ML20155G797
| ML20155G797 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 04/29/1988 |
| From: | Murley T Office of Nuclear Reactor Regulation |
| To: | Martin T, Miraglia F Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20154Q170 | List: |
| References | |
| NUDOCS 8806200104 | |
| Download: ML20155G797 (12) | |
Text
-. . . -
. GdLt an atog#o g UNITED STATES
[ g NUCLEAR REGULATORY COMMISSION
$ E WASHING TON, D. C, 20656
+,..... April 29, 1988
\ MEMORANDUM FOR: Thomas T. Martin, Acting Associate Director for Inspection and Technical Assessment
. Office of Nuclear Reactor Regulation Frank J. Miraglia, Associate Director for Projects Office of Nuclear Reactor Regulation FROM: Thomas E. Murley, Director Office of Nuclear Reactor Regulation
SUBJECT:
PRIORITY RANKING SYS FEM FOR REVIEW EFFORTS l
To allow more effective management of our technical resources, a uniforin work priority ranking scheme will be used throughout NRR. This ranking system will identify a priority hierarchy which will be used by management to establish completion schedules and staff assignments. While the priority ranking system was developed primarily for use in the licensing action process, it encompasses most expected activities, so that work requests are considered within the broad scope of all resource demands.
Both Projects (ADP) and Technical (ADT) will apply the enclosed priority system.
Projects will indicate the appropriate priority on all work requests transmitting new work to the technical branches. Although work maintained for review within Projects nonna11y does not require a work request, the PM will be required to prioritize all work efforts. The Project Manager Report (PMR) will be modified so that the PM can indicate the appropriate priority code for all licensing actions. Separate instructions will be issued to the PMs for this effort. This new prioritization scheme is reauired for all new work received as of the date of this memorandum. All previous work (i.e., the backlog) should be completed -
oh the previously agreed upon schedule to the extent possible. This memorandum I
' does not require the issuance of new work requests for the backlog of licensing actions where a schedule already exists. However, if it becomes necessary to l change the schedule of a backlog item, the procedures of this prioritization l scheme shall be followed to reschedule that licensing action. '
Basis for Ranking Scheme The prioritization scheme utilizes safety significance, operational impact and '
Connission statutory responsibilities in assigning priority. The ranking scheme defines four categories which are described generally below, along with a corre-
@onding resource allocation. Enclosure 1 delineates specific examples of work rhich fall into each category. It should be noted that the examples contained in Enclosure 1 are part of a living document. The Executive Team will periodi-cally provide direction, either verbally or in writing, to the Division Directors concerning relative work priorities which will supersede the examples in Enclo-l sure 1. Additionally, management may declare a set priority for all actions on a single plant, if desired, due to unusual circumstances at the plant.
' CONTACT, 8806200104 880607 l
Mark Rubin, SAD / DEST 49-20777 U
k
Addressees 2 Priority 1: Significant safety concerns which require immediate action or response to issues which have demonstrated very high risk significance. j Actions needed to prevent plant shutdown, allow restart or prevent significant derate, when required action could not .
have been anticipated in a more timely manner by utility or vendor.
Issues where immediate actions needed for compliance with statutory and judicial requirements or Commission directives.
Includes such activities as response to court orders, !
E00/ Congressional tickets, support for hearings, and ,
response to 2.206 petitions.
Resource Allocation Immediate resources will be allocated. Short response jobs will be ;
accommodated as rapidly as possible. '
Priority P: Significant safety issues which require near term staff evaluation.
Activities needed to determine the safety significance /
oeneric significance of an operating event.
Actions needed to support continued plant operation or t evaluation of necessary modifications or enhancements. :
Plant specific resolution of very significant generic r topics which have been identified as matters of hiah '
risk significance.
Topical Report raviews which will have extensive appli-cation in the shcrt to mid term, and whose application results in a significant safety benefit.
Licensing reviews vhere SER preparation is needed 4
within six months to prevent impact on CP, OL, PDA, and FDA issuance.
Resource Allocation The assignments will receive sufficient resources of ADT personnel and con-tractors to complete the issue in a timely manner, consistent with the demands of priority 1 assignments. Generally, the review schedule will result in a '
review period from three to six months, though longer schedules may be necessary I for tasks involving significant licensee / vendor interaction. '
Priority 3: Important issues (potentially of moderate safety significance) which reauire staff action over the long term.
i Addressees 3 Support for generic issue resolution and multiplant ,
actions.
Topical report reviews which will have wide reference-ability in the short to mid term whose application offers
. operational or economic benefit. .
l Technical Specification chances not needed to correct a safety problem or support continued plant operation or l prevent derate.
Long term license reviews, including naval and non-power reactor evaluations.
