ML20217B855
| ML20217B855 | |
| Person / Time | |
|---|---|
| Issue date: | 10/04/1999 |
| From: | Wessman R NRC (Affiliation Not Assigned) |
| To: | Lochbaum D UNION OF CONCERNED SCIENTISTS |
| References | |
| NUDOCS 9910130096 | |
| Download: ML20217B855 (4) | |
Text
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'k UNITED STATES j
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WASHINGTON, D.C. 30806 0001
. NUCLEAR REGULATORY COMMISSION October 4,1999
- Mr. David A. Lochbaum Union of Concemed Scientists 1616 P Street NW," Suite 310
- Washington DC 20036-1495 :
SUBJECT:
REPLY TO AUGUST 4,1999, LETTER TO DAVID MEYER, OFFICE OF ADMINISTRATION, NUCLEAR REGULATORY COMMISSION
Dear Mr. Lochbaum:
I am responding to your letter of August 4,1999, to David Meyer of our Office of Administration regarding our Interim Enforcement Policy relating to Year 2000 (Y2K) transition issues.
"Specifically, you expressed concems regarding our interim Enforcement Policy during the Y2K transition period and requested that the U.S. Nuclear Regulatory Commission (NRC) revise the Interim Enforcement Policy before December 31,1999.
We have reviewed your concems and find our interim Enforcement Policy to be appropriate and adequate in protecting the public health and safety.
By way of background, I restate some of the considerations that led to the issuance of the Interim Enforcement Policy. It is recognized that,in spite of every reasonable effort by licensees to identify and correct Y2K computer system problems at their facilities, some software, applications, equipment, and systems may remain susceptible to the problem.
Additionally, software, data, and systems extemal to the facility could adversely affect the facility (for example, interruption of communications or partblloss of offsite power). The electricity production and delivery systems, as two of the more important elements of the North American economic and social infrastructure, must remain dependable during the Y2K transition or rollover periods. Most other critical elements of the infrastructure depend on the availability of an interconnected, stable, and reliable supply of electrical power. There is no
~ doubt that cascading or even localized outages of generators and transmission facilities could have serious short-term and long-term consequences. Continued safe operation of nuclear power plants during the Y2K transition or rollover periods will play a major role in maintaining stable and reliable electrical power supply systems, providing necessary reserve powerif there L are major losses at other generating facilities. The interim Enforcement Policy is appropriate in certain situations where power reactor licensees encounter Y2K-associated compliance problems in the Y2K transition period (December 31,1999, through the first few days of 2000) or in other key rollover periods. Tha exercise of enforcement discretion may support a licensee
- decision to keep the plant in operation, if the licensee has determined that safety will not be
' unacceptably affected, in order to help maintain electrical grid stability and reliability.
l You stated that the nuclear industry and the NRC, based on their audits, reviews, inspections
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and tests, have concluded that nuclear power plants in the United States will not be adversely
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affected. Therefore, you believe that the proposed enforcement discretion policy would be.
f g necessary only when the licensees of nuclear power plants "....did an inadequate job of O
nN7 s reviewing its safety systems and if the NRC did an inadequate job of auditing readiness preparations." Based upon our reviews, we believe that the industry has adequately addressed
' the Y2K issue and as such, during the Y2K transition period, there may not be a need for exercising enforcement discretion. The Interim Enforcement Policy is a prudent measure and is
_ part of our contingency plans for any unlikely Y2K induced problems. It is important to note that 99i013009699go04
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the NRC is under no obligation and will not exercise discretion merely because a licensee
' requested it. The decision to forego enforcement action is discretionary. Our exercise of t
enforcement discretion is not a waiver of enforcement, but rather it states the NRC's intent to j
exercise its discretion to refrain from taking enforcement action for the specific noncompilance L
and circumstances in the interest of protecting public health and safety. Whether a situation L
- leading to a licensee's request for exercise 'of enforcement discretion is caused by its
~ inadequate performance is a matter for taking appropriate enforcement action, and is not necessarily a safety issue.
l Your letter also stated that the revised Interim Enforcement Policy does not satisfy two of the l
four Commission's stated goals, namely, maintaining safety and enhancing public confidence p
. because the revised policy "... tolerates reduction in safety" and is neither "... scrutable nor; l
objective."_ zThe criteria in the enforcement policy provide for " acceptable sma_Il plant risk" only after a balancing determination that th_e attemative to continued operation with noncompliance, 1
a 1.e., plant shutdown, may not be in the best interest of protecting overall public health and safety. ;This determination will consider grid stability and reliability and whether a shutdown
- would exacerbate localized or widespread power outages that could potentially have more serious public consequences. Such an NRC action is consistent with its safety mission..While the emergency circumstances would not permit a advance public notice, both the licensees' NOED requests and the NRC's disposition of them, including the basis for its action, will be h
documented and made available to the public. Such documentation would be " scrutable and objective."
l-
' You also suggested that the Interim Enforcement Policy should include specific criteria for exercising enforcement discretion such that it would."... provide the public with the opportunity to review the criteria and express concern with any shortcomings." As you are aware, the NRC's Enforcement Policy (NUREG-1600) provides a process, known as the Notice of Enforcement Discretion (NOED) for addressing temporary nonconformance with the technical specifications (TS). The NRC Inspection Manual Chapter Part 9909 (Part 9900) provides staff guidance for implementing the NOED policy (See Administrative Letter 95-05 Revision 2, copy enclosed).
The interim Enforcement Policy is a specific case of this general NOED policy and pr wides j
specific criteria for exercising enforcement discretion in the Y2K situations. The intr.im Enforcement Policy states that licensees should follow the existing Part 9900 gul6nce to the maximum extent practicable, and provide as much information as possible to enable the NRC l
staff to make a determination for exercising enforcement discretion. (See Section C.4.0 Part 9900, NOED guidance). Specifically, licensees should provide details of the' status of the plant, basis and nature of the emergency, potential challenges to off site and on-site powe.r sources and consequences of forced compliance with license conditions to the p5nt and to exacerbation of the emergency situation. As stated in the interim Enforcement Policy, for Y2K situations, enforcement discretion will only_be exercised when the licensee has determined that:
(a)-
complying with the license conditions would require a plant shutdown; (b)
. continued plant operation is needed to help maintain a reliable and stable grid; and (c).
any decrease in safety as a result of continued plant operation is small (considering both
- risk and deterministic aspects), and reasonable assurance of public health and safety, the environment, and security is maintained with the enforcement discretion.
