ML20217J141
| ML20217J141 | |
| Person / Time | |
|---|---|
| Issue date: | 07/01/1997 |
| From: | Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM) |
| To: | Larkins J Advisory Committee on Reactor Safeguards |
| Shared Package | |
| ML20217J128 | List: |
| References | |
| ACRS-3066, COMSECY-96-028, COMSECY-96-28, DSI-19, FACA, NUDOCS 9708140025 | |
| Download: ML20217J141 (17) | |
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UNITED STATES i
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NUCLEAR REGULATORY COMMISSION 3
WASHIN010N, D.C. SIEIS July 1, 1997 CHAmMAN MEMORANDUM TO:
John T. Larkins Executive Director, ACRS/AON FROM:
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SUBJECT:
RESPONSE TO STAFF REQUIREMENTS - COMSECY 028 - STRATEGIC ASSESSMENT ISSUE PAPER:
INDEPENDENT OVERSIGHT (DSI 19)
In the Staff Requirements Memorandum (SRM) dated August 21, 1996, the Comission directed the ACRS/AQM to undertake the following tasks:
t 1) conduct a comprehensive review of the ACRS and ACM charters to assess whether external and internal factors would necessitate a changes 2) establish critatia for Commission consideration under which the performance of the comittees would be evaluated in the future; and 3) examine the pros and cons of having AQM become a stand-alone ACRS subcommittee in the future.
The Executive Director of ACRS/AO N responded in a letter to the Commission on December 23, 1996.
The response contained the following three recomendations:
1)
Based on a review by ACRS/AQM members and staff, ACRS/AON recomands no changes to either charter at the present time.
2)
The ACRS/ACNW members and staff believe that the perfomance criteria (provide independent advice, identify significant technical and policy issues, issue letters and reports, express opinions on the activities and facilities of other Federal agencies, States, Indian Nations, and other groups, provide an effective open forum for valuable debate) provided to the Comission in an August 15, 1994 memorandum, meet the comission's request and should be approved.
After receiving-Commission approval, ACRS/AQM anticipates using these criteria periodically to evaluate the performance of the ACRS and ACNW.
3)
The ACRS/AQN members and staff recomend that the AQM remain-a separate advisory committee for the next 2-3 years or until the current uncertainties with regard to waste issues and the intentions of Congress regarding DOE are resolved.
9708140025 970711 PDR ACRS 3066 ppg
The Comission concurs in the ACRS/ACNW recomendations with respect to retaining the current charters of both advisory committees and the proposal to continue to maintain the ACNW as a separate entity for the next 2-3 years or until the current i
uncertainties about waste issues and the intentions of Congress with respect to the Department of Energy are resolved.
- However, the Commission believes that ACRS/ACNW performance evaluations should be conducted annually, that the evaluation process should include appropriate mechanisms to inco gorate program office inputs, and that the t rformance criteria should include performance measures at criteria that are consistent with those proposed for the Commit 6ee to Review Generic Requirements, as stated in the April 18, 1997 SRM on SECY 97-052.
The Committees are directed to propose additional performance measures and criteria that would permit the Commission to relate the benefits received from Committee activities to total resources expended relative to committee operations and
, activities.
( ACRS/ACNW)'
SECY Suspense 7/14/97) cci commissioner Rogers Commissioner Dicus Commissioner Diaz Commissioner McGaffigan EDO OGC SECY
ACRS PERFORMANCE - 1/1-6/30 1997 I.
