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MEMORANDUM FOR: John G. Davis, Director, NMSS W Harold R. Denton, Director, NRR James M. Taylor, Director, IE Thomas E. Murley, Regional Administrator, Region-1 J. Nelson Grace, Regional Administrator, Region-II James G. Keppler, Regional Administrator, Region-Ill Robert D. Martin, Regional Administrator, Region-IV John B. Martin, Regional Administrator, Region-V FROM: James H. Sniezek Acting Deputy Executive Director Regional Operations and Generic Requirements
SUBJECT:
REVISION OF OFFICE PROCEDURES FOR PLANT-SPECIFIC BACKFIT MANAGEMENT Pursuant to V. Ste11o's memorandum to you of February 27, 1986 concerning Manual Chapter 0514, I am enclosing for your use a list of generic modifications for incorporation in your office procedure for implementing MC-0514. The procedures which you developed last year, when modified to reflect the enclosed generic modifications, should be consistent with Manual Chapter 0514 dated February 1986.
Please modify your procedures and provide them to me for review to ensure consistency with MC-0514 by May 1, 1986, if there are any questions on the contents of the enclosure or on interpretations of MC-0514, riease call Tom Cox, X24357, or me.
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ames H. Sniezek cting Deputy Executive Director Regional Operations and Generic Requirements
Enclosure:
Generic Modifications to Office Procedures .
cc: R. Minogue l C. Heltemes P. Norry G. Cunningham l
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E4 78?!2 8722o4 p a g 3333 WEISS87-714 PDR V V
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ll GENERIC MODIFICATIONS TO OFFICE PROCEDURES
- 1. Use definitions as in Manual Chapter 0514-05, pp 19-22.
- 2. Use infomation elements 1 through 10 for regulatory analyses as in MC-0514-043, pp 12-14.
- 3. Clearly define the responsibilities for identifying backfits within the office or region management structure.
- 4. Clearly define the responsibility and authority for initiating a regulatory analysis.
- 5. Provide for a timely production of backfit analyses or resolution of appeals; normally:
- 3. 4 weeks maximum to provide a regulatory analysis for office director or regional administrator approval following either (1) staff identification of backfit, or (2) determination that a licensee claim of backfit is valid (MC-0514-042, pp. 9, 10, and 11).
- b. 3 weeks maximum to respond to licensee appeal at any level (MC-0514-044, p. 15).
- 6. Provide a method to ensure accountability for staff managers responsible for implementing MC-0514.
- 7. Clarify that only power reactor licensees are covered by the provisions of MC-0514 (MC-0514-01, p. 1).
- 8. When a proposed backfit and supporting regulatory analysis are approved by the Office Director or Regional Administrator (OD/RA), the documents (copy) must be fomarded to the EDO for infomation prior to transmitting the documents to the licensee. Clearly indicate that, "the Office Director (Regional Administrator) shall fomard the backfit and supporting regulatory analyses to the licensee without awaiting feedback from the EDO." The EDO will use the infomation as a means of monitoring the offices backfitting activities (MC-0514-043, p. 12).
- 9. State that the EDO may review and modify any plant-specific backfit decision, at EDO initiative or at the request of a licensee, in accordance with MC-0514-044.
- 10. State that NRC staff positions may be identified as potential backfits by NRC staff or may be claimed by other persons te be backfits (MC-0514-038).
Licensee claims should be written to OD/RA with copy to EDO. Note also that if staff position is detemined not to be a backfit, a documented evaluation will be completed and the OD/RA responsible then will deal with the issue in accordance with office procedures other than MC-0514.
- 11. Describe the WRC staff's responsibility in processing)infomation requests pursuant to 10 CFR 50.54(f) (MC-0514-041, pp. 8 and 9 .
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- 12. State that when licensee appeals an NRC decisian, a copy should be sent to -l I EDO by the office, if not sent directly to the EDO by the licensee l (MC-0514-044,p.15),
- 13. Conform office procedures to MC-0514-042 pp.10 and 11, discussion of )
staff proposed positions that are detemined not to be backfits or that j are backfits required to assure that a facility poses "no undue risk.* '
There are particular documented evaluat4ns required in those cases, but --
the evaluations are not regulatory analyses as in 50.109(c) or MC-0514-043.
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