ML20212H317
| ML20212H317 | |
| Person / Time | |
|---|---|
| Issue date: | 04/03/1998 |
| From: | Roe J NRC (Affiliation Not Assigned) |
| To: | Robert Evans NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT & |
| References | |
| PROJECT-689 NUDOCS 9804090344 | |
| Download: ML20212H317 (5) | |
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April 3, 1998
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Mr. Robert Evans Acting Director, Programs Nuclear Generation Division Nuclear Energy Institute 1776 l Street, NW Suite 400 Washington, DC 20006-3708
SUBJECT:
REVISED REGULATORY RESPONSE GROUP PLAN
Dear Mr. Evans:
By letter dated October 7,1997, NEl sent a revised Regulatory Response Group (RRG) Plan to the Nuclear Regulatory Commission for review. The staff has completed a review of the plan and its comments are enclosed. In general, the staff commented that the revised plan should (1) better identify the conditions that require the RRG to be mobilized; (2) clearly state the actions performed by the RRG, that is, quantify the generic safety significance of the concern and provide technical input for resolution within the regulatory framework; and (3) before dissolution of the RRG, identify the party (ies) responsible for completion of actions proposed by
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the RRG. These changes will better enable the RRG to quickly mobilize industry resources in response to events of high safety significance and generic applicability.
Based on our telephone conversation with you on March 28,1998, we would like to meet with you May 19 or 20 to discuss these comments. If you any questions on this matter, please contact Joseph Birmingham at 301-415-2829 or Peter Wen at 301-415-2832.
l Sincerely, i
David B. Matthews for/
Jack W. Roe, Acting Director Division of Reactor Program Management Office of Nuclear Reactor Regulation
Enclosure:
Staff Comments on Revised RRG Plan ec w/ encl: Ownerr Group Chairmen Project No. 689 DISTRIBUTION:
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April 3, 1998 Mr. Robert Evans l
Acting Director, Programs Nuclear Generation Division Nuclear Energy Institute 1776 i Street, NW, Suite 400 Washington, DC 20006-3708
SUBJECT:
REVISED REGULATORY RESPONSE GROUP PLAN
Dear Mr. Evans:
By letter dated October 7,1997, NEl sent a revised Regulatory Response Group (RRG) Plan to the Nuclear Regulatory Commission for review. The staff has completed a review of the plan and its comments are enclosed. In general, the staff commented that the revised plan should (1) better identify the conditions that require the RRG to be mobilized; (2) clearly state the actions perfo,med by the RRG, that is, quantify the ge,eric safety significance of the concern and provide technical input for resolution within the regulatory framework; and (3) before dissolution of the RRG, identify the party (ies) responsible for cornpletion of actions proposed by the RRG. These changes will better enable the RRG to quickly mobilize industry resources in response to events of high safety significance and generic applicability.
Based on our telephone conversation with you on March 28,1998, we would like to meet with you May 19 or 20 to discuss these comments. If you any questions on this matter, please contact Joseph Birmingham at 301-415-2829 or Peter Wen at 301-415-2832.
Sincerely,
,k!
q Jack W. Roe, Acting Director d
Division of Reactor Program Management e
Office of Nuclear Reactor Regulation Project No. 689
Enclosure:
Staff Comments on Revised RRG Plan l
cc w/ encl: Owners Group Chairmen I
l
O NRC Staff Comments on Revised Regulatory Response Group Plar.
The staff reviewed the proposed revised plan vis-a-vis the original Atomic Industrial Forum Plan to determine if the purpose of the Regulatory Response Group (RRG) was maintained. The i
staff also considered the results of the two RRG activations in 1997 and the one activation in 1998. On the basis of this review, the staff has the following comments.
Purpose The staff found that the proposed revision restated the purpose of the original plan, that is, to provide a basis for logical and reasoned regulatory response for significant safety concems, but added a precondition that the concern raise near-term continued operation issues at other nuclear facilities. The staff believes that the original language, " potential near-term, generic significant safety concerns," did not restrict RRG activation to concerns for continued operation only. The staff recommends retaining the originallanguage.