INDEPENDENT ADVICE The ACRS provided independent written advice to the Commisalon and the NRC ataff in the following areas from February - June 1997 (there wes no meeting in January 1997) :
REPORTS e
Human Performance Procram Plan e
Huclear Safety Research and Reaulatory Reform o
Proposed Standard Review Plan Sections and Regulatory guides for Risk-Informed. Performance-Based Reaulation Recommendations for ADoointment of ACRS Members e
ProDosed Reculatory Guidance Related to Imolementation of 10 CFR 50.59 (Chances. Tenis and Excerimentsl e
Risk-Based Regulatory Accentance Criteria for Plant-Soecific Application of Safety Goals e
Establishina a Benchmark on Risk durina Low-Power and Shutdown _Qperations e
Desian Basis Verification e
The Poliev Renardina Stocknilina of Potassium Iodide e
Ergoosed Staff Position Recardina Inclusion of a Containment Sorav System in the AP600 Desian e
Proposed Reaulatory Accroach Associated with Steam Generator Intearity LETTERS e
Publication of Procosed Journal Article Containina ROSA lest Data e
NRC Office of Nuclear Reculatorv Research Procram to Demonstrate the Adecuacy of the RELAP5/MQD3 Code to Analyze AP600 Passive Plant Behavior o
Procosed Final Poliev Statement on the Restruttating and Economic Dereaulation of the Electric Utility Ill@21.rY e
Procosed Final Generic Letter. " Assurance of Sufficient Net Positive Suction Head for Emeraency Core Coolina 3
and Containment Heat Removal Pumos" e
Procosed Generic Letter, " Potential for Dearadation of the Emeraency Core Coolina System and the Containment Sorav System After a Loss-of-Coolant Accident Becauce of Construction and Protective Coatina Deficiencies and Foreian Material in the Containment" In addition, the Executive Director, ACRS, sent 19 memoranda to the Executive Director for Operations regarding the review status of other issues.
II.
SIGNIFICANT TECHNICAL AND POLICY ISSUES Some technical and policy issues are raised initially by the ACRS.
Other reviews are carried out at the request of the staff or the Commission.
During the period from February -
June, 1997, the subjects reviewed by the ACRS included:
1.
Advice provided on issues raised independently by ACRS e
Shutdown Risk e
Plant-Specific Safety Goals e
Report to Congress 2.
Issues where ACRS recommendations were adopted by the staff e
Developing Risk-Informed, Performance-Based Regulations e
Developing Human Performance Program Plan e
Revised Steam Generator Tube Integrity Regulatory Approach e
AP600 ROSA Test Data e
AP600 Containment Spray System o
Regulatory Guide for Digital I&C System 3.
Issues where ACRS recommendatiot.s were not adopted by the staff e
Shutdown Risk e
Arthur Andersen Report Responses have not yet been received from the staff concerning some of the advice provided by the ACRS during this period.
III. SQUNR, CONCISE, SELF-CONTAINED REPORTS AND LETTERS This is a subjective judgment.
Of the list in Item I above, the ACRS believes a majority of these have met this criterion.
Upon review, the ACRS identified the following reports or letters as needing further improvement:
1
Digital I&C System IV.
L'XPRESS OPINIONS ON ACTIVITIES AND FACILIT_iES OF OTHER FEDERAL AGENCIES When requested to do so, the ACRS reviews activities of other Federal agencies.
The ACRS was not asked to review the activities of other Federal agencies during chis period.
V.
PROVIDE FORUM FOR PUBLIC PARTICIPATION The ACRS full Committee meetings are attended by representatives of a variety of Federal agencies and other nongovernmental organizations, as well as the general public.
Most ACRS Subcommittee meetings are also open to the public but are attended mostly by NRC staff and industry representatives.
Representatives of 47 organizations attended ACRS full Committee meetings from February to June 1997.
VI.
TIMELINESS OF ACRS ADVICE ACRS agendas are largely based on requests from the NRC Commission and staff, but also include issues raised independently by ACRS members.
Commission requests are communicated by Staff Requirements Memoranda.
NRC staff issues are listed in a Memorandum prepared each month by the EDO's office.
The timing of a review is determined by the NRC staff availability to make presentations and provide documentation to the Committee.
All requests for ACRS review have been met within 60 days (meetings occur monthly, but there is no meeting in January or August) after they appear in an SRM or an EDO list.
VII. USE OF MEETING TIME The Advisory Committee on Reactor Safeguards tracks the time spent in full Committee meetings in the following categories:
1.
Review Items:
Meeting time for agenda items that result in a report to the Commission or a letter to the Executive Director for Operations (EDO) 2.
Report Preparation:
Time spent reaching a Committee consensus and preparing the report to the Commission or letter to the EDO 3.
