ML20151X417
| ML20151X417 | |
| Person / Time | |
|---|---|
| Issue date: | 09/11/1998 |
| From: | Stewart Magruder NRC (Affiliation Not Assigned) |
| To: | Essig T NRC (Affiliation Not Assigned) |
| References | |
| PROJECT-689 NUDOCS 9809170078 | |
| Download: ML20151X417 (7) | |
Text
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UNITED STATES g
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t WASHINGTON, D.C. 20566 0001 R.....l September 11, 1998 MEMORANDUM TO: Thomas H. Essig, Acting Chief Generic Issues and Environmental Projects Branch Division of Reactor Program Management Office of Nuclear Reactor Regulation FROM:
Stewart L. Magruder, Project Manager C L%ef 4 Generic issues and Environmental Projects Branch V
Division of Reactor Program Management Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF AUGUST 27,1998, MEETING WITH THE NUCLEAR ENERGY INSTITUTE (NEI) REGARDING GENERIC COMMUNICATIONS On August 27,1998, representatives of the Nuc! ear Energy Institute (NEI) met with icpresentatives of the Nuclear Regulatory Commission (NRC) at the NRC's offices in Rockville, Maryland. Attachment 1 provides a list of meeting attendees.
The purpose of the meeting was to discuss the NRC generic communication process. The NRC staff invited NEl to discuss industry perceptions of generic communications and to offer suggestions for improving or clarifying the process. The meeting opened with a short discussion of the importance of early communication between the staff and industry on issues.
Everyone agreed that effective communication, early in the process, has been a critical factor in the successful examples of cooperation between the staff and the industry in resolving issues.
The NEl representatives next presented a draft flowchart for a redesigned generic communication process. The flowchart is included as Attachment 2. The majority of the rest of the meeting was spent discussing this flowchart.
The NEl representatives stated that there is some confusion in the industry about the difference between a bulletin and a generic letter. They noted that the definitions in NRC Manual Chapter 0720 were almost identical but the perception in the industry is that a bulletin is reserved for more significant issues and that it is treated as a higher priority. The draft flowchart attempts to draw a sharper distinction between a bulletin and a generic letter.
The NEl representatives next stated that, regardless of the vehicle that the NRC chooses to use, almost anything that the NRC issues ends up high on a licensee's priority list. They noted that the staff should be aware of the impact they have on a licensee.
T [ O h \\l The group next discussed why there is a need to reference 10 CFR 50.54(f) in generic communications. The NRC staff noted that this is the regulation that allows the staff to require licensees to provide information. The NEl representatives stated that there is an important h) impact on licensees in preparing their response and they beheve that 50.54(f) should only be 9909170078 990911 PDR REV9P ERGNUMRC PDR g
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T. Essig
-2 September 11, 1998 cited for very significant issues and that maybe it should be used only on a licensee-specific basis. The NEl representatives pointed out that they believe that less formal requests for information from the industry would be sufficient commensurate with the safety significance of the issue.
The group next discussed the pros and cons of relying on resident inspectors to gather information. The NEl representatives asked the staff why the NRC did not routinely request that residents do this. The staff responded that they were surprised that the industry would propose this. They noted that they had looked into this possibility several years ago and concluded that the industry would probably object. The staff noted that several factors contributed to this decision. The primary factor was that there would be inconsistency in the information requested since some residents would interpret the request differently than the headquarters staff intended. The staff also did not want to give the impression that it was trying to circumvent the information collection rules of the Office of Management and Budget.
The group next discussed again the importance of communicating early and often when an issue arises. The NRC staff noted that it intended to continue its practice of holding public meetings on issues as it develops its position. The staff noted that all proposed Bulletins and Generic Letters are briefed to management before a lot of staff time has been spent on developing them. The staff also cited statistics on the disposition of proposed bulletins and generic letters over the period 1997 to 1998 including the numbers of generic correspondence cancelled. The NEl representatives suggested adding the list of canceled Bulletins and Generic Letters to the public version of the Directes Quarterly Status Report.
The meeting concluded with a short discussion of the difficulty of sharing international experience and " pre-decisional" information. The NRC staff suggested that another meeting with industry on the subject of generic communications be held in a few months.