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In such circumstances, the NRC staff may grant enforcement discretion on the basis of balancing the public health and safety or common defense and security of not operating against i
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potentially small increases in radiological or other hazards associated with' continued operation, and a determination that safety will not.be unacceptably affected by exercising the discretion.
. Enforcement discretion will be granted on a case-by-case basis, considering the individual plant circumstances.-'Accordingly, it is not appropriate to be more prescriptive than the present criteria described in the Part 9900 guidance and the interim Enforcement Policy..
The Commission has recognized that continued safe operation of nuclear power plants during the transition to the Year 2000 may be important to help maintain reliable electrical power
- supplies. ' As such, as a companion to the NRC Y2K contingency plan, the Commission has expanded its enforcement discretion policy to allow for rapid decision-making under L circumstances where an emergent, unanticipated Y2K problem might result in licensee non-compliance, but would not affect continued safe plant operation. The NRC has a policy of i
exercising its enforcement discretion with regard to temporary non-compliance of license -
conditions when it can be demonstrated that it is in the interest of safety. The Y2K transition enforcement policy builds on the existing enforcement discretion policy and continues to ensure public health and safety while appropriately considering some of the unique aspects associated with the Y2K transition. '
I trust that you will find the above information responsive to your letter. Should you have any questions or comments regarding these matters, please write or call me at (301) 415-3298.
Sincerely,
' Original signed by':
Richard H.. Wessman, Deputy Director Division of Englneering Office of Nuclear Reactor Regulation
Enclosure:
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3-potentially small increases in radiological or other hazards associated with continued operation, and a determination that safety will not be unacceptably affected by exercising the discretion.
I Enforcement discretion will be granted on a case-by-case basis, considering the individual plant circumstances. Accordingly, it is not appropriate to be more prescriptive than the present -
criteria described in the Part 9900 guidance and the Interim Enforcement Policy.
The Commission has recognized that continued safe operation of nuclear power plants during
- the transition to the Year 2000 may be important to help maintain reliable electrical power supplies. As such, as a companion to the NRC Y2K contingency plan, the Commission has expanded its enforcement discretion policy to allow for rapid decision-making under circumstances where an emergent, unanticipated _Y2K problem might result in licensee non-compliance, but would not affect continued safe plant operation. The NRC has a policy of l
exercising its enforcement discretion with regard to temporary non compliance of license conditions when it can be demonstrated that it is in the interest of safety. The Y2K transition l
enforcement policy builds on the existing enforcement discretion policy and continues to ensure
- public health and safety wh 's appropriately considering some of the unique aspects associated l
with the Y2K transition-4 i
i trust that you will find the above information responsive to yourletter. Should you have any
- questions or comments regarding these matters, please write or call me at (301) 415-3298.
Sincere,
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T.N.
1 Richard H. Wessman, Deputy Director Division of Engineering
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Office of Nuclear Reactor Regulation i
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Enclosure:
As stated I
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UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION WASHINGTON, DC 20555-0001 l
' July 27,1999 i
l NRC ADMINISTRATIVE LETTER 95-05, REVISION 2: REVISIONS TO STAFF GUIDANCE
- FOR IMPLEMENTING NRC POLICY ON NOTICES OF ENFORCEMENT l
DISCRETION Addressees All holders of operating licenses for nuclear power reactors.
l Purpose The U.S. Nuclear Regulatory Commission (NRC) is issuing this administrative letter to inform addressees of revisions to staff guidance for implementing the NRC's policy on Notices of Enforcement Discretion (NOEDs). No specific action or written response is required.
Backaround l
. This administrative letter supersedes in its entirety Administrative Letter 95-05, Rev.1, dated February 19,1999, on the same subject.
NUREG 1600, " General Statement of Policy and Procedures for NRC Enforcement Actions,"
l states that the staff, under certain limited circumstances, may choose not to enforce applicable plant-specific power reactor technical specifications (TSs) or other license conditions. This type of discretion is designated as a Notice of Enforcement Discretion (NOED). A NOED may be warranted if forced compliance with a power reactor license would involve an unnecessary plant transient; performance of tests, inspections, or system realignments not appropriate for current j
plant conditions; or unnecessary delays in startup, without any corresponding health and safety benefits. It is a legitimate regulatory mechanism that allows the NRC staff to address unforeseen and temporary situations in which the staff believes that strict compliance is neither l
the correct nor the safest course to follow and no other suitable regulatory approach is l-available. A valid NOED request that satisfies all the established criteria does not reflect i
negatively on a licensee's performance unless the licensee created the need for the NOED as a result of poor planning or failure to take appropriate corrective action earlier.
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l Discussion The guidance in Administrative Letter 95-05, Rev.1 has been further revised to (1) clarify considerations for a NOED requested as a result of severe weather or other I
natural events,
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AL 95-05, Revision 2 July 27,1999 Page 2 of 2 (2) reflect certain administrative changes as a result of the recent reorganization of the Office of Nuclear Reactor Regulation.
The revised guidance is attached to this administrative letter.
This administrative letter requires no specific action or written response. If you have any questions about this letter, please contact one of the persons listed below or the appropriate NRC Project Manager.
l Original /s/'d by i
Ledyard B. Marsh, Chief Events Assessment, Generic Communications and Non-Power Reactors Branch Division of Regulatory improvement Programs Office of Nuclear Reactor Regulation l
Contacts: L. Raghavan, NRR Herbert N. Berkow, NRR 301-415-1471 301-415-1485 E-mail: lxr1@nrc. gov E-mail: hnb@nrc. gov
' Attachments:
- 1. NRC Inspection Manual, Part 9900, " Technical Guidance"
- 2. List of Recently lesued NRC Administrative Letters DOCUMENT NAME: S:\\DRPM_ SEC\\95-05R2.al
- To receive a copy of this document, indicate' in the box C= Copy w/o attachment / enclosure E= Copy with attachment / enclosure N = No copy OFFICE REXB=
s ech Editor C:REXb NAME' CHodge*_
RS*
LRaghavan*
'HBerkow*
LMarsh Dft f
DATE 7/21/99 07/19/99 7/19/99 7/19/99 1 b99 OFFICIAL RECORD COPY-s i
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AL 95-05, Revision 2 July 27, 1999 i
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UNITED STATES y
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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. m8 *
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NRC INSPECTION MANUAL DLPM l
PART 9900: TECHNICAL GUIDANCE NOED.TC OPERATIONS - NOTICES OF ENFORCEMENT DISCRETION A.