Information itvas:
Meeting time for agenda items that inform the Committee of significant events; periodic meetings with Office Directors, EDO, and Commissioners (no report or letter is prepared) 4.
Overhead Meeting time spent on organizational
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matters, strategic planning and other Committee issues During the period from February-June 1997, meeting time was spent as follows:
Review Items:
26%
Information Items:
11%
Reports / Letters:
46%
Commission Briefings:
5%
overhead:
12%
i VIII. COST / BENEFIT ANALYSIS This is a very subjective area.
It is quite difficult to estimate accurately the dollar value of advice provided to the cortission, (for example, of accidents averted because the advice was followed), of costs incurred when the advice was not accepted, or of costs incurred when the advice proved not to be correct.
One can, however, calculate the usefulness of time spent by the committee.
Approximately 53% of the reports and letters prepared in the February-June 1997 time period have resulted in clear evidence that the advice provided added value to the decision-making process (Commission decisions or letters of response from the EDO indicating such value.)
An additional 29% of the reports and letters provided a third-party review of staff actions and resulted in an indication of support for the staff position.
About 18% of the reports and letters provided advice that was not accepted by the Commission or the staff, although there is some value to having a thorough public review of an issue.
Furthermore, the advice may have been correct, whether or not it was accepted.
Conversely, some advice may have been accepted that will ultimately prove not to have been correct.
To relate the benefits received to total resources expended, a calculation could be made of the worth of Committee advice, although the result is subjective.
For example, an ACRS member noted the possibility of a Three-Mile Island-type accident well before that accident occurred.
The ACRS recommended the use of the safety goals and formulated them.
The ACRS also recommended that NRC emergency preparedness regulations not give State and local governments the ability to prevent the start-up of a reactor.
Failure to heed this advice cost the NRC many millions of dollars in legal disputes, not to mention the billions it cost the industry.
An assessment of the value of expert advice on risk-informed regulation alone might justify a considerable portion of the ACRS/ACNW budget as the agency moves toward risk-informed, performance-based regulation.
Place Insert Here 8
,t Although economics can be, and have been, achieved by reducing the number of meetings, the amount of travel, and the use of consultants, a dollar value cannot be placed on Committee advice any more than it can be placed on NRC regulation generally.
The benefit of the ACRS is its breadth and depth of expertise, its value as an independent source of advice to the staff and Commission, and its function as a forum for public participation in the review of safety issues.
a l
s-o' July 3, 1997 1
PROPOSED ACRS PERFORMANCE IN0!CATORS l
FOR JANUARY THROUGH JUNE 1997 OUANTITATIVE INDICATORS Comittee Time Spent on Review Items 26%
Comittee Time Spent on Information items -
lit Committee Time Spent on Letter / Report -
46%
l Average Time Spent per letter / Report -
47,7/18 - 2.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> / letter Number of Days of Subcomittee Meetings -
15 days (check Sumary Reports)
OUALITATIVE INDICATORS Items done on its own initiative Shutdown Risk Plant Specific Safety Goals Report to Congress i
ACRS recomendations adopted by the staff:
Developing Risk Informed Performance Based Regulations Developing Human Performance Program Plan Revised Steam Generator Tube Integrity Regulatory Approach Release of AP600 ROSA Test Data
-AP600 Containment spray System Regulatory Guide for Digital 1+C System Shutdown Risk ACRS recommendations not adopted by the staff:
10 CFR S0.59 Arthur Anderson Report l
5 4
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COST INDICATORS-l t
Assumptions:
Products of the ACRS are recommendations contained in ACRS reports and letters.
ACRS adds value to the regulatory process by developing recommendations that result in modifications of staff, practices or policies, Using hours spent on activities during full comittee i
meetings is an imprecise method of estimating resource expenditures, but may provide insights into resource utilization.
