ML20195G609
| ML20195G609 | |
| Person / Time | |
|---|---|
| Issue date: | 10/20/1987 |
| From: | Bryan S Office of Nuclear Reactor Regulation |
| To: | Murley T, Sniezek J, Starostecki R Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20195G227 | List: |
| References | |
| FOIA-87-768 NUDOCS 8710260408 | |
| Download: ML20195G609 (2) | |
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MEMORANDUM FOR:
Thomas E. Murley, Director Office of Nuclear Reactor Regulation James H. Sniezek, Deputy Director Office of Nuclear Reactor Regulation Richard W. Starostecki, Associate Director for Inspection and Technical Assessment Frank J. Miraglia, Jr., Associate Director for Projects Office of Nuclear Reactor Regulation FROM:
Samuel E. Bryan, Chairman NRC Working Group for Improving 10 CFR 50.59 Reviews
SUBJECT:
STATUS OF ACTIVITIES TO DEVELOP 10 CFR 50.59 CRITERIA j
AND GUIDELINES This is an update on the status of the NRC/ Industry effort to develop guidelines for 50.59 reviews.
By memorandum dated August 5, 1987, Rich Starostecki formed and chartered an NRC Working Group to interact with Industry to develop 10 CFR 50.59 criteria and guidelines.
This action followed a June 8, 1987 HRR memorandum to Regional Directors regarding "Improvements in 50.59 Revi.ews." Those two memoranda and the Working Group Charter are included as Enclosures 1 through 3.
Working Group members have visited and interacted with management in three regions to discuss 50.59 reviews.
The Working Group gained additional insights into 50.59 problems by obtaining and reviewing copies of licensee's 50.59 administrative control procedures (i.e., examples of both good and bad procedures).
On September 23, 1987, the Working Group met with the NSAC/NUMARC Working Group to present and discuss NRC comments on an initial draf t of Criteria and Guidelines for conducting 10 CFR 50.59 reviews.
A summary of that meeting which includes our mark-up of the NSAC/NUMARC initial draf t Criteria and Guidelines is included as Enclosure 4.
Three items of particular interest are apparent from our review and discussion with the NSAC/NUMARC Working Group:
Even though not well organized in their first draft, the scope of changes which require a 10 CFR 50.59 review reaches well beyond what has been required by the NRC in the past.
The criteria and guidelines document should have a separate section defining as precisely as possible what types of changes require a 50.59 review.
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October 20, 1987 Experience, qualifications, and quality guidelines for those involved in the 50.5S review process should be included for both originators and reviewers.
Based on our preliminary comments NSAC/NUMARC will revise the Criteria and Guidelines and then circulate another draft for parallel Industry and NRC comment. At this point, we have not identified any impediments to getting the everall job done.
However, I believe there may be some resistance by individual licensees to the draft Criteria and Guidelines because of its broad 4
scope. NSAC/NUMARC resolution of utility comments on the draft could be j
difficult to obtain.
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While NSAC/NUMARC has the next action, we have been exerting some pressure to keep the the effort moving.
In our meeting the staff indicated that a year for industry to develop criteria and guidelines would be too long and that we are looking for something much shorter (e.g., six months or less to complete the entire effort).
Members of the industry Working Group were present for the October 2,1987 Commission briefing on the Technical Specification Improvement Program and heard Mr. Stello say that improved criteria and guidelines must be in place before granting any amendment for upgrading Technical Specifications based on the Policy Statement.
His statement should add impetus to the industry's 50.59 improvement activities. We will keep you and the regions abreast of our actions,
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f Samuel E. Bryan, Chairman NRC Working Group for Improving 10 CFR 50.59 Reviews
Enclosures:
As stated t
ution:
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