PURPOSE This document provides guidance to staff in the Regional Offices and the Office of Nuclear Reactor Regulation (NRR) on the process for the NRC to exercise enforcement discretion with regard to limitin power reactor Technical Specifications (TS) g conditions for operation (LCO) in or other license conditions. This type of discretion is addressed in Section VII.C of the "Geaeral Statement of Policy and Procedures for NRC Enforcement Actions" (Enforcement Policy. NUREG-1600) and is designated as a Notice of Enforcement Discretion (NDED). This guidance is not applicable to non-power or permanently shutdown reactors. N0EDs may be warran;ed for operating reactors if compliance with a TS LCO or with other license condition would involve:
(1) an unnecessary plant transient, or (2)
. performance of testing. inspection, or system realignment that is inappropriate for the specific plant conditions. or (3) unnecessary delays in plant startup without a corresponding health and safety benefit. An N0ED can be issued for a 1
power reactor at power. in startup. or in shutdown, provided the specific applicable criteria set forth below are met. N0EDs may also be ap severe weather and other external events could have a potentia ~
propriate when impact on the overall health and safety of the public.
The NOED process is designed to address temporary nonconformances from the license conditions and TS only and is not appropriate for nonconformances with regulations. Updated Final Safety Analysis Reports (UFSARs), or codes.
Exemptions from regulations, non-compliance with UFSARs. and reliefs from codes must be processed in accordance with the provisions of Title 10 Code of Federal Reaulations (10 CFR) 50.12, 50.59 or 50.55a. Nonconformance with regulations.
UF$ARs. or codes normally do not, in themselves, require immediate shutdown. In such situations, the licensee must perform a prompt safety assessment of the noncompliance and make an appropriate operability determination. The licensee should further determine what other NRC requirements apply to the situation, e.g.
10 CFR Part 50. Appendix B. Criterion XVI 10 CFR 50.12 etc. and take required actions. Generic Letter (GL) 91-18. "Information to Licensees Regarding NRC In ection Manual Sections on Resolution of Degraded and Nonconforming Ccnditlins." cnd associated NRC Inspection Manual Chapter Part 9900 provide staff guidance for aadressing such circumstances.
When an N0ED is granted, it is recognized that the operating license will be violated, but the NRC is exercising its discretion not to enforce compliance with the operating license for a specified time period. In all cases. appropriate enforcement actions consistent with the NRC's Enforcement Policy should be considered for the root causes leading to the need for the N0ED.
Issue Date: 06/29/99 1-9900. NOED 49o 3+ec n !
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B.
CRITERIA 1.0 General Considerations A licensee may depart from its TS in an emergency, pursuant to the provisions of 10 CFR 50.54(x). without prior NRC approval, when it must act immediately to protect the public health and safety. However. situations occur occasionally that are not addressed by the provisions of 10 CFR 50.54(x) and for which the NRC's exercise of enforcement discretion may be appropriate. Provided that the licensee has not abused the emergency provisions of 10 CFR 50.91 by failing to apply for
.an amendment in a timely manner, it is appropriate that the NRC have the N0ED procedure for expeditious notice to a licensee of NRC's intention to exercise enforcement discretion under limited circumstances.
The NRC staff is expected to issue N0EDs infrequently. Although requirements may dictate that.a plant must be shut down, refueling activities suspended, or plant
'startup delayed absent the exercise of enforcement discretion, the NRC staff is under no obligation to issue an N0ED. The decision to forego enforcement action is discretionary. An N0ED is to be issued only if the NRC staff is clearly satisfied that such action is warranted from a public health and safety standpoint. An N0ED should be granted on a case-by-case basis, considering the individual plant circumstances. If appropriate and feasible. the> staff should perform a qualitative probabilistic risk analysis (PRA) as an input to its decision process. If the NRC decides not to issue an N0ED the licensee must take the action required by the TS (except as stated in 10 CFR 50.54(x)). In addition, if a Licensee Event Report (LER) is required by 10 CFR 50.73 as a result of the non-conformance. the licensee must submit that LER notwithstanding the staff's issuance of an N0ED.
Careful regulatory scrutiny should be given to any deviation from the required actions of the TS or other license conditions for circumstances involving violations, poor planning, repeated N0ED requests for the same reasons. or some similarly avoidable situation. To prevent the potential for such abuse and the lack of up-front public notice and participation in the N0ED process, the staff will apply criteria similar to those in 10 CFR 50.91 to verify that the exigency was unavoidable.
2.0 Situations Affectina Radioloaical safety The following are N0E0 criteria applicable for various plant conditions:
1.
For.an operating plant, the N0ED is intended to (a) avoid undesirable transients as a result of forcing compliance with the license condition and, thus, minimize potential safety consequences and operational risks or-(b) eliminate testing inspection, or system realignment that is
-inappropriate for the particular plant conditions.
i 2.
For.,lants in a shutdown condition. the N0ED is intended to reduce j
shutdown risk by avoiding testing, inspection. or system realignment that 4
is inappropriate for the particular plant conditions, in that it does not provide an overall safety benefit. or may, in fact. be detrimental to safety in the particular plant condition.
i i
9900. N0ED Issue Date: 06/29/99
- s 3.
For plants attempting to start up.2 the need for an NOED is expected to occur less often than for operating plants, because delaying startup does not usually leave a plant in a condition in which it could experience undesirable transients. Thus, the issuance of N0EDs for plants attempting i
to start up must meet a higher threshold, as described below. N0EDs for plants attempting to start up are to be exercised only when the licensee considers and the NRC staff has concluded that:
4 a.
The equipment or system does not perform a safety function in the mode in which operation is to occur (e.g.. a TS which requires the equipment to be operable in a mode not required by the UFSAR); or.
b.
The safety function performed by the equipment or system is of only marginal safety benefit, and remaining in the current mode increases the likelihood of an unnecessary plant transient or.
c.
The TS or other license conditions require a test, inspection, or system realignment that is inappropriate for the particular plant conditions in that it does not provide a safety benefit, or may. in fact, be detrimental to safety in the particular plant condition.
The letter issuing an N0ED should specifically address which of the above three criteria were sat'isfied. If the criteria, as described above, are not satisfied, the licensee must comply with the license requirements until a license amendment is requested and issued.
3.0 Situations Arisina from Severe Weather or Other Natural Events In unusual situations. severe weather or other natural events may result in a 90vernment entity or a responsible independent entity making the assessment that the need for power and immediate overall public (non-radiological) health and safety considerations constitute an emergency situation.