Evaluation of ACRS Effectiveness Based on Activity Hours During Full Committee I
Meetings:
Time D ent of overhead items / issues:
23%
Time spent developing recomendations:
774 i
Percentage of re> ort / letter preparation time (47.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />) resulting in substantial c1anges to staff programs or Ccmission decisions:
53%
Percentage of report / letter preparation time resulting in recommendations not adopted by the staff or Commission:
18%
Percentage of report / letter preparation time resulting in confirmation of staff work:
29%
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1997 ACRS MEETINGS - 1ST HALF 7/1/97 Activity SumOfHours 438 439 440 441 442 Commissioners gg 4.7 4.7j Futuro Activities yz 4.5 0.7 0.8 0.5j 1.7l 0.8 Information item j ; y, 11.1 1.8, 2.4j 1.4j 2.6, 2.9 Opening Remarks l f 5, 1.4, 0.2 0.3 0.3 0.2 0.4 P+P Report i y 7, 4.6 1l 0.7 1.3, 0.6 1
Reconcillation
- y,
- 1. 3, 0.4 0
0.2 0.2 0.5 Report / Letter
- y r, 47.7.
10.2 10.1; 7.9 6.5 13 ReviewI;am 2gg 2G.4 3.3 8.5 3.1 3.4 8.1 Strategic Planning 2%
1.9 07 1.5 1
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4 ACRS 1996 Report (Summary) 01.Jul.97 Activity Project Deecription Hours Commissioners Meeting 3
Preparation 1.7 Commissioners
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4.54 : L Future Activities 4.5 Future Activities 4.5 4.34 %
information item AEOD Spent Fuel Pool Study 0.9 Boraf'ex Degradation 0.7 DOE Proposal for Tritium Production 1.2 Independent Assessmanet of Main YarAsa 1.2 Maintenance Rule implementation I
PRA implementation Plan 2
Regulatory Effectiveness 1.3 Report on Commission meeting regarding the watch list 0.2 Research 0.4 Severe Accident Rulemaking 0.9 Subcommittee Report on l&C Subcommittee Meeting 0.4 Subcommittee Report on T-H Sucommittee Meeting o.9 laformation item 11.1 10.71 %
Opening Remarks 1.4 Opealag Remarks 1.4 1.35 %
P+P Report 4.6 7 FP Report 4.6 4.44 %
i d
,A s Acevity Project Description Hours Reconciliation 1J Reconcillation IJ 1.25 %
Report / Letter 10 CFR 50.5g 2.s Annual Report to Congress I
AP600 Containment Spray System 3.5 AP600 ROSA Test Data 1.8 Authur Anderson Report on Senior Management Meeting 2.1 Capability of Code to Assess AP600 2.6 Design Basis Verification 2
GL Concoming Degredation of ECCS After a LOCA 1.2 GL Conooming NPSH for ECCS Pumps 1.3 Human Performance Program Plan 4
NAS/NRC Phase 2 Study Report on Digital l&C 1.1 Regulatory Approach for SG Tube Integrity 2.s Regulatory Guidance for Digital l&C Systems 4.5 Risk informed, Performance Based Regulation 2.5 Shutdown Operations Risk 4.2 Site-Specific Application of Safety Goals 6.4 Use of Kl 2.s Utility Restructuring and Deregulation 2
Report /14tter 47.7 46.04 %
Review item 10 CFR 50.5g 1.1 AP600 Containment Spray System 2.2 AP600 ROSA Test Data 1.2 Arthur Anderson Report on Senbr Management Meetings 1.5 Capability of Code to Assess AP600 1.s Design Basis Verification 1.7 GL Concoming Degredation of ECCS After a LOCA o.:
GL Concoming NPSH for ECCS Pumps o.s 2
3
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Activity Project Description Houn NAS/NRC Phase 2 Study Report on Digital I&C 2.s Reactor Water Cleanup System Line Break 0.4 Regulatory Approach for SG Tube Integrity 1.7 4
Regulatory Guidance fc. Digital l&C Systems 1.s RG 1.164 Time Operator Actiens 0.8 Risk informed, Performece Based Regulation 2
Risk Informed, Performance-Based Regulations 1.2 RWCS Break Outside Containment 0.s Shutdown Operations Risk 1J Steam Generator Integrity 1
Use of Kl 0.6 Utility Restructuring and Deregulation 0.9 Review Item 26.4 25.4s %
Strategic Planning 0.4 Development of Site Specific Safety Goals 0.8 Setting Research Priorities 0.7
+
Strateglc Pisaning 1.9
!.s3%
Greed Total:
103.6 3
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UNITED STATES '
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NUCLEAR REGULATORY COMMISSION
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WASHINGTON, D.C. sees cMAmMAN Ul/2 1997 9
MEMORANDUM TO:
L. Joseph Callan Executive Directer for Operations FROM:
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SUBJECT:
THE STATEMENT OF CORE DAMAGE FREQUENCY OF 10**
AS A FUNDAMENTAL COMMISSION GOAL In a Staff Requirements Memorandum, dated June 15, 1990, the Commission stated that, " Implementation of the safety goal may require development and use of ' partitioned' objectives."
