ML20135A512

Standard Review Plan Maintenance Program Implementing Procedures Document

ML20135A512
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Issue date:	11/30/1996
From:	Office of Nuclear Reactor Regulation
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NUREG-1561, NUDOCS 9612030270
Download: ML20135A512 (68)

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AVAILABILITY NOTICE I

Availability of Reference Materials Cited in NRC Publications Most documents cited in NRC publications will be available from one of the following sources: l

1. The NRC Public Document Room, 2120 L Street, NW., Lower Level, Washington, DC 20555-0001

2. The Superintendent of Documents. U.S. Government Printing Office, P. O. Box 37082,  ;

Washington, DC 20402-9328 l

3. The National Technical information Service, Springfield, VA 22161-0002 Although the listing that follows represents the majority of documents cited in NRC publica-tions, it is not intended to be exhaustive.

I Referenced documents available for inspection and copying for a fee from the NRC Public 1 Document Room include NRC correspondence and intemal NRC memoranda; NRC bulletins,  !

circulars, information notices, inspection and investigation notices; licensee event reports; vendor reports and correspondence; Commission papers; and a'pplicant and licensee docu-ments and correspondence.

The following documents in the NUREG series are available for purchase from the Government Printing Office: formal NRC staff and contractor reports, NRC-sponsored conference pro-ceedings, international agreement reports, grantee reports, and NRC booklets and bro-chures. Also available are regulatory guides, NRC regulations in the Code of Federal Regula-tions, and Nuclear Regulatory Commission Issuances.

Documents available from the National Technical Information Service include NUREG-series reports and technical reports prepared by other Federal agencies and reports prepared by the Atomic Energy Commission, forerunner agency to the Nuclear Regulatory Commission.

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Single copies of NRC draft reports are available free, to the extent of supply, upon written request to the Office of Administration. Distribution and Mail Services Section, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001.

Copies of industry codes and standards used in a substantive manner in the NRC regulatory process are maintained at the NRC Library, Two White Flint North,11545 Rockville Pike, Rock-ville, MD 20852-2738, for use by the public. Codes and standards are usually copyrighted and may be purchased from the originating organization or, if they are American Nat!onal Standards, from the American National Standards Institute,1430 Broadway, New York, NY 105 8-3308.

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NUREG-1561 4

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l Standard Review Plan '

Maintenance Program l Implementing Procedures

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l Manuscript Completed: September 1996 Date Published: November 1996 j

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I Abstract

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The Implementing Procedures Document (IPD) was developed by the Inspection Program Projects Branch, Office of Nuclear  ;

l Reactor Regulation, with assistance from Pacific Northwest National Laboratory, for the Standard Review Plan Maintenance  !

! Program (SRP-MP). The SRP-MP was established to maintain the Standard Review Plan (SRP) on an on-going basir The IPD i i

provides guidance, including an overall approach and procedures, for SRP-MP tasks. The objective of the IPD is to ensure that 5

modifications to SRP need to reflect current NRC requirements and guidance are identified and that a consistent methodology is used to develop and revise SRP sections.

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Contents Abstract . . . .. . .. . . . .. iii Executive Summary . . . . . . . .. ix 1 Introduction . . . . . . . . 1.1 1.1 Background and History of the SRP, Including Its Modifications . . .. . .. 1.1

1.2 Purpose and Scope

of the SRP ,

. . . . 1.1 1.3 Structure of the SRP . . . . . . . 1.2 1.4 Revisions to the SRP . . . . ... 1.3 1.5 Purpose and Maintenance of this Implementing Procedures Document . .. . .. . .. 1.3 1.6 Definitions . . . . . . . . .. 1.4 1.6.1 NRC Organizations . . .. . 1.4 4 1.6.2 Databases . . . . . . . . 1.4 1.6.3 Position Titles . . . 1.4 1.6.4 SRP Sections . . . . . . . 1.4 1.6.5 SRP-MP Process . . ... . . 1.4 1.6.6 Types of SRP Revisions . . . . .. 1.4 1.6.7 Reactor Terminology . . . .. . . 1.5 1.7 NRR Responsibilities Regarding SRP Modifications . . . . . .. . . 1.5 2 Identification and Review of Documents . .. 2.1 I

2.1 Documents. . . . . . . ,. 2.1 2.1.1 Approach . . . . . . . .. . . .. 2.1 2.1.2 Procedure for Routine Maintenance of the Text Retrieval System . . . .. . 2.3 2.1.3 Procedure for Identifying Other Documents . . . . . . 2.4 1

2.2 Identifying Potential SRP Impacts . . . . . . .. 2.5 2.2.1 Approach . . . . . . 2.5 2.2.2 Procedure for Identifying Potential SRP Impacts .. .. 2.6 2.3 New and Revised Regulatory Document Analysis . . . .. 2.10 2.3.1 Approach . .. .... .... . . 2.10 2.3.2 Procedure for Routine Regulatory Document Analysis . . . . ... 2.11 1

• 4 Industry-Consensus Codes and Standards 2.12

. .. . . . j 2.4.1 Approach . . . . . . . . . 2.12 2.4.2 Procedure for Codes and Standards citation Maintenance . . . .... 2.13 l

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Contents 2.4.3 Procedure for Codes and Standards Version Maintenance . . .. .. .. 2.13 2.4.4 Procedure for Performing Code Comparisons . . . . . ... . 2.14 3 SRP Maintenance . . .. ... . . . . . . .. .. . . . . .. 3.1 3.1 Integratingimpacts . ... ... . . . . .... .. . .... . . . . ...... .. 3.1 3.1.1 Approach . . . . . . ..... . . .. . 3.1 3.1.2 Procedure for Integrating Impacts . ... .. .. .... .. 3.3 3.1.3 Procedure for Preparing Placeholder Integrated Impacts . . . . . .. . . .... . 3.4 3.2 Identifying the Need for SRP Revisions . .. .. . . .. ... . 3.7 3.2.1 Approach . . . . . ..... . ... .. . .. .. . 3.7 3.2.2 Procedure for Identifying the Need for SRP Revisions . . .. . . .. . . 3.7 3.3 Drafting SRP Sections .. ... . . . . .. .. 3.8 3.3.1 Approach . . . .. . .. .. .. . .. . . 3.8 3.3.2 Procedure for Evaluating Integrated Impacts ... . .. ... .. 3.9 3.3.3 Procedure for Drafling SRP Sections . . . 3.10 4 Review and Approval of SRP Revisions . . . . 4.1 4.1 PRB Review of Draft SRP Sections . . . . . . .. .... 4.1 4.1.1 Approach . .. ... . . . . . . ... . . .. 4.1 4.1.2 Procedure for PRB Review of Drafi SRP Sections . .. . . 4.1 4.2 ConsistencyReview . . . 4.2 4.2.1 Approach ... .. . .. . . . . . . . 4.2 j 4.2.2 Procedure for Performing Consistency Review . . . 4.3 j 4.3 SRP Revision Package Integration . . . . .. . . 4.4 4.3.1 Approach . . . . . .. 4.4  ;

4.3.2 Procedure for Integration of the SRP Revision Package . 4.4 4.4 NRC Review and Approval . .. . . 4.5  ;

4.4.1 Approach . . . 4.5 l

4.4.2 Procedure for Obtaining NRC Review and Approval - Type I Revisions . . . 4.5 l 4.4.3 Procedure for Obtaining NRC Review and Approval - Type II Revisions . .... 4.6 )

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Contents 6t h,. e Review of Work . . . . . . . . . . . . .

. . . . . .. .... .. . .... ... . . . . . . . . . . . ... . . . . . .... 6.1 6.1 Discuamon . . . . . . . . . . . . . . . . . . . . . . . . ... .. .... .. ... .. ........ ... . . . .... 6.1 ,

7 Identification of Candidates for Future Work . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . .. . . . .... 7.1  !

7.1 Discuamon . . . . . . . . . . . . . . . . .. . . .. . . .. . ........ ... ... . . . . . . . . . . . ..... 7.1 7.2 Procedure for Identification of Candidates for Future Work . . . . . . . . .. ...... ..... .. . .......... 7.1 I

Appendoc A - Standard Review Plac Format . . . . . . ... .... . ... . .. ......... .. . . . . .. . . . . .... A.1 Tables P

t 1.1 Chapters of the Standard Review Plan . . . . . . . ..... ..... . . . . . . . . . . . ... . . . . . . . .... 1.2 4.1 R~-n= " _Cm ht ......... ... . . . . . . . . . ..... . ... . . . . . . . . . . .. . . . . . . . . .... 4.8 i

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Executive Summary The Nuclear Regulatory Commission (NRC) Oflice of Nuclear Regulation (NRR) has established a program, the Standard Resiew Plan Maintenance Program (SRP-MP), to address the on-going maintenance of the SRP. This Implementing Procedures Document (IPD) establishes the guidance and procedures to implement the SRP-MP.

The SRP was first issued in 1975 as NUREG-75/087. The SRP was extensively revised in 1981 - 1 3ubsequently issued as NUREG-0800. In 1991 the Standard Review Plan Update and development program (SRP-UDP) was established to update the SRP for use in reviewing future reactor design applications. The SRP-UDP was completed and the revised SRP was issued for public comment in 1996. The SRP-MP was established following the completion of the SRP-UDP to maintain the SRP on an on-going basis.

The SRP and SRP-MP are described in Chapter 1 of this IPD. Chapter 2 describes the methods for periodically identifying and reviewing documents that contain information which is potentially relevant to the maintenance of the SRP. Chapter 3 describes the methods for assessing the need for SRP modifications and developing draft SRP sections. Chapter 4 addmsses the process for the review and approval of SRP sections. Chapter 6 describes independent work review guidelines for SRP-MP tasks. Chapter 7 i other regulatory development activities relevant to the SRP are coordinated with SRP-hF. I In order to produce high quality and consistent SRP modifications, it is intended that NRC stafTas well as contractor staff involved in the modification of the SRP will follow this Implementing Procedures Document.

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ix NUREG-1561

1 Introduction The U.S. Nuclear Regulatory Commission's (NRC's) Stan- which represent new positions and are issued following dard Review Plan for the Review of Safety Analysis Reports public comment.

for Nuclear Power Plants (SRP) provides guidance to the Office of Nuclear Reactor Regulation (NRR) staff in 1991, the Standard Review Plan Update and Develop-performing safety reviews oflicense applications for ;he ment Program (SRP-UDP) was established to update construction, operation, and modification of nuckw power NUREG-0800 for use in reviewing future reactor design plants. The SRP was extensively revised and issued for applications. NUREG-1447,"Starxiard Review Plan Up-public comment in 1996. The NRC has undertaken a date and Development Program - Implementing Procedures

, program to maintain the SRP on an on-going basis. This Document" (IPD), was issued in May 1992 to describe the Implementing Procedures Document contains the approach SRP-UDP and establish the procedures for updating the and procedures for the tasks to be performed in maintaining SRP, Prior to the SRP-UDP, the SRP had not tuxlergone a the SPf. Some of the tasks described in this document will general revision since 1981, although 21 indisidual SRP be performed by NRC staff and others by NRC contractor sections had been revised. The objectives of the SPJ-UDP personnel. However, all regulatory decisions will be made were to update the SRP to reflect the substantial changes in by the NRC. regulation and regulatory guidance that occurred since the 1981 revision of the SRP and to reflect the experience of the safety reviews conducted of design certification applications 1.1 Background and History of the for evolutionary nuclear plants. The revised SRP included

, , several new SRP sections and was issued for public com-SRP, Including ItS Modifications ment in 19%.

The SRP was first issued in 1975 as NUREG-75/087. It In addition to revising the SRP to reflect new regulatory evolved from many years of NRC staff experience in estab- requirements and guidance, the following significant lishing safety requirements and applying them in safety changes were also implemented during the SRP-UDP: (1) evaluations ofnuclear facilities. Use of the SRP as a routine application of the NRC metrication policy; (2) resolution of tool for the NRC staffin the safety evaluation ofnuclear NUREG-0933 Generic Issue B-3, as related to the SRP; power plants was established by NRR Office Ixtter No. 2 (3) reconciliation of TMI Action Plan items; (4) addition of dated August 12,1975. Technical Rationale for Acceptance Criteria; and (5) changes related to the 10 CFR 52 licensing process.

The NRC undertook a major program to resise NUREG-75/087, culminating in a new cdition of the SRP issued in Following preparation of the 19% revision of the SRP for July 1981 as NUREG-0800. This revision program had public comment, the NRC established the Stan<ierd Review three major objectives: (1) to more completely identify the Plan Maintenance Program (SRP-MP) to maintain the SRP NRC requirements that are relevant to each review topic; on an on-going basis.

(2) to more fully describe how the resiew determines that safety requirements have been met; cad (3) to incorporate a number of newly established regulatory positions. T accomplish these objectives and to conform the SRP to the

1.2 Purpose and Scope

of the SRP revised NRR organization, some SRP sections were added' deleted, spht, or combined.

W SRP e - Walitpnd uniformity of staff reviews, to present a well-defined base NRR Office letter No. 800 dated November 24,1987, es- fr m which to evaluate future reactor applications and to Provide the pubhc with NRC,s interpretation of en ac-tablished a Procedure for NRC management approval of ceptable level of safety" for light water reactor facilities.

SRP revisions. Office Letter No. 800 distinguished Type I The SRP makes information about the NRC's approach to revisions, which represent accepted NRC positions and may reactor safety regulation widely available and improves be issued without pubhc comment, and Type Il resisions, understanding of the staff review process by interested 1.1 NUREG-1561 1

i Introduction l

1 members of the public and the nuclear power industiy. In The Safety Analysis Report is the primary means by which short, the SRP plays a primary role in ensunng that the the applicant provides the infonnation to enable the NRC stafTperforms an adequate review and that all plants resiewing staff to determme whether the proposed plant can licensed include those features that are essential to protect be built and operated without undue risk to the health and ,

the public health and safety. safety of the public. This determmation is documented in the Safety Evaluation Report prepared by the reviewing The SRP provides guidance for the safety review ofcon- stafTat the conclusion of their resiew. l stniction permit applications, operating license applications, l

final design approval and design certification applications, and requests for amendment of operating licenses, The SRP currently addresses only light water reactors 1.3 Structure of the SRP (pressurized-water reactors and boiling-water reactors) of The structure of the SRP reflects its purpose and scope. I conventional design.

Each section of the SRP describes a specific review per- ,

fbrmed by the NRC StafT. In general, the numbering of SRP l NRR stafTs safety review of nuclear power plant license ap- '

sections corresponds to the sections of Regulatory Guide plications is based on the mformation provided in the apph-1.70," Standard Format and Content of Safety Analysis cant's Safety Analysis Report required by 10 CFR Section Reports for Nuclear Power Plants - LWR Edition." As 1 50.34--m the case of a construction permit application, the shown in Table 1.1, the SRP sections are grouped into Preliminary Safety Analysts Report; m the case of an chapters, each of which addresses a general topic.

operating license application, the Final Safety Analysis 1 Report. Applications for design certifications and combined The Appendix to this Implementing Procedures Document licenses must meet the techmcal content requirements of prosides a detailed description of the organization and 10 CFR Sections 52.47 and 52.79, respectively, which format for SRP sections. 'Ihe following summanzes the six l incorporate by reference the applicable requirements of subsections of an SRP section: J 10 CFR 50.34.

Table 1.1 Chapters of the Standard Review Plan

1. Introduction and General Description of Plant 11. Radioactive Waste Management

2. Site Characteristics 12. Radiation Protection

3. Design of Structures, Components, Equipment, and Systems 13. Conduct of Operations

4. Reactor 14. Initial Test Program

5. Reactor Coolant System and Connected Systems 15. Accident Analysis

6. Engineered Safety Features 16. Technical Specifications

7. Instrumentation and Controls 17. Quality Assurance

8. Electric Power 18. Human Factors Engineering

9. Auxiliary Systems 19. Severe Accidents

10. Steam and Power Conversion System 1

NUREG-1561 1.2

Introduction '

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i Subsection I- Areas of Review, describes the scope of the provides a basis for orderly modifications of the review review for which that SRP section provides guidance: that process in the future.

is, it specifies what is being reviewed by the NRR branch j having primary review responsibility (primary review The Commission disseminates infonnation regarding cur-a branch) and required input from other review branches rent safety issues and proposed solutions through various (Secondary Review Branch). This subsection contains a means such as generic communications, proposed rules, i description of the systems, components, analyses, data, or proposed NRC regulatory guides, and generic safety issues.

other information on which the review will be based. Areas In the interim period prior to publication of a revir.ed SRP, of Review also contains a sub-subsection, Review safety review ofinformation provided by applicants will

. Interfaces, that identifies the review performed by other also include consideration of these on-going safety issues in

] branches used by the primary review branch in its overall addition to the criteria contained in the SRP. As these 4

review under this SRP section. safety issues are resolved and regulations and guidance are finalized and promulgated, the SRP will be revised as Subsection II- Acceptance Criteria, identifies which necessary An SRP Modification Data Base (MDB)is 4

NRC requirements are applicable, and the specific criteria maintained that identifies these issues and documents i for detemurung the acceptability of the design or the related to the scope of reviews currently addressed in the 4 programs within the scope of the area of review of the SRP SRP.

section. A discussion is provided to describe the safety rationale associated with selecting and applying specific ne SRP will be maintained current by periodic revision to regulatory reqmrements to the area being reviewed in the reficct new NRC reqmrements and guidance relevant to SRP section. licensing reviews. The criteria and procedures for eva!-

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uating the need for SRP revisions are described in Section Subsection III - Review Procedures, identifies the general 3.2 of this Implementing Procedures Document. Until a a

steps that the reviewer is to follow in pedonning the review. revision to the SRP section is published, the NRC will

maintain and publish annually a list of the additional issues t

Subsection IV - Evaluation Findings, states the conclu- that will be considered in the resiew oflicense applications.

sion that the reviewer is expceted to reach following com- ne SRP revision in effect at any time consists of the l pletion of the review. Such a conclusion is included in the published SRP plus these additional issues.

staffs Safety Evaluation Report, which combines the staffs findings under all the SRP sections.

