ML20141L005
| ML20141L005 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 03/17/1997 |
| From: | Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM) |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20141L002 | List: |
| References | |
| SECY-97-036-C, SECY-97-36-C, NUDOCS 9706020237 | |
| Download: ML20141L005 (3) | |
Text
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j s NOTATION VOTE 4
RESPONSE SHEET j
TO:
John C. Hoyle Secretary of the Commission l
FROM:
CHAIRMAN JACKSON
SUBJECT:
SECY-97-036 - MILLSTONE LESSONS LEARNED REPORT, PART 2:
POLICY ISSUES with Approved XX comments Disapproved Abstain I
Not Participating Request Discussion COMMENTS:
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See attached comments.
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1 lS-A W SIdNATURE Release Vote
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3[t1/T 7 DATE 9706020237 970520 PDR COMMS NRCC CORRESPONDENCE PDR Entered on "AS" Yes XX No 9 706 cz or 57
1 CHAIRMAN JACKSON'S COMMENTS ON SECY-97-036 I believe the Updated FSAR is an essential facet of the NRC's regulatory scheme and plays a primary role in assuring that licensed facilities remain within NRC requirements for the following reasons:
the FSAR describes how a licensee is complying with NRC requirements; 10 CFR 50.59 identifies changes to facilities which require NRC approval before implementation, and directly references the facility as described in the FSAR; the FSAR is being referenced in performing inspections; and, as we move toward Improved Standard Technical Specifications, the FSAR is an appropriate place for relocation of certain parts of existing Technical Specifications.
Whatever controls are put into place to control parts of Technical Specifications which are removed should be subject to analogous updating and safety consideration which are ombodied in 10 CFR 50.71(e) and 10 CFR 50.59.
After a review of the short and long term actions, I have the following comments. The staff should implement 10 CFR 50.71(e) to ensure that FSARs are updated to the fullest extent possible to reflect changes to the design bases and effects of other analyses performed since original licensing which should have been included by that regulation.
The staff should determine the appropriate mechanism to clarify the FSAR update content requirements of 10 CFR 50.71(e), as set forth in short term action 9.
Short term action 9 is important to implement.
In addition, I support implementation of short term actions 3,'4, 10', 11, 12, 13,'and 16. With regard to Action 14, it has been my understanding that we have the necessary requirements to assure that plants 6 are being operated consistent with the design bases and are able to take enforcement actions where needed.
It is my understanding that 10 CFR 50.34 already establishes the regulatory requirement to identify the design basis (50.2 definition) in the FSAR.
If so, effectively implementing 10 CFR 50.71(e) should address long term action 14.
The responses to the recent 10 CFR.50.54(f) letters on the same topic will be used to provide additional confidence that design bases are being met, and to target design related inspections.
With regard to long term actions 5, 6, 7, 15, 18, and short term actions 1, 2, 8, 17,'I have the following comments. While the Commission is awaiting comments on SECY-97-035, " PROPOSED REGULATORY GUIDANCE RELATED TO IMPLEMENTATION OF 10 CFR 50.59 (CHANGES, TESTS AND EXPERIMENTS)," the staff should assess the information and/or commitments that would not be contained in the updated FSAR but the staff considers important, and determine if this information, or a portion thereof, needs to be directly controlled by regulatory process.
In making this determination, the staff should establish the significance level at which direct regulatory control of information and/or commitments is necessary considering the threshold of existing NRC mechanisms which we use to control changes to information we consider significant, that is, information in the FSAR (controlled by 50.59), technical specifications, license conditions, and orders.
As part of this process, the staff should consider whether it would be sufficient for licensees to maintain changes to this information in some kind of auditable form, such as following NEI's guideline for managing commitments made to the NRC, so that the NRC staff can assess through inspection whether those changes are appropriate, or are significant such that the commitment should be imposed by order or license 1
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condition. The staff should consider a recently licensed plant and an older plant in this assessment.
l Following conclusion of the comment period SECY-97-035, " PROPOSED REGULATORY GUIDANCE RELATED TO IMPLEMENTATION OF 10 CFR 50.59 (CHANGES, TESTS AND l
EXPERIMENTS)," the staff should prepare a paper for the Commission considering l
the Millstone Lessons Learned along with the findings of the assessment described above, and public comments on SECY-97-035, and provide recommendations for further improvements to the regulatory process.
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