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Category:INTERNAL OR EXTERNAL MEMORANDUM
MONTHYEARML20217M6061999-10-20020 October 1999 Notification of 991102 Meeting with Util in Port Gibson,Ms to Discuss Bases for Emergency Preparedness Plan Change Submitted in & Supplemented by 990120 & 0715 Ltrs ML20217D7031999-10-0707 October 1999 Informs That USNRC Had Dicussions with Licensee on 990908 Application for License Amend to Relocate 18-month Standby Diesel Generator Insp Sr.Forwards Preliminary Info Submitted by Licensee Re Supplement to Application ML20217A8641999-10-0606 October 1999 Forwards NRC Approved Operator Licensing Exam (Facility Outline & Initial Exam Submittal & as-given Operating Exam) for Tests Administered on 990829-0903 ML20212L3481999-10-0101 October 1999 Forwards Document Re Replacement SG Water Level Trip Setpoint Differences to Be Placed in PDR ML20212H0351999-09-27027 September 1999 Revised Notification of 991007 Meeting with Util to Discuss Status of Radiation Protection Program ML20216F9021999-09-21021 September 1999 Notification of 991005-07 Meeting with STP Nuclear Operating Co in Bay City,Tx,To Review Plant Categorization & Feedback Process of Risk Ranking Components IR 05000416/19990021999-09-10010 September 1999 Notification of Significant Licensee Meeting with Entergy Operations,Inc on 991018 to Discuss Listed Topics Identified in NRC Insp Repts 50-416/99-02,99-03 & 99-06 ML20211P1801999-09-0808 September 1999 Notification of 991007 Meeting with Util at DD Eisenhower Learning Ctr to Discuss Status of Radiation Protection Program ML20211K7171999-09-0202 September 1999 Forwards Ineel Technical Ltr Rept, Evaluation of Fuel Pin Failure Timing in Boiling Water Reactors Dated 990730.Rept Used for Review of BWROG Rept on Revised Source Term Accident Analysis ML20211H4441999-08-27027 August 1999 Notification of Significant Meeting with Util on 990916 & 17 in Arlington,Tx to Improve Utility & NRC Understanding of Industry & Regulatory Perspectives on Current Issues ML20211J2141999-08-27027 August 1999 Notification of 990831 Meeting with Util to Discuss Issues Associated with STPNOC Recent Request to Exclude safety- Related Low Risk Significant & non-risk Significant Components from Scope of Special Treatment Requirements ML20211G2671999-08-27027 August 1999 Notification of 990909 Meeting with Util in Rockville,Md to Discuss Proposed TSs for Emergency Feedwater Sys at Waterford 3 ML20211G7001999-08-25025 August 1999 Forwards Examination Rept with as Given Written Exam Administered on 990706-15 for Distribution Under Rids Code IE42 ML20211G2501999-08-25025 August 1999 Forwards NRC Approved Operator Licensing Exam (Facility Outline & Initial Exam Submittal & as-given Operating Exam) for Tests Administered on 990706-15 ML20211E1491999-08-23023 August 1999 Notification of Licensee Meeting with Util on 990830 to Discuss Recent Refueling Maint Outage ML20211F3801999-08-20020 August 1999 Notification of 990831 Meeting with Util in Rockville,Md to Discuss Issues Associated with STPNOC Recent Request to Exclude safety-related low-risk Significant & non-risk Significant Components, Designated Under Gqa Program ML20210P9351999-08-0909 August 1999 Notification of 990923 Meeting with Util in Arlington,Tx to Introduce New Director,Safety Quality Concerns Program & Status of Activities to Support Confirmatory Order Modifying License ML20210M6841999-08-0505 August 1999 Notification of Licensee Meeting with Util on 990914 in Arlington,Tx to Discuss New Mgt Team Introduction & Site Status ML20209G2421999-07-14014 July 1999 Notification of 990722 Meeting with License in Rockville, MD to Discuss Changes in EOI Licensing