1 Resource Allocations i Technical resources will be allocated consistent with the demands of priority 1 )
and 2 tasks. Schedule slippages may occur due to development of higher priority assignments, but will be minimized via use of contractors and Regional resources.
The review schedule will typically be four months or longer.
Priority 4: Issues not directly impacting plant safety.
Administrative tech spec changes. I Topical report reviews with limited referenceability or safety benefit.
Actions on generic and confirmatory items with relatively low safety impact.
Resource Allocation ADT technical branches will schedule resources as available from the demands of priority 1, 2, and 3 assignments. Review schedules by technical branches will typically be six months or longer on will be utilized to accomodate available , priority slots of4reviewer assignments time.as the work Schedule slippages will likely occur on priority 4 assignments due to reouirements of higher priority work, but repeated rescheduling should be minimized to the extent practical. Periodically management will review priority 4 items to determine if the work effort should be continued or eliminated.
Use of Risk Assessment Insights in Determination of Safety Importance
' As a general rule, the safety significance of an issue should be guided by ,
an assessment of its risk significance. Issues which imoact components or '
systems that are involved with major accident scenarios should be considered as an appropriate high safety priority. A prime example would be in the area of problems associated with station batteries or diesel generators, since i station blackout accidents have been identified as major contributors to 1
l
I Addressees 4 public risk at a number of sites. In a similar sense, issues related to containment integrity would be likely candidates for high priority since containment bypass accidents also contribute significantly to public risk, f Identification of components and systems involved as safety or nonsafety are not in themselves sufficient justification for assignment of priorities, as . <
is clearly evidenced by the problems of the ICS (nonsafety) at B&W plants.
Impacts on important support systems must be carefully considered. Signifi-cant contributors to initiating events that may result in challenges to the plant need to have an appropriate high pricrity. In the future, guidance will be provided on determination of risk significance based on past PRA studies.
Prior to this, necessary guidance should be obtained from the responsible ADT Branch Chief, or Assistant Director's office.
Implementation of Program !
The above prioritization scheme will be initiated with receipt of this memo.
Each new work request being transmitted to the technical branches will have the appropriate prioritization category identified by the PM and concurred in by the Project Director as indicated by appropriate initials on the work request form (Enclosure 2). While the above priority descriptions are meant to provide a general framework, Enclosure 1 identifies examples of specific actions which fall within each category. Enclosure 2 is to be the new standard Work Request form. It has been modified to allow a space to indicate the priority being J requested as well as the basis for the priority. Each assignment should be i given a priority designation, and this should be indicated on the assignment form. In justifying priority assignments, the specific example from Enclosure 1 ,
l should be cited, if feasible. The more general guidance above can be of assistance where an issue is not explicitly indicated in Enclosure 1. )
4 l
The technical review branch management will retain a copy and retura the !
original work request form within five working days either agreeing to the l prooosed completion date or, for cases where the technical review Branch Chief disagrees with the priority assignment or schedule, the appropriate Project Director will be contacted to discuss the issue. If resolution of priority and schedule cannot be reached, the issue should be elevated to the Assistant Director level.
For work assignments which are comnleted by multiple branches, the PM will l coordinate the assignment to assur that a unifonn priority determination is m
agreed upon by all review branches. Branch specific schedules will of course be controlled by competing workloads within the branch, l
For review of multiplant actions (MPAs), priorities and review schedules will !
be detennined by the designated lead reviewer and lead Project Manager. The !
use of work 'eauest forms is not necessary for individual plants within an ,
PPA. The lead reviewer will ensure that a uniform priority is established I when multiple review branches are necessary for a given MPA. The lead Project Manager will work with the individual plant Project Managers to insure that I
i
4
- Addressees 5 the appropriate review priority is entered for all plants in the RITS/PMR data base for their assigned MPAs, Unique design features or special circumstances at certain plants may result in non-uniform review priorities within a specific ,
MPA.
The prioritization scheme is not meant to be a rigid framework. Some assign-ments may not fall within the categories described. Allocation of resources, however, will be guided by the principles inherent in our prioritization orocess. That is, issues of greatest safety significance and operational impact will be prioritized high, as well as those areas which the Commission has identified as of importance. In the near future, our computerized licensing action tracking systems will be modified to include the prioritiza-tion scheme to allow management monitoring of the program.
Modifications to Schedules The following procedure will be used to document modifications in schedules or priorities for all plant specific work requests under review by the technical branches. This includes the backlog of work in process before this program was implemented. The plant PM is to be kept informed of any necessary schedular or priority adjustments prior to the expiration of the original negotiated schedule.