1.5 Purpose and Maintenance of this Subr,ection V - Implementation, provides guidance to ap- .

I plicants and licensees regarding the staffs plans for use of IInP iementing Procedures Document the SRP section and its applicability.

The NRC has established the Standard Review Plan Main-Subsection VI - References, lists the references used in the tenance Program (SRP-MP) to maintain the SRP on an on-review process. g ing basis. This implementing Procedures Document 4

provides guidance, including an overall approach and procedures, for each of the tasks involved in the on-going 4

1.4 Rev. .iSions to the SRP development and maintenance of the SRP. In order to produce high quality and intemally consistent SRP The SRP is intended to provide complete and comprehen- modifications, all NRC staff as well as all contractor staff i

sive guidance for staff review of applicant submittals within involved in the modification of the SRP will follow this its scope. The Standard Review Plan is the result of many Implementing Procedures Document. His Implementmg years of experience by the staffin establishing and using Procedures Document reqmres the recordmg and entry of l i regulatory requirements to evaluate the safety ofnuclear data into the SRP Modification Database (MDB).

power plants and the review of Safety Analysis Reports.

The Standard Review Plan may be considered part of a nis Implementing Procedures Document will be a living l continuing regulatory standards development activity that document used to keep the SRP current. Accordingly, the l

i not only documents current methods of review but also implementing Procedures Document itself will be revised 1.3 NUREG-1561

Introduction I

l over time to reflect the experience and knowledge gained Reviewer refers to the individual who performs an inde- l during its use and to reflect evolving NRC requirements and pendent review of work accordmg to the guidance provided  !

priorities. in Procedure 6.0.

1.6.4 SRP Sections i 1.6 Definitions 1 SRP Sectiorn - for purposes of the SRP Maintenance Pm-1.6.1 NRC Organizations gram, are the fundamental units of the SRP. They contain the complete review procedures for a given review topic.

Each SRP section currently contains six subsections, Generic Issues and Envimnmental Pmjects Branch numbered from I through VI. Some SRP sections include (FGEB) NRR - is the branch responsible for managing the  ;

appendices and Branch Technical Positions (BTPs).

SRP Maintenance Program.

Primary Review Branch (PRB) - with respect to a particular 1.6.5 SRP-MP Process SRP section, is the NRR branch that is assigned primary responsibility for conducting the review within the scope of PotentialImpact - is a discrete requirement, NRC Staff the SRP section. The responsible PRB is specified at the Position, or other item ofinformation identified from analy-beginning ofeach SRP Section. sis of documents that may have relevance to revising the SRP. Potential Impacts are specific to an individual SRP Secondary Review Bmnch (SRB) - with respect to an SRP section. As such, a potential impact defines a relaticatship section, is a branch which has responsibility for certain between a single item ofinformation from a document and a technical issues found in the SRP section, but not the SRP specific SRP section.

section in its entirety. The SRB prosidea safety evaluation input to the PRB. The responsible SRB (s) is/are specified IntegratedImpact - describes an issue that is relevant to re-at the beginning ofeach SRP Section. vision of the SRP. An integrated impact references one or more potentia! impacts and describes how the issue impacts )

1.6.2 Databases the existing SRP. Integrated impacts contain a specific l proposal related to modifying the SRP.

l SRPkfodification Database (MDB) - is the database estab-R'"'3I#" O riP ns Checklist - documents how an issue de-lished to catalog SRP modification-related data and in-formation, to track SRP modification activities, and to scribed an a integrated impact was actually addressed in a i revision to the SRP. The revision options checklist sum-facilitate admmistrative and management control of the SRP manzes the analytical work performed during the develop-Maintenance Program.

ment of the revision, including the resolution of any conflicting infonnation or criteria. The revision options Text RetrievalSystem (TRS) - is the database established to checklist also documents a determmation of tle SRP revi-store full text versions of documents being used in the SRP si n type (see Subsectior ' .6) which establishes review I Maintenance Program. I and approval requirements for the resision.

AutomatedSRP -is the sptem that contains an eletronic copy of the SRP. 1.6.6 Types of SRP Revisions Type IRevisions - revisions that incaporate reqmmments 1.6.3 Position Titles or guidance that have received public comment and have been approved by the Director, NRR and for which Analyst - refers to the individual performing work under any additional public comments are not necessary Changes that procedure except Procedure 6.0 and excluding management are clearly admmistrative or clarifying m nature. Accepted activities (e g., assignment of analysts).

NRC positions are taken from approved regulatory ,

documents including positions documented in Safety i Evaluation Reports. Also included are revisions that l NUREG-1561 1.4

-A- A es a _n 4 A Introduction mcorporate new positions that have been approved by the Director, DRPM, NRR Director, NRR, and by CRGR and EDO as being so clearly i needed that a public comment period would cause

• Approves all SRP revisions and additions.

unacceptable delay in implementing them.

Generic Issues and Environmental Projects Branch Type llRevisions - revisions that incorporate proposed new (PGEB),NRR or revised requirements, positions, or guidance that have not been previously reviewed and approved, including new SRP

• Responsible for the overall management and coordination sections, and are issued for public comment. of the SRP Maintenance Program.

1.6.7 ReactorTerminology Primary Review Branch,NRR Evolutionary Reactors - light water reactors that include

• Responsible for revisions and additions to assigned SRP some advanced design features, but are considered evolu. sections and maintains this primary responsibility even tionary developments of current nuclear plant designs (such when another NRR branch or NRC office performs the as the General Electric ABWR and the ABB/ Combustion majority of the work involved in the revision-Engmeermg System 80+).

• Is responsible for determining whether an SRP section AdvancedReactors - include both passive light water requires revision and selects one of the following options reactors (such as the Westinghouse AP 600, the ASEA / for performing the revision: (1) perfonns the SRP Brown Boveri PIUS, the General Electric SBWR, and the revision in house; (2) enlists a contractor ofits choosmg ABB/ Combustion Engineering SIR) and non-light water to either perform or assist in performing the revision; (3) reactors (such as the AECL CANDU-3, the General requests the Generic Issues and Environmental Projects Atomics MHTGR, and the General Electric PRISM). Branch (PGEB), NRR, to prepare, with contractor assistance, an initial draft of the revision The PRB Future Reactors - refers to both evolutionary and advanced remains responsible for revision of the section, regardless reactors. of the option chosen

• Ensures that the appropriate NRR organizations and other NRC offices are given the opportunity to participate 1.7 NRR Respons.bilities i Regardm.g in the revision of SRP sxtions.

SRP Modifications

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• Reviews all proposed modifications to the assigned SRP NRR staff responsibilities regarding SRP modification are sections to ensure that they are consistent with applicable as follows: NRC policies and guidance.

s Director,NRR

• Coordinates its activities pertauung to revisions or additions with appropriate Secondary Resiew Branches-

= Establishes and coordinates NRR SRP policies, guid-4 ance, and programs. Secondary Review Branch,NRR Associate Director for Inspection and Technical

• Is responsible for an assigned tecimical area with respect

. Assessment,NRR to an SRP section.

= Assigns Pnmary and Secondary Review Branch respon-

• Prosides proposed changes and review and comment on  ;

sibilities for SRP sections to branches within the draft changes prepared by others to tle Primary Review associate directorship. Branchin a timely manner i

1.5 NUREG-1561

2 Identification and Review of Documents j

An important aspect of maintaining the SRP is identifying also describes the procedures that SRP-MP penannel and and reviewing documents that contain reqmrements, other NRC staff use to identify and obtain these docummts.

guidance, staff positions, and other potentially relevant in-formation. Chapter 2 specifies the methods for identifying Documents that meet the following three criteria are likely and reviewing documents that contain information wMeh is to be relevant to maintenance of the SRP:

potentially relevant to the maintenance of the sri'. The information from these document reviews is u.w! in the 1. The document has the potential to provide information subsequent SRP maintenance tasks described in Chapter 3 useful in revising SRP sections for future nuclear power of this Implementing Procedures Document. plant applications, making Type I versus Type II revision detenninations, establishing bases for Chapter 2 is orgamzed as follows: Acceptance Criteria, or revising SRP sections for unique technology or unique applications of existing

• Section 2.1, Documents - the approach is described for technology in future reactor designs.

identifying and obtaining documents pertment to main-taining the SRP. This section also describes the SRP-MP 2. The document contains regulatory requirements, J

Text Retrieval System (TRS) and the procedures for its accepted NRC positions or guidance or othenvise has maintenance. sufficient technical authority to merit consideratial for use in revising or developing the SRP. Dccuments are

• Section 2.2, Identifying Potential SRP Impacts - the generally considered to have sufficient technical

, approach and procedures are described for identifying authority if they meet one or more of the following e

specific SRP potential impacts resulting from the analysis criteria:

ofpertinent documents.

• The document was issued by the Commission or staff l

e Section 2.3,New and Revised Regulatory Document for use by staff or licensees and is generic in nature '

j Analysis - the approach and procedures are described for (this includes reports and generic correspondence).

l performing periodic analysis of new or resised regulatory  ;

, documents added to the Text Retrieval System.

• The document is a formal report of work performcd '

by a contractor for the NRC, has generic application, I

• Section 2.8, Industry-Consensus Codes and Stan- and has been endorsed by the NRC in the licensmg I dards - the approach and procedures are described for process.

identifying new or resised industry-consensus codes and i standards that may be pedinent to maintaining the SRP.

• The document was prepared by an orgamzation that clearly has the expertise to address the technical

issues involved (e.g., vendor reports describing its 2.1 Documenis designs or product lines) and is referenced by the NRC m support of a genene staffposition.

s 2.1.1 Approach

• The document was prepared by indisiduals recog-l nized as experts in their fields or has been peer i information potentially relevant to maintaining the SRP is reviewed by such individuals and has direct ref-A contained in numerous NRC documents as well as doc- erence to NRC generic positions.

uments originating fmm the NRC's contractors, industry, and the technical community. The purpose of Section 2.1 is 3. The document contains information that is generically to describe specific documents that are considered in the applicable.

maintenance of the SRP and the database used in the SRP-MP to collect and work with these documents. Section 2.1 1

4 2.1 NUREG 1561

Identification and Review The SRP-MP Text Retrieval System . Regulatory Guides - Regulatory Guides are published by I the NRC to inform applicants, licensees, the nuclear The SRP-MP Text Retrieval System (TRS) is a searchable industry, and the public of various solutions and full text regulatory document database used in support of approaches to meetmg requirements that are acceptable SRP maintenance activities. The TRS serves the following to the NRC staff. However, they are not the only possible two primary purposes relative to the SRP-MP: solutions and approaches to meeting regulatory  ;

requirements. l

. The TRS supports the analysis of documents for potential l SRP impacts. He TRS has a full text search capability . NRC Generic Ixtters - Generic Letters are prepared to l that aids in this process. inform applicants and licensees of regulatory require-  !

ments related to licensmg and schedules for compliance.

l

. The TRS supports documentation of SRP revisions and These letters include requests for licensee information i the development of new SRP sections. To the extent pursuant to 10 CFR g 50.54(f) and are also used to clarify practical, and consistent with applicable restrictions (e.g., NRC policy. l copyright, proprietary information, etc.), the TRS j contains documents that are referenced by the SRP and . NRC Bulletins - Bulletins transmit information to )

the documents that were used to develop SRP revisions licensees regarding safety, safeguards, or environmental and new SRP sections. matters and may request specified actions and a written response.

J The TRS is intended to be a high-quality database that 1 serves as a useful tool to persons involved in SRP-MP e NRC Circulars - Now discontinued, NRC Circulars were activities and to other NRC staff that find the data and issued to licensees to provide information on a somewhat search capabilities of the TRS useful. The database may less urgent basis than Bulletins. ,

I contain errors and omissions in the documents represented in the database. These errors and omissions result from . NRC Information Notices - Information Notices are practical limitations of the methods used to convert issued to licensees to provide information that may be documents into TRS compatible data formats. The TRS relevant to safety, safeguards, or emironmental issues.

does not replace the documents represented in the database.

Final technical daisions and legal determinations shall be . NUREG-0737 - The TMI Action Plan, issued as made using appropriately controlled versions of the NUREG-0737, describes certam NRC decisions and documents represented in the TRS, and not the TRS alone. actions taken or to be taken as a result of the Three Mile The TRS contains a wide variety of documents, including many of the NRC's principal regulatory documents. The . NUREG-0933 - Summanzes Unresolved Safety Issues, TRS is periodically updated to incorporate the latest Generic Safety Issues, and Three Mile Island action regulatory documents applicable to the maintenance of tne items. His document describes the current status of i SRP. The following document categories contained in the these issues and any actions taken to resolve the issues. l TRS have beenjudged likely to contain documents meetmg the above stated criteria for applicability to the SRP-MP: . Safety Evaluation Reports (SERs) for Evolutionary and Advanced Reactors - These reports document the NRC

• NRC Regulations (Rules)- The NRC's rules in 10 CFR staff resiew of proposed future nuclear plant designs.

Parts 0-199 include the basic regulatory requirements These reports reflect recent staff thinking on a wide range I governing the licensing and operation of nuclear power of safety issues including the application of new l plants. technologies in nuclear plant designs. l

. NRC Policy Statements - From time to time, the NRC Several of the document types included in the TRS will not issues Policy Statements, which authoritatively set forth be directly considered in tasks associated with the SRP the NRC's position on matters within the scope of the Maintenance Program because they are not generic in policy. scope, do not represent staff resolutions ofissues, or do not otherwise meet the three criteria set forth above. Examples NUREG-1561 2.2

Identification and Review of the dmunant types not considered include; Licensee reports issued by other federal agencies (such as the Evat Reports, Systematic A--naat ofLicensee Department of Energy, the Environmental Protection Performance reports, and the NRC Enforcement Manual. Agency, the National Institute of Standards and Technology, the National Oceanic and Atmosphenc Industry Codas and Standards Administration, the Army Corps ofEngmeers, and others), monogrsphs, and conference prauage h SRP, as well as many of the other documents in the Text Retneval System, makes frequent reference to the . NUREG Reports - NUREG reports addreas a variety of codes and arandards of such industry and professional topics that may potentially impact the SRP, These groups as the Amencan National Standards Institute, the documents are formal reports on regulatory, technical, Amencan Nuclear Society, the American Society for Test- and adnunistrative issues ofinterest to the NRC staff, ing and Matenals, the American Society of Civil Engineers, industry, other governmental entities, and the public.

the Amencan Society of Mechanical Engineers, the Institute ofElectrical and Electromes Engmeers, and many others. These other documents do not normally meet all of the pre-viously discussed criteria for documents that are relevant to A listing ofindustry consensus codes and standards refer- the maintenance of the SRP, particularly the criteria related enced in regulatory documents has been developed, and is to generic applicability. These other docaments potentially periodically updated, for the purpose of supporting SRP. impact the SRP when a document that does meet the criteria MP activities. This listing has been published as cites these other documents in a manner that establishes NUREG/CR 5973," Codes and Starulards and Other Guid- generic applicability.

ance Cited in Regulatory Documents " In addition to identifying cited codes and standards, NUREG/CR-5973 Where practical and where copyright restrictions allow, also identifies the latest versions of cited codes and these other documents may be added to the Text Retrieval standards and charactenzes the nature of the regulatory System when it is determined that a specific document is citations for the purposes of SRP-MP activities. relevant to the SRP-MP.

Due to copyright considerations, codes and standards am 2.1.2 Procedure for Routine Maintenance of not incorporated in the TRS. Section 2.4 of this knplement-ing Procedures Document describes how codes and the Text Retrieval Systern standards are addressed in the SRP-MP.