Organization Including Division of Responsibilities within New EOI Corporate Licensing Group ML20209F6111999-07-12012 July 1999 Revised Notification of 990805 Meeting with Util to Discuss Radiation Protection Issues Identified in NRC Insps Repts 50-458/98-10 & 50-458/99-04 ML20209D5751999-07-0909 July 1999 Notification of 990722 Meeting with Util in Rockville,Md to Discuss Licensee Proposed SG Water Level Trip Setpoint TS & Setpoint Impact on Pressurizer Water Level TS Per 10CFR50.36 ML20196L1481999-07-0707 July 1999 Forwards Info Provided by Licensee to Facilitate Conference Calls Re Licensee Desire to Propose Emergency Technical Specification Changes on Fuel Handling Building Exhaust Air Sys ML20209D8271999-07-0707 July 1999 Notification of 990719 Licensee Meeting in Arlington,Tx to Discuss Failed Fuel Recovery Project ML20196G1291999-06-26026 June 1999 Notification of 990727-28 Meeting with Util to Discuss Licensee Use of Risk Info in Low Power & Shutdown Operations at Wolf Creek Generating Station.Meeting Held in Burlington,Ks ML20212J2641999-06-24024 June 1999 Forwards Addl Info from Licensee Re Clarification of Sentence in Util (on Page 4 of 7) Which States That, Isolation Valves in This Sys Designed to Be Operated remote-manually from Control Room ML20196G0321999-06-24024 June 1999 Notification of 990726 Meeting with Util to Discuss Radiation Protection Issues ML20196F0391999-06-23023 June 1999 Notification of 990707 & 08 Meeting with EOI in Conference 1 at GGNS Energy Svc Ctr to Discuss Low Power Shutdown Risk Assessment Methods & Associated Probabilistic Risk Assessment Model ML20195J0441999-06-14014 June 1999 Refers to Discussions with Licensee on Future Suppl to Application on Replacement Steam Generator Reactor Coolant Flow Differences ML20195J0841999-06-14014 June 1999 Forwards Info Re Suppl to Application on TS 3.6.3,action B, to Clarify Use of Check Valve with Flow Through Valve Secured as Means to Isolate Affected Containment Penetration,To Be Placed in PDR ML20195G0011999-06-11011 June 1999 Submits Record of 990430 Telcon Re Nondestructive Exam ISI Issues,Including Increased Sensitivity of UT Exam Performed After Electrosleeve Installation Versus Eddy Current Test Performed Prior to Sleeve Installation ML20195F8811999-06-10010 June 1999 Notification of 990622 Meeting with Util in Rockville,Md to Discuss Related Issues Associated with Fuel Integrity Problems Experienced During Recent Cycle 8 Operation ML20207E8961999-06-0303 June 1999 Discusses Which Submitted Relief Request RR-ENG-2-8 Which Requested Relief from ASME Code Based on Provisions of Code Case N-491-2.Requests That Encl Be Placed Into PDR ML20207E9231999-06-0202 June 1999 Notification of 990611 Meeting with EOI in Rockville, Maryland to Be Briefed by EOI & to Discuss Related Issues Associated with Fuel Integrity Problems Experienced During Recent Cycle 8 Operation ML20207G3761999-06-0202 June 1999 Revised Notification of 990611 Meeting with EOI in Rockville,Maryland to Discuss Issues Associated with Fuel Integrity Problems Experienced During Recent Cycle 8 Operation.Meeting Cancelled ML20207D9911999-05-28028 May 1999 Informs That NRC Requested That Licensees Respond to Survey on Hydrogen Storage Facilities,To Support Preliminary Evaluation to Determine If Addl Study Warranted.South Texas Project Licensee Response Encl for Placement in PDR ML20207C3391999-05-26026 May 1999 Forwards NRC Approved Operator Licensing Exam Facility Outline & Initial Exam Submittal for Retake Exam Administered on 990416 ML20207A6671999-05-20020 May 1999 Notification of 990602 & 03 Meeting with Util in South Texas Project Nuclear Support Ctr,Southwest of Bay City,Tx,In Order for