ML20126E559
| ML20126E559 | |
| Person / Time | |
|---|---|
| Issue date: | 02/19/1992 |
| From: | Speis T NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | Hopenfeld J NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| References | |
| RES-1-R2, NUDOCS 9212290195 | |
| Download: ML20126E559 (3) | |
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FEB 191992 HEMORANDUM FOR:
Joram Hopenfeld Reactor and Plant Safety Issues Branch Olvision of Safety Issue Resolution Office nf Nuclear Regulatory Research FROM:
Themis P Spels Deputy Director for Research Office of Nuclear Regulatory Research
SUBJECT:
YOUR OIFFERING PROFESSIONAL OpINTON (DPO) DATED 12/23/91 On January 24, 1992,- a number of RES staffers', including myself, met with you to discuss and explore the various issues / concerns associated with your DP0 related to multiple steam generator tube failures (Enclosure 1).
Based on my reading of your DPO, it was not clear to me with what staff position you differed; or whether based on recent experience with detection of steam generator tubo degradation (e.g., as you indicated at the Trojan plant), you were recommending the formulation of a "new" staff position; the objective of the meeting was then to informally explore and gain a more precise understanding of your concerns and recommendations, including their bases.
Based'on your DP0 as described in your 12/23/91 memo, and the discussions with you and the other RES staffers at the subject meeting, you are conce,med that "a Main Steam Line Break (HSLO) outside containment could trigger a multiple steam generator tube failure which would result'in a core melt because of a depletion of. coolant inventory" and as a result, you recommend that "the NRC should request the affected licensees to provide warranties that they have the capability to keep the core intact and prevent allowable dose releases with a MSLB and a multiple. tube rupture of no less than 80% of all tubes." This is not, within the design basis and interpretation of GDC 31 as currently applied by the staff.
In summary then, based on the discussions we had at the subject meeting, it seems that you are recommending the development of-a new staff position.
As you know, we have in place at NRC a process (described in NUREG-f 0933 and managed by the Offico of Rosearch) whereupon when an issue is identified, it goes through a prioritization process [it involves other Offices plus the ACRS] to determine whether the identified issuo merits further consideration, including its designation as either a USI or a geni.'ic issue. Once it has been categorized as either a USI or a generic issue, a program plan is developed, including a schedule for its resolution [ including all the appropriate interactions with_the ACRS, CRGR, and Commission] and, depending on the resolution / findings, appropriate staff-positions are
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developed and recommended for-implementation, normally via a rule, regulatory guide, changes to SRP, etc.
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FEB 191997 Therefore, based on our discussions and in order to facilitate the process described above, we agreed at the subject meeting that you should provide more detailed information -[in fact you told us at the meeting that you were in the process of doing just that) about the basis for your concern so that we can proceed to prioritize this issue.
One of the reasons for the need of this.
information is to estimate to the extent possible the probability of the event which you have postulated, the associated consequences and the cost of potential backfits which could prevent the event from taking pisce or mittaate its consequences.
Therefore, it will be useful to define the issue as precisely as possible and provide any further information (and its basis) which you have concerning the probability of a large number of tubes with sufficient degradation which could tnen fail coherently as a result of a MSLB, the probability of periodic eddy current testing not finding the degradation, the location and the associated probability of a HSLB; the probability that the forces associated with a HSLB are beyond the capacity of the degraded tubes which would then lead to coherent failure of large numbers of tubes; the probability that this event would go undetected long enough (i.e., before isolation of the faulted SG) and that the coolant inventory will be " lost" outside containment and thus not available for tho " recirculation 3hase" of core cooling.
For more guidance and details on the proceoures to 'e followed and the information to be provided so that a draft prioritization of the issue can be prepared, see RES Office letter No.1, Revision 2, " Procedure for identification, prioritization, and Tracking of the Resolution of Generic Issues," dated July 12. 1991 (Enclosure 2).
Especially valuable to you will be Attachment 1 to the RES Office Letter which lists the type of infomation needed in order to allow RES to make an assessment of the importance and priority of the issue.
on g.,y.a n, TheYPhkis Deputy Director for Research Office of Nuclear Regulatory Research
Enclosures:
1.