The Commission further stated that, "A core damage probability of less than 1 in 10,000 per year of reactor operation appears to be a ve:ey useful subsidiary benchmark in making judgements about that portion of our regulations.which are directed toward accident prevention."
In a letter, dated August 15, 1996.. the ACRS stated:
We believe the safety goals and subsidiary objectives should be used to derive guidelines for plant-specific applications.
It is, however, impractical to rely exclusively on the Quantitative Health Objectives (QHos) a for routine use on an individual plant basis.
Criteria based on core damage frequency (CDF) and large, early release frequency (LERF) focus more sharply on safety issues and can provide assurance that the QHos are met.
They should be used in developing detailed guidelines.
In the same ACRS letter, the committee also stated,
...the current subsidiary goal of 10" per reactor-year should be maintained and should be stated as a fundamental safety goal, along with the QHO."
There appears to be both pros and cons for using CDF as a fundamental Commission goal.
The pros include: (1) the CDF of lo** is by de 'f acto already used as a fundamental Commission goal; (2) tha derivation of a CDF from the QHOs may yield unacceptably large CDFs; and (3) a core damage frequency goal would constitute a fundamental expression of our defense-in-depth philosophy.
L. Joseph Callan The cons includes (1) several operating plants do not meet the CDF of 10** as measured by their IPEs, and (2) the CDP goal is difficult to justify on a societal basis (i.e., the QHos follow directly from societal considerations).
I request that you send a policy paper to the commission with your views on the merits of the ACRS recommendation to elevate the subsidiary CDF objective to a fundamental safety goal.
The paper should clearly articulate the rationale and the pros and cons for your recommendation and should also propose a mechanism for stating CDF as a fundamental safety goal.
cc Commissioner Dieus Commissioner Dia:
Commissioner McGaffigan SECY OGC CIO i
.,a DRAFT FY 1999 INTERNAL PROGRAM / BUDGET REVIEW APPENDIX B SCENARIO PLANNING INTRODUCTION In developing the FY 1999-FY 2001 budget estimates, the Budget Review Group evaluated four scenarios for FY 1999. These are:
Scenario 1:
The FY 1999 budget proposal. This represents the Budget Review Group's and Executive Council's best estimate of the resources necessary to conduct agency programs and implement Commission guidance.
Scenario 2:
The lowest priority work to be performed to reduce the FY 1999 budget proposal to approximately the level of the FY 1998 President's budget ($481 million). This amounts to approximately $39 million. (This scenario also includes the identification of the lowest priority work to be performed to reduce the FY 1998 budget to approximately five percent below the FY 1998 President's Budget.)
Scenario 3:
The lowest priority work to be performed to further reduce the FY 1999 budget proposal to approximately five percent below the level of the FY 1998 President's Budget. This amounts to approximately an additional $24 million.
Scenario 4:
Altemate FY 1999 reductions that could be substituted as cuts to fund Implementation of DSI work identified in Scenario 2. The DSI work identified in Scenarir ' amounts to approximately $4.8 million. These attemate reductions are takenirom Scenario 3.
To develop the desired information, each office was requested to develop and submit its budget request including a list of prioritized reductions. That information was reviewed by the Budget i
Review Group which provided recommendations to the Executive Counci! for all four scenarios.
Based on those recommendations, the Executive Council decided on the recommendations contained in this appendix. Those recommendations are summarized in Table 1. Table 2 delineates the specific reductions by office and reduction level for Scenarios 2,3, and 4.