Licensee to Present low-power Shutdown Risk Model ML20207A7321999-05-20020 May 1999 Submits Record of 990429 Telcon with Union Electric Personnel Re Electrosleeve Amend Application for Callaway Plant,Unit 1.Info Provided by Ue Included in Attachments 1 & 2.List of Personnel That Participated in Telcon Encl ML20207A3381999-05-19019 May 1999 Informs of Discussions with Licensee on 980831 Application for License Amend to TS 3.4.9.3 to Reflect Revised Cold Overpressure Mitigation Curve Associated with Replacement Sgs.Request That Encl Documents Be Placed in PDR ML20207A2551999-05-18018 May 1999 Notification of 990603 Meeting with EOI in Rockville,Md to Discuss EOI Submittal on BWROG Source Term Analysis & Possible Related Future Amend Requests from EOI ML20206N6411999-05-13013 May 1999 Refers to Discussions with Licensee on Response to GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions ML20206G2041999-05-0404 May 1999 Discusses 981201 Telcon Between NRC Staff & STP Re 10CFR50.59 Evaluation of MSLB Reanalysis & Effect on Isolation Valve Cubicle & Rcb.Requests That Encl Draft Info Be Placed in PDR ML20206G5041999-05-0404 May 1999 Requests That Enclosures 1 & 2 Re 990412 Conference Call, Discussing Preliminary Results of SG Insp,Be Placed in PDR ML20206F8831999-04-30030 April 1999 Informs That NRC Staff Will Discuss Encl Draft for RAI with Eoi,Re EOI Response to GL 95-07, Pressure Locking & Thermal Binding ML20206A4851999-04-26026 April 1999 Informs That Staff Needs to Conduct Phone Call with Licensee on Licensee Response to GL 95-07.In Order to Conduct Phone Call,Staff Needs to Provide Licensee with Attached Info DD-99-05, Forwards Monthly Rept on Status of 10CFR2.206 Petition as of 990331.During March,Director'S Decision (DD-99-06) on Browns Ferry & DD on Army Corps of Engineers Was Issued & (DD-99-05) on Diablo Canyon Became Final Agency Action1999-04-20020 April 1999 Forwards Monthly Rept on Status of 10CFR2.206 Petition as of 990331.During March,Director'S Decision (DD-99-06) on Browns Ferry & DD on Army Corps of Engineers Was Issued & (DD-99-05) on Diablo Canyon Became Final Agency Action ML20205R8791999-04-20020 April 1999 Notification of 990422 Meeting with Util in Rockville,Md to Discuss NRC Staff Review of Util Amend Application Requesting Approval of Electrosleeve Steam Generator Tube Repair ML20205R8871999-04-20020 April 1999 Notification of 990504 Meeting with Util in Rockville,Md to Discuss Proposal to Submit Consolidated Security Plan for Util Sites ML20205Q8111999-04-15015 April 1999 Forwards Draft Undated Rev 6 to Operations QA Plan Independent Technical Review, Per Discussions with Licensee on 990407 Re Proposed Change to TSs on Independent Safety Engineering Group ML20205Q8251999-04-15015 April 1999 Forwards Documentation on Licensee 980928 Proposed Changes to TS on Control Room & Fuel Handling Bldg Ventilation Sys, Per 990304 Discussion with Util 1999-09-08
[Table view] Category:MEMORANDUMS-CORRESPONDENCE
MONTHYEARML20217M6061999-10-20020 October 1999 Notification of 991102 Meeting with Util in Port Gibson,Ms to Discuss Bases for Emergency Preparedness Plan Change Submitted in & Supplemented by 990120 & 0715 Ltrs ML20217D7031999-10-0707 October 1999 Informs That USNRC Had Dicussions with Licensee on 990908 Application for License Amend to Relocate 18-month Standby Diesel Generator Insp Sr.Forwards Preliminary Info Submitted by Licensee Re Supplement to Application ML20217A8641999-10-0606 October 1999 Forwards NRC Approved Operator Licensing Exam (Facility Outline & Initial Exam Submittal & as-given Operating Exam) for Tests Administered on 990829-0903 ML20212L3481999-10-0101 October 1999 Forwards Document Re