPOSE:
To inform the Commission of the staff's intent to take no further action on the issuance of the subject generic letter.
BACKGROUND:
The Commission issued a policy statement' describing its expectations and the Agency's future actions to verify the availability and adequacy.of design information. The policy statement stated that the staff would issue a generic letter to request power reactor licensees (1) to describe the programs that are implemented or planned to ensure design information is correct, accessible, and maintained; and (2) to submit the schedule for implementing or completing reconstitution programs that they are conducting.
The policy statement also stated that the generic letter would request that licensees that are not implementing a design reconstitution program submit their rationale for not doing so.
Responding to recommendations made during the September 22, 1992, meeting of the Committee to Review Generic Requirements (CRGR), the staff included in the generic letter a statement that a response to the generic letter is voluntary.
NOTE:
TO BE MADE PUBLICLY AVAILABLE hiHEN THE FINAL SRM IS MADE AVAILABLE CONTACT:
Eugene Imbro, NRR (301) 504-296,
' " Availability and Adequacy of Design Bases Information at Nuclear Power Plants," Federal Reaister, Volume 57, Number 154, page 35455, August 10, 1992.
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I The Commissioners 4 DISCVSSION:
A notice of opportunity for public comment on the proposed generic letter was published in the Federal Reaister on March 24, 1993.
Comments were received from NUMARC, Westinghouse Electric Corporation, Ohio Citizens for Responsible Energy, Inc., and 19 commercial nuclear power reactor licensees.
The significant comments focused on: (1) the questionable need for the request sitco the information may already be available within the NRC from various i.L; actions, reports and meetings, (2) the questionable usefulness in comparing licensee programs which are based on unique factors to assist the staff in prioritizing inspections, and (3) the concern that the generic letter seeks to obtain commitments from licensees with the implication of the use for subsequent inspections, enforcement actions, and SALP scores.
All the responoents, except for Ohio Citizens for Responsible Energy, Inc., concluded that the generic letter was unnecessary and unwarranted.
Based upon review of the comments on the subject generic letter and the available informal Design Document Reconstitution (DDR) information, the staff has concluded that it would not significantly benefit the staff in its licensee oversight functions to issue the proposed generic letter for the following reasons:
The issuance of the policy statement and the proposed generic letter for public comment has conveyed to the industry the Commission's concern in this matter. The staff believes that formally issuing the generic letter will not further heighten licensees' awareness of the importance of DDR activities.
In addition, the staff has seen evidence that licensees have recognized the importance of this issue and reacted to For example, the NRC has been notified regarding design our concerns.
issues surfaced by licensees' programs.
In preparing for design-related inspections such as safety system functional inspections (SSFIs), the staff will gather detailed information from licensees to the extent such information pertains to scope of the inspection sample. This process will give the staff insights as to the DDR programs as well as their effectiveness in ensuring the adequacy and accessibility of design bases information.
i Further, as part of NRC's normal inspection program, the resident and regional inspectors will obtain information on design control adequacy as they review plant modifications.
f Information regarding licensee's design document reconstitution programs as such will not be useful to the staff.
Therefore, not issuing the generic letter will eliminate an unnecessary burden on the licensees to respond to the generic letter and on the staff to evaluate the l
responses.
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The Commissioners.
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The staff will continue to ensure that design information is correct, accessible and maintained by conducting such performance-based design i
inspections as SSFis, safety systems outage modifications inspections (SSOMIs), service water system operational performance inspections, and system i
based instrument and control inspections. Although these inspections address the products of DDR programs (e.g., calculations) and thereby provide insights as to the effectiveness of licensee DDR programs, the staff will refrain from the inspection of DDR programs per se due to the voluntary nature of these q
programs.
RECOMMENDATION:
Unless the Commission advises to the contrary within 10 working days from the date of this paper, the staff plans to discontinue all activities related to the issuance of the subject generic letter.
.T)flof
..e s ecutiveQirector for Operations SECY NOTE:
In the absence of instructions to the contrary, SECY will notify the staff on Friday, November 5,
- 1993, that the Commission, by negative consent, assents to the action proposed in this paper.
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