Project No. 689 Attachments: As stated cc w/att: See next page
I T. Essig September 11, 1998 cited for very significant issues and that maybe it should be used only on a licensee-specific basis. The NEl representatives pointed out that they believe that less formal requests for information from the industry would be sufficient commensurate with the safety significance of the issue.
The group next discussed the pros and cons of relying on resident inspectors to gather information. The NEl representatives asked the staff why the NRC did not routinely request that residents do this. The staff responded that they were surprised that the industry would i
propose this. They noted that they had looked into this possibility several years ago and concluded that the industry would probably object. The staff noted that several factors contributed to this decision. The primary factor was that there would be inconsistency in the information requested since some residents would interpret the request differently than the headquarters staff intended. The staff also did not want to give the impression that it was trying to circumvent the information collection rules of the Office of Management and Budget.
The group next discussed again the importance of communicating early and often when an issue arises. The NRC staff noted that it intended to continue its practice of holding public meetings on issues as it develops its position. The staff noted that all proposed Bulletins and Generic Letters are briefed to management before a lot of staff time has been spent on developing them. The staff also cited statistics on the disposition of proposed bulletins and generic letters over the period 1997 to 1998 including the numbers of generic correspondence cancelled. The NEl representatives suggested adding the list of canceled Bulletins and Generic Letters to the public version of the Director's Quarterly Status Report.
The meeting concluded with a short discussion of the difficulty of sharing international experience and " pre-decisional" information. The NRC staff suggested that another meeting 3
with industry on the subject of generic communications be held in a few months.
Project No. 689 Attachments: As stated cc w/att: See next page j
i DISTRIBUTION: See attached page Document Name:g:\\simi\\msum0827.98 OFFICE PGEB:DRPM BC:PECB:DRPM SC:PGEB:DRPM NAME SMagrude$'s@ JStolk,
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Distnbution: Mtg. Summary w/ NEl Re Generic Communications Dated September 11,'1998_
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SMagruder JStoltz EMail SCollins/FMiraglia l
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NRC/NEl MEETING ON GENERIC COMMUNICATIONS LIST OF ATTENDEES August 27,1998 NAME ORGANIZATION Dave Modeen NEl Alex Marion NEl Tony Pietrangelo NEl Bob Bishop NEl Marvin Strand NUS LIS Altheia Wyche SERCH/Bechtel Bob Dennig NRC/NRR John Stoltz -
NRC/NRR Jim Shapaker NRC/NRR David Matthews NRC/NRR Jack Roe NRC/NRR Stu Magruder NRC/NRR Bob Spence NRC/AEOD John Boardman NRC/AEOD l
t I
c NEl DRAFT GENERIC COMMUNICATION FLOWCHART t
Event /lssue/ Concern 1 r
/
I Safety Sign:ficant?
Drop issue NO YES U
Consider Substantial Covered by Backfit issuing Adequate Regulations?
Analysis NO Protection?
NO Information Notice YES YES 3,
U Rulemaking Action Necessary issue Generic for Adequate Letter Requesting Protection?
NO Information YES U
lssue Bulletin with 50.54 (f)
Statement
_ _ _._.~.
E Nuclear Energy Institute Project No. 685 l
l cc:
Mr. Ralph Beedle Ms. Lynnette Hendricks, Director
~
l Senior Vice President Plant Support and Chief Nuclear Officer Nuclear Energy Institute l
Nuclear Energy institute '
Suite 400 l
Suite 400 17761 Street, NW i
1776 l Street, NW Washington, DC 20006-3708
-Washington, DC 20006-3708 Mr. Alex Marion, Director Programs i
l Nuclear Energy Institute l'
Suite 400 1776 l Street, NW Washington, DC 20006-3708 Mr. David Madeen, Director Engineerirg Nuclear '_nergy institute l
Suite (JO L-1776 5 Street, NW I
Washington, DC 20006-3708 Mr. Anthony Pietrangelo, Director l
Licensing
)
Nuclear Energy Institute j
Suite 400 1776 i Street, NW Washington, DC 20006-3708 Mr. Nicholas J. Liparulo, Manager Nuclear Safety and Regulatory Activities Nuclear and Advanced Technology Division Westinghouse Electric Corporation P.O. Box 355 Pittsburgh, Pennsylvania 15230 Mr. Jim Davis, Director Operations Nuclear Energy Institute Suite 400 l
1776 i Street, NW l
Washington, DC 20006-3708 i
i