If the changes are due to competing priorities of other work assigned to the technical review branch, the reviewer will route a revised work request throuah their management to the PM. Before the request is routed for concurrence, the PM and reviewer should infonnally negotiate the schedule. If an acceptable alternative cannot be negotiated, the issue shall be elevated for hiaher level management review. If the changes are due to reasons under control of the PM or licensee, the PM will initiate the transmittal of a revised work request to document the chanae. For minor schedule slippages of no more than approximately one month, the PM may determine that transmittal of a re rised work reauest is unnecessary if he/she has received timely notification o*/ an acceptable schedule change from the assioned reviewer and reviewer's management. Project Managers and ADT staff should make all possible efforts to establish realistic schedules so that multiple schedule changes are avoided.
For multiplant issues, schedule and peinrity discussions should be held between the lead Project Manager and lead reviewer. The lead PM is responsible for informing plant specific project managers of schedule or priority changes in a timely manner so they can update their PMR appropriately. Quarterly the lead Project Manager and lead reviewer will issue a sumary report of their multi-plant activities.
ADP Review
/
As indicated in Enclnsures 3 and 4, Projects has assumed review responsibility for some amendment applications. Dependina upon the issue and the expertise of the individual, review by a Droject Manaaer may be aooropriate for issues !
of all priorities.
However, if a review branch has a considerable workload of '
priority 1 and ? items, it should re-evaluate its priority 3 and 4 comitments to determine if they can now be adecuately reviewed by Projects.
1
\ _ __
Addressees 6 ,.
7 The procedure for determining if Projects will conduct a review is provided in Enclosure 3. Before a Project Manager commences a review, he/she should receive concurrence from technical branch management that Projects can conduct the review. When a review conducted by Projects is completed, the safety evaluation or amendment package must have the concurrence of the technical Branch Chief (s). To properly support this program, the review Branch Chief will normally provide concurrence and/or coments within 10 working days of receipt of the amendment package.
Regional Resources Where feasible, technical reviews will be considered for assignment to the Regions. Either the Project Manager (PM) or technical branch can request a regional review. However, the letter transmitting the work request to the Region will be signed by the appropriate ADP Assistant Director (who will be responsible for cocrdinating the total work assigned to the Region) and have the concurrence of the associated technical Branch Chief. If it is initially decided that a PM will conduct a particular review and then later the PM decides to transmit the work to the Region, concurrence by the technical Branch Chief on the transmittal letter is not required but the Branch Chief is to receive a copy of the transmittal letter for information purposes. However, all final amendment packages or safety evaluations sent to the licensee, where the review was not conducted by the NRR technical branches, will include the appropriate technical Branch Chief on concurrence. The purpose of this procedure is to ensure that the technical branches are cognizant of all efforts in their area of technical expertise.
The effectiveness of this prioritization system will be carefully monitored by ADP and ADT personnel. If necessary, a reevaluation of the methodolojy will be conducted to determine possible improvements approximately six te twelve months af ter implementation.
'NL W Thomas E. M6rley, Director Office of Nuclear Reactor Regulation
Enclosures:
- 1. Examples of Actions / Issues
- 2. Work Request Form
- 3. Memo, "Project Manager Review Responsibility" dtd 9/4/87
- 4. Memo, "Project Manager Review Responsibility" dtd 1/6/88 .
cc: All NRR Technical Staff s
ENCLOSURE 1 EXAMPLES OF ACTIONS / ISSUES WITHIN EACH PRIORIT!7ATION CATEGORY Priority 1 - HIGH PRIORITY IMMEDIATE ACTION ISSUES
- 1. Operating plant safety assessments of very high significance including. i 1
- a. event analysis of a serious operating incident 1
- b. B&W plants reassessment
- c. Part 21 reports of high safety significance
- 2. Bulletin, development 1
- 3. 10 CFR 50.54(f) letter development 1 l
4 Team inspection (AIT/IIT/OSTI/SPECIAL INSPECTIONS) support
- 5. Safety Evaluation Reports for problem plant restart reviews
- 6. Emergency Technical Specification reviews where necessity could not have been anticipated in a more timely manner
- 7. Equipment modifications required to ensure continued safety operation if there is a significant safety concern, such as ATWS modifications
- 8. Exemption requests necessary to allow restart or to prevent unnecessary reactor shutdown or significant derating of operating plants
- 9. E00/ Congressional ticket items
- 10. Support for court and Licensing Board hearings and response to inter- l rogatories and 2.206 petitions
- 11. Incident Response Center Support l 1
IP. Technical support for Temporary Waivers of Compliance or Safety Evalua- ,
tion Reports for license amendments for actions to prevent unnecessary reactor shutdowns or startup delays or significant derating of the plant, if such action would potentially have a safety impact 13 ACRS/ Commission Briefings 14 Technical Support for orders or 50.54(f) letters consistent with safety significance
- 15. Resolution of inspection or RER team findings with high safety or safeguards significance Note: Items such as 2, 4, 9, 11, 13, and 15 do not necessarily involve ADP assignment or tracking, but are included for perspective on work priority.