The licensee must provide the name, organization and telephone number of the official in the government or independent entity that made the emergency assessment. If deemed necessary. the staff may contact the appropriate official to independently verify the information provided by the licensee prior to making an N0ED determination.
In such circumstances, the staff may grant an NOED based on balancing the overall public health and safety implications of not operating, with the potential radiological or other hazards associated with continued operation of the facility while in nonconformance with the particular requirement.
The request must provide details of the basis and nature of the emergency; its potential consequences such as plant trip. controlled shutdown. delayed startup:
the condition and operational status of the plant (equipment out of service or otherwise inoperable): status, and potential challenges to off-site and on site power sources, and the impact of the emergency on plant safety. The licensee must identify actions that it took to avert and/or alleviate the emergency situation.
including steps taken to avoid being in the noncompliance, as well as efforts to minimize grid instabilities (e.g., coordinating with other utilities and the load dispatcher organization for buying additional power or for cycling load, shedding interruptible industrial or non-emergency loads). In addition, the licensee's request must be sufficiently detailed for the staff to evaluate the likelihood that the event could affect the plant, the capability of the ultimate heat sink.
on-site and off site emergency preparedness status, access to and from the plant.
For purposes of this guidance. "startup* is defined as any condition with the 2
reactor being in other than " operation" in Mode 1 or cold shutdown.
Issue Date: 06/29/99 9900. N0ED l
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F acceptability of any increased radiological risk to the public and the overall public benefit.
C.
N0ED PROCESS 1.0 Reaional NDED A region-issued NOED is appropriate when the noncompliance is nonrecurring, will not exceed 14 days in duration, and a license amendment is not practical because the plant will return to compliance with the existing license in a short period of time. Matters that a region-issued N0ED may address include:
1.
A noncompliance of short duration with the limits of a function specified in an LCO.
2.
A noncompliance with an action statement time limit.
3.
A noncompliance with a surveillance interval or a one-time deviation from a surveillance requirement.
The authority to issue an N0ED is assigned to the Regional Administrator, who may delegate the authority to the Regional Division Director of Reactor Projects. The NOED should be based on a written request (or in some cases an oral request followed by a written request within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) from a licensee. Before issuing an NOED. the region should obtain the concurrince of the NRR Project Director (PD). The PD. in turn, should consult with the cognizant NRR technical branch chief (s) concerning the acceptability of issuing the NOED. Whenever a regional NOED is exercised, the staff's evaluation of the licensee's request, including the apphcable items in Section C.4 of this guidance, should be documented in a letter tc the licensee from the Regional Administrator or his/her designated official. The letter should follow the format and content of Attachment A to this guidance, and specify and discuss the maximum period of time for which the N0ED is in effect (not to exceed 14 days). The region may grant an N0ED verbally, but this should be followed by written authorization within 2 working days of the verbal N0ED authorization. Resolution of the condition that led to the request for enforcement discretion should terminate the NDED.
All licensee - staff teleconferences to discuss NOED requests should be made through the NRC headquarter's Emergency Operations Center recorded telephone line (Telephone No.
(301) 816-5100). This provides a record of the discussion and a basis for future verification of its consistency with the licensee's follow-up written request.
2.0.
NRR N0E0 Matters that an NRR-issued N0ED may address include:
1 i
1.
A noncompliance with an element specified in a limiting condition for operation until such time as the element can be revised by a license amendment.
2.
A noncompliance with an action statement time limit for which a license amendment will be processed to make the extension either a one-time or a permanent change to the TS.
3.
A noncompliance with a surveillance interval or change to a surveillance requirement that will be incorporated by an amendment.
9900. N0ED Issue Date: 06/29/99 4
d
The authority to issue an NOED is delegated to the appropriate PD. The N0ED should be based on a written recest (or in some cases, an oral request followed by a written request within 24 Murs) from a licensee. Before issuing an NOED.
the NRR PD should obtain concurrence from the responsible Regional Division Director of Reactor Projects. In addition, the PD should consult with and obtain i
written concurrence from the appropriate NRR technical branch chiefs The staff may grant an N0E0 verbally, but this should be followed by written authorization within 2 working days of the verbal N0ED authorization. All licensee - staff teleconferences to discuss N0ED requests should be made through the NRC headquarter's Emergency Operations Center recorded telephone line (Telephone No.
(301) 816-5100). This provides a record of the discussion and a basis for verification of its consistency with the licensee's follow-up written request.
Whenever an NRR N0ED is granted. the staff's evaluation of the licensee's i
request. including the applicable items in Section C.4 of this guidance, should j
be documented in a letter to the licensee from the appropriate NRR PD. The letter i
should specify and discuss the maximum period of time for which the N0ED is in effect (resolution of the condition that led to the request or issuance of the
]
follow-up license amendment would return the licensee to a condition of compliance with the license), and should follow the format and content of Attachment A to this guidance. Follow-up license amendments for NRR-issued N0EDs should be processed on an exigent basis in accordance with the process for exigent amendments. The follow-up license amendment must be submitted by the licensee within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of its oral request and should be issued by the NRC staff within 4 weeks of the issuance of the N0ED unless otherwise justified by any special circumstances. Such special circumstances should be documented 3romptly in a memorandum from the responsible PD to the Associate Director for 3roject Licensing and Technical Analysis. If necessary, an NOED-re'ated issue that is part of a larger license amendment request should be handled as a l
separate amendment if that will expedite issuance. When amendments involving N0EDs are issued, the transmittal letter should identify the NOED which 'the amendment supersedes.
Also, the NRR Project Manager (PM) should send an electronic copy of the letter issuing the follow-up license amendment to the E-mail address: N0ED.
NRR is responsible for N0EDs involving severe weather conditions or other natural events. NRR has the lead for staff determination of the validity of the emergency and whether to grant an N0ED. The PM. with assistance from appropriate technical staff, should make reasonable efforts to get a good assessment of the nature of the emergency. A teleconference should be held as soon as possible among senior licensee management. NRR and regional staffs. Participating staff personnel should include: NRR - PM. PD. cognizant technical branch chiefs. including the chief of the Electrical and Instrumentation and Controls branch, if possible, to evaluate the emergency assessment: Regional Projects Division Director, and Resident Inspector. Following the teleconference the licensee must imediately submit (within a few hours) a follow-up written request documenting all the bases, justifications, commitments and other considerations and conditions discussed and agreed upon.in the teleconference.