Purpose and Scope of tble Procedure Other Documents The purpose of this procedure is to periodically identify new or revised regulatory documents with potential SRP impacts The SRP and the other documents in the Text Retrieval Sys-and to make these documents available in the Text Retrieval tem contain nurnerous references to documents that support 3

stated positions or otherwise contain related information other than those described above. The following are some Prerequisites for Performing this Procedure examples:

1. b TRS has been established and has been deployed

. Technical Reposts - NRC's contractors as well as reactor vendors and owner groups prepare technical reports that to those sites dere SRP-MP wtivitime #M may support NRC positions or NRC-endorsed guidance

2. Agreements and permissions have been obtained re-or illustrate solutions to safety issues that the NRC staff garding the use and distribution of TRS software and i has found acceptable in the past. As such, these i data (i.e., electronic versions of regulatory documents).

documents may contain potential SRP impacts.

3. Arrangements have been made to convert hard-copy

. Technical Literature - The scientific and technical litera-documents into an electronic format compatible with ture that supports NRC positions may melude the TRS with in-house an&or contractor orgamzations information with potential SRP impacts. This literature under approved procurement procedures.

includes articles in technicaljoumals, staff and contractor 2.3 NUREG-1561

Identification and Resiew l

l Overview of this Procedure 2.1.3 Procedure for Identifying Other The Text Retrieval System has been established to store full j text versions of regulatory documents relevant to main: Purpose ies.and Scope of this Procedure tenance of the SRP in order to facilitate SRP-MP activit The types of regulatory documents that are likely to be This procedure provides a means to identify relevant significant to SRP maintenance have beena _d ntified. As documenu, osa hn eose routindy idenEd unda new documents of these types are issued, concs of these Procedure 2.1.2, that may contain potential SRP impacts.

documents are obtamed m either hard-copy or electroruc Tkse documenu may be iden@d in se cowse of form. These documents are then processed (scanned, performing other SRP-MP activities or by NRC staff not converted, etc.) as necessary and entered in the Text . directly involved in SRP-MP activities. These other Retrieval System. Updated versions of the Text Retneval domb will be addd b k TRS where practical and Syst;m data are then made available to NRC staff and other where adding these documents to the TRS is compliant with staffinvolved in SRP-MP activit es. Documents added t copyright and NRC procedural restrictions. I the TRS under this procedure are reviewed for potential '

SRP impacts under Section 2.3.

This procedure may also be used to accommodate NRC staff requests to add documents to the TRS that are not Procedure specifically relevant to SRP-MP activities but are useful to  ;

. . the staff for other purposes. In this case, the portions of this

1. On at least an annual basis, identify new regulatory pmedwe rdatd b egablishing a document's rdevance 6 documents in the document categories identified m the SRP and reviewing the document for potential SRP Section 2.1.1 that have been issued or revised since the mpacts are not applicable.

last update of the TRS.

2. Determine whether the document is available in elec-

"H" " * ""'" E ""

tronic format from either the organization that

. The prerequisites for performing this procedure are the developed the document, NRC online information m as bse h PmcMwe 2.1.2.

systems, or through a service to which the NRC subscribes' Overview of this Procedure

3. Obtain a copy of the document, preferably in electronic Any NRC staff person may identify documents that may format. In cases where the document is not readily contain potential SRP impacts or may otherwise be relevant available m-house, select a source that best meets SRP-to SRP-MP activities. After being identified, these MP needs (cost, schedde, document format documents are reviewed for relevance to the SRP-MP and a compatibility, etc.).

determination is made as to the practicality ofincorporating

. the document in the TRS. The documents in this category

4. If the document is a hard-copy, arrange to have the can be originated by wide variety of different sources and document convened to an electrome format compatible '

may contain information that must be restricted in some we h TRS. manner. As such, it must be established that the document ,

. can be included in the TRS within copyright and NRC

5. Prior to entering newly converted documents m the pmedad :enrictim h osa documenu are kn TRS database, take reasonable steps to ensure the con-either added to the TRS using the applicable portions of vend version of the document accurately represents Procedure 2.1.2, or a copy of the document is housed in the se n,gm, aldocument.

SRP-MP library. ,

6. Transfer the new or revised documents to the TRS database and create updated search indexes of the I revised document set. l

7. Update the TRS data at all online sites.

i l

NUREG-1561 2.4 t l

l i

Identification and Review r

Procedure 6. The document should be reviewed for potential SRP impacts as follows.

1. Requests to consider a document for potential SRP im-pacts may be made by NRC staffin person, by a. If analysis of the document for potential SRP telephone, orin writing. impacts is not likely to involve substantial resources '

l l beyond that required for nonnal periodic SRP l

2. Determine if the document meets the criteria of Section maintenance activitics, analysis of the new

• 2.1.1 regarding the likelihood of the document con- document may be incorporated in the periodic taining potential SRP impacts and verify that the docu- analysis activity described in Section 2.3.

ment has not been previously reviewed for potential SRP impacts. b. If analysis of the document will involve substantial resources that cannot be -nmmadated within the

3. If the document does not meet the criteria for docu- routme scope of Section 2.3, analysis of the ments likely to contain potential SRP impacts or, if the document should be addressed as a Candidate for l document was already reviewed, notify the requester Future Work. Procedures for addressing Candidates immediately what actions have already been taken with for Future Work are provided in Chapter 7.0.

l regard to the document. No further action is required I under this procedure. 7. Inform the requestor of actions taken or planned to  ;

l review the identified document for potential SRP i

! 4. If the document is not available in-house: impacts.

d. Determine the document source to be used. Select l l a source that best meets SRP-MP needs (cost, schedule, document format compatibility, etc.).

2.2 Identifying Potential SRP Impacts l

i

b. Make necessary arrangements for obtaining the 2.2.1 Approach document. Procurement will be accomplished in accordance with established procedures. This section describes the process used to identify potential SRP impacts contained in documents described in Section

5. Where practical, documents identified under this 2.1. The term " potential impact" is used in the SRP-MP to ,

procedure should be added to the TRS as follows: des ribe the result ofidentifying a document, or portion of a document, that may be relevant to maintaining the SRP.  !

a. If the document is not sourced from the NRC, Potential impacts identified under this procedure hr a the determine if the document can be incorporated in f 11 wing significant characteristics: '

l the TRS within copyright restrictions. Obtain any .

required permissions or agreements from the . A p tendalimpact addresses a single topic (regulatory  ;

originator of the document. reqmrement, NRC Staff position, or other item of information) relevant to maintaining the SRP.

l b. Verify that the document can be incorporated in ,

the TRS within NRC policy and procedures. . A p tential impact is related to a specific SRP section.

Documents in the TRS shall not contain propri- .

etary or pre-decisional information. . Potentialu.npacts are identified in a liberal manner, a potential impact, in-and-of itself, does not establish a

c. Process as necessary and add the document to the nzd to revise the SRP.

TRS per the applicable portions of Section 2.1.2.

j Potential impacts are used to identify links between docu-If the document is not added to the TRS, a copy of the ments relevant to maintaining the SRP and specific SRP i document should be retained in the SRP-MP library, sections. Potential impacts facilitate the process of ,

determuung the need to revise an SRP section or develop  !

new SRP sections. Once the need to revise the SRP is de-2.5 NUREG 1561 )

l

-- - -. - ~ - .. - - _.- - _ .-. - - - - - - - . . -.

l l

)

Identification and Resiew l

l l

I termmed, potential impacts facilitate the analytical work  ::~;tians. several potential impacts should be created. As an necessary to prepare and document changes to the SRP. example of the foregoing,, ccrMer 10 CFR 50.44. This

! regulation contains a number of requirements %=di.n g A potential impact must meet one or more of the following combustible gas control. Two of those requirements l criteria relative to one or more SRP sections: (among a number of others) include the prmision of hydrogen recombiners and training in the use of the

1. Contains establMhed staff positions, guidance, or gen- recombiner equipment. Recombiners are appropriately eric requirements directed at applicants or licensees addressed in SRP Section 6.2.5; training in SRP Section l 13.2. Therefor e, $50.44 should result in at least two

2. Contains conclusions or recommendations suggesting different potential impacts. (In actuality, this regulation i that current requirements or guidance are inadequate, would result in additional potential impacts if all  !

I overly restrictive, or otherwise need some revision. requirements contained therrin were considered.) i

3. Contains design or analysis information, or evaluation All potential impacts should be identified and recorded, and of design or analysis information, that can be used in there should be a reasonable expectation that the potential establishing licensing requirements for evolutionary impact will relate in some way to an actual change to the reactor designs. SRP. A potential impact that appears somewhat insignificant when viewed in isolation may be important

4. Contains design or analysis information, or evaluation when considered in the context of other related potential of design or analysis information, that can be used in impacts. Correlation of potentialimpacts and the establishing licensing requirements for future reactor climination ofinsignificant potential impacts are addressed designs. in Section 3.1.

5. Contains design, operational, or analysis information, Two different methods ofidentifying potential impacts are or evaluation of design, operational, or analysis described in this procedure. The first method, called the  ;

information, that can be used in establishing technical " document-to-SRP method," requires that documents bc ,

rationales for SRP Acceptance Criteria. reviewed in their entirety by analysts in order to find l potential impacts. The analyst then uses the Text Retneval

6. Contains backfit or other analyses, or requirement System to assist in correlating potential impacts with the approvals that can be used in making Type 1/f 3pc 11 SRP sections that may be affected. The second method, l SRP change determinations. called the "SRP-to-document method," identifies potential impacts associated with a given SRP section through use of ,

The above six criteria are a more specific version of the electronic key-word searches of the TRS based on the l three criteria discussed in Section 2.1.1. These six criteria content of that SRP section. The "SRP-to-document  !

are based on the specific uses envisioned for the information method" requires that documents being reviewed for to be collected in SRP-MP program work, potential impacts be entered in the Text Retrieval System and the " document-to-SRP method" does not. Both of these Each potential impact identified should address a single methods are described in this procedure topic. The topic may be broadly or narrowly defined by the analyst, depending on the nature of the subject, the re- 2.2.2 Procedure for Identifying Potential lationship of the potential impact to the SRP, and the SRP Intpacts judgment of the analyst identifying the potentialimpact. If a given document or part of a document meeting any of the Purpose and Scope of this Procedure i six review criteria addresses more than one topic, a separate i potential impact should be identified for each topic This procedure establishes guidance for reviewing docu.

addressed. ments to identify potential SRP impacts. It provides criteria for performing this review and a methodology to assist in In general, the entirety of a potential impact should apply t assigning potential impacts to the specific SRP sections they the SRP section to which it is assigned. In cases where affect.

different issues m a document apply to different SRP l l NUREG-1561 2.6

- . _ - . . _ . . ~. _ - - - -.. _- - --- . _ _ _ - _

i

Identification and Resiew 4

i Prerequisites for Performing this Pmcedure impact cannot be correlated to any existing SRP

section:

1. The Text Retrieval System, described in Section 2.1, is available. a. Select an SRP section that provides the best cor-

, relation between the subject of the potential impact

2. Doemnents to be reviewed for potential impacts have and the SRP. This section will be used as basis for been identified and obtained es described in completing the required potential impact Section 2.1. documentation.

Overview of tble Procedure b. Document the need to consider new SRP content development by completing a Research/ Regulatory Potential impacts are identified using either a " document- Action Need Form in accordance with to-SRP" or "SRP-to-document" method. In the Chapter 7.0.

" document-to-SRP" method, the analyst identifies potential impacts in a specific document and then, using the analyst's 4. Create a potential impact for each identified document-knowledge of the SRP or by performing searches of the to-SRP section link. Record results of the review on Text Retrieval System, identifies those SRP sections that the Potential Impact identification Form or enter the may be affected. In the "SRP-to-document" method, the information directlyin the MDB.

analyst reviews a specific SRP section and then searches a defined set of documents for potential impacts using the 5. If a Potential Impact identification Form was used, search capabilities of the Text Retrieval System. submit the form for data entry.

Potential SRP impacts are identified and assigned to SRP-to-Docmnent Method specific SRP sections by an analyst using the analyst's knowledge andjudgement. The process is assisted by the 1. Review the assigned SRP section and develop search use of the Text Retrieval System (TRS). The potential strings to be used m TRS document searches.

impacts are recorded either on a form or directly in the SRP Modification Database (MDB). Potential impact forms are 2. Perfonn TRS scarches using the search strings retained until such time that the data is entered in the MDB. developed in St.p 1.

Independent verification is performed in accordance with Chapter 6.0. 3. Review each sewch " hit" identified in the TRS stored text.

Procedure

4. Create a potential impact for each identified document-Document-to-SRP Method to-SRP section link. Record results of the resiew on the Potential Impact identification Form or enter the

1. If using a TRS version of a document for the potential information directly in tle MDB.

impact review, verify that the document is complete (i.e., all referenced attachments and enclosures are 5. If a Potential Impact identification Form was used, present). If necessary, obtain a hard<opy of the submit the form for data entry.

document.

Forms

- 2. Identify any potential impacts contained in the docu-ment being reviewed by applying the six review criteria The Potential Impact identification Form serves to record described in Section 2.2.1. data that will be input into the SRP Modification Database.

Use of the form is not required if the analyst records the

3. Assign each potentialimpact to the appropriate SRP data directly in the MDB. All organizations implementing section(s). If helpful, create search strings for each this procedure must record their work either on the potential impact and use the TRS to assist in correlating indicated form, an altemate form that incorporates tie same potential impacts with SRP sections. If the potential information, or directly in tie MDB.

2.7 NUREG-1561

1 l

b 6

Identification and Review i

l I

Potential Impact identification Form l

l Assigned Analyst 1

l Document Identification )

i Document No  !

9 j

Document Title ,

1 i

Document Revision Document Date -

I Impact Identification  !

Impacted SRP Section No.  !

)

t Reactor Type _,

Impact Size and Location:

[

?

Entire Document Block: From To  !

Impact Summary l l

?

l I

t NUREG-1561 2.8 L I

Im-b and Review Potential Impact Identification Form (Continued)

TRS SearchIndex(es)

TRS Search Strings I

i l

l Impact Criteria:

1. Staff position, guidance, or requirement

2. _ Suggestion that requirement or guidance needs revision

3. Information that can be used for establishing criteria bases or licensing requirements for evolutionary reactors

4. Information that can be used for establishing criteria bases or licensing requirements for advanced reactors

5. Information that can be used for establishing technical rationales for Acceptance Criteria

6. Information that can be used for making Type 1/fype II determmations Analyst Signature Date Data Entry Information MDB Assignment Number PotentialImpact Number

• 2.9 NUREG-1561 l

I klentification and Review

(

l How to Complete the Form potential impact summary convey suflicient information to ensure that another analyst will understand how the The following are summary instructions for completing the potential impact was intended to relate to the content of the  ;

Potential Impact Identification Form. More detailed SRP section.

instructions, including instructions for entering data directly

( in the MDB, is available in the MDB user's manual. TRSScarch Inder(es)/I'RSSearch Strings 'the TRS search index(es) and search strings used that resulted in the l AssignedAnalyst - Person's name that identified the identification of the potential impact. This field is only used ;

potentialimpact. for potential impacts identified using the SRP-to-Document l method (enter "None" in this field if the Document-to-SRP Document No. - A number that uniquely identifies the method was used). Search indexes indicate the scope of document (e.g., GL 94-01) that contains the potential documents marched and the revision of the TRS data used l impact. For regulatory documents, use document type during the search.

prefixes that correspond to document type codes used in the i l

MDB (refer to MDB user's manual). Impact Criteria - Indicates the pertment potential impact criteria. Check all criteria that apply; however, at least one l Document Title - Title of the dmument that contains the criterion must be checked. Some guidelines regarding the potentialimpact. assignment ofimpact criteria are:

Document RevistorvDocument Date - The revision and/or . Most potentialimpacts are assigned impact criterion I date of the document that contains the potential impact. and/or 5.

ImpactedSRP Section No.- The number of the SRP section . Potentialimpacts associated with CFRs, Regulatory I

impacted. Guides and Policy Statements are normally assigned an impact criterion 1.

Reactor Type - Normally the reactor type should be con-sistent with the reactor type associated with the SRP section . Generic letters are assigned an impact criterion 1 if the (Generic, Generic PWR, or Generic BWR). If the potential Generic letter includes a staff position or guidance.

impact is being developed from a Safety Evaluation Report (SER), the reactor type should be consistent with the . Impact criteria 3 and 4 are assigned for potential impacts specific reactor type being addressed by the SER (ABWR, that only afTect future reactor designs. i CE80+, or others as may be added to the MDB). J AfDB Assignment Number /PotentialImpact Number - This l I

Impact Sire andLocation - This information is used to information is created by the MDB during data entry and indicate if the entire document or a specific portion of the used to uniquely identify the potential impact.

document forms the basis of the potential impact. Do not over-use the Entire Document designation. If more than 2.3 New and Revised Regulatory one location in the document relates to the potential impact, multiple locations can be identified.