Replacement SG Water Level Trip Setpoint Differences to Be Placed in PDR ML20212H0351999-09-27027 September 1999 Revised Notification of 991007 Meeting with Util to Discuss Status of Radiation Protection Program ML20216F9021999-09-21021 September 1999 Notification of 991005-07 Meeting with STP Nuclear Operating Co in Bay City,Tx,To Review Plant Categorization & Feedback Process of Risk Ranking Components IR 05000416/19990021999-09-10010 September 1999 Notification of Significant Licensee Meeting with Entergy Operations,Inc on 991018 to Discuss Listed Topics Identified in NRC Insp Repts 50-416/99-02,99-03 & 99-06 ML20211P1801999-09-0808 September 1999 Notification of 991007 Meeting with Util at DD Eisenhower Learning Ctr to Discuss Status of Radiation Protection Program ML20211K7171999-09-0202 September 1999 Forwards Ineel Technical Ltr Rept, Evaluation of Fuel Pin Failure Timing in Boiling Water Reactors Dated 990730.Rept Used for Review of BWROG Rept on Revised Source Term Accident Analysis ML20211H4441999-08-27027 August 1999 Notification of Significant Meeting with Util on 990916 & 17 in Arlington,Tx to Improve Utility & NRC Understanding of Industry & Regulatory Perspectives on Current Issues ML20211J2141999-08-27027 August 1999 Notification of 990831 Meeting with Util to Discuss Issues Associated with STPNOC Recent Request to Exclude safety- Related Low Risk Significant & non-risk Significant Components from Scope of Special Treatment Requirements ML20211G2671999-08-27027 August 1999 Notification of 990909 Meeting with Util in Rockville,Md to Discuss Proposed TSs for Emergency Feedwater Sys at Waterford 3 ML20211G2501999-08-25025 August 1999 Forwards NRC Approved Operator Licensing Exam (Facility Outline & Initial Exam Submittal & as-given Operating Exam) for Tests Administered on 990706-15 ML20211G7001999-08-25025 August 1999 Forwards Examination Rept with as Given Written Exam Administered on 990706-15 for Distribution Under Rids Code IE42 ML20211E1491999-08-23023 August 1999 Notification of Licensee Meeting with Util on 990830 to Discuss Recent Refueling Maint Outage ML20211F3801999-08-20020 August 1999 Notification of 990831 Meeting with Util in Rockville,Md to Discuss Issues Associated with STPNOC Recent Request to Exclude safety-related low-risk Significant & non-risk Significant Components, Designated Under Gqa Program ML20210P9351999-08-0909 August 1999 Notification of 990923 Meeting with Util in Arlington,Tx to Introduce New Director,Safety Quality Concerns Program & Status of Activities to Support Confirmatory Order Modifying License ML20210M6841999-08-0505 August 1999 Notification of Licensee Meeting with Util on 990914 in Arlington,Tx to Discuss New Mgt Team Introduction & Site Status ML20209G2421999-07-14014 July 1999 Notification of 990722 Meeting with License in Rockville, MD to Discuss Changes in EOI Licensing Organization Including Division of Responsibilities within New EOI Corporate Licensing Group ML20209F6111999-07-12012 July 1999 Revised Notification of 990805 Meeting with Util to Discuss Radiation Protection Issues Identified in NRC Insps Repts 50-458/98-10 & 50-458/99-04 ML20209D5751999-07-0909 July 1999 Notification of 990722 Meeting with Util in Rockville,Md to Discuss Licensee Proposed SG Water Level Trip Setpoint TS & Setpoint Impact on Pressurizer Water Level TS Per 10CFR50.36 ML20209D8271999-07-0707 July 1999 Notification of 990719 Licensee Meeting in Arlington,Tx to Discuss Failed Fuel Recovery Project ML20196L1481999-07-0707 July 1999 Forwards Info Provided by Licensee to Facilitate Conference Calls Re Licensee Desire to Propose Emergency Technical Specification Changes on Fuel Handling Building