ML20148Q159
| ML20148Q159 | |
| Person / Time | |
|---|---|
| Issue date: | 11/21/1986 |
| From: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| TASK-PII, TASK-SE SECY-86-346, NUDOCS 8801290346 | |
| Download: ML20148Q159 (5) | |
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- l POLICY ISSUE November 21, 1986 SEcY-86-346 FOR: The Comissioners FROM:_
Victor Stello, Jr.
Executive Director For Operations l
SUBJECT:
EVALUATIOM OF MANAGING PLANT-SPECIFIC BACKFIT REQUIREl To provide the Comission with an evaluation of the results l PURPOSE: j of managing plant-specific backfit reouirements, BACXGROUND:
In its 1984 Planning and Program Guidance document, the l Commission directed the staf# to provide an evaluation of the l
managerrent of plant-specific backfit requirements after one l
year of experience gained from Since thethe application staff was of the recom-revising 10 CFR mendations in SECY 83-321.
50.109, the evaluation was delayed until the backfit rule was revised and the associated NRC Manual Chapter (0514) was ap-proved by the Comission and in use for six months. The revised l
10 CFR 50.109 was issued on September 20, 1985, and the associ-ated Manual Chapter 0514 was approved February 21, 1986.
This paper provides an evaluation of the implementation of l plant-specific backfit requirements derived from the Backfit Rule.
l DISCUSSION: Since the issuance of the revised Backfit Rule (10 CFR 50.109) and approval of Manual Chapter 0514, the staff has taken a number of steps to ensure the proper implementation of the revised rule. Shortly after Manual Chapter 0514 was issued, members of the ECO's sta " provided briefings to NRC headquarters staff members. These briefings identified changes in the backfit rule, and provided a discussion of changes in staff implementa-tion of backfits.
To assure a consistent approach to backfitting, each EDO 0## ice prepared an instruction or updated existine instructions that detailed how that Office is to implement + .e new backfit rule and Manual Chapter 0514 Each of these i structions was reviewed by the ECO staff to assure consistercy be ween Offices and con-sistency with the Manual Chapter, h12 6 861121 6-M6 PDR
Contact:
J. Clifferd, NRR x28041 Ju
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To assure continued management attention to, and support of, the backfit process, managers in the E00's Offices are held accountable for adherence to the back'it process.
In April, May and June, 1986, the NRC staff, with members from the ED0's staff and the EDO Offices participating, conducted four workshops for industry representatives. These workshops involved briefings by the NRC staff on the new backfit rule, presentations by industry representatives on how the industry viewed the backfit rule, how the backfit rule would impact the industry, and question and answer periods.
Training has also been provided for regional personnel during 1986. This training, similar to that provided headquarters offices earilr in this year, provides details of staff imple-mentation of the backfit rule. Regional training was conducted at meetings that included resident and senior resident inspectors frem plant sites.
The training and workshops have provided an increased awareness in both the staff and the industry on the correct process neces-sary for implementation of new requirements in a controlled, technically accurate manner that will help assure any plant changes improve safety.
Monitoring of the management of plant-specific backfits is ,
accompl *-hed through use of the Plant-Specific Backfit System, j a computer-based data system that uses the National Institute of Health (NIH) computer. As backfits are identified and work )
is accomplished, the data base is updated at a terminal within the appropriate Office to reflect the current status of the backfit. Data on each backfit is available at all times to all NRC locations involved in managing backfits.
l Enclosure 1 provides a sumary of the backfit issues that have been identified since the new backfit rule was issued in September, 1985. A potential backfit is identified for each issue and each unit to which the issue applies. A total of 29 Ofpotential back-the total, 22 fits have been identified during this period.
were identified by licensees. Twenty potential backfits have been resolved as shown in the Enclosure 1.
The effectiveness of the training provided on the backfit rule is evident in -the increasing number of staff identified backfits, and i.n the quality and cuantity of potential backfits ide' tified from ,
all tources. The issues that have been identified btte generally l been substantive. The combination of these consider tions reflect the seriousness with which the industry and he staff l l
are approaching backfit issues. )
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. '. l Of the issues that have reached the point of having regulatory analyses performed, one required inrediate imposition so the regulatory analysis followed the imposition, two regulatory analyses have demonstrated the four associated backfits to be cost-effective, and one analysis has shown the three associated i backfits not to be cost-effective. One of the cost-effective !
backfits is currently undergoing management review for issuance.
The staff through its training sessions and systein for formal '
monitoring of plant-specific backfits, has taken a number of actions to implement the revised backfit rule. The l effectiveness of these efforts is reflected in the six staff-identified backfits that have been identified since this training began, compared to three licensee-identified backfits during the same period. In contrast, one staff-identified and i nineteen licensee-identified backfits were identified in the six l months before the training began. This reflects a trend towards l more effective and efficient identification, evaluation, and '
processing of potential backfits.
tor S lo, r.
Executive Director for Operations
Enclosure:
As stated DISTRIBUTION:
Commissioners OGC (H Street)
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, s ENCLOSURE SUMARY OF PACXFIT ISSUES 29
- 1. Number of Potential Backfits Considered:
Staff Identified Total Of# ice Licensee Identified 6 27 NRR 21 O 0 IE O 0 1 NMSS 1 O O R-I O O O R-II O 1 1 P.-! !I O 0 0 R-IV 0 0 0 R-V 0 22 7 Totals 20
- 2. Number of Potential Backfits Resolved:
- a. Number of Potential Back-fits That Were Resolved 3 l By Imposition as Backfits: l
- 1. Due to need for insnediate imposition to assure no l 1
undue risk: l
- 2. Backfits issued following l
completion of Regulatory 2
Analysis:
- b. Number of Potential Back-fits That Were Resolved But Not Imposed As 17 Backfits:
- 1. Due to licensee agreement that issue was one of compliance with applicable regulatory 11 position:
- 2. Due to staff wit 5drawal of issue after licensee provided additional 1
information:
- 3. Due to staff withdrawal of issue after licenset proposed acceptabic 2
alternative;
- 4. Staff did.not impose potential backfit after Regulatory Analysis
,showed imposition would not be 3
cost-beneficial:
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2 9
- 3. Potential Backfits Currently Under Review:
I 4 Potential Backfits for which Regulatory 7 Analyses have been completed: 4
- a. Backfits justified: 3
- b. Backfits not justified:
- 5. Age of Potential Backfits from Identifica.
tion as potential backfit to resolution as backfit:
1985 average 7.7 months (6.6 w/o the 22 maximum: 22 months month issue) weeks 1986 average 2.3 months minimum: 2 average: 5.5 months I
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