OP0 frm. J. Hopenfeld dtd.
12/23/91
-2.
Memo to Office Dir. and Reg.
Dir. frm. E. Beckaord dtd. 7/12/91 cc:
EBeckjord JHel temes WHinners RBosnak BSheron ADurda Distributto -
subj-cir fchron TSpeis Off M R Name M < y Date: 2/ /92 0FFICAL RECORD COPY P
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ENCL.0$tlRE 1 DIFFEBlNGfEQFESSIONAL OPINION
-g Recent experience at the Tro,ian plant indicates that present inspection techniques are not sufficiently sensitive to deteci steam generator tube degra'dation. The problem is inherent in the eddy current probe design and its use, it is essentially impossible to detect tight through the wall crncM, especially at the tube support plate regions.
The plants were not designed to operata continuously with a large number of tubes containing through the wall cracks.
My concern is that a Main Steam Line Break (MSLB) outside containment could trigger a multiple steam goncrator tube failure which would than result in a core melt because of depletion in coolant inventory.
NRC is currently addressing the uncertainties in the in-service inspection procedures by considering the possibility of a!!owing affected utilities to operate with tube imperfections beyond the 40% tech specs through the wall plugging limit.
While the above action is useful fcr the lon0 term, I believe it is not focused on the main issue. The main issue is whethor the core can be maintained intact and radioactivity release prevented with a MSLB outside containment and multiple stoam j
generator tube rupture. While considorable research will be required to defino a new plu0ging limh and change the SRP, the result will not increaso plant safety. The basic problem is with the NDE procedures and their inability to predict tube degradation and leakage.
Rather than concentratin0 offorts on a!!crnate plugging limits, the NRC should request
.all affected licenscos to provide warrantics that they have the capability to keep the
' core intact and prevent allowable dose releases with a MSLB and a multiple tube rupture of no less than 80% of all tubes, J.
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MEMowinM ron-R. Fraley, ACRS T. Murley, NRR E. Jord6n, AE00 R. Bernero, HMSS J. Partlow, OSP W. Russoll, Reg.1 S. Ebnetor, Reg. 11 A. Bert Davis, Reg. 111 R. D. Martin, Reg. IV J. B. Martin Reg. V FROM:
Eric S. Beckjord, Director Office of Nuclear Regulatory Research
SUBJECT:
RES OFFICE LETTER NO 1, REVISION 2, " PROCEDURE FOR IDENTIFICATION, PRIORITIZATION, AND 1 PACKING OF THE RESOLU-TION OF GENERIC ISSUES
- As a result of the NRC reorganization in April 1987, the functional respon-sibility for the early stages of generic issue management was transferred to the Office of Nuclear Repa nory Research (RES). RES Office Letter No. 1 (01.-1) was published on December 3,1987, to replace the guidance previously provided by HRR Office letter No. 40, and Revision 1 was published on March 22, 1989. The purpose of this revision to RES OL-1 is to reflect recent -
changes in the generic issues prioritization procedure brought about by the recent transfer of the function from the Division of Regulatory Analysis to the Division of Safety Issue Resolution. One major change is that NRR is asked to participate in the peer review process of those prioritizations for which RES recommends a low or Drop priority, but need not concur for GSis prioritized High or Medium. NRR will continue to participate in the peer review of the final resolution packages of all such issues.
The generic issue process consists of six phases:
Identification, Prioritiza-tion, Resolution, imposition, implementation, and Verification. The enclosure to this letter specifies the procedure to be followed for the management of generic issues through the first two stages (Identification and Prioritiza-The tion) as well as the tracking of those issues through their resolution.
procedures for managing generic issues through the Resolution stage (RES Office letter No. 3) and the Imposition, Implementation, and Verification stages (NRR Office Letter No. 25) are provided separately. This procedure was developed to provide a mechanism to document new safety concerns with existing and future reactors and to have the RES staff formally evaluate these concerns for safet: *ignificance and appropriate action. Since potential generic issues may arise from different offices within Headquarters or from sources outside of the Headquarters staff such as the ACRS, Regional Offices or the public and since the prioritization of these issues may involve review by other offices, this procedure is being provided outside RES for information 1
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E8I Multiple Addresses and use, as appropriate. RES intends to accept potential generic issues for evaluation from any source provided they generally follow the attached procedure an:. provide adequate information regarding the concern (as prescribed in Attachment I to the Procedure) to allow RES to make an.
assessment of their priority.