Exhaust Air Sys ML20196G1291999-06-26026 June 1999 Notification of 990727-28 Meeting with Util to Discuss Licensee Use of Risk Info in Low Power & Shutdown Operations at Wolf Creek Generating Station.Meeting Held in Burlington,Ks ML20212J2641999-06-24024 June 1999 Forwards Addl Info from Licensee Re Clarification of Sentence in Util (on Page 4 of 7) Which States That, Isolation Valves in This Sys Designed to Be Operated remote-manually from Control Room ML20196G0321999-06-24024 June 1999 Notification of 990726 Meeting with Util to Discuss Radiation Protection Issues ML20196F0391999-06-23023 June 1999 Notification of 990707 & 08 Meeting with EOI in Conference 1 at GGNS Energy Svc Ctr to Discuss Low Power Shutdown Risk Assessment Methods & Associated Probabilistic Risk Assessment Model ML20195J8301999-06-18018 June 1999 Staff Requirements Memo Re 990618 Affirmation Session for SECY-99-133, Final Rev to 10CFR50.65 to Require Licensees to Perform Assessments Before Performing Maint & SECY-99-145 Re Antitrust Issues for Wolf Creek Unit 1 ML20195J0841999-06-14014 June 1999 Forwards Info Re Suppl to Application on TS 3.6.3,action B, to Clarify Use of Check Valve with Flow Through Valve Secured as Means to Isolate Affected Containment Penetration,To Be Placed in PDR ML20195J0441999-06-14014 June 1999 Refers to Discussions with Licensee on Future Suppl to Application on Replacement Steam Generator Reactor Coolant Flow Differences ML20195G0011999-06-11011 June 1999 Submits Record of 990430 Telcon Re Nondestructive Exam ISI Issues,Including Increased Sensitivity of UT Exam Performed After Electrosleeve Installation Versus Eddy Current Test Performed Prior to Sleeve Installation ML20195F8811999-06-10010 June 1999 Notification of 990622 Meeting with Util in Rockville,Md to Discuss Related Issues Associated with Fuel Integrity Problems Experienced During Recent Cycle 8 Operation ML20207E8961999-06-0303 June 1999 Discusses Which Submitted Relief Request RR-ENG-2-8 Which Requested Relief from ASME Code Based on Provisions of Code Case N-491-2.Requests That Encl Be Placed Into PDR ML20207G3761999-06-0202 June 1999 Revised Notification of 990611 Meeting with EOI in Rockville,Maryland to Discuss Issues Associated with Fuel Integrity Problems Experienced During Recent Cycle 8 Operation.Meeting Cancelled ML20207E9231999-06-0202 June 1999 Notification of 990611 Meeting with EOI in Rockville, Maryland to Be Briefed by EOI & to Discuss Related Issues Associated with Fuel Integrity Problems Experienced During Recent Cycle 8 Operation ML20207D9911999-05-28028 May 1999 Informs That NRC Requested That Licensees Respond to Survey on Hydrogen Storage Facilities,To Support Preliminary Evaluation to Determine If Addl Study Warranted.South Texas Project Licensee Response Encl for Placement in PDR ML20207C3391999-05-26026 May 1999 Forwards NRC Approved Operator Licensing Exam Facility Outline & Initial Exam Submittal for Retake Exam Administered on 990416 ML20207A7321999-05-20020 May 1999 Submits Record of 990429 Telcon with Union Electric Personnel Re Electrosleeve Amend Application for Callaway Plant,Unit 1.Info Provided by Ue Included in Attachments 1 & 2.List of Personnel That Participated in Telcon Encl ML20207A6671999-05-20020 May 1999 Notification of 990602 & 03 Meeting with Util in South Texas Project Nuclear Support Ctr,Southwest of Bay City,Tx,In Order for Licensee to Present low-power Shutdown Risk Model ML20207A3381999-05-19019 May 1999 Informs of Discussions with Licensee on 980831 Application for License Amend to TS 3.4.9.3 to Reflect Revised Cold Overpressure Mitigation Curve Associated with Replacement Sgs.Request That Encl Documents Be Placed in