,r - _ . - , - , - - . - _ , , . . - _ - . .
2 Priority 2 -
HIGH PRIORITY SHORT TERM
- 1. Safety Evaluation Reports and Technical Specifications for NTOL activities
- 2. Safety Evaluations necessary for restart support event assessment and -
problem plant activities which are not Priority 1
- 3. Evaluation of changes required as a result of Operating Events, inspection findings, and significant Part 21 reports 4
Reviews of response to 10 CFR 50.54(f) letters / bulletins, if potentially safety important i i
- 5. Assistance to Reatons fif safety significant) including: j
- a. Inspection team support i
- b. l Consultation
- c. Task interface agreements !
S. BWR piping degradation and repair reviews and evaluations
- 7. Erosion / corrosion evaluations !
- 8. Major saftty, emergency planning, or safeguards issues !
- 9. Radiological reviews for new or unique major modifications or equipment repairs j
- 10. Technical Specification Upgrade Program
- 11. Standard plant reviews
{
- 12. Reload reviews which result in TS changes, which are necessary to assure no reduction in safety margins l
- 13. Multiplant issues of high safety significance l 14 Emergency Operating Procedure Reviews from a plant specific perspective
- 15. Support for enforcement action other than orders
- 16. Emergency Operating Procedure Reviews from a vendor perspective 1
e
-- - , . . - - - - - . , - , >-g -
w - -, - - , - - .- - , , - - , , - , - m,,,e . - - .-- ,m,--,-- - - . . ,
Priority 3 -
MODERATE PRIORITY - LONG TERM
. 1. License Qualification to perform Plant Safety Analyses
- 2. GDC-4 leak-before-break reviews
- 3. Multiplant actions not priority 2
- 4. Surveillance program review l
- 7. Vent and purge valve operability l
- 8. Non-power reactor issues, if safety signiitca..t ;
l
- 9. Vital equipment and vital area reviews l
- 10. Changes necessary to satisfy NRC orders, license conditions on regulations affecting numerous plants, if change has moderate safety significance
- 11. Spent fuel pool expansion reviews not meeting priority 1 or 2 requirements I
- 12. Piping as-built / design non-conformance reviews
- 13. Participation in ASME, ANSI, and IEEE Code and Standards activities
- 14. Code Topical Report reviews which are required to demonstrate compliance with the regulations, or provide operating flexibility / economic benefit l and are expected to have wide reference ability l
l Examples
- a. Codes necessary to support cross-vendor reload
- b. Haddam Neck conversion to zircaloy clad fuel
- c. LOCA models for UPI plants i
- 15. Safety significant problems with Offsite Dose Calculation Manual (0DCM) I or Radiological Effluent Technical Specifications l
- 16. Decommissioning efforts
- 17. Regulatory Guide 1.97 Reviews l
- 18. Steam generator replacement
- 19. Rulemaking assistance to RES l
i l
- 20. FTOL Conversions
- 21. Long term follow-up of events which are not of high safety significance '
- 22. Support to RES on high priority generic issues
- 23. Severe accident policy implementation
- 25. Review and evaluation of containment integrity issues
- 26. Pressurized Thermal Shock review and evaluation
- 27. Significant control room habitability issues
- 28. Seismic hazard characterization
- 29. Advanced reactors plant reviews
- 30. Inservice inspection and testing programs implementation and relief requests not affecting continued operations or restart
- 1. Technical Specification relief requests that are in essence "relief" from current requirements (excluding those that involve unnecessary reactor shutdowns or plant derating)
- 2. Research coordination
- a. Review of research programs
- b. B&W thermal hydraulics testing
- c. Proposed regulatory changes (e.g., 50.46) l
- 3. Power upgrade proposals ;
- 4. Plant life extensions
- 5. Changes in core operating limits only to increase margin and not associated with the technical speTc11 cation upgrade program .
- 6. Increased surveillance intervals, unless safety benefit l
i 4
4
- r -
4 ,
n
. I t
?
. l i
- 7. Larger acceptable operating bands for equipment only needed to i provide operational flexibility ,
i
- 8. Code reviews which are needed only to improve operating flexibility i i
- 9. Turbine missile reviews >
- 10. ASME Code case reviews for ors i
- 11. Review of effluent reports !
t f
i 4
l l
t I
l l
t i
i l
i 1
e I
1 j
ENCLOSURE 2
, Date Prepared Requested Target Date WORK REQUEST
, T0: , Branch Chief, Branch THRU: , Director, PD FROM: , Project Manager, PD Mail Stop TAC / TITLE:
Descrintion of Review Requested Priority:* Rases for Priority:
Please indicate your acceptance of the Work Request and Target Date by Signature and Assignment of Reviewer (s). Work Package should be retained by reviewer (s).