This procedure is not intended to be applied to screen all current or
_ture work going on within NRC (which may be initiated through various mechant'sms) but should be used for new potential generic issues assnciated with nuc; ear.
power plants.
S.hM A
Eric S. Beckjord,dlirector Office of Nuclear Regulatory Research
Enclosure:
Procedure for Identification, Prioritization and Tracking of the Resolution of Generic Issues cc:
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f INCLOSURE Pf0CEDURLf.0R_IDENIlmall0LE10RIJ1ZAllDN AND TRACK 1HG 9f_lH LBE 50WJ ION _0f._GEH ERIC_15WE 5 1RIE0WCIION A generic issue is an issue that is applicable to all, several, or a class of reactors or reactor related facilities. Generic issues can arise from various concerns and, accordingly, are classified into one of the following four categories. A Generic Safety Issue (GSI) is a generic issue that involves a-safety concern that may affect the design, construction, operation or decom-missioning of all, several, or a class of reactors or facilities and may have a potential to require licensees to make safety improvements and/or require the promulgation of new or revised requirements or guidance. A Regulatory impact Issue (RI) is a generic issue not related to inoroving safety, but to modifying current NRC requirements or guidance, with tie primary purpose of reducing the regulatory impact, usually cost, of requirements on Itcensees or applicants. An Environmental issue (EI) is a generic issue involving impacts on those items protected by the National Environmental Policy Act (NEPA). A Licensing Issue (l.I) is a generic issue related to actions the NRC staff should take to increase knowledge, certainty, and/or understanding in order to
. crease confidence in assessing levels of safety; improve or maintain the NRC capability to make independent assessments of safety; establish, revise, and carry out programs to identify and resolve safety issues; document, clarify, or correct current requirements and guidance; or improve the offectiveness or efficiency of the review of applications.
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The generic issue management program is divided into six distinct stages:
identification, prioritization, resolution, imposition, implementation, and verification. The procedure described herein is to be utilized only for the identification and prioritization stages of generic issue managesient, includ-ing their tracking through resolution. Procedures for the management of generic issues during resolution, imposition, implementation, and verification are not covered by this procedure.
In the identification stage, potential generic issues may be suggested by organizations or individuals within the NRC, the Advisory Comittee on Reactor Safeguards -(ACRS), the nuclear power industry, or the public. Generic issues may also be suggested as an outcomo of reactor research programs. Potential risk to the public is the principal consideration in suggesting a potential generic issue. Once suggested, potential generic issues are screened for duplication, overlap, or integration-with existing generic issues. When a potential generic issue is accepted as a new generic issue it is assigned a number and title, the scope of the issue is defined, classified by type (GSI, RI, El or LI), and catalogued with all other generic issues in NUREG-0933, "A Prioritization of Generic issues.'
Each new GSI is normally prioritized by developing a quantitative assessment of safety benefits (risk reduction) and NRC and utility impacts (cost) as described in NUREG-0933. Based on the extent of potential risk reduction to the public and the value/imo rt ratio developed from this assessment, and as i
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further adjusted by qualitative judgments and other considerations, a priority is assigned to each GSI. Ris, Lis, and Els are evaluated and quantitative and qualitative estimates of their merits are described.
The preliminary priority assessments for each issue are sent for peer review and coment.
These peer review coments are then addressed, the original preliminary assessment revised, as necessarv, and a final priority recomanded, as appropriate.