PDR ML20207A2551999-05-18018 May 1999 Notification of 990603 Meeting with EOI in Rockville,Md to Discuss EOI Submittal on BWROG Source Term Analysis & Possible Related Future Amend Requests from EOI ML20206N6411999-05-13013 May 1999 Refers to Discussions with Licensee on Response to GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions ML20206G2041999-05-0404 May 1999 Discusses 981201 Telcon Between NRC Staff & STP Re 10CFR50.59 Evaluation of MSLB Reanalysis & Effect on Isolation Valve Cubicle & Rcb.Requests That Encl Draft Info Be Placed in PDR ML20206G5041999-05-0404 May 1999 Requests That Enclosures 1 & 2 Re 990412 Conference Call, Discussing Preliminary Results of SG Insp,Be Placed in PDR ML20206F8831999-04-30030 April 1999 Informs That NRC Staff Will Discuss Encl Draft for RAI with Eoi,Re EOI Response to GL 95-07, Pressure Locking & Thermal Binding ML20206A4851999-04-26026 April 1999 Informs That Staff Needs to Conduct Phone Call with Licensee on Licensee Response to GL 95-07.In Order to Conduct Phone Call,Staff Needs to Provide Licensee with Attached Info ML20205R8791999-04-20020 April 1999 Notification of 990422 Meeting with Util in Rockville,Md to Discuss NRC Staff Review of Util Amend Application Requesting Approval of Electrosleeve Steam Generator Tube Repair ML20205R8871999-04-20020 April 1999 Notification of 990504 Meeting with Util in Rockville,Md to Discuss Proposal to Submit Consolidated Security Plan for Util Sites DD-99-05, Forwards Monthly Rept on Status of 10CFR2.206 Petition as of 990331.During March,Director'S Decision (DD-99-06) on Browns Ferry & DD on Army Corps of Engineers Was Issued & (DD-99-05) on Diablo Canyon Became Final Agency Action1999-04-20020 April 1999 Forwards Monthly Rept on Status of 10CFR2.206 Petition as of 990331.During March,Director'S Decision (DD-99-06) on Browns Ferry & DD on Army Corps of Engineers Was Issued & (DD-99-05) on Diablo Canyon Became Final Agency Action ML20205Q8251999-04-15015 April 1999 Forwards Documentation on Licensee 980928 Proposed Changes to TS on Control Room & Fuel Handling Bldg Ventilation Sys, Per 990304 Discussion with Util 1999-09-08
[Table view] |
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t>" R8009 UNITED STATES
- y. . $'g NUCLEAR REGULATORY COMMISSION 4 $ REGloN IV
'44
- [ 611 RYAN PLAZA DRIVE, SulTE 400 9..++/ AR LINGToN, TEXAS 76011-8064 March 20, 1997 MEMORANDUM FOR: File FROM: Michael Vasquez, Enforcement Specialist
SUBJECT:
MEETING BETWEEN THE REGION IV UTILITY GROUP (RUG)
AND NRC This documents the meeting conducted in the Region IV office on February 25,195 between the RUG and the NRC. This meeting was held at the RUG's request to dis .s the NRC's Enforcement Policy as it is applied to nonescalated enforcement. The RUG expressed its intent to comment on the NRC's Enforcement Policy. No decisions were ;
made at this meeting. l I
In accordance with Section 2.790 of the NRC's " Rule of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this memorandum, with the attachments, will be placed in the NRC's public Document Room.
Any questions should be addressed to the NRC Region IV enforcement staff.
Enclosures:
- 1. Attendance List
- 2. RUG Presentation Handout l
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i l DOCUMENT NAME: G:\EA\ DRAFT \ RUG-SUM. FIN To receive copy of document, indicate in box:"c"-
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750001 -
4 REGION IV UTILITY GROUP MEETING February 25, 1997. 8 a.m.
Region IV Training Conference Room Arlington. TX NAME (PLEASE PRINT) ORGANIZATION TITLE 1
Crny SAnmu #cescriou4 Enfouc w r Orecee l Lour oes Fe_ftawne2. _%.pri.y Synen . W WP-2. L , c e M S ,sa c,- M 4 a u , ,,t.