Docuntent Analys.is Impact Summary - This field provides a brief one or two 2.3.1 Approach paragraph description of the impact. If the potential impact i I

is identifying a concise requirement, criterion, or recom- Maintaining the SRP requires that new and revised regula-mendation, simply state the information as it appears in the tory documents be identified and reviewed for potential SRP document. If the potential impact involves a complex cet of impacts. Section 2.1 describes how documents are information, usejudgement and develop a summary with an identified and the process of updating the Text Retrieval appropriate level of detail. Potential impacts will be System. As relevant documents are identified, they are integrated to establish the basis for possible changes to the either reviewed for potential impacts as part of tim routine SRP as described in Section 3.1. It is important that the SRP-MP activity described in this section or a special analysis task is developed. Identified potential impacts are NUREG-1561 2.10

Identification and Review then evaluated to determine if there is a need to revise the described in Section 2.1. Following each TRS update, a list SRP as described in Chapter 3. is developed of the new or revised regulatory documents that have been am to the TRS. His list ofdocuments is Any documents identified in accordance with Section 2.1 then subjected to a screemng process to identify those may be reviewed under this process; however, new or re- documents that have an application with respect to SRP.

vised documents of the following types periodically added MP. A review for potential impacts is then perfonned in to the Text Retrieval System are normally evaluated: accordance with Section 2.2. Independent verification is performed in accordance with Chapter 6.0.

. NRC Regulations (Rules)

Pmeedure

. NRC Policy Statements

1. Following each TRS update, a special TRS index is

. Regulatory Guides developed that indicates those documents in the TRS that have been added or updated. The index is referred

. NRC Generic Letters to as the " delta index." Using the TRS, print a list of all documents identified in the delta index.

. NRC Administrative Letters

2. Delete any documents from the list that are not associ-

. NRC Bulletins ated with the document types identified in Sec-tion 2.3.1, except draft Regulatory Guides.

PGEB makes the determination if an identified document is reviewed under this procedure or if a special analysis task 3. Screen each document identified on the list resulting should be developed. In general, documents that require from Step 2 by resiewing the document list and identi-extensive resources to review or involve unique review fying those documents that have no obsious application criteria are addressed under special analysis tasks (e.g., the with respect to the SRP (e.g., a Regulatory Guide analysis of a Safety Evaluation Report issued in support of a applicable to fuel manufacturing plants).

design certification application). In any case, the resiew process of Section 2.2 is used to perform the actual 4. Perform a detailed review of each remaining document document analysis. on the list for potential SRP impacts using the Document-to-SRP method of Section 2.2.

2.3.2 Procedure for Routine Regulatory Document Analysis 5. For each potential impact identified, determme if work is currently in progress to revise the relevant SRP Purpose and Scope of this Procedure section in accordance with the procedures of Chapter 3.

If any such work is in progress, notify PGEB. PGEB  ;

This procedure establishes guidance for reviewing new or will make the determination if the potential impact j revised regulatory documents to identify potential SRP should be addressed within the scope of the m-progress impacts. This procedure is normally perfomied anytime the revision efTort or deferred to the next SRP revision Text Retrieval System data is updated. "YCIC*

Prerequisites for Performing this Procedure 6. D cumentation resulting from the performance of this task are the potential unpacts developed during the The Text Retrieval System has been updated to include new review fnew w mvised mgulatmy documents added j

to the TRS. The potential impacts may be recorded on or revised regulatory documents as described in Section 2.1. i Potential Impact identification Fams (Section 2.2), or entered directly in the SRP Modification Database Overview of this Procedure (MDB).

The Text Retrieval System (TRS) is periodically updated to incorporate any new or revised regulatory documents as 2.11 NUREG-1561

Identification and Review 2.4 Industry-Consensus Codes and ment 8 'el8ted to the cit 8 tion 8ad (5) current version and date of the cited code or standard.

Standards The status ofindustry codes and standards citations are 2.4.1 Approach subject to continual change. Industry codes and standards are continually evolving. Also, the publication of new and Codes and standards referenced in regulatory documents revised regulatory documents result in citation of additional provide many of the specific acceptance criteria presented codes and standards, or may change information related to in the SRP. As part of the SRP-MP, codes and standards an existing citation. Accordingly, the SRP-MP codes and cited in regulatory documents are periodically re-evaluated standards citations database must be periodically updated.

to ensure that the most appropriate code and standard Procedures 2.4.2 and 2.4.3 of this section describe the revisions are used in the SRP, process used to maintain the database.

Industry-consensus codes and standards are developed in The data contained in the database have been published as the following process. The participating members of a NUREG/CR-5973," Codes and Standards and Other standards-writing group who represent the various interests Guidance Cited in Regulatory Documents." The data are of that industry (e.g., product manufacturers, material published to make the information readily available to manufacturers, product users, utilities, insurers, designers, indisiduals who might fmd this information useful and to constructors, consultants, and regulators, whether local, facilitate obtaining comments regarding the contents of the regional, or national) develop a standard. An database. NUREG/CR-5973 is revised periodically to' industry-consensus process does not approve, recommend, reflect changes made to the database.

nor endorse any specific or proprietary design or manufacturing process The standards-writing group Codes and Standards Comparisons members regularly meet on a formal basis to consider re-visions of the current requirements, requests for inter- Changes in the status ofcodes and standards can impact the pretation of current requirements, and new requirements as appropriateness of citations in the SRP or regulatory dictated by technological development. The industry- documents referenced in the SRP. In the course of main-consensus process satisfies the separate and distinct needs, taining the SRP-MP codes and standards citations database, requirements, and interests ofits participants through a changes in the status of codes and standards cited in the process of aniving at mutually agreed-upon rules. SRP and other regulatory documents are identified. These changes in status may result in a need to compare a code or NRC regulatory documents may endorse, either in whole or standard, or referenced portion of a code or standard, with in part, industry-consensus codes and standards "F#dorse" the latest version. These comparisons, referred to as " code in this case, means that the solutions and approaches comparisons," contain detailed descriptions of the contained therein are acceptable to the NRC staff, but that differences between the cited version of a code or standard they are not required as the only possible solutions and and the current version. Code comparisons also contain any approaches. recommendations regarding appropriate changes to the regulatory documents citing or endorsing the code or Malatenance of the Codes and Standards Citation standard, including changes to qualifications that may be Catabase associated with the endorsement. The nent to perfonn a comparison is identified and evaluated s a carxtidate for A database of NRC regulatory document industry codes and future work in accordance with Chapte 7.0. Procedure standardi citations is maintained as part of the SRP-MP for 2.4.4 of this section describes the process for performing a the purpose of supporting SRP-MP actisities. Information code comparison.

presented in the database includes the following: (1) the code or standard title, number, and date; (2) the NRC Changes in the status of cited codes and standards, pendmg document containing the citation and date; completion of a code comparison and resolution of the code (3) characterization of the citation, including whether the comparison recommendations, are documented in the SRP NRC document endorses the code or standard; (4) com- Modification Database. This is accomplished by creating a NUREO 1561 2.12

Ideathatha and Review

" placeholder" integrated impact in accordance with 2. Using the TRS, search the latest regulatory de=nent Section 3.1. index using appropriate search strings to identify all documents that contain codes and standards citations.

2.4.2 Procedure for Codes and Standards Citation Mainienance 3. Review each document in the TRS sean:h result list and identify those documents that are not currently recorded Purpose and Scope of this Procedure in the SRP-MP codes and standard database.

This procedure establishes guidance for periodically re- 4. Review each search " hit" in the documents identified in viewing new or revised regulatory documents to identify Step 2 toidentifynew citations, new or revised citations of codes or standards in the SRP or other regulatory documents. This procedure is normally 5. For each new code or standard citation, create a new performed prior to the update of NUREG/CR-5973, but SRP-MP codes and standard database record.

may be done more frequently (e g., when the Text Retrieval System data are updated'# 6. Dannent canpletion of the task by cmating a repost of all new citation records added to the database Parequisites for Performing this Procedure 2.4.3 Procedure for Codes and Standards

1. The Text Retrieval System has been updated to include Version Maintenance new or revised regulatory documents as described in Section 2.1. Purpose and Scope of this Procedure

2. An up-to-dste index is available that indicates the latest This procedure establishes guidance for periodically up-published versions of standards for all the industry code dating the latest code and standard version data contained ta groups currently identified in the SRP-MP codes and the SRP-MP codes and standard database. This procedure standard database. is performed at least annually.

3. The SRP-MP codes and standards citations database is Prerequisites for Performing this Precedure available at the location where this procedure is to be perfonned. 1. An up-to-date index is available that indicates the latest published versions of standards for all the industry code Overview of this Procedure groups currently identified in the SRP-MP codes and standard database.

The Text Retrieval System (TRS) is periodically updated to incorporate any new or revised regulatory documents as 2. The SRP-MP codes and standards citations database is described in Section 2.1. At least annually, the TRS is available at the location where this procedure is to be searched for any new code or standard citations contained in performect.

new or revised regulatory documents. New citations identified are then recorded in the SRP-MP codes and Overview of this Procedure standards citations database. Independent verification is performed in accordance with Chapter 6.0. Data regarding the latest versions ofcited codes and stan-dards listed in the SRP-MP codes and standarcis citations Procedure database are reviewed and the database is updated using latest available information. Any changes to the latest

1. All changes made to the SRP-MP codes and standard version of a code or standard are evaluated for relevance to database data during the performance of this procedure the SRP-MP. Recommendations are then developed to shall be made to appropriately controlled versions of perform code comparisons, as necessary Independent the database. verification is performed in accordance with Chapter 6.0.

2.13 NUREG-1561

Identification ard Review l

Procedure 2.4.4 Procedure for Performing Code '

Comparisons

1. All changes made to the SRP-MP codes and standard database data during the performance of this procedure

shall be made to appropriately controlled versions of Purpose and Scope of this Procedure )

the database.

This procedure establishes guidance for performing a com- l parison ofcodes and standards cited in regulatory

2. For each unique code or standard in the database, documents with the cu: Tent version of the codes and determine the latest version and/or date of the standard standards.

and compare with information contained in the database.

Prerequisites for Performing this Procedure

3. Update cach citation record in the database, as A need for a code comparison has been identified in accord- I necessary, ance with Procedure 2.4.3 and the need has been documented and evaluated per Chapter 7.0.

4. For each updated code or standard citation, determine if the update affech a code or standard referenced in the Overview of this Procedure SRP or a Regulatory Guide cited in the SRP. If so, perfonn the foDowing:

The cited version and the current version of the code and standard are compared and a code comparison document is

a. Determine if a Research/ Regulatory Action Need prepared. The code comparison is published to allow an Form (as described in Chapter 7.0) currently exists opportunity for public comment on the comparison and its to recommend performance of a code comparison recommendations. Following a public comment review l for the cited and current versions of the code or period and review by cogmzant NRR technical branches, standard.

the recommendations relevant to SRP are documented as potential SRP impacts in accordance with Section 2.2. The i

b. If such a recommendation exists, update the Reg- 1 potential impac ' are later evaluated and incorporated in ulatory/Research Action Need Form and any SRP revision process described in Chapter 3. Independent related integrated impact (s) to mdicate the latest verification is performed in accordance with Chapter 6.0.

code or standard vers,on.

i

c. If such a recommendation does not exist: .

1. Obtain copies of the cited version and the latest version (1) complete a Research/ Regulatory Action Need  !

of the code or standard to be compared.

Form to recommend performance of a code com- 1 parison for the cited and current versions of the 2. Compare the current version of the code or standard I code or standard m accordance with Chapter 7.0. with the referenced version and develop a code com-parison document. The code comparison document (2) document the code comparison recommenda- should contain the following elements:

tion m the SRP Modification Database by creating an integrated impact that references the ResearcW

a. Identification of the cited code or standard.

Regulatory Action Need Form m accordance with Section 3.1. b. Identification of the current code or standard.

c. Identification of existing regulatory citations of the i code or standard. I

d. Characterizationofeachregulatorycitation. This includes to what extent the code or standard was NUREG-1561 2.14 i

Identification and Review endorsed and any exceptions that are stated in the 3. Submit the code comparison document to PGEB for regulatory document (s).

review and comment. PGEB will review the document for consistency with previously prepared code

c. Detailed side by-side comparison of the current comparison documents and coordinate or perform any and cited versions of the standard. The compari- other reviews deemed appropriate based on the nature son will identify any significant diffe.ences of the code comparison.

between the two versions. A significant difference is:

4. Resolve PGEB comments and revise the code com-parison as necessary.

a substantive change to a portion of the code or standard that the NRC has relied upon to establish 5. Submit copies of the fmal code comparison to cogni-a position in the regulatory document. Specifically zant NRR technical branches for comment.

in the case of SRP citations, a change is significant ifit affects a portion of the code or standard relied

6. Publish the code comparison document. The published upon as the basis for SRP acceptance criteria; or version should include a description of the reason for performing the comparison and should solicit public the addition of substantive new information or cri- comments.

teria within a code or standard that has been endorsed either in whole, orin part. 7. After receising comments from the cogmzant NRR technical branches and allowing a sufficient interval for

f. Discussion of differences. This section describes public comment, resolve the comments and revise the the rationale in making significant/not significant code comparison as necessary difference determmations.

8. Publish the revised version of the code comparison.

g. Recommendations that address each regulatory citation associated with code or standard. 9. Create potential impacts for each SRP recommendation contained in the final comparison in accordance with Section 2.2.

2.15 NUREG-1561 r_ -.

J 4

3 SRP Maintenance l

This chapter describes the approach and procedures for initial draA of the revised SRP section and associated

maintaining the SRP for use in the review of future reactor documentation for its review and approval.

license applications to reflect current NRC requirements

) and guidance. The final draft of a revised or new SRP section will be

considered a PRB product, without regard to which of the

! Chapter 3 is organized as follows: above optionsis chosen.

i'

, e Section 3.1," Integrating Impacts"- describes the Documentation of Changes to the SRP Not Prepared

process of developing specific recommended changes to Under the SRP-MP  ;

the SRP based on the evaluation of potential SRP 3 impacts. Sections 2.2,3.1, and 3.3 of this Implementing Procedures

Document describe the SRP-MP process ofrevi; wing e Section 3.2," Identifying the Need for SRP Revi- documents for potential SRP impacts and processing these sions" - describes the process for determuung the need to potential impacts to the point of preparmg a draA SRP j create new SRP sections or revise existing SRP sections section and associated documentation for PRB review. As 1 as a result of the evaluation of SRP impacts (resulting described in Section 3.2, revisions to the SRP may result l

from processes described in Chapter 2 and Section 3.1) from work being performed under programs other than the or in response to NRC staffrequests. SRP-MP.

A

• Section 3.3," Drafting SRP Sections"- describes the Changes to SRP prepared under other programs are doc-

process for, evaluating integrated impacts, drafting re- umented in the SRP Modification Database in the same way vised or new SRP sections, and documenting the analysis that changes to SRP under SRP-MP are documented;

, work associated with drafi SRP section development, however the methodology of arriving at the draft SRP and j supporting documentation may be reversed (i.e., Revision l Participation by Primary Review Branches Options Checklists and associated potential impacts are 4

developed by analysis of a draft new or revised SRP  ;

Regardless of who performs work related to preparing new section).

or revised SRP sections, the designated Primary Review l Branch (PRB) for each section is ultimately responsible for j the technical content of : hat section.

3.1 Integrating Irnpacts i The PRB reviews the integrated impacts identified in Sec-tion 3.1. The PRB can delete, modify or add integrated 3.1.1 Approach

+

impacts as necessary. Once integrated impacts are approved and the need for a new or revised SRP section is g,  ; g  ;

i identified, three options are available to accomplish the p tential SRP impacts and establish specific recommenda-l work of developing a draft SRP section: nons for changes to the SRP Es activity achims the following objectives:

4 1. The PRB may perform the work in-house.

te k htihaidin potentialimpacts i

2. The PRB may enlist a contractor ofits choosing to by grouping related potential impacts and identifying assist in performing the work. p tential impacts that are not relevant to revising g

3. The PRB may request that PGEB arrange fri the work .

a Develop specific recommervhiion(s) with resp to to be done, assisted by PGEB's contractor. If this option is used, POEB will provide the PRIl with the revising the SRP. (Detailxl analysis associated with u, n-4 f

3 3.1 NUREG-1561 i

i

. _ . _ . -y. .

SRP Maintenance plementing the recommendation is performed in accord- document on-going issues that have the potential for ance with section 3.3.) significant future impacts on the content of the SRP. These integrated impacts serve to identify issues that may be

. Identify any conflicts between potential impacts that may relevant in licensing reviews, but have no established need to be addressed. generic resolution. The following are examples of such integrated impacts.

. Characterize the amount of effort that is likely to be required to implement the recommendation. Codes andStandards Placeholders - As described in Sec-tion 2.4, new versions of codes and standards currently cited The tasks involved are described in more detail in the in regulatory documents are issued by standards organi-following paragraphs: zations. Placeholder integrated impacts identify the dif-ferences in cited and current versions of those codes and Integrating the information contained in potential impacts is standards that are detennined to be relevant to SRP resiew accomplished by reviewing the documents associated with criteria. These integrated impacts document recom-potential impacts, grouping related potential impacts into mendations and decisions made regarding code com-specific topics that relate to possible SRP changes, and parisons and the cunent status of related code compansons discarding potential impacts that are determined not to be Once code comparison process has lx:en completed as relevant to changing the SRP. described in Section 2.4, the integrated impact is updated to reflect the fmal resolution.