Issues which are assigned a HIGH or MEDIUM priority move on to the resolution state. All HIGH priority Generic Safety Issues are screened for additional designation as an Unresolved Safety Issue (US1). An issue assigned a LOW or OROP priority by nature of the rating standard is of so low a public risk reduction potential that resolution of the issue is not pursued.
All issues are documented in the catalogue of generic issues maintained in NUREG-0933.
Generic issues not initially assigned staff resources for resolution (LOW or DROP) may be reactivated in the future if new infonnation becomes available which may change the original priority assignment or change their classifica-tion. HUREG-0933 serves as the repository for the priority assignment and resolution for all identified generic issues. NUREG-0733 is updated semiannually. RIs Lis, Els, and HIGH and HEDIUM priority GSIs are assigned by the Office Director, Office of Nuclear Regulatory Research (RES), to the apprcariate NRC Office for resolution. Most GSis are usually resolved within RE5; aowever, from time to time other officos are assigned GSis for resolu-tion.
LIs are assigned to NRR for disposition. RIs and Els are assigned within RES, and decisions to work on the resolution of these issues are made by qualitative judgment and the availability of staff resources.
In the resolution stage, an in-depth technical evaluation of the issue is performed by the office assigned the task of resolu~ ion.
The status of issue prioritization and resolution is tracked in the Safety Issues Management System (SIHS).
For each issue, the SIMS includes a synopsis of the issue, work scope, work status, and program milestones.
EROCEDURE:
1.
IDENTIFICATION:
a.
Anyone inside or outside NRC can identify a proposed generic issue.
A generic issue may be proposed by an individual or by an organization unit. However, when proposed, an attempt should be made to include all the infonnation specified in Attachment I so that there is a clear understanding of the issue and its safety significance.
b.
Proposed generic issues submitted to NRC's Office of Nuclear Regulatory Research (RES) should be addressed to the Director, RES.
c.
RES/DSIR will screen all proposed generic issues for duplication or overlap with previously identified generic issues and to see if, in fact, they are generic, not plant specific issues.
Proposed issues that may be plant specific will be sent to NRR for review and appropriate action.
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for' each generic issue accepted, RES/0 SIR will assign it a number and will maintain a log of its status and disposition.
RES/DSIR will promptly advise the originator of the receipt and initial disposition of the issue.
This dis >osition may include a deter-mination that the issue is covered )y another e.tisting issue or Multi-Plant Action (HPA), that it has been accepted for prioritiz-atinn, or that additional information is needed, e.
After their acceptance, generic issues that originate from outside NRR or from an individual within NRR (i.e., not sent through NRR management) will be transmitted by RES to NRR/PHAS for an inmediate action determination and screening for identification of overlap or duplication with already imposed or completed Multi-Plant Actions (MPAs).
If HRR cannot complete the inmediate action determination and HPA screening within 15 days RES should be informed when the NRR review will be completed.
2 PRIORITIZATION a.
RES/DSIR will classify each accepted ganeric isste as a GSI, RI, ll, or EI. Based upon its classification, one of the following actions will be taken:
1, Issues classified as RIs, LIs, and Els will be evaluated and their merits quantitatively and qualitatively estimated and described in a preliminary assessment repo.s 2.
Issues classified as G51s will be evaluated by RES/DSIR and assigned a preliminary priority estimate based on engineering judgment and/or very rough quantitative risk calculations.
The preliminary estimate (i.e., safety significance) will be used by DSIR to establish an order for entering GSIs into the prioritization process; i.e., thosa with preliminary priority estimates of HIGH will be entered into the process before GSIs with preliminary priority estimates of HE0iUM, LOW and DROP, MEDIUM before LOW and DROP, and LOW before DROP.
b.
