ML20205G645
| ML20205G645 | |
| Person / Time | |
|---|---|
| Issue date: | 03/30/1999 |
| From: | Jerome Murphy Committee To Review Generic Requirements |
| To: | Travers W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20137G543 | List: |
| References | |
| NUDOCS 9904070319 | |
| Download: ML20205G645 (3) | |
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/.a u: UNITED STA1ES O NUCLEAR REGULATORY COMMISSION E WASHINGTON, D.C. SpeeH001
% *** ** 7 March 30, 1999 MEMORANDUM TO: William D. Travers Executive Director for Ooeratiors FROM: Joseph A. Murphy, Chairmanf 7 d
Committee To Review Genpfc R@uiremen s . /
SUBJECT:
MINUTES OF THE CRGR MEETING NUMBER 337 The Committee To Review Generic Requirements (CRGR) met on Tuesday, February 23,1999, fro'.i 9:00 am to 11:30 pm. Attachment 1 contains a list of attendees.
R. Pierson and C. Cox, both of NMSS, presented for CRGR re-review the draft revised Procedures and Policy Letter (PPL) 1-53,"GDP Plant Specific and Generic Backfit Management." This PPL contains formal guidance for the staff on implementation of the backfit provisions of Title 10 Code of Federal Regulations (10 CFR) Part 76.76, specifically on identification and justification of potential backfits. It also contains guidance for the certificatees on the NRC's backfit appeal process. The Committee had reviewed these procedures on October 13,1998, at its 329* meeting. The minutes of that meeting were issued on January 29, 1999. As noted therein, the CRGR endorsement of the revised procedures was held back because the Committee wished to re-review these procedures.
At the 337* meeting, the staff informed the Committee that the revised PPL, which was submitted to the CRGR on January 15,1999, included all of the Committee's comments and recommendations from the 329* CRGR meeting. Furthermore, the revised procedures were made consistent with the corresponding NRR backfitting prowdures. The Committee made additional comments and recommendations which are included in Attachment 2. Most importantly, the CRGR asked the staff to (1) delete references to certificatee commitments as legally binding requirements; (2) require office director leve! approval for adequate protection rel9ted actions; (3) make appropriate changes to the flow chart to be consistent with the l procedures; (4) ensurc independence of the staff that would review the certificatee's backfit claim j from the one who iniS11y determined that a proposed action is not a backfit; and (5) as j specifically noted in item 8 of Attachment 2, delete the as-proposed wording; instead, use the
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i corresponding text in the CRGR Charter.
The Committee also identified the need for both the NRR and NMSS backfitting procedures to be consistent. The Committee recommanded that the NMSS staff meet with the NRR staff to provide the Committee's most recent comments and recommendations. AdditionaDy, the CRGR's NRR member indicated that he will ensure that the Committee's advice is relayed to the h, manager responsible for maintaining NRR backfitting procedures. CRGR wishes to review the O revised NRR and NMSS backfit procedures prior to issuance. g]%g~
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9904070319 990330 PDR REVCP NROCROR \
HEETINO337 PDR i
W. D. TravIrs -2 March 30, 1999 The re<ised PPL 1-53 will be submit'ed for CRGR members' approval by negative consent.
i After CRGR endorsement, the revised procedures will be attached to an amendment to these meeting minutes.
During the October 1998 review of the PPL, the Committee had remarked about inconsistencies in the backfit rule for the GDPs and those for power reactors, namely,10 CFR 76.76 and 50.109, and had recommended U1at the staff consider a revision to Part 76.76 in the near future. 1 At this meeting, there was a brief discussion on insufficient guidance contained in NUREG/BR-0058, " Regulatory Analysis Guidelines," regarding evaluation of chemical hazards, it is noted again that as reflected in the minutes of CRGR Meeting No. 329, the Committee recommends that before issuing the PPL final, the staff revise all those appendices, which have been directly excerpted from the CRGR Charter, Revision 6, and will be affected by the Charter revision in progress.
Also at this meeting, in a closed session, the members discussed various aspects of the CRGR Charter revision. The issues discussed will be incorporated in the Commission paper on the subject.
In accordance with the EDO's July 18,1983 directive conceming " Feedback and Closure of CRGR Review," a written response is required from the cognizant office to report agreement or disagreement with the CRGR recommendations in these minutes. The response is to be forwarded to the CRGR Chairman and if there is disagreement with the CRGR recommendations, to the EDO for decision making.
Questions conceming these meeting minutes should be referred to Raji Tripathi (415-7584).
Attachments: As stated cc: Commission (5) SECY F. Miraglia, DEDR M. Knapp, DEDE M. Springer, ADM J. Larkins, ACRS K Cyr, OGC H. Bell, OIC S. Collins, NRR A. Thadani, RES /p C. Paperie!Io, NMSS J. Lieberman, OE I H. Miller, RI L. Reyes, Ril '
J. Dyer, Rill E. Merschoff, RIV E. Ten Eyck, NMSS d)g \ i Distribution:
File Center (w/atts.) PDR (NRC/CRGR)(w/o atts.)CRGR SF CRGR CF .
STreby JMitchell JJohnson, OCM BSheron DDambly JJohnson, Rif MVirgilio MFederline GWest RPierson CCox DISK / DOCUMENT NAME: S:\CRGR\ MINUTES.317 To recorve a cxipy of tNs document ind,cete in the box: "C" a Copy w/o attacnment. "E" = Copy w/ettechment. H* = et copy f 9$fGR OFC CRGR MAME RTripathi y DATE 31.//99 OFFICIAL RECORD COPY Minutes of CRGR Meeting No. 337, February 23,1999
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- W. D. Travers
After CRGR endorsement, the revised procedures will be attached to an amendment to these meeting minutes.
During the October 1998 review of the PPL, the Committee had remarked about inconsistencies in the backfit rule for the GDPs and those for power reactors, namely,10 CFR 76.76 and 50.109, and had recommended that the staff consider a revision to Part 76.76 in the near future.
At this meeting, there was a brief discussion on insufficient guidance contained in NUREG/BR-0058, " Regulatory Analysis Guidelines," regarding evaluation of chemical hazards. l It is noted again that as reflected in the minutes of CRGR Meeting No. 329, the Committee recommends that before issuing the PPL final, the staff revise all those appendices, which have been directly excerpted from the CRGR Char'er, Revision 6, and will be affected by the Charter revision in progress.
Also at this meeting, in a closed session, the members discussed various aspects of the CRGR Charter revision. The issues discussed will be incorporated in the Commission paper on the subject.
In accordance with the EDO's July 18,1983 directive conceming " Feedback and Closure of CRGR Review," a written response is required from the cognizant office to report agreement or disagreement with the CRGR racommendations in these minutes. The response is to be forwarded to the CRGR Chairman and if there is disagreement with the CRGR recommendations, to the EDO for decision making.
Questions conceming these meeting minutes should be referred to Raji Tripathi (415-7584).
Attachments: As stated cc: Commission (5) SECY F. Miraglia, DEDR M. Knapp, DEDE M. Springer, ADM J. Larkins, ACRS K. Cyr, OGC H. Bell, OlG ;
S. Collins, NRR A. Thadani, RES -
C. Paperiello, NMSS J. Liebemlan, OE H. Miller, RI L. Reyes, Ril J. Dyer, Rlli E. Merschoff, RIV i E. Ten Eyck, NMSS 4
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