Aner integrating potential impacts, a recommendation to revise the SRP is developed. The description of this recom- Draft Regulatory Guide and ProposedRule Placeholders -

mendation is referred to as the impact summary. This Draft Regulatory Guides and Proposed Rules may identify description is usually two to three paragraphs in length that safety issues for which there are proposed solutions, but no includes a description of the issue, how the issue relates to currently approved generic resolution. These issues may be the SRP section, NRC action to address the issue, and a relevant to licensing reviews and may indicate the need to general summary of the proposed changes to the section. establish case-by-case resolutions for the purpose of reaching safety conclusions. Integrated impacts are There may be occasions during the grouping of related developed to identify drafi Regulatory Guides and Proposed potential impacts that a conflict is identified in information Rules that are determined to be relevant to licensing resiews presented in potential impacts. Any such conflicts are desenbed in the SRP. Once the Regulatory Guide or Rule described in the impact summary discussion. These con- is finalized and approved, the integrated impact is updated.

flicts are identified, but not resolved, at this point in the process. Future WorkItem Placeholders - During the course of SRP-MP activities, the need for new regulatory documents, After developing the recommendation, the amount of elToit or for revisions to existing regulatory documents (including that is likely to be required to implement the recom- the development of new SRP content), are identified that are mendation is identified, not within the scope of the SRP-MP. These needs are identified and tracked as candidates for future work in The process for evaluating potential impacts and developing accordance with Chapter 7.0. Integrated impacts are integrated impacts is described in Section 3.1. The developed for those SRP sections that are likely to be integrated impact process is documented by completing an affected by work identified in candidates for future work. I Integrated Impact Form. The Integrated Impact Form Codes and Standards Placeholders described above are a included in this section is a hard-copy representation of data specific form of this type ofintegrated impact. In addition normally entered directly in SRP Modification Database. to identifying issues that may need to be considered in I licensing reviews, as previously discussed, these integrated Placeholder Integrated Impacts impacts also serve to help prevent duplicate potential impact identification, analysis work, and needs identification In addition to providing documentation of potential impact for those issues that have already been identified and for analysis and a mechanism to present recommended changes which solutions have already been proposed.

to the SRP, integrated impacts may also be developed to NUREG-1561 3.2

SRP Maintenance l Procedure 3.1.3 describes the process for developing 3. Perform a potential impact /section consistency check placeholder integrated impacts. by completing the Potential Impact /Section Conhncy Form or by entering data directly in the MDB for each 3.1.2 Procedure for Integrating Impacts potential impact. Indicate the need to retain each potential impact for further evaluation by answering the Purpose of this Procedure questions indicated on the form or in the database. Ifit is determined during this process that a potential impact This procedure describes the process for evaluating poten. was incorrectly assigned to the SRP section, create a tial impacts on a section-by-section basis, that have been related potential impact for the appropriate SRP section identified for an SRP section as described in Section 2.2 and and record the new (replacement) potential impact l developing recommendations for changes to the SRP. The number in the disposition comments for the original results of this procedure are used as a starting point for Potentialimpact. i evaluating the need for SRP revisions (Section 3.2,) and for draft section development (Section 3.3). 4. Review the potential impacts and group them into specific topics relevant to the revision of the SRP.

Prerequisites for Performing this Procedure

5. Identify any conflicts among potential impacts in each Potential impacts have been identified for the assigned SRP topic group.

section as describal in Section 2.2 of this Implementing Procedures Document and the potential impacts have been 6. From anahsis of the potential impacts in each topic entered in the SRP Modification Database. group, develop a specific recommendation related to the revision of the SRP.

Overview of this Procedure

7. Develop an integrated impact summary description.

On a section-by-section basis, potential impacts related to The summary is usually two or three paragraphs in the assigned SRP section are retrieved and evaluated for length, but may vary, and should contain the following their relevance to revising the SRP. Relevant potential elements:

impacts are orgaruzed, and combined as necessary to address specific topics associated with revising the SRP. A

• Introductmy statement that briefly introduces the specific reconunendation related to revising the SRP is then subject ofintegrated impact and describes the nature developed based on analysis of the potential impacts. The of the proposed change (e.g., a change to Acceptance evaluation also characterizes the amount of cifort that is Criteria, Review Procedures, etc.)

likely to be required if the recommended changes are implemented in a draft SRP section. The results of the

• Brief description of the regulatory concern or issue  ;

evaluation and resulting recommendation are described on and, if not obvious, how this issue relates to the SRP i an Integrated Impact Form or entered directly in the SRP section.

Modification Database (MDB). Integrated impact fonns are retained until such time that the data is entered in the MDB.

• Brief description of the NRC action taken with Independent verification is performed in accordance with regard to the issue and any associated requirement or Chapter 6.0. guidance that resulted from the action taken.

Procedure . Briefdescription of any conflicts noted in Step 5, as applicable. I

1. Become thoroughly familiar with the contents and sub-ject matter of the assigned SRP section. Summary description of the proposed change (conclusion).

2. Obtain, from the SRP Modification Database, the new potential impacts related to the SRP section under 8. Characterize the amount of effort that is likely to be consideration. required to implement the recommendation presented in the integrated impact summary by designating one of 3.3 NUREG-1561

i i j SRP Maintenance 1

the following four categories in Part B of the Integrated are identified in the course of other SRP-MP activities Impact

described in Chapters 2 and 3. Following identification, the issues represented by these documents are describcx! in

. MAJOR revision - the SRP section will largely have integreted impacts assigned to specific SRP sections, to be rewritten. Integrated impact forms are retained until such time that the  !

data is entered in the MDB. Independent venfication is

. SIGNIFICANT revision - a major subsection will perfonned in accordance with Chapter 6.0, a have to be rewritten or significant changes will have to made throughout the SRP section Procedure i

e MODERATE revision - a number of minor revisions 1. Develop an integrated impact summary description, I will be required throughout the SRP section usually two or three paragraphs in length, that l add esses the following items: l

. MINOR revision - small werd, sentence, or param-l eter value changes. . An identifying statements "This integrated impact identifies a draft regulatory guide / proposed rule and

9. Complete an Integrated Impact Form or enter the integ- will not be processed further."

rated impact data directly in the MDB.

Note: This statement indicates to the analyst per-i 3.1.3 Procedure for Preparing Placeholder forming integrated impact evaluations during draft i

! Integrated Impacts section development work (as described in Sec-  ;

tion 3.3) that the integrated impact is not intended to be used as a basis for proposing changes to the SRP Purpose of this Procedure at this time.

1

, This procedure desenbes the process for preparing place-holder integrated impacts as discussed in Section 3.1.1. . A discussion of the regulatory issue involved,in-These integrated impacts are used to document regulatory ciuding an identincation of the regulatay docu- ,

ment (s) involved, as applicable. This discussion 1

, activities in progress that have significant potential for affectmg the content of the SRP. should also indicate why the regulatory issue iden- l tified is relevant to the SRP.

Prerequisites for Performing this Procedure

. Identification of the applicable Research/ Regulatory Action Need Form number, as applicable.

A regulatory development activity as documented on a Research/ Regulatory Action Need Form (IPD 6.0), a draft

2. Complete an Integrated Impact Form or enter the Regulatory Guide, a Proposed Rule, or a revised code or mtegrated impact data directly in the MDB.

standard, has been identified that has significant potential for affecting the content of the SRP. ,

Forms Overview of this Procedure l The Potential Impact /Section Consistency Form and Integ- j rated Impact Form serve to record data that will be j Draft Regulatory Guides, Proposed Rules, revised codes '

and standards, and Research/ Regulatory Action Need Fonns input into the SRP Modification Database. Use of the forms form that incorporates the same information, or directly in is not required if the analyst records the data directly in the the MDB.

MDB. All organizations implementing this procedure must record their work either on the indicated fonn, an altemate NUREG-1561 3.4

SRP Maintenance PotentialImpact/Section Consistency Form Analyst SRP Section No.

PotentialImpact No. (Attach Copy)

1. Is this potential impact already incorporated in the SRP?

Yes No

2. Retain this potential impact as a technical rationale for acceptance criteria?

Yes No

3. Was this potential impact incorrectly assigned to this SRP section?

Yes No

4. Should the potential impact be eliminated from consideration for some other reason?

l Yes No )

If any of the above is answered "yes", provide further explanation:

I i

Analyst Signature Date Reviewer Date

! MDB Data Entry Date l l

3.5 NUREG-1561 i

l

I I

SRP Maintenance

)

i I

Integrated Impact Form Part A -Impact Identification j SRP Section No. I Related PoteraialImpact Nos.

Integrated Impact ID Description of fmpact l

l l

1 l

l Part B - Determmation ofImpact Significance  ;

I l

Major Significant Moderate j Minor Analyst Signature Date Reviewer Date MDB Data Entry Date MDB Assigmnent Number Integrated Impact Number NUREG-1561 3.6

SRP Maintenance 3.2 Identifying the Need for SRP The dxumentation, approval. and publication of new or re-

.. vised SRP sections resulting from NRR programs other Revisions ,

than the SRP-MP may be assisted by the PGEB. The PGEB will coordinate with other NRR organizations to determine 3.2.1 Approach the scheduling of such support, taking into account available 1

SRP-MP resources. The development of documentation for The SRP section is the basic unit of the SRP. Most of the drafi SRP sections not prepared under the SRP-MP is work performed in revising the SRP is scheduled and described in Section 3.3. The incorporation of such SRP secomplished on a section-by-section basis. The need to sections in the periodic review, approval, and publication of revise an existing SRP section or develop a new SRP sec- NUREG-0800 revisions will be coordinated by the PGEB.

tion is identified through the following processes:

3.2,2 Procedure for Identifying the Need for

• The periodic SRP-MP review of new or revised reg-ulatory documents as described in Section 2.3.

SRP Revisions e

. Purpose of this Procedure NRR requests for the preparation of SRP revisions by the PGEB.

This procedure describes the process for detemunmg the need to revise existing, or to develop new, SRP Sections.

• SRP section revisions or the development of new SRP This detennination is based on the evaluation, as described sections resulting from NRR programs other than the SRP-MP. in Section 3.1, of potential impacts that have been identified during the review of new or revised regulatory documents Regardless of how the need to revise the SRP is identified as described in Section 2.3. This procedure is nonnally pe,.fM on an annual basis.

and how the drafting of these revisions is accomplished, SRP revisions must ultimately be incorporated in the SRP-MP so that revisions to the SRP are documented in the SRP Prerequisites for Performing this Procedure Modification Database and to facilitate review, approval, andpublicationofrevisionstoNUREG-0800. When

. Potential impacts have been identified from the review of completed, SRP revisions that are developed on a sect on-by-section basis are consolidated into a NUREG-0800 new and revised regulatory documents as described in Sec-tions 2.2 and 2.3 of this implementing Procedures revision package as described in Chapter 4.

Document.

The need to revise the SRP as the result of the periodic

. Overview of this Procedure SRP-MP review of new or revised regulatory documents is evaluated at least annually by reviewing potential impacts Potential impacts added to the SRP Modification Database that have been identified as hscribed in Sections 2.2 and since the last revision of NUREG-0800 are evaluated as 2.3.

described in Section 3.1. The integrated impacts are then assessed for the need to develop new or revised SRP Other NRR organizations may request the assistance of the sections for the next revision of NUREG-0800.

PGED in p. paring SRP revisions or new SRP content.

The PGEB will determine the ability to support these Prwdure requests within available SRP-MP resources. Development of new or revised SRP sectior s by the PGEB with the

1. Query the SRP Modification Database to determme assistance ofits contractor will follow the processes those SRP sections that have had potential impacts described in Chapters 2 and 3 regarding the identification of assigned since the last update of NUREG-0800.

relevant documents, identification of potential SRP impacts, and the development of draft SRP sections and supporting

2. For each SRP section identified in Step 1, perform documentation.

impact integration in accordance with Section 3.1.

3.7 NUREG-1561

4 i

4 SRP Maintenance l

l 1

I

3. Evaluate the integrated impacts for each SRP section Options Checklist represents a detailed and specific and prioritize SRP sections based on the significance of recommendation to revise the SRP. During the review and  ;

the integrated impacts. For those SRP sections that do approval of a draft SRP section (described in Chapter 4), J not have substantive integrated impacts, SRP section the Revision Options Checklist (s) associated with the draft ,

revisions may be deferred, dependmg on SRP-MP SRP section is(are) revised as necessary to reflect the  !

resource constraints. resolution of comments received during the review process S After a draft SRP section is approved, the data in the SRP l 4. Develop a schedule for the completion of drafi SRP Modification Database related to the Revision Options ,

i section development to be performed in accordance Checklist serves to proside a detailed histoncal record of i

, with Section 3.3. changes made to the SRP.

The process for performing integrated impact analysis and -

C mPl eting the Revision Options Checklist is described in 3.3 Drafting SRP Sections Procedure 3.3.2. The following discussion provides j additional information regarding characterization of i 3.3.1 Approach proposed changes as Type 1 or Type Il changes.

This section describes the process for evaluating integrated Characterizing proposed revisions as Type i or Type 11 impacts, determining the SRP revisions that will be made requires an assessment of prior NRC approvals andjustifi-and drafting revised or new SRP sections. Drafling SRP cation for including each suggested revision in one of the sections involves two distinct tasks: the analysis of two categories. The categories are defined as follows: l integrated impacts, and the preparation of a draft SRP section. Type I - Revisions to the SRP Without Public Comments Evaluating Integrated Impacts . Revisions to existing SRP sections or new sections that mcorporate requirements or guidance that have received Evaluating m. tegrated impacts mvolves the following: public comment and have been approved by the Director, NRR, and for which additional public comments are not

• Analysis of the issue identified in the integrated impact. necessary (e.g., implementation or referencing in the SRP of Commission Policy Statements or instructions,

. Determination of the actual changes that will be made t Regulatory Guides, Standards and Resolution of Generic the SRP. Issues including approved Three Mile Island Action Plan

. Documentation of the analysis performed to arrive at the changes.

• Revisions that incorporate new positions in the SRP that have been approved by the Director, NRR, and by the

. Documentation of the resolution of conflicts between Committee to Review Generic Requirements (CRGR) documents identified in the potential impacts associated and the Executive Director of Operations (EDO) as being .

with the integrated impact. so clearly nehl that a public comment period would {

asa a ePtable delay in impicmenting thent

. Characterization of the changes to the SRP as Type I or Type 11 as defined in this section. . Clarifications, conections, changes in names or assign-ments of branches, deletions of unused references or Documentation of this integrated impact evaluation process other similar minor changes and editorial items that do is accc nplished by completing a Revision Options Check- not affect the technical content of the SRP.

list. The Revision Options Checklist is an extension of the integrated impact describc iin Section 3.1. The Revision Type II - Revisions to the SRP With Public Comments  !

Options Checklist form inusuded in this section is a hard-copy representation of data normally entered directly in SRP , Revisions that incorporate proposed new or revised re-Modification Databas . When completed, the Revision quirements, positions, or guidance that have not yet been NUREG-1561 3.8

SRP Maintenance reviewed and approved by the Director, NRR, CRGR and the EDO, or that include proposed new sections for 3,3.2 Procedure for Evaluating Integrated the SRP that address these new or revised requirements, Impacts positions, or guidance.

Purpose and Scope of this Procedure The determinations are made in terms of criteria listed in Part F of the Revision Options Checklist, and these enteria This pmedure buibes se pmcess fw M'% ee analysis necessary to develop specific and detailed SRP will fonn the basis for the Type I/fype 11 determination. A changes in order to implement the SRP change recommen-rationale is also developed by the analyst to assist decision dation made in integrated impacts developed under Section makers in assessing the results provided. The rationale is a brief description of how and why the proposed revision 3.1. This pmeda also pmvides guih fw completing the Revision Options Checklist that is used to document this meets the Type I or II criteria and is meluded in the analysis.

Revision Options Checklist.

Prerequisites for Performing tble Procedure l Draft SRP Section Preparation '

Responsibility for revising the SRP rests with the NRR

1. 8'" * * ** #* E*""

• technical branch that is designated as the Primary Review *** E" ** " " * " " " " * * ' * * " '

Branch (PRB) for the SRP section.

2. The PRB designated as hasing responsibility for the

. assigned SRP section has reviewed the integrated i PRB concurrence with proposed changes to the SRP is impacts and provided comments, as applicable, facilitated by providing a draft SRP section and Rension Options Checklist (s) as supporting documentation. The Overview of this Procedure information identified, processed, evaluated, and orgamzed by previous steps and procedures assists the PRB in Analysis is performed to determme the actual changes that determmmg the need for, and concurrence with, proposed will be made to the SRP to implement the s -A-SRP changes. This documentation will be provided to the tion (s) presented in the integrated impact (s) associated with PRBs and will be used by the PRBs, along with the the assigred SRP section. Any conflicts identified in knowledge and experience contained within the PRB staff, integrated impact are resolved. The analyst then documents to detennine which changes will be made.

the detailed, proposed changes for the assigned SRP section and the rationale associated with those changes. Finally, the Dec. .isions and comments of the PRBs will need to be analyst characterizes the proposed changes as Type I or recorded in the SRP Modification Database. To this end, Type II. Revision Options Checklist forms are retained the PRBs are asked to record their decisions and comments until the data are entered in the MDB. Independent m wnting. This infonnation is retumed to the PGEB, which verification is performed in accordance with Chapter 6.0.

will have it entered in the SRP Modification Database.