OSIR will prepare a draft prioritization write-up for each generic issue using the methodology described in NUREG-0933. GSIs will be assigned a priority ranking of HIGH, HEDIUM, LOW, or DROP based on their estimated ptblic risk reduction potential, their value/ impact ratio, and other considerations, RES/DSIR will send the draft prioritization write-up of each c.
generic issue to appropriate NRC persovinel for peer review prior to finalizing their priority. Those involved in peer review will include the DSIR Division Director, DSIR Branch Chiefs, NRR/PMAS (for distribution to cognizant NRR management and Staff), as appropriate, and the originator. NRR will be requested to participate in the peer review process only for GSis with a priority recommendation of I.ow or Drop. NRR/PHAS will be provided
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4 1r. formation copies of the priority write-up for GSIs with a High or Medium priority recomendation and issues classified as RI, El or LI. The offices designated for peer review for an individual issue are to provide coments on the draft prioritization and the priority ranking to RES/DSIR within 15 work days of receipt. NRR will perform a screening review of the prioritization and will perform a full staff review only if the result appears questionable.
In that case, a roYicW schedule Will be developed by NRR and RES will be informed of that schedule, d.
Based upon the results of the peer review, RES/DSIR will revise the draft prioritization to address the comments or identify the differences, include a recommended final priority ranking, as appropriate, and whmit it to the Director. RES, for approval.
For GSIs approved as HlGH or HEDIUM priority the Director, RES, e.
will assign them to the appropriate RES Olvision for resolution or request an other NRC Office to resolve them. For issues approved as I.Is, the 01'ector, RES will send the final assessments to RES or NRR for disposition, as appropriate, based on the nature of the issue. For issues approved as RIs or Els, the Director, RES, will assign the issues within RES based upon a decision to work the issues made by qualitative judgment and the availability of staff resources.
In addition, the Director, RES, will send the prioritization assessments of all approved generic issues to other Offices, the ACRS, and the Public Document Room for infonnation and coment.
f.
RES/DSIR will review those prioritized as HIGH and provide a recomendation to the Director, RES as to whether they should be designated as candidate Unresolved Safety Issues.
Criteria to be used are documented in NUREG-0705.
3.
TRACKING a.
Each HRC Office assigned the task of resolving one or more generic issues should prepare and implement a plan defining the respon-sibilities, process, and schedule for resolution.
The Office Director assigned the task of resolution of a newly approved issue will submit a copy of the work plan, including a detailed schedule and the plan for the regulatory analysis, to the Director, RES, within 6 weeks of being assigned the issue. This submittal shall contain the information listed in Attachment 2.
b.
The Chief of the cognizant HRC branch will submit status reports for each approved work plan to the Director, DSIR, quarterly or -as requested. When a status report indicates slippage of the estimated resolution completion date, the revised work plan must be approved by the cognizant Office Director and by the Depety Director for Generic Issues and Rulemaking, RES.
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RES'/DSIR will provide the. approved work plans for all generic issues as input to SlHS. RES/DSIR will provide updates to SlHS quarterly to incorporate approved' work plans for new generic issues and incorporate nodification to and/or chances in scheduler information for existing work plans.
d.
RES/DSIR will issue a quarterly status summary of Generic-Issue resolutio n progress through the Generic Issue Management Control Systems (GIMCS), by the second week of each quarter. Ocarterly reports will also be provideo by the Director, RES, to the EDO highlighting progress, problem areas, and schedule changes, RES/DSIR will upda6e NUREC-0933 semiannually to catalog new c.
generic issues, document the progress of staff efforts during the prioritization process, and document the priority assignments made for generic safety issues.
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n36*7 Pil Attachment.1 GENERIC ISSUE INFORMATION To the extent practical,-the following information should be provided in sufficient detail to permit the proposed issue to be analyzed and prioritized with a minimum of additional information gathering.
1.
A title for the proposed generic issue should be suggested. While brief, the suggested title should attempt to define the specific nature and scope of the proposed issue.
2.
Potential, suggested, or known deficiencies in the technical bases of existing staff guides or requirements should be identified (i.e.,
Regulatory Guides, Standard Review Plan Sections, Rule, etc.).
For proposed issues suggested by examination of LEds, a complete listing of applicable LERs and/or a complete set of copies of the applicable LERs should be provided.
3.
A description of the proposed lasue should be provided which discusses the background (bases) and perceived safety significLnce of the issue (i.e., contribution to risk, cor e melt frequency or public dose).