Priority Determination Acceptable: Yes No Alternative Priority Target Date Acceptable:* Yes No Alternative Target Date: .
Assigned Reviewer (s) Phone Phone Section Chief Signature Date Branch Chief Signature Date __
Return to plant PM within 5 working days of receipt If a revision to previously approved schedule:
New completion date or New priority Reason for revision Section Chief Approval: Branch Chief Approval:
- Review schedules for the 4 priority categories are normally:
Priority 1 Immediate assignment of resources Priority 2 Near term action Priority 3 Long term action Priority 4 Resource dependent action
( _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
E2K'LCSURE 3 -
s.,
/s. ? H Is 4'
UNITE D ST ATES i% ;
j
- NUCLEAR REGULATORY COMMISSION
, 7 wAs m NctoN.o c 20s55 l
- 3 l
September 4,1987 MEMORANDUM FOR: Distribution 1 i
F ROM:
Frank J. Miraglia Associate Director for Projects Richard W. Starostecki Associate Director for Inspection and Technical Assessment
SUBJECT:
PROJECT MANAGER REVIEW RESPONSIBILITY The staff has been exploring ways to more efficiently use our limited !
technical resources to focus on sa/ety significant issues. Effective )
immediately, the Project Managers will be responsibile for conducting more technical previously. reviews of license amendment requests than have been done It should be noted that where this memorandum uses the term Project Manager for a specific plant, the Project Directors are at liberty to substit.ute a Project Engineer or anothat Project Manager if appropriate.
Enc.
+d is a detailed procedure discussing the Project Manager and review branct. responsibilities under this program. Basically when an amendment is creeived, the Project Manager will place it in one of three categories.
commence1the
- stegory is review.
where the technical submittal by the licensee is inadequate to Category 2 is for amendments where a proposed "no '
significant hazards considerations (NSHC)" finding can be made by the NRC and where the request does not require specialized detailed technical review.
Category 3 is for amendments which require a detailed technical review war-ranting participation by the technical review branches. Amendments placed in Category 3 will be noticed with an opportunity for a hearing with no comments concerning significant hazards considerations.
Because of the nature of the issues raised in reload amendments,'it is under .
stood that assistance fairly routine of technical review specialists may be needed even for reload requests.
For reloads, categorization is to be based on nical review specialists.the complexity of the issues involved rather than on Similarly, there is no intent to affect the common practice of contacting the Region or technical branches concerning information relevant to emergency technical specification (TS) change requests, should be categorized based on the complexity of the issues rather than on theSuc basis of contact with the Region or technical branches.
CONTACT: J. Thoma X28285 0
DO & C Iys=mlT" I ^
W 3L # ~
Distribution September 4,1987 The Project Manager will discuss the review with the appropriate review Branch Chief or Section Leader before commencing the review or making a NSHC determination. This serves two purposes. First, it assures that the Project Manager is aware of the most current policy or review guidelines on a given topic. Secondly, it allows review branch input to ensure consistency in reviews. If the Project Manager prepares the safety evaluation, the appropriate review branch will be on concurrence on the final amendment package. If a hearing is requested on an amendment, the technical review branches and the Project Manager will be responsible for supporting the Agency's actions.
Presently it takes six months or longer to issue an amendment. Under this program, it is anticipated that a typical amendment involving NSHC will be issued in two months or less after receipt. It is recognized that we may now issue a notice for hearing for an amendment which we previously have issued on other plants as a NSHC. We may even be challenged by the licensees for this "apparent" change in position. The focus of the program is aimed toward
, optimum use of agency resources, recognizing that if an amendment truly involves I "no significant hazards considerations," then its respective technical review should not involve a significant amount of NRC review effort, other than the effort which is part of the responsibilities of the assigned PM.
This review procus will be periodically audited to determine its effectiveness.
We will consider issuing the program as an NRR Office Letter after program experi-ence is obtained.
This program is effective for amendments received after the date of this j memorandum. The Project Directors in conjunction with their Project Managers '
will review amendments in progress before the date of this memorandum to determine which ones woulJ have been placed in Category 2. The technical I review branches will be consulted on the status of the review; and on a case- i by-case basis, it will be decided if the Project Manager is to be assigned the !
review. Unless specifically notified otherwise, the technical review branches '
are to continue reviewing amendments in progress at the agreed upon sche Nie.
