ML20217H428

Discusses Review of Nuclear Energy Inst Guidance Document, Guideline for Managing NRC Commitments, Rev 2,dtd 951219

ML20217H428
Person / Time
Site:	Kewaunee
Issue date:	01/24/1996
From:	Crutchfield D NRC (Affiliation Not Assigned)
To:	Colvin J NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT &
Shared Package
ML20217H407	List: ML20217H403 ML20217H428
References
NUDOCS 9804030327
Download: ML20217H428 (2)

Text

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""g UNITED STATES 1

NUCLEAR REGULATORY COMMISSION

'WAseneetfool, e.C. mess eme e....

' January 24,1996 Mr. Joe F. Cp1 vin,

Executive Vice President and r

Chief ratt Officer l

Nuclear nergy nstitute 1774 I Street, Suite 400 Washington,D.C. 20006-3708

SUBJECT:

NEl's ' GUIDELINE FOR NAMAGils WRC ColgtlTNENTS." REVISION 2, DECDBER Ig, Igg 5 The staff of the U.S. Nuclear Regulatory Commission (NRC) has completed its review of the subject NEI guidance document and its evaluation of the industry As you are aware, the pilot program implementing the NEI guidance document. licensees with a change issue of defining the term "cosmitment" and providin agulatory Review Group process,for commLtmer.ts was identified by the NRC's as an area in which the regulatory process could be made more flexible without adversely affecting public health or safety. On the basis of its review, the i

staff has determined, with the following two comments, that NCI's " Guideline for Managing NRC Commitments

• is an acceptable method for licensees to follow for managing and changing their NRC commitments. 'We believe that the NE!

guideline provides a og cal method for evaluating commitments for possible modification or elimination and can reduce unnecessary regulatory burden by providing the industry the necessary flexibility to manage commitments with only 11a'ted NRC involvement.

One provision of the NEI guideline specifies that changes to those commitments not satts ing any of the five decision criteria conta'ned in the guideline included in the licensee's periodic report to the Commission need not summarizing the changed commitments. Although these commitments have negligible regulatory significance, they are nonetheless a part of the plant's licensing basis. In view of license renewal considerations with regard to maintain' m3 adequate control of a plant's licensing basis I emphasize the need for tlw licenses to maintain the documentation for changes to these commitments for the life of the plant, as stated in the NEI guideline.

The NE! guideline references NSAC-125 as a method that licensees may use in implementing 10 CFR 50.5g.: Licensees should bear in sind that NSAC-It5 has not been endorsed by the NRC, and therefore that document is not a substitute for or modification of the requirements contained in 10 CFR 50.5g. Topic Area 54 of the Regulatory Review Group splementation Plan f,$ECY g4-003)lgate proposed that the staff endorse NSAC-12 or separately develop and promu staff guidance. The endorsement of NSAC-Ill has not been possible due to conflicts between that document and to CFR 50.5g. The staff is finalizing an I

action plan to address the taplementation of 10 CFR 50.5g and related issues such as the adequacy of regul tory guidance. It should be noted that any p

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• changes to the 10 CFR 50.59 process or additional guidance on its implementation that result from the staff's completion of the action olan may affect licensees' future use of that portion of the NE! guideline.

To aid in the implementation of NEI's " Guideline for Managing NRC Commitments,' the staff is holding training sessions for NRC inspectors, project managers, and other appropriate NRC personnel. The staff will monitor the licensees' implementation of the NEI guideline or their alternative commitment control processas through periodic inspections. On the basis of the results of these inspections, the staff will reassess the need to promulgate staff guidance or initiate rulemaking. After experience has been gained using the NE! guideline, the staff, with input from industry, will assess the need to conduct workshops on the commitment management process with licensees and the NRC headquarters and regional staffs participating.

We are pleased with NEI's leadership role in developing and promulgating the

' Guideline for Nanaging NRC commitments." The cooperative and professional manner in which NEI perso'inel and the NRC staff interacted resulted in a product that provides important guidance to licensees that will save both l

licensee and staff resources. If your staff needs further information, they say contact Gene Imbro at 301-415-2969.

I Sincerely, j

t t

s N.

t old rector Division of Reactor Program Nanagement j

Office of Nuclear Reactor Regulation cc: R. P. Zimmerman, NRR l

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