The PM should inform the Commission through the cognizant Regional Coordinator. OEDO. as expeditiously as possible following granting of the N0ED.
See Attachment B for a sample memorandum fro *, the OED0 to the Ccr.ission. The cognizant PM should preparc this memorandum in draft and give it to the cognizant Regional Coordinator. OEDO. for finalization and processing.
3.0 Multiole N0EDs j
There may be occasions when several plants in different regions may request N0EDs j
simultaneously to address common conditions, e.g. a vendor advisory letter. In Issue Date: 06/29/99 9900. NOED
such cases. the regions and NRR should coordinate closely with each other to avoid potential duplication of effort and/or inconsistent approaches and to obtain any special assistance or expertise needed from NRR. In such cases, plant-specific N0EDs will be issued either by the region or NRR in accordance with Sections C.1 and C.2 of this guidance, to individual licensees. To assure consistency in staff determinations relating to the N0ED requests. approvals.
root cause violations and enforcement actions. the cognizant NRR technical branch chief (s) should be included in all discussions and decisions.
4.0.
Recuest for N0ED The staff should verify that the licensee's request for an N0ED includes the following:
1.
The TS or other license conditions that will be violated.
2.
The circumstances surrounding the situation. including apparent root causes, the need for prompt action and identification of any relevant historical events.
3.
The safety basis for the request. including an evaluation of the safety significance and potential consequences of the proposed course of action.
This evaluation should include at least a qualitative risk assessment derived from the licensee's PRA.
4.
The basis for the licensee's conclusion that the noncompliance will not be of potential detriment to the public health and safety and that no significant hazard consideration is involved.
5.
The basis for the licensee's conclusion that the noncompliance will not involve adverse consequences to the environment.
6.
Any proposed compensatory measure (s).
7.
The justification for the duration of the noncompliance.
8.
A statement that the request has been approved by the facility organization that normally reviews safety issues (Plant On-site Review Committee. or its equivalent).
9.
The request must specifically address which of the N0ED criteria for appropriate plant conditions specified in Section B is satisfied and how it is satisfied.
10.
If a follow-up license amendment is required. the N0ED request must include marked-up TS pages showing the proposed TS changes and a commitment to submit the actual license amendment request within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
- 11. For N0EDs involving severe weather or other natural events, the licensee's - recuest must be sufficiently detailed for the staff to evaluate the likelihood that the event could affect the plant. the capability of the ultimate heat sink. on-site and off-site emergency preparedness status, access to and from the plant. acceptability of any increased radiological risk to the public and the overall public benefit.
In-addition to items 1-10 above, as appropri;te, the licensee must provide:
9900. NOED Issue Date: 06/29/99
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Details of the basis a..d nature of the emergency:
potential l
consequences of forced compliance with the license conditions to the plant and to exacerbation of the emergency situation. The licensee must 3rovide the name, organization and telephone number of the offic' al that made the emergency assessment b.
Status. and potential challenges to off-site and on-site power l
sources, and the impact of the emergency on plant safety.
c.
Demonstrated actions taken to avert and/or alleviate the emergency l
situation, including steps taken to avoid being in the
- noncompliance, as well as efforts to minimize grid instabilities (e.g., coordinating with other utilities and the load dispatcher organization for buying - additional power or for cycling load, shedding interruptible industrial or non-emergency loads).
The request from the licensee should normally be sent by facsimile to the NRR PD and the Regional Projects Division Director. The signed original should be sent to the Document Control Desk. However, if circumstances do not permit time for the written request to be prepared and sent to the NRC the licensee may make the request orally, describing to the best of its ability the information required by the staff. The licensee's oral request needs to be followed promptly by written documentation (within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) addressing the appropriate items listed above. In cases where a license amendment is appropriate, the written request for the NOED should be followed within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> by the licensee's request for a license amendment for NRC staff consideration under the provisions of 10 CFR
- 50.91. The licensee's amendment request must describe and justify the exigency.
If the request is made orally, the NRC should have sufficient information to reach the same conclusions as if it had received a written submittal. The follow-up written request should confirm the information that the staff relied upon in arriving at its conclusion to issue the N0ED. If an NOED is authorized orally but the licensee subsequently determines that no violation of the license will occur and thus the N0ED is.not needed the licensee and staff should still follow up with appropriate documentation. In such cases, the licensee must submit a letter within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, documenting its oral request. the NRC's oral approval, and the circumstances that led to the determination that the NOED is no longer needed.
D. STAFF EVALUATION AND DOCUMENTATION Prior to issuance of an N0ED. to the extent practicable. the regional Projects
- Branch Chief and/or the PM should verify the licensee's oral assertions.
-including root cause and compensatory measures, and that the N0ED request is consistent with the staff's policy and guidance. If any of the verifications cannot be made prior to issuance of the N0ED. this should be done subsequently.
l as soon as time permits. The results of the verification activities are to be documented in a subsequent inspection report. When an NOED is granted either l
. by the region or NRR. the-responsible resident. inspector should open an Unresolved Item (URI). to facilitate promat tracking, documentation and closure of inspection. verification and resolut'on activities, including enforcement action determinations, associated with the NOED.
l, The staff's letter documenting the N0ED should be self-standing, address the appropriate items in Section C.4 of this guidance. and demonstrate that issuance of the NOED is consistent with the ;x)licy and guidance. The N0E0 letter should also clearly specify which of the licensee's arguments the staff accepted in Issue Date: 06/29/99 9900. N0ED
reaching its decision and the criterion that is latisfied. The sequence of events in the staff's letter should be clear and include: how and when the licensee
.first requested i.he discretion, what the. length of the A0T/ surveillance interval verbal involved was.. when the allcwd time would end, when (if applicable) discretion was issued, the date of the licensee's follow-up written request (if the specific period of discretion starting at the origW1 was made verbally), ED was terminated before the staff's letter is
~
the end of.he A0T and. if the N0 issued. i.ne letter should contain the time the N0ED was actually terminated. The staff should document in the N0E0 letter its verification of the consistency between the. licensee's verbal and written requests. The letter should also the key staff who participated in the NOED
. identify by name and title, evaluation and approval and, if applicable. when the licensee's follow up license amendment request will be or was submitted.