As stated above, the purpose of the program is to allow the technical review branches to focus their limited resources on safety significant issues. We acknowledge that the program will increase the burden on the Project Manager, and that problems may arise in the initial program implementation. It will require the support of all personnel to make this program effective.
J , d Frank J.CMir' 1 R chard W. ostecki Associate Direc or for Projects Associate Director for Inspection and Technical Assessment
Enclosure:
As stated cc: T. Murley J. Sniezek J. Scinto
)
DISTRIBUTION' Steven A. Varga, Director Division of Reactor Projects I/II Bruce A. Boger, Assistant Director for Region I Reactors Gus C. Lainas, Assistant Director for Region II Reactors Dennis M. Crutchfield, Director Division of Reactor Projects _ III, IV, V and Special Projects Gary M. Holahan, Assistant Director for Region III and V Reactors Frank Schroeder, Jr., Assistant Director for Region IV Rea: tors and Special Projects -
Charles E. Rossi, Director Division of Operational Events Assessment Lawrence Shao, Director ?
Division of Engineering and Systems Technology James E. Richardson, Assistant Director for Engineering Ashok C. Thadani, Assistant Director for Systems James G. Partlow, Director Division of Reactor Inspection and Safeguards Frank J. Congel, Director Division of Radiation Protection and Emergency Preparedness Jack W. Roe, Director Division of Licensee Performance and Quality Evaluation
l l
ChCLOSURE 1
l AMENDMEFT PEV!EV PPFCE0VDE l I
Wdthin ahnut FO working days after a license amendment is received by a Profeet Penager (FM), the PM should determine that the amendment fe.11s in one of t'.ree categories. The Project Manager 'PM) should discuss each amendment reovest with the appropriate technical review Branch Chief or Section Leader. The i discussion is to accomplish several goals. First, it is to educate or upca+e ;
the PM on current review ouidelines and policy in a given area. Second, it !
aids the review branches to ensure consisterey of approach. Third, it provides an independent assessment of the amendment as to the adequacy of the submittal and whether or not a detailed technical review is required. This consultatier should take less than one man-day of effort. As reviews are completed, the Project Directorate reading files will also become a valuable source of ,
inforretion on how similar amendments were treated. 1 Based on the above discussions, the amendment will be placed in one of three categories. Each category is discussed in turn:
Category I l
The packeoe is inadequate based or a general overall review. A letter will be sent to the licensee documenting reasons why the package is inadequate and rtating the corrective action the licensee needs to take before resubmittal. The rejection letter is to describe general areas which are either omitted or inadequately addressed in the licersee's submittal. It is not a detailed technical rejection or a disguised request for additional information, as both of these actions are more appropriate for Category 2 or 3. This is not a rejection of the -
licensee's amendment request but is a rejection of the overall adecuacy of the request.
For multiplant activities (MPAsl or plant-specific items which are an outgrowth of MPAs, the letter sent to the licensee should request a proposed resubmittal date. If the TAC was opened to cover the entire MPA review, it should remain open until the issues are resolved. I' the MPA includes Tech Specs, the TAC should remain open until the Tech Specs are issued. If a plant-specific TAC (which is not the result of a previous MPA or NRC initiated action) was opened to cover this review and the licensee is not plannin0 to respond in a timely manner l Isix months or less) to the rejection letter, then this plant-specific TAC is to be closed by the PM.
.g.
Category 2 The package, based on its face value alone, has adequate techn'ical ,
justification to conclude that no detailed specialist review is necessarj ' '
anc the amendment involves no significant hazards considerations. The l
PM prepares the Shelly notice, performs the safety review, and prepares '
the amendment package simultaneously. Thirty days after the Sholly notice has been published the amendment should be issued. This time frame, although not an exact requirement, should be a standard rule of thumb. The amendment package should have the concurrence of the appropriate technical review Branch Chief to ensure consistency in approach.
Amencments which can be classified as Category 2 must clearly satisfy the "no significant hazards considerations" requirements. Specifically, they must (1) not involve a significant increase in the prob, ability or consequences of an accident previously evaluated, (2) not create the possibility of a new or different kind of accident from any accident previ:usly evaluated, and (3) not involve a significant reduction in a margin of safety.
Examples of amendments which would usually be classified as Category 2 include the examples of "no significant hazards considerations" found in
.the Sholly procedures. Amendments involving these examples should reautre little detailed technical review effort.
For ease of reference, they are repeated as follows:
1.
A purely administrative change to technical specifications; for example, a change to achieve consistency throughout the technical specifications, correction of an error, or a change in nomenclature.
2.
A change that constitutes an additional limitation, restriction, or control not presently included in the technical specifications, e.g.,
a more stringent surveillance requirement.
3.