Scenarios 2,3, and 4 can be used by the Commission to make reductions to the FY 1993 budget proposal should the Commission determ:ne that reductions are desirable. Additionally, Scenario 2 can be used by the Commission to make reductions to the FY 1998 President's budget if the Congress does not appropriate the agency's full request for $481.3 million.
In reviewing Scenarios 2,3, and 4, the Commission should recognize that the scenarios are only one possible approach - and not necessarily the optimum approach - to achieve the I
specified levels of reductions. The scenarios are generally based on the assumption of no radical departures from established policy. Reductions as described in Scenario 3 should include consideration of structural changes to the agency.
G:991PBR\\RESOURC2.TBL B-1 June 27,1997 1
/6
FY 1999 INTERNAL BUDGET PROGRAM / BUDGET REVIEW
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Appendix B: Scenario Planning Table 1 (continued)
Scenario 2
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FY 1998 FY 1999 DRIVEN BY DSI Office ActMty 8
FTE FTE DECISION 30.ClO Cancel purchase of approximately 650 new PC workstations 1,300 N
- 31. CIO No expansion of web services beyond FY 1997 level 220 400 N
- 32. ClO Reduce IT quality control / assistance activities 5
290 5
N 33.ClO No improvements to selected IT operations 400 200 N
- 34. CFO Cancel development of integrated Financial Management System 2,500 2,250 1
N
- 35. CFO Suspend resident inspector 5 year relocation policy for 2 years 1,750 1,750 N
- 36. CFO Increase time to pay travel vouchers and l
commercialinvoices 310 N
- 37. OCA Less timely support 1
Y (14) 1
- 38. OGC Less proactive legal advice and less bmoly legal support 3
3 N
- 39. OPA Reduce from 2 to 1 public affairs officers in l
Region ll 1
1 N
- 40. SECY Eliminate Commission Decision Tracking System 30 1
N 41.SECY Postpone Electronic Hearing Docket 1 year 66 1
N
- 42. ACRSI Reduce Committees' advice to Commission Y (11,12,16, ACNW 10 percent 3
3 19,24)
- 43. ASL8P Postpone further automation of the hearing process 87 112 N
44.IG Do not contract financialaudits 450 N
l l
Subtotal 17,132 70 28,131 118 45.
Salaries and Benefits for FTE 6,300 NA 11,210 NA TOTAL 23,432 70 39,341 118 G.991PERGES,C'JRC2.TBL B-4 June 27,1997 /
46/18/87 10 31' PAX 8088310348 g o01 Dana A Powers Advisory Committee on Reactor Safeguards (505) 821-2735 voice 7964 Sartan Way, NE (505) 821-0245 fax Albuquerque, NM 87109-3128 FACSIMILE TRANSMITTAL Please deliver the following message of pages including the cover page to:
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NAME:
PLANNING AND PROCEDURES SUBCOMMITTEE
& SAM DURAISWAMY Fax #:
Voice #:
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SUBJECT:
LICENSE RENEWAL NEEDS SECY-97-118," Activities Associated with Implementatign of 10CFR54", delineates staff and industry activities in connectiohith i
license renewal. Quite a lot of activity is taking place among the various owners groups that are preparing a number of topical reports ao c have carried out demonstrations of the industry guidelines (NEI-95-10).
Staffis preparing SERs on the various topical reports. They are also preparing Reg. Guides. Current plans seem to call for draft Rek.
Guide to be available in July of 1997. There are also a variety of environmental impact statements in preparation.
All this leads me to believe that ACRS will have a FLOOD of work in connection with license renewal in the next 12 months, We should consider the formulatioh of a subcommittee that is devotyd to all of this and get the subcommittee to work becoming familiar wi-t all the background material ofwhich there is a lot. It is not at all evidert that the many ongoing activities are fully consistent with the curren; drive toward risk-informed, performance-based regulation, so the ACRS may T
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well have comments on the license renewal efforts. The Planning and Procedures Subcomminee may want to spend some time to consider how-much of all of the ongoing and future work should be examine and the detail to which it should be scrutinized. Questions in this regar might be the first task to assign the subcommittee on license renewal.
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