It.is. not acceptable to permit the licensee not to follow a TS or license condition while the staff considers a request for discretion. If the licensee is unable to provide the staff an adequate basis before the LCO time ends, the licensee must take the required actions to comply with the TS while endeavoring to provide the staff an adequate basis for granting the NOED. It is recognized that in cases involving short LCO times or complex issues, the staff may have to act before all the information is available. In such cases. if the information presented provides a clear basis that public health and safety is assured and that the criteria of the NDED solicy are satisfied, then an N0ED may be granted.
l If subsequent information fai's to support the initial issuance of the NOED. it the time it takes should be terminated, as discussed in Section E. In summary,lieve the licensee for the staff to evaluate the request for an NOED does not re from taking appropriate actions to comply with the TS.
E.
ENFORCEMENT 1.0 Early Termination of N0E0 If the NRC decides to terminate the N0ED for any reason before the time specified in the N0ED the staff should verify that the licensee takes steps to achieve the appropriate plant status and implement the existing TS required actions upon oral notification of the termination by the appropriate NRR PD or Regional Division Director.
Upon notification of termination of the.N0ED. the licensee must inform the NRC of the preposed course of action to restore the plant to a condition of compliance with the license. The termination of the NOED by the NRC should be documented in a letter to the licensee and should address the actions taken or planned by the licensee including W time necessary for the license i
all these cases. the NRC will not normally take enforcement action for the TS or license condition violations during the period the N0ED was in effect, except for t% root causes leading to the noncompliance, as discussed below.
2A Consideration of Enforggm_ eat The. decision to exercise enforcement discretion by issuing an N0ED does not change the fact that a violation will occur. nor does it imply that enforcement discretion is being exercised for any violation that may have led to the need for the N0ED. In each case where the NRC staff has chosen to exercise enforcement discretion. enforcement action will normally be taken for any violations that contributed'to the root causes leading to the noncompliance. Such enforcement Issue Date: 06/29/99 9900. NOED
action is intended to emphasize that licensees should not rely on the NRC's NOED process as a routine substitute for compliance or for requesting a license amendment.
NRR-issued N0EDs should be closely coordinated with the appropriate region to ensure that the region considers the need for enforcement action for any root cause violations that led to the NOED issued by NRR. The staff should follow the guidance in the NRC-Enforcement Manual. NUREG\\BR-0195. to determine and process the appropriate enforcement action. OE approval is required for not issuing an enforcement action if a violation is involved. The enforcement action should reference the N0ED number. All staff determinations regarding enforcement action associated with the issuance of an N0E0 should be documented by the region in the next appropriate inspection report under the URI established to track that N0ED.
regardless of whether or not the determination is to take enforcement action.
If the root cause underlying an NOED request results in an escalated action. the time during which the NOED is effective will not be counted in considering the impact of the violation.
F.
DISTRIBUTION Copies of the letter to the licensee shall be distributed according to established regional and NRR procedures and shall include the following:
1.
Regional Coordinator. OEDO 2.
Regional Administrator 3.
Associate Director for Project Licensing and Technical Analysis. NRR 4.
Division Director. Division of Licensing Project Management (DLPM). NRR 5.
Director. Office of Enforcement 6.
Public 7.
Technical Assistant. DLPH. NRR
{
8.
Electronic copy (Wordperfect file) to E-mail address: N0ED 9.
Electronic copy (Wordperfect file) to NRC Internet Webmaster. E-mail:
NRCWEB 10.
Appropriate Branch Chiefs (Region and NRR) 11.
Appropriate NRR PD and Section Chief l
12.
Appropriate Senior Resident Inspector Further. the issuing office should ensure that the licensee's request is also e
placed in the Public Document Room and that electronic copies of N0EDs are prepared in accordance with Attachment C.
NRR will post the staff's N0ED approval or denial letter on the NRC public web page. The N0ED will remain on t7e bulletin board for 6 months for easy public access. The Technical Assistant (TA). DLPH. NRR. will maintain a file of all NOEDs. Also, for NRR-issued N0EDs.
l the PM should send an electronic copy of the letter issuing the follow-up license amendment to the E-mail address: NOED.
G.
TRACKING OF NOTICES OF ENFORCEMENT DISCRETION The NRR PM should open a Technical Assignment Control (TAC) number under Licensing Action code LD for any NOED action involving NRR resources.
Each N0ED will be assigned a number to permit tracking. The issuing office (region or NRR) will assign a number consisting of six digits. The first two digits indicate the year, the third digit indicates the number of the region (or Issue Date: 06/29/99 9900. N0ED
6 for MRR) and the last three digits are the sequential number of the N0ED for
~
the issuing office. For example. NOED 98 3-02 is the 2nd N0ED issued by Region III in 1998. This number should be included in parenthesis at the end of the
'l subject line for the N0ED. for example: (NDED 98-3-02). The TA. DLPM. NRR. will assign numbers for all NRR~ N0EDs and regional assignments will be made in accordance'with regional procedures.
Each office (region or NRR) is responsible for tracking the N0EDs it issues and for entering the required data into its tracking system. Additionally, each region will be responsible for inspection. follow-up.. and enforcement for all N0EDs issued, including those issued by NRR. for plants in that region.
On a semi-annual basis, the TA. DLPM will request the regions to provide updated l database information regarding follow-up. actions to previously issued N0EDs.
This should include reference documents and dates for verification of licensees' oral assertions in the NOED requests, the determination to take or to not take enforcement action for any violations that may have led to the need for the N0ED.
and any follow up inspections of licensees' root cause determinations, and corrective actions.
H.
N0ED CHECKLIST An NOED checklist is provided in Attachment D as an aid to the staff in assuring'.
adherence to this guidance. It's use is discretionary and it is a companion, not a substitute, for the detailed guidance.
I.
REFERENCE NUREG-1600. " General Statement of Policy and Procedures for NRC Enforcement Actions.Section VII C. ' Exercise of Discretion for an Operating Facility" END Attachments:
A.
Sample Letter for N0E0 Issuance B. -Sample Letter for Notification to the Comission Regarding Issuance of N0EDs for Severe Weather or Other Natural Events.
C. File Format for Electronic Copy (Wordperfect file) of NOED Approval /
Disapproval Letters.