4 Appendix A to this Implementing Procedures Document j describes thc standard format for SRP sections and various 1. Obtain the integrated impacts for the section (produced guidelines associated with developing new or revised draft under Section 3.1).

SRP sections. Procedure 3.3.3 describes the process for j developing .! raft SRP sections, and supporting docu- 2. Resolve any PRB comments received on the Integrated

mentation, for PRB review. Impact (s). Document these review comments and J

action taken to resolve the corranent in Part A of the l

Revision Options Checklist (s).

J 3. Perform analysis as necessary to determme the specific changes to SRP that are necessary to implement the 4 recommendation of each integrated impact.

i 3.9 NUREG-1561 1

SRP Main *=nm

4. Complete Part C of the Revision Options Checklist described in the associated Revision Options MIW(s).

Form. To the extent practical, Pan C should reflect Two attachments to the draA SRP section are developed to changes as they are intended to appear in the actual provide a detailed identification of the sources of the proposed changes to the SRP section.1%* )

SRP section.

verification is performed in accordance with Chapter 6.0.

5. Complete Part D of the Revision Options Checklist Form. Part D is used to document the rationale associ- Procedure \

ated with how the issue described in the integrated impact was addressed in the SRP changes proposed in 1. Using the Revision Options Checklist (s) developed for I

Part C. the SRP section, draA the new or revised SRP section.

During preparation of the draft, observe the followmg

6. Resolve any conflict identified in the integrated impact.

Most conflicts arise from outdated information and can a. Appendtx A to this Implementing Procedures be resolved through careful analysis of the regulatory Document describes the standard fonnat for SRP documents associated with the issue. It may be sections and various guidelines associated with necessary to coordinate with the responsible PRB in developing new or revised draft SRP sections order to arrive at a satisfactory resolution. Document resolution of any ccnflicts by completing Part E of the b. If the SRP section is a revision of an existing Revision Options Checklist Form. section, start with a copy of the currently approved SRP section and indicate each text addition, deletion, or modification using redline /stnkeout {

7. R+- ad whether the changes to the SRP should be considered Type I or Type Il by completing Part F of text markers. Text markers should be provided for the Revision Options Checklist. editorial changes as well as changes ap~hlly related to a Revision Options Checklist. j 3.3.3 Procedure for Drafting SRP Sections

2. Prepare an attachment to the draa SRP section labeled

" Proposed Changes in Order of Occurrence," as Purpose of this Procedure follows:

The purpose of this procedure is to describe the process for

a. For revised SRP sections, each change identified developing a draR SRP section that incorporates the changes to the SRP detailed in Revision Options Checklists in Step 1.b should be provided with a super-associated with the assigned SRP section. The procedure scripted number corTesponding to a line item in the attachment. For new SRP sections, each signi-also describes the process for assembling a draft SRP section documentation package that will be used in the SRP ficant topic of the new SRP section should be review and approval process described in Chapter 4. provided with a superscripted number correspond-ing to a line item in the attachment.

Prerequisites for Performing this Procedure

b. Include in the following for each attachment line item: (1) A line item number; (2) Description of Integrated impacts have been evaluated and Revision the source of the change (e g.," Editorial" or Revi-Options Checklists developed for the assigned SRP section sion Options Checklist number); and (3) Brief 4 in accordance with Procedure 3.3.2.

description of the change.

Overview of this Procedure

3. Prepare a second attachment to the draft SRP section For SRP section revisions, a redline / strikeout copy of the labeled Summary ofROCs." Include a line item in the attachment that identifies each Revision Options SRP section is prepared that documents text additions, deletions, and modifications proposed in Revision Options Checklist used to develop the draft SRP section and the Checklists. For new SRP sections, a draft SRP section is subsections of the draA SRP section that were affected developed that implements the review topics and issues by the Resision Options Checklist.

NUREG-1561 3.10

__ ~ .. . _ _ . . . ... _...-___.-~_..___-__,_.__._._..._,__.____._.._.m_m_._, _ _ . _ . .

f SRP Maintenance i

i I

Forms- All organizations implementing this procedure must record I their work on the indicated form and forward the completed The Revision Options Checklist form (Parts A through F) l forms to the PGEB upter completion of the work, or enter  !

structures the analyst's review ofintegrated impacts and the the infinnation directly is the SRP Modification Database.

i resulting potential changes to the SRP, it provides the PRB [

j with the information needed to decide if and how the SRP e

! will be modified.

I L

l I i

t l

1 l

l l l

! 1

' i i .

I l 3.II NUREG-156I l

i

__ ._..._.____._.~.____...-._____m__.._-._. ._ . . . _ _ _ . _ . . _ . _ _ . _ _ . . . . . . _ _ . _ . ~ _

l l'

SRP Maintenance Revision Options Checklist Part A -Impact Identification SRP Section No.

i Related PotentialImpact Nos. I l

)

l Integrated Impact No.

1 Description ofImpact l 1

1 1

l i

I i

-i i

i Part B - Determmation ofImpact Significance l

MWor {

Signincant Moderate  :

Minor i Part C - Characterization of Type and Nature of Change l t

[

i h

I r

i 1

NUREG-1561 3.12

SRP Maintenance Revision Options Checklist (Continued)

Part D - Discussion of Possible Changes Statemeni of Option Pros f

1 I

Cons d

1 3.13 NUREG-1561

j i l

f ,

I I- SRP Maintenance I

i- 1 i

i Revision Options Checklist (Continued) ,

. Part E - Identification of Conflicts I I

Conflict Identified? Yes .__ , No -

Conflicting PotentialIsapact Nos. i Description of Conflict i

l i

I Potential Resolution r

i Rationale i

-1 I

i l

l Is potential research indicated? Yes ._ No I

. \

1 is potential rulemaking, regulatory guide  ;

revision, or other regulatory action indicated? Yes ._ _ No __ j 1

Is potential codes / standards development indicated? Yes _ No _. '

Are there additional conflicts? Yes _ No___

("Yes" to " additional conflicts" will require completion of another Part E)

NUREG-1561 3.14

t SRP Maintenance Revision Options Checklist (Continued)

Part F - Type I/fype 11 Determination Tyne I - Revisions to the SRP Without Public Comment

1. Do the suggested revisions incorporate new or revised requirements or guidance that have received,or will receive, public comment and have been approved by the Director, NRR, and therefore do not require additional public comments?

Yes No

2. Do the suggested revisions incorporate new positions that have been approved by the Director NRR, and by CRGR and EDO as being so clearly needed that a public comment period would cause an unacceptable delay in

' implementing them?

Yes No

3. Do the suggested revisions involve only minor changes, such as clarifications, corrections, changes in names or assignments of branches,or deletions of unused references?

Yes No Tyne II- Revisions to the SRP with Pulelic Commerts

1. Do the suggested revisions incorporate proposed new or revised requirements, positions, or guidance that have not been reviewed and approved by the Director, NRR, CRGR and the EDO,or which could result in new sections for the SRP? -

Yes No Provide Rationale for Above Determination l

l 3.15 NUREG-1561

SRP Maian===

I Revision Options Checklist (Continued)

Analyst Signature Date Reviewer Date MDB Data Entry Date l

l 1

l 1

i NUREG-1561 . 3.16 1

i _

l 4 Review and Approval of SRP Revisions This chapter contains the procedures to be followed in re- 4.1.2 Procedure for PRB Review of Draft viewing and approving revisions of the SRP developed as SRP Sections described in Chapter 3.

urp se of this Procedure Chapter 4 is orgamzed as follows:

I This procedure recommends a review process by which

. Section 4.1,"PRB Review of Draft hRP Sections," NRR hanches review SRP drd sections for which they are draft SRP sections are reviewed by the PRB. responsible, and provides general guidance for that review.

This procedure applies to new or revised SRP sections

. Section 4.2," Consistency Review,"PRB-approved resulting from the SRP-MP, and it applies to a PRB only for SRP sections are reviewed for consistency with estab- those sections for which it has pnmary responsibility. (The lished format and procedural requirements. application of this section is a PRB decision; the only  !

program regmrement is that the PRB must approve all draft j

. Section 4.3,"SRP Revision Package Integration," SRP sections for inclusion in the SRP.)

PRB-approved SRP sections are integrated into a SRP 1 Revision Package. Prerequisites for Performing this Procedure

. Section 4.4,"NRC Review and Approval," NRC An SRP section draft and sup;xxting documentation have review necessary for the issuance of SRP revisions is been prepared as described in Section 3.3.

accomplished.

Overview of this Procedure 4.1 PRB Review of Draft SRP Sections The PRB reviews the draft for consistency. After comments are appropriately resolved and the draft revised accordingly, l the drafiis reviewed and approved by PRB management.

4.1.1 Approach Although there may be discussion between PRB staff and e ntractors in preparation ofrevised drafts, PRB staff will Draft SRP sections are considered a PRB product, regard, make all decisions which are implemented by contractor less of who developed the draft. Therefore, the PRB must personnel. In the case of NRC staff-prepared drafts, approve all drafts before they are submitted for inclusion in comments are resolved between resiewers and preparers the SRP.

and the results are incorporated in the draft. Finally, the It should be noted that the intent of this section is to provide c mpleted drafi is forwarded to the PGEB with a memorandum documenting the PRB's approval.

for PRB review of draft SRP sections; other procedures that require such a review may be used in lieu of this procedure.

Tne guidance provida!in this procedure is general in _ Results of this Procedure nature, recognizing that the PRBs have developed their own The written product resulting from the implementation of methods based on the specific requirements associated with this procalure is a PRB-approved draft of a revised or new their review areas.

SRP section. Any intermediate resiew drafts, comments, or comment resolutions resulting frou the review are the It should be also noted that, in order to implement the responsibility of the PRD and are not maintained as part of Commission's Interim Policy Statement on Improving the SRP-MP.

Technical Specifications issued in February 1987, the PRBs should consult the Technical Specifications Branch when the Acceptance Criteria or review procedures of an SRP section could affect the plant's technical specifications.

4.1 NUREO.1561

Review and Approval l

l Procedure 5. Forward the draft section to the PGEB, along with the signed approval memorandum.

3 Any or all of the following steps may be superseded by existing procedures that accomplish the same goals.

1.

PGEB coordinates with the responsible PRB and estab.

4.2 Consistency Review

]

lishes resource availability and a scheduled completion i date in support of the SRP section draft review. 4.2.1 Appronch '

I

2. PRD informs PGEB of any changes to the review Section 4.1 describes the process for a technical and policy l

schedule as soon as schedule impacts become apparent. review of each SRP section by the PRB. Section 4.2 provides for a review of each section for consistency with

3. PRB reviews drafts, as follows: f nnat and procedural requirements established by this document and for consistency with other SRP sections. The

a. Assign the PRB staff member (s) responsible for c nsistency review makes four deternunations: (1) whether reviewing the draft and resolving comments. The the revised SRP section meets the requirements set forth m assigned reviewer should not have had sigrJicant this document (primarily the ones included in Section 3.3 involvement with the preparation of the portion of and Appendix A to this document);(2) whether technical the document being reviewed. issues also treated in other SRP sections are treated in a consistent manner; (3) whether the revised SRP section is

b. Review the draft to ensure that PRD objectives are e nsistent with established fannat; and (4) whether the l met. Verify that the draft provides adequate review revised SRP section meets basic editorial requirements. 1 guidance, is technically correct, and is consisten;  !

with NRC and NRR policy and procedures. Appendix A sets forth the established SRP section fonnat I and guidelines for subsection conteat. Section 3.3 sets forth

c. Document the reviewer comments and,if erquired* the basic requircraents for the drafting of new or revised transmit comments to the section preparer. SRP sections. These guidelines include such items as the development of Acceptance Criteria technical rationale,

d. Revise the draft and associated Revision Options Presentation of parameter values in metric and English Checklists, as necessary, to incorporate comment units, and incorix> ration of new positions approved by the ,

resolutions. Revisions may be made by the PRB PRD. Most of the gmdance and procedures preceding

{

staff, or the PRB staff may direct the contractor to Section 3.3 involve supporting infonnation and will not j do so. directly contribute to this consistency resiew. Therefore, the first check performed by this procedure is to detenmne

e. PRB reviews the revised draft to ensure proper whether the substantive requirements set forth in this  ;

implementation ofreview results. Implementing Procedures Docmnent are addressed in each l SRP section draft j

f. Iterate Steps d and e until the draft is in a satisfactory fonn. The second check detennmes whether technical issue (s) in  !

the SRP section drafi are treated in a manner consistent with l

g. Provide the draft section to the PRB Branch Chief treatment of the same issue (s)in other SRP sections. This or designated individual for approval review. check ensures that treatment of technical issues in one section is not m conflict with or unnecessarily redundant to

h. Obtain the PRB Branch Chiefs cc '. signated the coverage of the same issues in other sections.

individuars signature and date on a memorandum .

indicating PRB approval of the SRP section. The third check perfonned in this procedure is to detamme whether each SRP section draft is prepared m, accordance

4. Assemble any fonns that were completed by the PRB in with the established SRP format. The fonnat is established evaluating impacts and drafting of the section revision. by Section 3.3 and Appendix A to this IPD. Within that NUREG-1561 4.2

Review and Approval format, it is also necessary to ensure consistency of writing quirements, be consistent with other SRP sections and with style and appropriate level of detail. the established format, and be editorially correct. De-pendmg on the number ofiterations that are required,in-The fmal check to be perfonned will be an editorial review. termediate drafts and associated comments may also result.

This will include correction of misspellings, punctuation, and grammar. Procedure In cases where the draft is found not to meet the require- Perform the consistency review.

ments established in this document, it will be retumed to the  !

PRB for rework. 1. Review the draft SRP section to ensure conformance

{

with the procedural requirements set forth in this docu- 1 4.2.2 Procedure for Performing Consistency ment (primarily Section 3.3). I Review

2. Review the drafi SRP section to ensure consistent treat-Purpose of this Procedure ment of technical issues also treated in other SRP ,

sections. )

'lliis procedure provides direction for the consistency re-view of each new or revi:,cd SRP Section. This procedure 3. Review the draft SRP revision to ensure conformance will be applied to SRP section drafts, as directed by the with format and editorial needs.

PGEB.

4. Ifno problems are identified during the review, proceed Prerequisites for Performing this Procedure t Step 10; otherwise, proceed to the next step.

Resolve any Review Comments.

Procedure 4.1.2 should be completed for any SRP sections to be subjected to the consistency review directed by this .

procedwe. 5. Resolve non-substantive comments with the PRB staff.

Make any necessary modifications to the section draft, documenting the nature and resolution of any non-Overview of this Procedure substantive comments addressed by the redraft. Proceed to Step 10 if there are no substantive comments.

This procedure specifies a three-step review process First, e review of draft SRP section revisions against prccedural .

6. Provide any substantive comments to the PRB and requirements included in this document is performed.

Second, a review of technical issues common to other SRP request technicaMreedon to resolve the comments.

The request should contain the substantive comments sections is done. The PRB is informed of any substantive  ;

and proposed resolution. A suggested redraft may be j deviations from the requirements or conflicts with other included widi diis request. .

sections, and the section drafi is revised. This process is iterated until the draft is satisfactory. Third, a format and editorial review is conducted, and the drafi is corrected 7. The PRB will redraft the SRP section to resolve the l

comments a will pmvide direction for further changes  !

accordingly. The draft revision will, at this point, be ready to addmss de comments.

for integration into a revision package (Section 4.3) and the formal NRC review and approval process as discussed in

8. The PGED will review any PRB redrafts in light of the previous comments or will incorporate PRB technical direedon in de drans. If de redraR or Weal Results of this Procedure direction is inadequate to resolve problems, document the reason and repeat Steps 6 and 7 until the draft is Implementation of this procedure will result in draft SRP adequate. Then pmceed to the next step.

sections that are ready for integration into the next SRP revision package for NRC review and approval process Submit the revised draft for PRB approval.

(Sections 4.3 and 4.4). Such drafts will meet procedural re-4.3 NUREO-1561 I 1

Review and Approval

9. If substantive changes are made, submit the revised 4.3.2 Procedure for Integration of the SRP draft to the PRB for approval. Provide the PRB a Revision Package marked-up copy with documentation of changes made and revised copy to facilitate its review.

Purpose of this Procedum Circulate draft SRP sections amone the P3Difg infgmation (PGEB responsibilitv1 his pmedwe provides dircedon fw Wating all new w redsd SRP sedons into an integratd revisia package on a periodic or one-time basis. This procedure will

10. Provide a copy ofeach completed drafi SRP section t operate on only those SRP sections that have been reviewed

, those PRBs not involved m preparation of the draft-and approved under Section 4.2 and any other SRPs that

, Circulation of draAs is for information and coordination have been approved at the time ofimplementation of this between the PRBs.

proc d we.

