ML20195G223
| ML20195G223 | |
| Person / Time | |
|---|---|
| Issue date: | 06/08/1987 |
| From: | Murley T Office of Nuclear Reactor Regulation |
| To: | Davis A, Grace J, Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20195G227 | List: |
| References | |
| FOIA-87-768 NUDOCS 8706150115 | |
| Download: ML20195G223 (2) | |
Text
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MEMORANDUM FOR: Williara T. Russell, Regional Administrator, Region 1 J. Nelson Grace, Regional Administrator, Region 11 A. Bert Davis, Regional Administrator, Region Ill Robert D. Martin, Regional Administrator, Region IV John B. Martin, Regional Administrator, Region V FROM:
Thomas E. Murley, Director Office of Nuclear Reactor Regulation
SUBJECT:
IMPR0/EMENTS IN 10 CFR 50.59 REVIEWS In recent months the staff has become increasingly aware that the lack of specific standards for licensee performed 10 CFR 50.59 evaluations has provided an opportunity for misinterpretation of the extent of changes, tests, and experiments that can be accomplished without prior NRC approval under the provisions of this regalation. The detail required for licensee reviews is not well defined and tiists for unreviewed safety questions are of ten narrowly interpreted resulting In many changes being made without the appropriate prior staff review.
Additional attention has been focused on the effectiveness of 10 CFR 50.59 by actions to upgrade Technical Specifications (TS).
An important element of the TS improvement program is the relocation of lesser important specifications to other licensee controlled documents, e.g., the FSAR. When the TS improvement program was presented to the Coenission by the staff, Commissioner Asselstine questioned the enforcenbility of FSAR commitments. The staff responded that they are enforceable through 10 CFR 50.59 (see memorandum of June 27, 1986, Enforceability of FSAR Commitments, to Commissioner Asselstine from Marty Malsch and Guy Cunningham), but acknowledged that enforcement of items relocated to the FSAR may be more difficult, Mindful of the potenti11 problems with the application of 10 CFR 50.59, the Commission encouraged 'the industry to pursue development of criteria and guidelines for evaluating changes, tests, and experiments performed under 10 CFR 50.59 as a part of the implementation of the Commission Policy Statement en Technical Specifications Improvement. Such an effort has been undertaken by a joint EPRl/NSAC aid AIF Working Group.
The Commission directed the staff to work with industry 'In developing the criteria and guidelines and af ter approval to give the etiteria and guidelines regulatory status (e.g., by a separate policy statement, regulatory guide, or generic letter).
I have directed the To:hnical Specifications Branch (TSB) to be the point of contact for staff interaction with the industry Working Group developing
'these criteria and guidelines.
In addition to working with industry on their i
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efforts, TSB will work with the Inspection, Licensing, and Research Integration Branch (ILRB) to develop policy and procedures for NRCs use in monitoring industry perforrence of 10 CFR 50.59 evaluations. These policies and procedures will be bsued by ILRB and will include Headquarters and Regional activities.
The Regional Offices will have a major role in our improved overview of 10 CFR 50.59 evaluations with support from NRR where needed. The Regions have vast experience in dealing with 10 CFR 50.59 reviews and know the many shortcomings of its application.
I will look for your support, and I encourage dialogue between the Regions. TSB and ILRB.
Until we have acceptable industry guidelines and criteria and our own internal policy and procedures worked out, the Regions should continue their present activities for monitoring the licensees
- performance in this area. Also, I would like to encourage the Regions to.ower their threshold for seeking NRR inputs, in particular for evaluations such as the Turkey Point vessel head instrwnent seal leak,and for other areas where the technical depth needed for the evaluation is of the nature of that done for the initial licensing of facilities.
We will k'eep you informed of industry progress in this area as well as seek Regional support in the development of policy and procedures for improving NRC cversight reviews.
f Original signed by James H. Sniezek
[ Office of Nuclear Reactor Regulation Thomas E. Murley, Director Distribution:
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