1 D. N0ED Checklist 9900. NOED Issue Date: 06/29/99
AtiSchment A SAMPLE LETTER FOR N0ED ISSUANCE Addressee
SUBJECT:
NOTICE OF ENFORCEMENT DISCRETION FOR [ LICENSEE NAME] REGARDING [ PLANT NAME(S)] [ TAC NO. XXXXXX (if applicable). NOED NO.XXXX]
By letter dated [date of letter), you requested that the NRC exercise discretion not to enforce compliance with the actions required in [TS or license condition citation]. Your letter documented information previously discussed with the NRC in a telephone conference on [date) at [ time). The principal NRC staff members who partic1 pated in that telephone conference included [ list name and titles of the princ1 pal staff participants). You stated that on [date and time] the plant (s) would not be in compliance with [TS/ license condition) which would require
[ statement of the. requirement including the A0T and the date and time when the action statement was entered] You requested that a Notice of Enforcement Discretion (N0ED) be issued pursuant to the NRC's policy regarding exercise of discretion for an operating facility, set out in Section VII.c. of the " General Statement of Policy and Procedures for NRC Enforcement Actions" (Enforcement Policy). NUREG-1600, and be
)
effective for the period [ state licensee's requested period for the NOED). This letter documents our telephone conversation on [date and time) when we orally issued this NOED. [lf appropriate: We understand that the condition causing the need for this N0ED was corrected by you causing you to exit from the [TS/ license condition]
and from this NOED on [date and time).
[Briefly restate the licensee's description of the events leading up to the request for the NOED and a summary of their safety rationale for issuing the NOED. Include l
any compensatory measures that the licensee has proposed.]
[ Summarize the staff's evaluation of the licensee's request and supporting safety rationale including the items in Section C.4 of this guidance, state which cf the licensee's justifications the staff accepted to the extent that staff verification l
Of the licensee's oral assertions including root causes and compensatory measures.
has been made prior to issuance of this letter. such verification should be documented here]. and cite the explicit criterion in Section B of this guidance that the licensee satisfied.]
On the basis of the staff's evaluation of your request, we have concluded that an l
NOED is warranted because we are clearly satisfied that this action involves minimal or no safety impact is consistent with the enforcement policy and staff guidance, and has no adverse impact on public health and safety. Therefore. it is our intention to exercise discretion not to enforce compliance with [TS/ license condition) for the period from [date and time] until [if region-istued: date and i
time; if NRR-issued: until issuance of a license amendment, and state when the i
amendment request was or will he submitted: state if the approved NOED effective duration differs from the requested time and why]. [For NRR-issued N0EDs: The staff plans to complete its review and issue the license amendment within 4 weeks of the date of this letter.
As stated in the Enforcement Policy, action will te taken. to the extent that violations were involved, for the root cause that led to the noncompliance for which this NCED was necessary, 51gnature Project Director. NRR or Regional Administrator or designee Docket No(s).: 50 xxx Issue Date: 06/29/99 A-1 9900. N0ED, Attachment A
rt P
T f
8 I
F
. 1 1
.k_
s X,
.I I.
E O
.%'l l
4'
r 3
i Attachment B 3
SAMPLE MEMORANDUM FOR NOTIFICATION OF N0E0 FOR SEVERE WEATHER OR OTHER NATURAL EVENT b
(Date) 0FFICE OF NUCLEAR REACTOR REGULATION NOTIFICATION OF ISSUANCE OF AN NOED FOR SEVERE WEATHER OR OTHER NATURAL EVENT Licensee: (Name of Licensee)
Facility:
Docket No:
N0ED No.
To:
Chairman and Comissioners
SUBJECT:
ISSUANCE OF AN N0E0 FOR [Be specific: SEVERE WEATHER OR OTHER NATURAL EVENT)
This is to inform the Commission that a Notice of Enforcement Discretion (N0ED) as a result of [ severe weather or other natural events] was issued on
[date] to [ licensee name and facility].
This action is based on the licensee's request on [date] for an NOED. This is an information memorandum and requires no Commission action.
[ Describe in summary form: the name, organization and telephone number of the official that made the emergency assessment Details of the basis and nature of the emergency: consequences of forced compliance with the license conditions to the plant and to exacerbation of the emergency situation, status, and potential challenges to off-site and on-site power sources, and the impact of the emergency on plant safety: demonstrated actions taken to avert and/or alleviate the emergency situation, including steps taken to avoid being.in the noncompliance, as well as efforts to minimize grid instabilities i
(e.g... coordinating with other utilities and the load dispatcher organization for buying additional power or for cycling load, shedding interruptible industrial or non emergency loads).
Contact:
(name), NRR 415-XXXX Distribution:
Regional Administrators Director, NRR Cognizant PM/PD Issue Date: 06/29/99 B-1 9900, N0ED, Attachment B
Attachnent D N0ED CHECKLIST NOTE: This is an aid to the staff in assurina adherence to this auidance.
It's use is discretionary and it is a comDanion. not a substitute. for the detailed ou1 dance.
Oral Request Date:
TAC No.
j N0ED No, NRC NOED Letter Date
- 1. APPLICABILIT(
ltem Check l Guidance 1.
Non-compliance related to non-power or Yes Stop. NOED ls not apphcable.
pertwanently shutdown power reactors 2.
Non-comphance with TS or license condition Yes No Stop. NOED is not applicable.
3.
NOED is for short duration (not exceed 14 Yes Regional responsibikty days), one-time situations 1
No l NRR responsibihty 4.
Non-compliance related to severe weather or Yes NRR responsibility. NOED per Section B3. Review other natural events that require balancing of justrfication per Section C 4, item 11. Inform the overall pubhc health and safety.
Commission of the NOED issuance expeditiousty.
No 5.
NOED request is caused by licensee failing Yes Carefully scrutinize to preclude abuse of NOED process.
to apply for an amendment in a timely Evaluate criteria for an exigent amendment per 10 CFR manner, i.e, Poor planning 50.91.
No 6.
AOT has expired prior to staff approval of Yes Stop. Licensee must comply with TS.
NOED i
No l
l NOED approval requires closer scrutiny.
7.
D > any of the following apply:
Yes l
- a. TS has been violated I
l
- b. Poor planning No j
i
+
II. SAFETY CONSIDERATIONS l
Guidance ltem Check l
l ltem is or ib. must be satisfied.
1.
NOED is for an operating plant Yes l Proceed to item 2.
No i
l a) NOED is for avoiding undesirable plant Yes transient, i e., shutdown.
No item 1a or ib, must be satisfied b) NOED would eliminate testing, inspection or Yes j
/
system realignment that is inappropnate for particular plant condrtions.
No l
l Item 2a must be satisfied.
2.
Is the plant in a shutdown condrtion?
Yes No Skip 2a and proceed to item 3.
l a.