The issue should be scoped to ident'.fy those individual plants or classes of plants affected by the proposed issue.
4.
Sufficient attention should be devoted to the proposed issue to suggest a potential solution and/or alternative solutinn (i.e., design and hardware changes and/or additions; procedural ceanges; changes in plant staffing and/or management; accident management changes, etc.).
5.
The suggested solution and/or alternative solutions should be evaluated in sufficient detail to determine whether the solution (s) would be expected to result in:
a) the need for additional research, staff studies, testing, new procedures, rulemaking, etc.;
b) increase or decrease in operational-exposure of the plant operat-ing staff; and c) a plant shutdown or extension of a refueling cutage to implement the potential solution (s) for the proposed issuo.
6.
A preliminary value/ impact assessment should be provided for the potential solution (s) for the proposed issue. The reference documents listed below provide methodologies for both risk and cost analysis, and illustrative exa,uples.
and organization (s) of all persons currently working on this 7.
Name(s)hould be provided.
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8.
The name of the person supplying preliminary value/ impact assessment information should be provided.
9.
Appropriate references (memorandum, NUREGs, SRPs, etc.) should be provided.
10.
The transmittal memorandum should reflect the concurrence of the office of the originator, if possible; however, this is not mandatory.
Reference Documents NUREG/BR-0058 Revision 1. " Regulatory Analysis Guidelines for the U.S.
Nuclear Regulatory Cosnission,' May 1984 NUREG/CR-3568, "A Handbook for Yalue-Impact Assessment," December 1983.
NUREG-0933, "A Prioritization of Generic Safety Issues," December 1983.
NUREG/CR-2800, " Guidelines for Nuclear Power Plant Safety Issue Prioritization Information Developrent,' February 1983 and Supplements 1, 2, 3, and 4.
HUREG/CR-3971, 'A Handbook for Cost Estimating,' October 1984.
NUREG/CR-4568, "A Handbook for Quick Cost Estimates," April 1986.
AEDO Procedure 3
" Application of Risk Perspectives: A Procedures Guide,"
Peter Lam, U.S. NRC, October 15, 1984
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<1 AutchaienLZ Eeneric Iss.ye_MRatgement Control Information 11enjumbAt (Gener?c Issue Number) litig (Generic issue Title)
Lead Office /Div/Br As appropriate ather 0f.f_tceID1Ylfr As appropriate luk Manaaer (Name) lite _ _Humber (As assigned)
Eork Auth9r_izatlon (if di-fferent from Parts A, B, and C of Appendix F from Operating Plan)
Contract Title Provide Contract Title (if contract issued)
Contractor Name],
Identify Contractor Name and FIN Number.
FIN NO.
(as appropriate)
Work Scoce Describe briefly the work scope for completing the issues Affected E9EEgg Issue NUREG-Revise and issue Regulatory Guide 1.xx; Revise and issue SRP Section x.x.x.; Revise and process STS' change Technical Resolution Select milestones from the initial date Division-
- Director was requested for information through issuance of revised SRP change.
For the most part the selected milestone dates will vary from issue'to issue. Typiral milestones should
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include but are not limited to.t.ose on the following page.
. Status Describe current status of work.
Er E,em/ Resolution include potential problems and actions being taken to resolve them.
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- "A7 P1's 3-2 Milestone Examples Oriqinal Current-attual o Date information reauested from division o Date received from Division o Proposai Solicited o Proposal Evaluated and Accepted o Contract Scheduld, if_ applicable Testing Schedule, if applicabic o
o Draft NUREG/CR report from contractor / consultant-o Staff review of draft NUREG/CR report o Value Impact Statenent prepared-o Final report prepared by' Division o Final report forwarded to RES for processing o RES Director Review completed o Review Package to CRGR o CRGR review completed o EDO approval o Federal Register Notice of Issuance of SRP for Public Comment o OMB Clearance.if applicable o Division review of-public comment completed-o RES Director review completed o CRGR review completed-o EDO approval o Federal Register Notice of Issuancel of SRP