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Background t-e January 29-30,1996, American Nuclear Society sponsored " Utility-NRC :
Interface Workshop - Region IV"- finding that although the NRC has successfully established a clear framework and detailed guidance for escalated enforcement actions, a non-escalated enforcement policy has not been sufficiently developed.
e ' March 19,1996, Region IV Utility Group (RUG IV) special committee on non-escalated NRC enforcement policy assessment process formed to provide input to the NRC on non-escalated enforcement (Severity Level IV, Non-Cited Violations :NCVs], and Minor Violations).
o Currently 95% of all NRC enforcement actions (approximately 600- Og fall into the category of non-escalated enforcement. /
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Consistent Policy e Enable informed individuals at all levels [public, licensee, inspectors, licensee management, NRC management] to understand enforcement actions which are applied to specific events / conditions
- " . ..the [NRC] believes the [ enforcement] process can be simplified to improve the predictability of decisions making and obtain better consistency between regions." - Section ll!.C, " Conclusions," NUREG-1525, Assessment of the NRC Enforcement Program.
e "...the [NRC:lG] noted the enforcement policy does not appear to have been uniformly applied between regions... "and" ... [NRC organizational structure]
contributes to inconsistent program implementation, particularly in the use of j violations. " - Report, Office of the inspector General, Factors p Contributing to inconsistency in the Operating Reactor inspection [ 7 Program, (OlG/95A-C4).
A- ps
l Non-Escalated Enforcement Policy Assessment Process The NRC Enforcement Policy,Section VI.B.2, " Civil Penalty Assessment,"
contains a flow chart which is a graphical representation of the civil penalty ,
l assessment process. Similarly, the following flow chart is a graphical l
representation of the entire enforcement policy assessment process: ,
l Facts / Safety No ssues = "' Significanc r Minor Circumstances Yes n I
Escalated
~
Go To Level I, il or 111 Yes Level IV u .
Yes Non-Cited 6""
No Response No ?
- Cited Level IV = Mitigation Violat. ion Requ. ired ,
Definitions ,
. Improvement and/or Consistent Application in Enforcement Definitions
- Safety Significance
- - Potential Safety Significance
- Regulatory Significance / Concern
- Minor Violations L
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Safety Significance The Enforcement Manual, Section 3.5.a, " Safety Significance," States in part:
" Safety significance, as used in the enforcement program, involves consideration of three factors: (1) the actual safety consequences (e.g.,
overexposure, offsite release, loss of safety system), (2) the regulatory significance, and (3) the potential safety consequences of a violation. In other words, consideration is given to the matter as a whole in light of the circumstances surrounding the violation. There may be cases where the actual safety consequence of a violation represents a minor concem but the regulatory significance or the potential safety consequences represents a significant concem." .
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m Safety Significance The following definition from the Enforcement Policy is proposed:
Actual Safety Significance The event must cause an actual overexposure in excess of NRC regulatory limits (10CFR20), offsite release of radioactivity in excess of NRC regulatory limits (10CFR20), or result in the actual loss of the safety function of a safety system (inability of the safety system to perform its safety function as described in the UFSAR, as credited in the Chapte 15 Accident Analysis). p gk e
. ,y
t Potential Safety Significance Evaluate Use of Existing Definitions Such as 10 CFR 50.72 & 73 and NUREG-1022
- Not all NUREG-1022 Examples are Violations Illustrate Using Examples of Escalating Severity Level Violations
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Potential Safety Significance 10 CFR 50.72,50.73, and NUREG-1022
, 50.73 (b) l
- Reasonable and Credible Alternative Conditions -
Power and Mode 5'O.73(aX2XiXB)
- Operation of the Plant Prohibited by Tech Specs
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l Potential Safety Significance 10 CFR 50.72,50.73, and NUREG-1022 (continued) ]
50.73(aX2Xii)
- Principle Safety Barrier Seriously Degraded
- Unanalyzed Condition Significantly Compromised Plant Safety l
- Being Outside Design Basis
- Condition Alone Could Have Prevented Fu!fillment of Safety Function of Systems Necessary to .