Forms Prerequisites for Performing this Procedum

, No forms are used to implement this procedure. Comments t Procedure 4.2.2 should be completed for any new or revised and approvals will be documented m, correspondence sections that are to be incorporated in the integrated SRP between the contractor and the NRC and m miemal

' revision package. Sections from other, previously memoranda within NRR.

approved, SRPs may also be incorporald.

4.3 SRP Revision Package Integration New and revised SRP sections are assembled into a collec-4.3.1 Approach tion of electronic files as a revision package and appro-priately maintamed. An overall review of the completed A " revision package"is a group of SRP sections, or a single SRP revision package is then performed.

SRP section, that will be issued as a formal revision to NUREG-0800. The revision package consists of the Results of this Procedure revised SRP section(s), as a redline / strikeout, and supportingjustification for the changes (attachment tables The written product resulting from this procedure will be an with change descriptions, integrated impacts and potential integrated SRP revision package in electronic files and in impacts related to the redsions in the package). As the Prirl-ready hard copy.

revised SRP sections are reviewed and approved by the PRBs, they will be combined into SRP revision packages. Procedure Integration of SRP sections into a revision package may be based upon a periodic (e g., annual) update of the SRP or Build and maintain a arounine of electronic files for the upon a commitment to incorporate new staff positions in the SRP revision oackant SRP.

1. Copy the electronic file for each SRP section into the PRB-approved, revised or new SRP sections will already be master grouping for the SRP revision.

in correct fonnat as a result ofimplementation of previous procedures. Individual sections will be assembled into a set 2. Update the SRP table ofcontents and perfonn any other of electronic fdes. The SRP table of contents will be needd maintenance of the SRP files as sections are updated. Finally, as the SRP revision package nears added.

completion, a review of the overall document will be

perfonned to identify any areas where improvement is 3. Track the completion of the integrated SRP and

~

needed (e.g., missing review areas, inconsistent approaches, Periodically report progress.

etc.).

NUREG-1561 4.4

Review and Approval

4. Establish the criteria to be used in performance of the approved reqmrements. Type 11 revisions require more overall review ofintegrated SRP. extensive review.

5. Review the completed SRP revision package according 4.4.2 Procedure for Obtaining NRC Review to the established review criteria. Identify any areas where corrections or further work is required, and and Approval- Type I Revisions identify candidates for future work as described in Purpose of this Procedure Chapter 7.0 as appropriate to the areas identified.

This procedure provides direction as to how proposed Type I revisions to the SRP are to be reviewed and approved.

4.4 NRC Review and Approval The scope of this procedure includes only those proposed SRP revisions that are considered Type I changes.

4.4.1 Approach Prerequisites for Performing this Procedure This section addresses the various reviews and approvals that are required in order to issue SRP sections. Included Procedure 4.3.2 will be completed prior to performance of are NRC management, the Committee to Review Generic this procedure.

Requirements (CRGR), the Advisory Committee on Reactor Safeguards (ACRS) and provision for any required public Overview of the Steps in this Procedure comments and comment resolution. It is the intent of the SRP-MP that for review purposes, revised or new SRP The CRGR and the ACRS are advised of the intent to issue sections will be grouped into " revision packages." In most the SRP revision, including the basis for designating the cases, review should be facilitated by the fact that the revision as Type I. The issuance of the SRP revision revisions to the SRP are made specifically to reflect Package is then noticed in the FederalRegister.

established staff positions and regulatory requirements.

Results of this Procedure In general, the PGEB will be responsible for overall man-agement and oversight of the review and approval process Written Pmduct . Written products resulting from the im-(including tracking progress) and reporting progress to Pl ementation of this procedure will include various review NRR management. For revision packages constituting the packages, FederalRegister notices, and approved versions work product of a single PRB, the PRD will be responsible of SRP section revisions.

for preparing review packages for the CRGR, the ACRS, and public comment; making CRGR presentations; Procedure resolving public comments; coordinating revision of section drafis; and coordinating with interfacing NRR divisions and It is intended that this procedure will be implemented on a branches. The SRBs will provide technical support to the " revision package" basis.

PRBs as requested by the PRBs, but at a mmimum will have an opportunity to review and comment on all drafts. 1. Review the revision package for completeness and For major updates or revisions involving multiple PRB re. format and verify that the proposed change meets the sponsibilities, the PGEB will coordinate: preparation of criteria for a Type I revision, ensure that the revision review packages for the CRGR, the ACRS, and public does not go beyond the scope of approved requirements, comment; CRGR presentations; resolution of public or that clarifications do not go beyond the intent of comments; revision of section drafis; and interfaces with existmg regulations. (PGEB or PRB responsibility, interfacing NRR divisions and branches. depending on scope of resision package.)

The extent of NRC review and approval is dependent on the 2. Forward the draft revision package to appropriate NRR nature of the SRP revision. Type I revisions require less divisions, other tecimical ofIices, and the Office of review since the changes do not go beyond the scope of General Counsel for information. Resolve any comments to the extent possible. (PGEB or PRB 4.5 NUREG-1561

. Review and Approval responsibility, dependmg on scope of revision Results of this Procedure package.)

Written Pmduct - Written products resulting from the im-

3. Prepare a draft SRP revision package including plementation of this procedure will include various review memoranda to the ACRS and the CRGR for the signa- packages, status reports, FederalRegister notices, and ture of the Director, NRR, that summarizes and approved versions of SRP section revisions along with explains the need for the revision and provides the comment resolution and approval histories.

basis for designating the revision as a Type I change.

This memo should request expedited review and Other - Other results include presentations to the CRGR concurrence with the designation of the SRP revision as and others, as requested.

Type 1. (PGEB or PRB responsibility, depending on scope ofrevision pack ge.) Procedure

4. Transmit the package for information, with the it is intended that this procedure will be implemented on a memoranda signed by the Director, NRR, to the ACRS " revision package" basis.

and the CRGR. (PGEB will coordinate this activity.)

Obtain internal NRC reviews /anorovals for revised or

5. Prepare a FederalRegister notice of SRP revision and new SRP sections forward the notice to the Division of Freedom ofInfor-mation and Publications Services under the signature of 1. Record the accomplishment of each milestone in the the Branch Chief, PGEB. (PGEB responsibility.) SRP Revision Package Review and Approval Status record. (PGEB responsibility)

Forms

2. Prepare an SRP revision package including a draft No forms are specified for this procedure. memorandum to the CRGR for the signature of the Director, NRR, that summarizes and explains the need 4.4.3 Procedure for Obtaining NRC Review for the revision and includes a regulatory analysis or and Approval- Type II Revisions backfit analysis prepared in accordance with NRR procedures. (PGEB or PRB responsibility, dependmg Purpose of this Procedure on scope ofrevision package.)

This procedure provides direction as to how proposed Type 3. Forward the revision package to appropriate NRR 11 revisions to the SRP are to be reviewed and approved. divisions, other technical offices, and t!e Office of The scope of this procedure includes only those proposed General Counsel for review. Resolve comments to the SRP revisions that are considered Type 11 changes. extent possible and obtain the appropriate concur-rences. (PGEB or PRB responsibility, depending on Prerequialtes for Performing this Procedure scope ofrevision package.)

Procedure 4.3.2 will be completed prior to performance of j 4

sp M um divergent views that could not be resolved. (PGEB or PRB responsibility, dependmg on scope of revision Overview of the Steps in this Procedure package.) If a smgle PRB is responsible for the SRP Section drafts are reviewed by appropriate NRR divi-pa age, fomarkson pa&gM comment sions, the Oflice of General Counsel, the CRGR, and the umentad n to se N ACRS, and all comments are addressed. The revision is

5. Fonvard the revision package to the Director, NRR, at then noticed in the FederalRegister for public comments, least four weeks prior to the scheduled submission to pubhc comments are resolved, and the revised SRP section the CRGR. (PGEB will coordinate this activity.)

is subjected to the same NRC reviews and approvals noted above.

NUREG-1561 4.6

Review and Approval

6. Support any dry sun CRGR presentations requested by ments to PRBs for resolution. Public comments will the Director, NRR, and revise the revision package and be recorded as Potential Impacts as described in transmittal memorandum in accordance with any Section 2.2. (PGEB responsibility) comments and instructions from the Director, NRR.

(PGEB or PRB responsibility, depending on scope of 14. Resolve each substantive comment, makmg the neces-revision package.) sary modifications to the draA SRP section. Maintain a l record ofcomment resolutions and accompanying SRP l

7. Once the Director, NRR, has approved the revision changes. Prepare a fmal revision package. Forward package, schedule a meetmg with the CRGR. Trans- the fmal revision package, along with comment mit the package, with the memorandum signed by the resolution records, to the PGEB. (PGEB or PRB Director, NRR, to the CRGR. (PGEB will coordinate responsibility, depending on scope of revision this activity) package.)

8. Make necessary presentations to the CRGR and re- 15. Enter comment resolution into the SRP Modification solve any CRGR comments. Prepare a response to Database. Resolution of public comments will be CRGR comments for transmittal by the Director, NRR, recorded as Potential Impact consistency check com- ,

within one week of receiving the comments. (GEB or ments and/or Integrated Impacts in a manner similar to  !

PRB responsibility, depending on scope of revision impacts from other regulatory documents (see Section j package) 3.3). Enter the fmal section revision into the electronic SRP. (PGEB responsibility.)

9. Prepare a memorandum to the ACRS, from the Direc- ,

tor, NRR, transmitting the revision package. The Obtain fmal internal NRC reviews /annrovals. l memorandum should summanze the revision, explain the need for the revision, and include the regulatory 16. Repeat Steps 3 through 11 for the fmal revision analysis. 'Ihe PRB should forward the dran package. Responsibilities remain as indicated in those memorandum to the PGEB. (PGEB or PRB respon- steps.

sibility, depending on scope of revision package.)

17. Update the SRP Modification Database and electronic

10. Review the draA memorandum, resolve any conunents SRP files with appropriate information resulting from with the PRB, obtain the signature of the Director, implementation of Step 16. (PGEB responsibility.)

NRR, and forward the memorandum and revision package to the ACRS. (PGEB will coordinate.) 18. Prepare a FederalRegister notice of SRP revision and forward the notice to the Division of Freedom of

11. Support any presentations to the ACRS, resolve any Information and Publications Services under the ACRS comments, modify the revision package, and signature of the Branch Chief PGEB. (PGEB forward the package to the PGEB. (PGEB or PRB re- responsibility.)

sponsibility, dependmg on scope of revision package.)

Forms Obtain and resolve public comment.

No forms are specified for this procedure; however, a SRP

12. Assemble the revision package, prepare a Federal Revision Package Review and Approval Status Record will Register Notice ofIntent to revise the SRP, and for- be created for each revision package processed under this ward the FederalRegister notice to the Rules Review procedure. The purpose of the SRP Revision Package and Directives Branch, Division of Freedom of Review and Approval Status Record is to allow tracking of Infonnation and Publications Services under the fonnal review and approval for each SRP revision. The signature of the Branch Chief PGEB. (PGEB SRP Revision Package Review and Approval Status Record responsibility.) should document the information listed in Table 4.1.

13. Ensure that public comments received are entered into the SRP Modification Database, and forward com-4.7 NUREG-IS61

_ - . . _ . - . . - --. -.. -._ . . _ - . .. ~ .. - .. .._ .

Review and Approval Table 4.1 Recommended Content t

Type II SRP Revision Package Review and Approval Status Record Revision package description (including SRP section numbers): ,

Milestone By whom Date completed CRGR Review Final draft of SRP section revision prosided to PRB PRB/PGEB cover memo to CRGR drafted, resision package completed, package sent to PGEB Revision package fonvarded to Director, NRR CRGR meetmg held CRGR comments resolved ACRS Review Draft ACRS memorandum forwarded to PGFl3 ACRS memorandum transmitted ACRS comments resolved Public Comment FederalRegister notice sent to Division of Freedom of Information and Publications Senices Fedem! Register notice published FR ref:

Public comment response due date-1 1

Public Comments resolved Second CRGR Resiew PRB cover memo to CRGR drafted, revision package completed, package sent to PGEB 1

NUREG-1561 4.8

Review and Approval Table 4.1 (continued)

Milestone By whom Date comepleted Revision package forwarded to Director, NRR CRGR meetmg held CRGR comments resolved Second ACRS Revig Draft ACRS memorandum forwarded to PGEB ACRS memorandum transmitted ACRS comments resolved Public Cnmment Eederal Resister notice sent to Division of Freedom of Information and Publications Senices Federal Renister notice published:

FR Ref:

4.9 NUREG-1561

5 Reserved 1

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5.1 NUREG-1561

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l 6 Independent Review of Work i

! This chapter outlines measures to be taken to ensure the The method ofreview used is dependent on the nature of the j accomplishment of high quality work by contractors per- work. In general, the reviewer is assumed to be sufficiently i forming tasks in support of the SRP-MP. The specific im- qualified and experienced to be able to deternune the most plementation of these measures will be determined by the appropriate resiew method. The result of an independent POEB as work tasks are assigned to contractors, taking into review is typically the generation of a set of comments. The account the nature and complexity of the work to be preparing aradyst and the reviewer will resolve any performed. comments regarding the work or how it was performed.

Contractor management personnel shall periodically review 6.1 Discussion the results ofindepmdent reviews and critically review the results to identify any trends or programmatic concerns that Reviews of work will be performed by a reviewer indepen- c uld compromise the quality ofprogram work and dcnt of the initial performance of the work. The inde. Products. Any problems identified shall be investigated for pendence criterion is taken to mean that the reviewer may the root causes and appropriate corrective actions taken.

not have been directly involved in the actual accom- Following the accomplishment of corrective actions, the plishment of the work. An analyst may not review his or her areas ofconcent sliall be re-examined to verify the eHicaer own work; two persons working together on the same item f the corrective actions. I may not review each other's work. .

Documentation related to the performance of the activities {

In general, independent reviewers should meet at least the described in this chapter shall be maintained by the i contractor.

same qualifications as the individual originally performing the work, and, if possible, should have more experience than the original work performer (analyst).

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6.1 NUREO-1561

f 7 Identification of Candidates for Future Work This chapter describes the procedures to ensure that needs 7.2 Procedure for Identification of for research, regulatory action, or codes and standards development are brought to the attention ofcognizant NRC Candidates for Future Work organizations.

Purpose of this Procedure

. . This procedure ensures that needs for research or regulatory 7.1 Discussion action, identified in the implementation of other procedures described in this Implementing Procedures Document, are The SRP MP recognizes that in the course of perform.mg

, brought to the attention ofcognizant NRC organizations for SRP-MP activities, the need for actions outside the scope of resolution. This procedure also provides a mechanism to the SRP-MP itself may be identified. Some examples of track these issues that may affect the content of the SRP.

such situations are:

. Procedure a where regulatory requirements or positions are insuf-ficient to establish a basis or suflicient guidance for SRP

1. Prepare a Research/ Regulatory Action Need Form for reviews, each need identified. Completion of this form is the responsibility of the analyst who identifies the need.

• where the current NRC endorsement of codes and stan-

.The form attached to this secdon may be gleted or dards need to be reconsidered due to changes m the status the data may be entered directly in the SRP ofendorsed codes and standards, Modification Database. t

. where it is determined that an existing regulatory docu-

2. Create an integrated impact describing the issue ment, other than the SRP, is found to need revision t identified in the Research/ Regulatory Need Fonn for update existmg mformation.

the appropriate SRP section(s) as described in Section Once needs for research or regulatory action are identified. l this procedure will ensure that cogmzant crganizations 3. Transmit the Research/ Regulatory Need Form to the within the NRC are made aware of such aceds, and will PRB for approvals, as necessary (PGEB responsibility) provide a mechanism to track the NRC's response so that, once resolved, they may be factored into the SRP-MP 4. The PRB approves or disapproves the Research/

maintenance p ocess Regulatory Need Form and returns it to the PGEB.

The SRP-MP may identify circumstances where substantial 5. Enter the Research/ Regulatory Need Form data in the changes are required to the SRP that cannot be accommo- SRP Modification database, if not already done.

dated within the routine scope of SRP-MP activities or where regulatory development has already been identified

6. The PGEB forwards approved Research/ Regulatory and is in progress, but not completed. This procedure will Need Form to the cognizant organizations within the be used to document and track planned SRP new content NRC for funher action, if applicable.

development activities that may not be accom=v4ted in the current SRP revision cycle. 7. Track the progress ofidentified and approved needs.

Update the Research/ Regulatory Need Form and asso-ciated integrated impact data in the SRP Modification I Database, as necessary 7.1 NUREG-1561

4-

, Identification 1  :

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8. Create Research/ Regulatory Need status reports at the Forms l 3

frequency determined by the PGEB.

t The Research/ Regulatory Action Need Fonn is used to 3' 9. When activities are completed, close the Research/ identify potential needs, to obtain PRB and PGEB Regulatory Need Form and associated integrated approvals, and to transmit this information to responsible

' i impact data in the SRP Modification Database. organizations. The form is also used to record the current status and fmal disposition of the need, I

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d NUREG-1561 7.2

Idenhfication Reseanh/ Regulatory Need Forms I

Need Number  !