Background
The revised plan did not have a Background section as did the original. The staff finds this change to be reasonable, although the background section provided insights into the need for the RRG.
Considerations The revised plan did not include a Considerations section. The staff finds this change to be reasonable because the salient information from this section is included elsewhere in the revised plan.
Recommendations The revised plan did not have a Recommendations section. In the original ps, this section described the recommended makeup of the RRG; provided for maintenance of an up-to-date roster of RRG members available to each utility, plant, architect / engineer, nuclear steam supply system vendor, ex-officio organizations, and the NRC; described the process to be followed upon RRG activation; described the information to be developed and provided for development of a proposed schedule by the RRG.
The staff believes that it is important to maintain the description of actiont com the original section because those actions define the role of the RRG in the analysis of the concern and also describe the schedule for presentation of the initial analysis and the recommended actions to the U.S. Nuclear Regulatory Commission (NRC). These actions are important to the role of the RRG as an industry-sponsored, quick-response organization that provides a basis for logical and raasoned regulaiory response to potential near-term, generic, significant safety concerns. Further, this section provided guidance on the relationship of the RRG to the various reactor vendors. The staff believes that it is impcrtant that the plan describe the role of the reactor vendors in the RRG.
Enclosure
2 The revision would extend the time for presentation of the results of the RRG analysis to the NRC from within 5 working days to within 10 working days of the initial report. The staff proposes that the 5-working-day schedule be retained with a provision that the schedule be changed if mutually agreed upon by all parties. This step is important if the NRC is to take prompt and appropriate regulatory action. The staff believes that it is not necessary for representatives from each potentially affected utility to participate in the presentation, but that the RRG be represented suf' dy to characterize the significance of the generic concem and propose appropriate actions. In some instances, a written report detailing the RRG's initial findings, preliminary recommended actions, and proposed schedule may be sufficient.
The staff recommends maintaining the four bulleted items in the Recommendations section because they provide the basis for a reasoned and logical regulatory response.
Regarding the information in the " Regulatory Response Plan Details" portion of the original plan, the staff determined that (1) the details of Section A, " Organization," would be adequately provided in the Organization and Funding sections of the proposed revised RRG plan if a provision for maintenance of an up-to-date roster of the RRG makeup were added; (2) the information in Section B, " Criterion for Activation," is not maintained in the proposed revision, that is, the proposed revision does not identify a clear criterion for RRG activation as did the original plan; and (3) Section C, "RRG Action Requests," and Section D, "RRG Communications," are adequately addressed in the corresponding sections of the proposed revision.
Regarding RRG activation, the staff notes that the appropriate determination of the significance of an event, analyses, or a concem and of the need for near-term regulatory action are key in making the decision to activate the RRG. For issues for which it can be determined that the concem, although of high safety significance, is not sufficiently generic, it would be inappropriate to activate the RRG. However, for concems involving one or more of the criteria under Section B, " Criterion for Activation," and that are considered to potentially be significant generic concerns, RRG activation is appropriate. This view is in keeping with the purpose of the RRG to focus appropriate industry resources on potentially generic near-term significant safety concerns and thus provide the NRC with a basis for a logical and reasoned response to the concern. Therefore, the staff recommends the retention of the originallanguage in Section B, which calls upon the RRG Chairman to make this determination.
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B&W Owners Group Project No. 693 Mr. J. W. Hampton, Chairman B&WOG Executive Committee Duke Power Company MC: ONOIVP P. O. Box 1439 Seneca, SC 29679 Boiling Water Reactor Owners Group Project No. 691 K. P. Donovan, Chairman Boiling Water Reactor Owners' Group Centerior Energy Perry Power Plant MC A210 P.O. Box 97 Perry, Ohio 44081 Westinghouse Owners Group Project No. 694 Mr. Thomas Greene, Chairman Westinghouse Steering Committee Georgia Power Co.
P.O. Box 1295, Bin 042 Birminghem, AL 35201 CE Owners Group Project No. 692 Mr. David Pilmer, Chairman CE Owners Group San Onofre Nuclear Generating Station 14300 Mesa Road San Clemente, CA 92672