ML20196F463

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Discusses Systematic re-review of Operating Plants.Technical Reviewers Remaining in Current Organizational Structure Recommended.Creating Third Technical Review Group Would Multiply Existing Problems
ML20196F463
Person / Time
Issue date: 12/20/1976
From: Shao L
Office of Nuclear Reactor Regulation
To: Eisenhut D
Office of Nuclear Reactor Regulation
Shared Package
ML20196F442 List:
References
FOIA-87-854 NUDOCS 8803040051
Download: ML20196F463 (2)


Text

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MEMORANDUM FOR: D. G. Eisenhut, Assistant Director for OT, 00R FROM: L. C. Shao, Chief, Engineering Branch, 00R

SUBJECT:

SYSTEMATIC RE-REVIEW OF OPERATING PLANTS In order to effectively control the technical aspects of the system-atic re-review of operating plants, it is imperative that the technical ,

reviewers remain within their current organizational structure.

Foming a separate re-review gmup outside the present D0R technical branches would not work and would create insumountable problems. The following am the reasons for such recomendation.

1. Foming a separate re-review group is essentially to create another technical group. Already in NRR, we have two technical review groups (one in 00R and comparative group in 055 or DSE). With this new group, we would have three technical groups. Even with two groups, we have experienced numerous interface, liaison and dupli-cation problems. In addition it takes more people to make technical decisions arid it is difficult for NRR to speak with a single technical voice. With one more group, these problems would be multiplied. It is bound to create friction and personnel problems and there would be more probability for dissension on technical m issues.
2. In order to properly re-review the old operating plants, it might be necessary to generate another set of criteria (similar to those i in Standard Review Plan) which are not as conservative as those in SRP but are still considered to have adequate margins. These criteria are best generated by the present technical branches rather than by a few members in the re-review group whose decisions might be challenge' d and refuted by others in the future. A lot of time and effort would be expended on settling the differences in opinions.
3. It should be noted that the task of re-review is not a simple one and the extent and depth of such re-review would be largely based on sound engineering judgnent and past experience. Presently most of the major decisions are made by Section Leaders and Branch Chiefs together with the staff members. With a separate group, the decisions .

would be solely made by this group without the advice and experience of the experts in the technical review branches. jf a

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D. G. Eisenhut DEC 2 0 n

4. Tiie manpower requirement (especially requirement for experienced engineers) would be less if the re-review gmup is fonned within the present technical branches, as many technical problems are similar in nature and the. Branch Chiefs and some senior members can easily supervise and advise the re-review effort. Although the size of D0R technical branches seems to be very large, actually they are not, because of the varied disciplines each branch has to cover. This is evident when these branches are com#ared to the corresponding AD offices in DSS or DSE. Actually there are not too many experienced engineers in each discipline, and it would really hurt if some of them would be transferred out of the branch to fonn re-review group.
5. 14any generic items such as reactor vessel supports Mark I Con-tainments, Steam generators, etc. that the re-review group has to work on should be also resolved for other operating plants even though these plants are not subjected to a complete re-review.

If the members of the n-mview group do not remain within the technical review branches, there would be all kinds of coordination problens, much larger than what we are facing between DOR and DSS.

To put it bluntly, it is my opinion that creating another re-review group outside the present technical organization is asking for trouble.

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L. C. Shao, Chief Engineering Branch Division of Operating Reactors -

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