' Need Title '

i Need Source SRP Section(s)

' Need Type:

_ Research _ Rulemaking i

_ Regulatcs) Ouide Development / Revision _ Codes / Standards Development

_ Other l l

Description ofNeed I

1

. References .

Analyst's Name (print) i Signature Date Analyst's Supervisor's Approval Date 1

PGEB Approval Date 7.3 . NUREG-1561

Identification Research/ Regulatory Need Form (Continued)

Status Remarks

_, Need Resolved Signature Date _...

NUREG-1561 7.4 i

Identification llow to Complete the Form NeedNumber- This number has the fomt 'SRP Section Number - Sequential form number'. The sequential form number must be obtained from the SRP Modification Database by detennining the last form entered for the specified SRP section.

Need Title - The title is created by the analyst and should convey the essence of the need.

Need Source - The source is the IPD procedure being perfonned when thcc need is identified.

SRP Section(s) - The SRP section or sections associated with the need.

Need Type - Select the option that describes the type of need or check 'Other*,

Description ofNeed- Enter a brief description of the need and indicate any applicable reference documents. The description should include how the need and SRP are related.

Status Remarks - When new information regarding the status of the need is identified, create an entry, that starts wi+h the date of the entry, reficcting the status infonnation.

Need Resolved - This line is marked when no further action related to the need is expected to occur that is significant to the SRP.

MP.

l 7.5 NUREG-1561

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Appendix A Standard Review Plan Format l

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Appendix A Standard Review Plan Format This Appendix describes the standard format for SRP sections and provides guidelines associated with developing new or revised drafi SRP sections. In general, the prescribed format retains the essential features of the original issue of NUREG-0800 since the NRR staff and licensees are familiar with that format, and most existing safety analysis reports are written in this format. This Appendix also includes guidance for: impkmentation of the NRC's Metrication Policy; formatting of SRP reference citations and References listings; and implementation of the resolution of Generic Issue B-3.

A.1 Numbering of SRP Sections The existing numbering structure of the SRP will be preserved. It is preferable to fit new concepts into existing SRP sections whenever it is reasonable to do so. If new SRP sections need to be added, they should be numbered in such a way that existmg sections are not renumbered. The numbering of any new sections should correspond to the appropriate SRP chapter with similar content.

A.2 Incorporation of Future Reactor Designs The SRP currently addresses two types of reactor designs: boiling water reactors (BWRs) and pressunzed water reactors (PWRs). The SRP Maintenance Program may expand the SRP scope to include a manber of evolutionary and advanced reactor designs. Many of the design concepts for the future reactors will incorporate conventional reactor technology; some will use '

unconventional applications of existing technology and application of new technology. New reactor types will be incorporated in the SRP using the following guidance. (The indicated format parallels the format currently used in the SRP for BWRs and PWRs).

Any of the following approaches is acceptable. Ilowever, the approaches are presented in order of preference.

1. Make SRP sections generically applicable to all reactor types addressed in the SRP. Some sections are relatively insensitive to differences in reactor design and can be made to apply to all designs without exceptions. The SRP sections in Chapter 2 (Site Characteristics) and Chapter 17 (Quality Assurance) are examples of fully generic sections. <

2. Make SRP sections as generic as possible while allowing for the inclusion of design-specific review guidance within the subsections of the SRP section. Refer to SRP Section 5.4.7 (Residual iIcat Removal System) for an example of this approach.

3. Create an introductory SRP section that addresses common design aspects of different reactor concepts, and then develop a l series of SRP sections that address each design specifically. Refer to SRP Section 6.2.1 and its subsections for an example of this approach.

4. Create a design-specific SRP section. In cases where a design concept is unique to a particular reactor type, there is no reasonable alternative to the preparation of a unique section for that concept. Examples of this approach are prosided by A.1 NUREG-1561

. -~ .. - - _ - . . -. .-.- .- .. .. . . . - --

Appendix A I

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j j SRP Sections 5.4.1.1 (Pump Flywheel Integrity),5.4.8 (Reactor Water Cleanup System), and 5.4.11 (Pressurizer Relief i

Tank). i A.3 SRP Section Development Guidelines l The following guidance should be applied when developing new or revised SRP sections

NRC Metrication Policy Each numeric value associated with units should be expressed in metric SI units as described in Federal Standard 376B. The equivalent value and units in inch-pound (US standard practice English units) should follow the SI units, enclosed in parentheses, if the numeric value was originally published (in the SRP or other regulatory document) in inch-pound units.

The conversion methodology of Federal Standard 376B, Sections 4.4 and 4.5 should be followed to ensure that the dual unit or converted values are consistent. When converting units, limits (e.g , muumum and maximum values) established in regulations or in regulatory documents must be preserved during the conversion. Calculations involved in conversion should always be subjected to an independent review as described in Chapter 6.0.

Event Terminology Discussions of design basis events in SRP sections should incorporate the resolution of NUREG-0933, Generic Safety Issue B-3, l

" Event Categorization," by clearly distinguishing between anticipated operational occurrences and accidents. The following can  !

be used to assist in distinguishing between these categories ofevents:

Anticinated Operational Occurrences (AOOs) are those conditions of normal operation which are expected to occur one or more times during the lifetime of the plant. Acceptability is based upon GDC 10 which requires appropriate design margins to assure that specified acceptable fuel design limits are not exceeded during any condition of normal operation, including the efTects of AOOs.

Accidents are events which are not expected to occur during plant lifetime but are postulated by considering credible initiating events. Acceptance Criteria associated with postulated accidents are based upon 10 CFR 100 which establishes limits for the radiological effects of the event.

Events invoMne multiple safety system failgr_g are specific events required by regulation to be addressed in the plant's  ;

design. In these cases, the specific regulation specifies acceptability. Examples of such design basis events include i Anticipated Transient Without Scram (10 CFR 50.62) and Station Blackout (10 CFR 50.63).

Severe Accidents are events involving multiple safety system failures but which are not addressed by a regulation specific to the event. Severe accidents are "beyond design besis" events typically identified as significant by performance of a i i

probabilistic risk assessment. The NRC has established safety goals and a severe accident policy that requires a balance of preventive and mitigative design features to provide an acceptable level of public protection. Review of such events should be addressed in SRP Chapter 19.

SRP Reference Citation Formats The first citation of each reference in the SRP text, except citations of CFR references and Regulatory Guides, should include a parenthetical notation identifying the References subsection item number for that document. Subsequent citations of references need not include the parenthetical reference notation.

NUREG-1561 A.2

Appendix A i

i Citations of codes and standards should not include version information unless necessary to distinguish betwcen different versions being discussed. The version of the code or standard currently in use by the NRC staff should be identified in the References subsection. <

1 j The following styles should be used for the References subsection listing and the first Acceptance Criteria citation of CFRs:

- e 10 CFR Part 50, $50.55a," Codes and Standards."

• 10 CFR Part 50, Appendix A, General Design Criterion 10," Reactor Design."  !

l e 10 CFR Part 50, Appendix 2. " Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors." l l

I

, Other than the initial citation in the Acceptance Criteria subsection and the References subsection listing, CFR citations for the

above examples would appear as

• 10 CFR 50.55a e General Design Criterion 10 or GDC 10 (depending on whether or not GDC has been defined)

~

• 10 CFR Past 50, Appendix J or Appendix J (where the context is clear) l SRP Reference Verification i

The periodic SRP-MP review of new or revised regulatory documents (described in Section 2.3 of this Implementing Procedures Document) and status of codes and standards (described in Section 2.4 of this Implementing Procedures Document) will result in periodic updating of codes and standard citations, as well as references to the following types of regula'ory documents:

i l l

• NRC Regulations (Rules) . NRC Genericletters

• NRC Policy Statements . NRC Bulletins l = RegulatoryGuides j During the preparation of revisions to existing SRP sections, references to documents and computer codes not identified above i should be verified: (1) as still relevant to the review described in the SRP section; and (2) as the version currently in use by the i NRC staff for its identified purpose.

References to NRC Organizations During the preparation of new SRP sections or revisions to existing SRP sections, all references to NRC organizations should be verified as reflecting current organization names, responsibilities, and acronyms.

l A.4 Format for Individual SRP Sections The following format should be followed for all SRP section content:

REVIEW RESPONSIBILITIES

> Primary - list the NRR branch with the lead (primary) responsibilityfor review of the subject area.

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A.3 NUREG-1561 i

j Appendix A i

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1 Secondary - Iht any NRC branch (es) with nsponsibilitiesfor a portion ofthe review necessary to reach the conclusions listed in Evaluation Findings.

L AREAS OF REVIEW 1

Describe the objectives and the scope ofthe review. The description ofthe scope shouldidentify whichportions ofthe

, applicant 's Safety Analysis Report are reviewed (ifnot obvious) andshould specify which structures, systems or compo.

nents are reviewedunder the section. Discrete topics to be twviewedshould be ducussedin sepamteparagraphs with a

text structurr (numberedparagmphs with subheadings, etc.) that can befollowed in Review Procedurws and Evaluation Findings subsections. An introductory backgmunddiscussion may be included to aid the reader's understanding ofthe needforthe review.

4 Review Intedaces 1

Describe reviews perfonnedin otherSRP Sections which niate to the topics reviewedin the SRPsection andthe usults of which arv niied upon in the overall evaluation ofthe SRP section. Review interfaces arv typically bmken down into two lists: 1) related reviews performed by the same PRB under related SRP sections; and 2) related reviews performed by other review branches under otherSRPsections. Review interfaces should be listedin numberedparagraphform with separate paragraphsfor different PRBs andSRP sections. Interfaces that inwive a single PRB and relatedSRP sections can be identifed as a single item. The interface descriptions shouldidentify: 1) the niated topic arwa(s); 2) the PRB responsiblefor the review; and 3) the relatedSRP section number (s).

IL ACCEPTANCE CRITERIA l List the primary requirements (Acceptance Criteria) that maal be metfor the reviewed area to meet NRC rwgulations.

These typically consist ofGeneral Design Criteria (GDCs)fmm Appendix A to 10 CFR Part 30, but may include specifc ngulations that apply to the areas ofreview. Acceptance Criteria spec @edfor the analysis oftransients andaccidents shalladdress Generic Safetyissue B-3 by using terminology consistent with the categorization ofthe ennt being reviewed in the SRP section (refer to the discussion under SRP Section Denlopment Guidelines - Ewnt Terminology, abow).

i Many SRP sectioru also include discussion ofguidance (ident$ed as " Spec @c Criteria " or " specific acceptance cd-tena ") which ident$es approachesfound acceptable by the NRC stafthat may befol! owed to meet the relevant nquirs-ments ofthe Acceptance Criteria. Spec @c Criteria often reference Regulatory Guides, industry consensus codes and standards, and/orBranch TechnicalPositions. Ifincluded, a clear distinction should be made between Specific Criteria (guidance) andAcceptance Criteria (rsquirements).

i Technical Rationale l

Descnbe each Acceptance Criterion, pmvide a narrative explanation ofhow the ident$edrequirwment applies to the topics twviewed under the section, and discuss the safety benefI ofmeeting the requirrment. Guidance (spec @c criteria) may be discussedin the context ofapplicable Acceptance Criteria, but do not warrant sepamte technical rationale

discussions. l 1 IIL REVIEW PROCEDURES ,

)

Describe the steps that should befollowed by the nviewer(s) and any additionalguidancefor how the review should be

, performed. This is the appmpriate location to discuss stafpositions such as those promulgatedin such genenc com-munications as NRC Bulletins and Generic Letters (which are not appropriate to be listed as Acceptance Criteria). If NUREG-1561 A.4 1

}

Appendix A sewml arwas are reviewed under the section, the Review Pmceduns should be organized (with appmpriate subtopic headings, etc.) coruistent with the organization ofAreas ofReview.

IV. EVALUATION FINDINGS Pmvide example Evaluation Findings suitablefor incorpomtion into the stafs Safety Evaluation Report. Each Acceptance Criterion should be additssedspecifically. Thefndings ahouldidentify the reviewer's conclusions and the basesfor those conclusions. Evaluation Findings do not typically address topics covered only in Review Pmcedures, except as the topics relate directly to an Acceptance Criterion.

V. IMPLEMENTATION Pmvide a description of the stafs plansfor use of the SRP section, including a schedulefor application ofthe specifc section!rsvision and any limitations as to which types ofapplications the section will be usedfor. Ifstafpositions that art not intended to be imposed upon a set ofapplicants orlicensees have been added to the SRP, this subsection should clearly identify those applicants / licensees to which the positions apply.

VL REFERENCES List alldocuments, except SRP sections, citedin the text ofthe other subsections. This listing should assign a unique refennce numberfor each document listed. Documents not citedin the SRP text should not be included in the references listing.

Each reference listing shouldinclude a descriptiw title, any identifying document numbers, and specapc date or version identifcation. Forindustry codes and standards, this is the proper location to specify the particular version ofthe code / standard that the stafwill use in their review.

The nferences listing should be ordered asfollows: 1) Code ofFedem! Regulation (CFR) citations in alpha-numeric onter; 2) CFR appendices, including GDCs, in alpha-numeric order; 3) NRCpolicy statements, including Regulatory Guides, in alpha-numeric order; 4) NUREG reports; 3) generic communications such as Generic Letters and Bulletins:

6) other NRC correspondence; 7) Contractor NUREGERs; 8) Industry codes and standards; and 9) other documents.

See reference citationformat guidancefor styles to be usedin listing ofCFRs. Thefollowing style should be usedfor the References subsection listing ofGeneric Letters and Bulletins:

. NRC letter to All Holders of Operating Licenses for Nuclear Power Reactors With Mark I containrnents," Installation of a Hardened Wetwell Vent (Generic Letter No. 89-69)," September 1,1989.

• NRC Bulletin to All Holders of Operating Licenses or Constmetion Permits for Pressunzed Water Reactors,"NRC Bulletin No. 89-03: Potential Loss of Required Shutdown Margin During Refueling Operations," November 21,1989.

A.5 NUREG-1561

4 NRC roRM 336 U.S. NUCLEAR REGutATORY COMMISSION 1. REPORT NUhEER 04M (Aesened by senc. Ace vol., supp., nov,,

$"3E BIBLIOGRAPHIC DATA SHEET '"d'*****""""***'*"*"F4 NUREG-1561

2. TlTLE AND SUBTITLE

, Standard Review Plan Maintenance Program implementing Procedures Document wouTH YEAR l

November 1996

4. FIN OR GRANT NUMBER

5. AUTHOR (S) 6. TYPE OF REPORT Technical

7. PERIOD COVERED pncJus&e Defes)

April 1996 to September 1996

8. PERFORMING ORGANIZATION . NAME AND ADDRESS (FNRC, provede Dymm OWre a Regm & S Nuctow Reguiekry Conmsson, and sneshng addoss, #corteckr, provede aume and me<4ng address J Division of Inspe,ctiore and Support Programs Offics of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

9. SPONSORING ORGANIZATION . NAME AND ADDRESS (F NRC. type %me as e6 ave'; acortectr. provede NRC Dwsm omce a Regm u s NucAser Reguinkry commesm a and meekng ed&ess)

Sama as 8 above.

10. SUPPLEMENTARY NOTES

11. ABSTRACT (200 wads a hess)

The implementing Procedures Document (IPD) was developed by the inspection Program Branch, Office of Nuclear Reactor Regulation, with assistance from Pacific Northwest Laboratory, for the Standard Review Plan Maintenance Program (SRP-MP).

The SRP-MP was established to maintain the Standard Review Plan (SRP) on an on-going basis. The IPD provides guidance, including an overall approach and procedures, for SRP-MP tasks. The objective of the IPD is to ensure that revisions to the SRP reflect current NRC requirements and guidance, and that a consistent methodology is used to develop and revise SRP sections.

12. KEY Vv0ROS/DESCRIPTORS (Lut words a piroses that ws# essist researchers m sacersna the sepwf J 13 AvAILAsiUTY STATEMENT unlimited Standard Review Plan (SRP)

NUREG-0800 14 SECURffYCLASSirCATION crha poge) unclassified (The Repa0 unclassified

15. NUMBER OF PAGES

16. PRICE l

wac ronnisas aim Tw.s vo,. sciruncen, p,oduo.d 6, Ei F.d.,ei For inc.

He'Um N PROCEDURES DOCUMENT UNITED STATES NUCLEAR REGULATORY COMMISSION g 37 ,

WASHINGTON, DC 20555-0001 POSTAGE AND FEES PA!D USNRC PERMIT NO, G47 CFFOAL BUSINESS PENALTY FOR PRIVATE USE, $300 120555139531 1 1AN11T US NDC-0ADM DIV FOIA & PU9LICATIONS SVCS TPS-PDR-NUREG 2WFN-6ET WASHINGTON DC 20555 I

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