For a nuclear power reactor, a change resulting from a nuclear reactor core reloading, if no fuel assemblies significantly different from those found previously acceptable to the NRC for a previous core at the facility in question are involved. This assumes that no significant changes are made to the acceptance criteria for the technical specifications, that the analytical methods used to demonstrate conformance with the technical specifications and regulations are not significantly changed, and that NRC has previously found such methods acceptable.
4.
A relief granted upon demonstration of acceptable operation from an operating restriction that was imposed because acceptable operation was not yet demonstrated. This assumes that the operating restriction and the' criteria to be applied to a request for relief have been established in a prior review and that it is justified in a satisfactory way that the criteria have been met. .
3
- 5. Upon satisfactory completion cf construction in connection with $n operating facility, a relief granted from an operating re'striction that was imposed because the construction was not yet completed setisfactorily. This is intended to involve only restrictions where it is justified that ennstruction has bien completed satisfactorily, f.
A change which either may result in some increese to the probability or consequences of a previously analyzed accident or may reduce in some way a safety margin, but where the results of the change are clearly within all acceptable criteria with respect to the system or cerpenent specified in the Sta.1dard Review Plan, e.g., a change resulting from the applit.ation of a small refinement of a previous'.y used calculational model or design method.
- 7. A change to conform a ifcerse to changes in the regulations, where the license change results in very minor changes to facility operations clearly in keeping with the regulations.
8.
A change to a license to reflect a minor adjustment in ownership shares among co-owners already shown in the license.
9.
A repair or replacement of a ma.40r component or system important to safety, if the following conditions are met:
- a. The repair or replacement process involves practices which have been successfully implemented at least once on similar components or systems elsewhere in the nuclear industry or in other industries and does not involve a significant increase in the prebability or consequences of an accident previously evaluated or create the possibility of n new or different kind of accident from any accident previously evaluated; and
- b. The repaired or replacement component or system does not result in a significant change in its safety function or a significant reduction in any safety limit (or limiting condition ef operation) associated with the component or system.
10.
An expansion of the storage capacity of a spent fuel pool when all of the following are satisfied:
a.
The storage expansion method consists of either replacing existing racks with a design which allows closer spacing between stored spent fuel assemblies or placing additional racks of the original design on the pool floor if space perinits; b.
The storage expansion method does not involve rod consolidation-or double tiering; c.
The Keff of the pool is maintained less than or equal to 0.95; and d.
No new technology or unproven technology is utilized in either thejustify to construction process or the analytical techniques necessary the expansion. .
4 There may De p"oposed amendments which woulc possibly fit withir. tne language of one of the examples, but which would in fact invo]ve complex technical issues. For example, there may be a review invol-ving a spent fuel pool rerecking which clearly fits the exam;les at..e but the review is so complicated that the Project Manager cannot reesc -
ably be expected to conduct the review. In such ca*.?s the review will te treated as a Category 3.
Although the same general principles apply to reload amenament requests, because of the specialized nature of the issues addressed, it is expectec that PMs may well need the assistance of Reactor Systems Branch in even a f airly roucine reload application. Therefore, categorization of relcaos should be based on the complexity of the matters involved rather than on whether the assistance of the technical review branch specialists is neecea.
Similarly, in processing emergency TS changes it is common practice to Ob-tain the views of the Region concerning the status of the plant and the cir-cumstances leading up the emergency request and the technical branches for adequacy of the proposal. There is no intent to affect such practice. Cate-gorization of emergency requests should be based on the complexity of the issues involved rather tha.n on the basis of contact with the Region or the technical branches.
Category 3 The amendment requires a detailed specialist review. The PM, after consulting with the appropriate review Branch Chief, will notice the amendment with an opportunity for hearing. Simultaneously, a work request will be generated sending the package to the technical review branches. Note for purposes of this procedure, the resources available in the Regions, with the exception of the resident inspectors, are to be considered a technical review branch. The PM and resident inspector are important technical resources but fall in a different category than specialized technical reviewers.
Work on the amendment request will then proceed in the normal f ashion.
The Project Manager and assigned reviewer will negotiate a mutually acceptable schedule for the review. All contact with the licensee will be via the Project Manager. The safety evaluation will be formally transferred by the reviewer to the Project Manager via a memorandum signed by the appropriate Branch Chief or other authority if so determined by NRR Office Letter 101, Delegation of Signature Authority. The Project Manager will prepare and issue the formal amendment or denial as appropriate.