- Shutdown Reactor pg
- Remove Residual Heat
- Control Release e
/
- Mitigate Consequence ,e
.i Regulatory Significance The NRC Enforcement Policy,Section IV, I
" Severity of Violations," states in part, '
Therefore, the relative importance of each violation, including both the technical and regulatory significance is evaluated... In some i cases, special circumstances may warrant an adjustment to the ,
severity level categorization... A. Aggregation of Violations... B.
Repetitive Violations... C. Willful Violations... D. Violations of Reporting Requirements..."
Therefore, the following definition from the En"orcement Policy is proposed:
[
Regulatory Concern w 4 .4,#
The event involves the special circumstances of any of thfe '.J*~ ^
f following: aggregation, repetition, willfulness, or reporting /
NUREG-0195
- b. Severity Level, as used in the enforcement program, involves consideration of the safety significance of a violation and categorization at one of four levels. Normally, all violations are categorized in terms of severity level. Severity Level I and 11 violations are the most significant and represent very significant regulatory concerns for which escalated enforcement action is normally taken. Severity Level 111 violations are cause for significant regulatory concern for which escalated enforcement action is normally taken.
Severity Level IV violations are less serious than Severity Level lli violations, but are of more than minor concem. If left uncorrected or repetitive, a Severity Level IV violation could lead to a more serious concern warranting a Severity Level lli categorization.
- c. Minor violations (previously categorized at Severity Level V) are not the subject of formal enforcement action and are not usually described in inspection reports. To the extent such violations are described, they are noted as Non-Cited Violations. (See Section 3.7 for additional guidance on documenting minor violations in inspection reports.)
A test of whether a violation should be categorized as a minor violation is whether, if it recurred several times, it would still be of minor concern. Such violations normally are characterized by (1) having no actual impact and little or no potential for impact on safety, (2) being isolated, not evidencing programmati weaknesses, and (3) relating to licensee administrative limits rather than to NRC regulatory limi an inspector identifies a violation, the determination of whether the violation is minor shoul' he following questions:
Does the violation have any actual impact (or any realistic potential for impact) on safe. _ g4
- Does the violation suggest a programmatic problem that could have a realistic pota Wafety'6r regulatory impact? g #
- Could the violation be viewed as the possible precursor to a significant event-?' '
k NUREG-0195 (continued)
If the violation recurred, would its recurrence be a more significant concern?
- If inadvertently left uncorrected, would this violation become a more significant safety and regulatory concem?
Are there associated circumstances that add regulatory concern to this violation (e.g.,. apparent willfulness, licensee refusal to comply, management involvement, etc.)?
If the answer to all of these questions is "no," the violation should be considered a minorviolation. If, on the other hand, the answer to any one of these questions is "yes," the violation should not be considered a minor violation.
An isolated record-keeping failure may be a minor violation. However, where record-keeping problems interfere in the ability to monitor or audit activities or identify performance problems, the failures are more significant and should not be considered a minor violation.
NUREG/BR-0195 page 6
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BOnef..ITS Clarity - Public, Licensees, inspector Focused ~o n Safety Efficient Use of Resources (NRC & Licensee) by Focusing on Significant Issues - Improve Overall Safety Consistent Implementation - Less
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Confrontation ff
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Actions Taken e Report Sponsored by RUG IV e Report Presented to Region IV (Joe Callanf e Report. Presented to Office of Enforcement (Jim Lieberman) e Report presented to RUG I/II and RUG 11, and to NEl
- Consensus Endorsement e RUG IV will meet with Lieberman and Dyer on February 24,1997, to review report.
Future Action -
'/f o Public Comment Period on NUREG-1600 fp-%
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