NOED would reduce shutdown risk by Yes I
avoiding testing, inspection or system realignment that is inappropriate for particular No NOED is not allowed.
plant conditions?
3.
Is the plant in a startup condition?
Yes item 3a. 3b or 3c must be satisfied No a) the equipment or system does not perform a safety function in the mode in which operation is to occur. or b) equipment or system safety function is of only marginal safety benefit.
Item 3a,3b or 3c must be satisfied Es remaining in the current mode increases the likelihood of an unnecessary plant transient, or c) test, inspection or System realignment is inappropriate for the particular plant conditions because it does not provide a safety benefit, l
or may be detnmenta! to safety 9900. NOED, Attachment D D-2 Issue Date: 06/29/99
s 111. PROCESS ltem Chk Guidance 1.
Licensee's request 1.
May be oral. Arrange licensee-staff telephone discussions thru the recorded line (301) 816-5100.
2.
Written request within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Address items in Section C.4.
3.
Submit follow-up license amendment within 48 hrs.
2.
TAC number assigned I
Licensing Action Code: LD.
3.
Venfication Region project's Branch Chief / NRR PM - Venfv licensee's oral assertions, to the extent practical.
NRR-issued: Requires regional Divisional Director of Reactor Projects' and cognizant NRR technical branch chief (s) concurrence.
4.
Issuing authority Region: Regional Administrator or designee NRR: Project Director 5
NOED number NRR:
Obtain from TA,. DLPM.
Region:
Per Region guidance 6,
NOED granting May be oral, to be followed by NOED letter within 2 working days.
7.
Specify maximum period for Region: Maximum 14 days which NOED is in effect NRR: Until the issuance of amendment (4 weeks maximum).
8 NOED letter 1.
Follow sample (See Attachment A).
2.
If subsequent to oral granting of an NOED, the licensee determines that no violation of the license will occur and thus the NOED is not needed, the licensee and staff should still followup with sppropriate documentation.
3.
Document consistency between the oral and written requests.
- 4. Cite and demonstrate how the specrfic NOED criteria satisfied 5.
Identify by name and title principal staff participants in the NOED approval.
6.
Evaluate and document applicable items in Section C.4 7.
Specify time period for which NOED wi!! be in effect..
9.
Follow-up license amendment 1.
Issue exigent amendment within 4 weeks. If not, justify (NRR) promptly by a memo to. Associate Director for Project Licensing and Technical Analysis, NRR.
2.
Send a copy of the amendment letter to email.NOED
- 10. Root cause violations Determination made. NRR coordinate with the regions
- 11. Inspection Report Region to document root cause violation determination, NOED approval basis, results of venfication activities to close URI.
- 12. Enforcement action Coordinate with OE. For all NOEDs, Region to open an URI and document determinations in the next appropriate inspection report.
- 13. Licensee LER Required even if NOED is issued (if otherwise required).
- 14. Distribution See Part 9900. Note: Electronic copy of Word Perfect file to Email addresses: NOED and NRCWEB IV. LICENSEE REQUEST FOR ENFORCEMENT DISCRETION Issue Date: 06/29/99 D-3 9900, N0ED, Attachment D
+
ltem Chk Remarks 1.
The TS or other heense condsons that wiu be woisted 2.
The crcumstances surroundang the estusta, including root causes, the need fer prompt schon and identrAcabon of any televant histoncal events.
3.
. TN safety basis for the request, induding an evaluation of the safety signincance and potential consequences of the proposed course of action.
4.
The basis for the hoensee's conclusson that the iscwT,,liance will not be of potential detr'mont to the public health and safety and that a significant hazard consideration is involved.
5.
The basis for the beensee's conclusion that the noncomphance will not involve adverse consequences to the environment 6.
Any pr* compensatory measure (s).
7.
The justincatson for the duration of the noncompliance.
8.
A statement that the request has been approved by the facility
. orgamrabon that normally reviews safety issues (Plant Onsite Review Committee. or its equivalent).
g.
The request must speerncelly address which of the criteria specined in Secta B is satisfied and how.
- 10. If a follow-up license amendment is required, the request must inclutte marked-up TS pages showing the proposed TS danges. end a commitment to submit the actual license
' amendment request within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />;
- 11. For NOEDs involving severe weather or other naturel events, the licensee must provide:
a.
details of the basis and nature of the emergswy; potential consequences of forced compliance with the Econse cond6tions to the plant and to exacerbabon of the emergency situation.
The Wmsee must provide the name, organizabon and telephone number of the official that made the emergency assessment b.
status, and potential challenges to offsite and onsite power sources, and the impact of the emergency on plant safety, c.
demonstrated actions taken to avert and/or alleviste tne emergency situabon, includhg steps taken to avoid being in the nonceryllence, as well as efforts to mwwmze gria instabitrhes (e.g., coortlinebng with other utilities and the load dispatcher organizabon for buying addmonal power or for cychng load, shedding interruptible industnal or non-emergency loads).
9900. N0ED, Attachment D D-4 Issue Date: 06/29/99
r" s
O AL 95-05, Rev. 2 July 27,1999 Page 1 of 1 LIST OF RECENTLY ISSUED NRC ADMINISTRATIVE LETTERS 4
Administrative Date of Letter No.
Subject issuance issued to 95-03, Rev. 2 Availability of the Reactor Vessel 7/26/99 All holders of operating licenses Integrity Database, Version 2 for nuclear power reactors 99-02 Operating Reactor Licensing 6/3/99 All power reactor licensees 1
~
Action Estimates 99-01 Reorganization of the Office 4/9/99 All holders of operating licenses of Nuclear Reactor Regulation or construction permits for reactor facilities 95-05, Rev.1 Revisions to Staff Guidance for 2/19/99 All holders of operating licenses Implementing NRC Policy on for nuclear reactors Enforcement Discretion 98-10 Dispositioning of Technical 12/29/98 All holders of operating licenses Specifications That Are Insufficient To Assure Plant Safety 98-09 Priority for NRR Review of 10/30/98 All holders of operating licenses Risk-Informed Licensing Actions for nuclear power reactors 98-08 Availability of Revised NRC 10/09/98 All NRC licensees Form 3, ' Notice to Employees" and Closure of NRC Walnut Creek Field Office 98-07 Interirr Suspension of the 10/02/98 All holders of operating licenses Systematic Assessment of for nuclear power reactors Licensee Performance (SALP)
Program OL = Operating License l
CP = Construction Permit