If a hearing is requested and granted, the Project Manager will work with OGC to assure necessary staff support is provided. Issuance of the amend-ment would await the outcome of the hearing process, or as otherwise advised
- l by OGC. i
3 S L'r ' Ar '. it 0;. CPU.T 4
,: .i'.;: [.',i RE C E l VE D
\/
r . G:.5aLTS 1.lTH ;
!!CF F./C Cr. 5/L N/
'EST F0D TECW'.! CAL ADE04ACY D:ADEN' ATE s REJECT'O" Ctery :, ;
LETTER -
A DE 0l' ATE
\/
SIG'.IrlCANT HAZADr5 CONS!DE r.ATIOFS w
NO YES s, S/
CAN PM DO No i flCTICE y Nn TECH BD.A!!CMEE WORK g HEARING REVIEW FOR RE00EST TO #F0 VESTED REVIEW SER HEARING TECHNICAL
/T BRANCHES PM PREP RES LICENSE AMElDP:"T YES tio YES OR REJECTICN AS v s, APPROPRIATE PM PREPARES Pr. CAii
. LLY NOTICE , YES RESOLVE
- ' COORDINATE ISSUES WITH OGC 3l AMENDMENT
/\ -
1 BC CONCL'RS ON AMENtMENT No TES u
AMENDvENT ISSUED l
l CATEGORY 2 .
1 CATEGORY 3
ENCLOSURE 4 T s
o, UNITED STATES
((pna y. h NUCLEAR REGULATORY COMMISSION s; } 1l ,
WASMNGTON. D. C. 20555 s.,
/ January 6, 1988 I
MEMORANDUM FOR: Steven A. Varga, Director i Division of Reactor Projects I/II ,
1 Dennis M. Crutchfield, Director Division of Reactor Projects III, IV, V and Special Projects FROM: Frank J. Miraglia Associate Director for Projects
SUBJECT:
PROJECT MANAGER REVIEW RESPONSIBILITY 1
On September 4,1987, a memorandum was issued which described a process for '
conducting technical reviews of license amendment applications. The purpose of this memorandum is to slightly modify the process to allow the Project Managers some degree of additional flexibility.
The process, as described in the September 4, 1987 memorandum, provides for i placing incoming amendments in one of three categories. Category I amendments I will'be sent back to the licensees for insufficient documentation. Category II l amendments are to be reviewed by the project manager and normally will be l noticed with a proposed no significant hazards consideration finding.
Category III amendments will be reviewed by the technical branches and will generally, but not always, be noticed with an opportunity for prior hearing. l The categorization process will remain the same but what is being modified, as of the date of this memorandum, is the treatment of the region resources.
For amendments properly classified as Category II applications, the Project Manager now has the option of sending that amendment to the Region for technical review using the appropriate procedure (i.e., letter from A/D to the Region),
and still retain the Category II classification. This is being done for several reasons. The main reason is that the trend of incoming applications is .
that a vast majority are classified as Category II, and this may soon overburden the PMs. This modification provides a relief path. Secondly, the majority of amendment reviews done in the past by the Regions would appropriately be classified as Category II applications.
. The Regions may receive work from two sources, i.e.. projects and technical.
If an amendment is properly categorized as Category III but the technical review branch, through some prioritization scheme or other mechanism, sends it to the Region for. technical review, then that amendaent will remain Category III and will be appropriately noticed. Any conflict in the demand for review resources from the Region will be resolved by the NRR Assistant Director for that Region.
CONTACT:
J. Thoma, DRPR ~
Ext. 28285 2
Steven A. Varga January 6, 1933 Dennis M. CrUtchfield It should also be noted that one of the purposes of forming a Category 11 classification was that the NRC should be able to complete our review of those amendments more efficiently. It is not desired for the Region review of Category 11 amendments to dramatically increase the resource needs or review time and, therefore, review schedules must be negotiated carefully. .
l f.uk : p ' ' I k. ,
Frank J. iragli '
) Associate Director for Projects cc: All ADP Personnel ADT l
l l
\
e
sb/ss
_. -__ 9rojed_3Yec3craie_R_l . _._ _ __ _ _..._.
%Lexa3ncoty1_Cpen TAQs - _.
- 7. hat T.R L L 7 1 T 2. 333 TIl 3h I. !
_ _ . . ._ % C4_ _
_.3]g h 30tyt..._._._ _ c2 6 _l]___ -1 26._ _
_ l. *
. .. . . . . . . - - . . - . . - . - . . . . . - - - - - - . - ~ ~ - - _ - . - . - . . . . . - . - - - - - ~ ~ - . - . - - .
Tw.rnL 2 . _ g_._ __ _. _ __ 3 _ _. 3) _ __O._ _ _ _.17,. .. _ .
__.hcrdicd .c .___ O __ . 7 Li D . aL__
7ediss_du l i Zb 11. 36 _
1 7cakie_McYd.L 2._ 2. // _I/ IL. i
_n - m .
. _ mNe eel>. . e.s 1
w.
- i
/
, / --
j
.- - - . _ - . . . . . .. - . . - -. . - - . -