ML20154N777
| ML20154N777 | |
| Person / Time | |
|---|---|
| Issue date: | 10/20/1998 |
| From: | Saele R Advisory Committee on Reactor Safeguards |
| To: | Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM) |
| References | |
| ACRS-R-1784, NUDOCS 9810220089 | |
| Download: ML20154N777 (2) | |
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UNITED STATES ACRSR-1784 8
NUCLEAR REGULATORY COMMISSION PDR o
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ADVISORY COMMITTEE ON REACTOR SAFEGUARDS e
g wasHWGTON, D. C. 20556 October 20,1998 The Honorable Shirley Ann Jackson Chairman U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Dear Chairman Jackson:
SUBJECT:
THE NUCLEAR ENERGY INSTITUTE'S PETITION FOR RULEMAKING TO AMEND PARAGRAPH (a) OF 10 CFR 50.54, CONDITIONS OF LICENSES During the 456th meeting of the Advisory Committee on Reactor Safeguards, September 30-October 2,1998, we reviewed a draft Commission paper which documents the proposed NRC staff position on the Nuclear Energy Institute's (NEl's) petition for rulemaking to amend 10 CFR i
50.54 (a). We also heard presentations by and held discussions with representatives of the NRC staff and the NEl conceming such a petition which was submitted in 1995 by NEl. The petition sought to broaden the scope of allowed unilateral changes that would not require prior NRC review and approval. They proposed to amend 10 CFR 50.54(a) to make changes exempt if they do not involve an unreviewed safety question as defined in 10 CFR 50.59. We also had the benefit of the documents referenced.
In its response, the staff agreed that 10 CFR 50.54(a) should be revised to allow a broader scope of unilateral changes to the quality assurance (QA) programs without prior NRC review but that use of 10 CFR 50.59 criteria to make such changes is not appropriate. Instead the f
staff proposes a direct final rulemaking to modify 10 CFR 50.54(a) to permit licensees to make g
changes to selected aspects of their QA programs prior to NRC review and approval.
Examples of additional changes that could be made by the licensees unilaterally include i
adoption of consensus standards newly endorsed by the NRC; use of generic organizational contained in consensus QA regulatory standards and QA regulatory guides.
f()xUfh and position titles; and elimination of descriptive QA program commitments that duplicate those b
in addition, the staff plans to develop an attemate process for changes that the licensees could voluntarily implement for further relief. The NEl generally supports the staffs altamative proposal, but expresses concem about the staffs proposed " monitoring" of the performance of the QA programs. The use of a risk-informed approach to such performance monitoring appears to be acceptable to all concemed.
We agree with the staff and NEl that the scope of changes in QA programs that can be made without prior NRC approval should be increased and granting such relief to the licensees should m
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., be given higli priority. We also agree that providing this relief through the staff's proposed modification of 10 CFR 50.54(a) is preferable to NEl's original proposal.
We are in general agreement with the approach outlined in the draft Commission paper and believe that the staff should proceed with its efforts to revise 10 CFR 50.54(a).
Sincerely, R. L. Seale Chairman References-1.
Letter dated June 8,1995, from Mr. Phillip Bayne, Nuclear Energy Institute, to the Honorable Ivan Selin, U.S. NRC Chairman, regarding NEl Petition for Rulemaking.
2.
Draft Memorandum (undated) from L. Joseph Callan, Executive Director for Operations, For the Commissioners,
Subject:
Partial Acceptance of Petition for Rulemaking Submitted by the Nuclear Energy institute (Predecisional).
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