ML20239A520
| ML20239A520 | |
| Person / Time | |
|---|---|
| Issue date: | 09/04/1987 |
| From: | Miraglia F, Starostecki R Office of Nuclear Reactor Regulation |
| To: | Boger B, Lainas G, Varga S Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20235J688 | List: |
| References | |
| FOIA-87-611 NUDOCS 8709170397 | |
| Download: ML20239A520 (8) | |
Text
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1 p %f cq UNITED STATES
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September 4,1987 l
MEMORANDUM FOR:
Distribution FROM:
Frank J. Miraglia l
Associate Director for Projects
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4 Richard W. Starostecki l
Associa:.c Director for Inspection l
and Technical Assessment l
PROJECT MANAGER REVIEW RESPONSIBILITY
SUBJECT:
1 ed The staff has been exploring ways to more efficiently use ou technical resources to focus on safety significant u
immediately, the Project Managers will be respons1 technical reviews of license amendment requests than have been done It should be noted that where this memorandum uses the term l
anager for a specific plant, the Project Directors are at liberty to ro et substitute a Project Engineer or another Project Manager if appropr a e.
Enclosed is a detailed procedure discussing the Project Manager and review Basically when an amendment is
[ w)t branch responsibilities under this program.
l received, the Project Manager will place it in one of three categories.
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Category 1 is where the technical submittal by the licensee is inadequate to l
Category 2 is for amendments where a proposed "no commence the review.
significant hazards considerations (NSHC)" finding can be made by the NRC and I
where the request does not require specialized detailed technical review.
i' Category 3 is for amendments which require a detailed technical review war-ranting participation by tM technical review branches.
Amendments placed in Category 3 will be noticed with an opportunity for a hearing with no comments concerning significant hazards considerations.
h Because of the nature of the issues raised in reload amendments, it is under-stood that assistance of technical review specialists may be needed even for fairly routine reload requests.
For reloads, categorization is to be based on the complexity of the issues involved rather than on the participation of tech-Similarly, there is no intent to affect the common nical review specialists.
practice of contacting the Region or technical branches concerning information Such requests relevant to emergency technical specification (TS) change requests.
should be categorized based on the complexity of the issues rather than on the basis of contact with the Region or technical branches.
CONTACT:
J. Thoma X28285
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Distrib'ution ' The Project Manager will discuss the review with the appropriate review Branch Chief or Section Leader before commencing the review or making a NSHC determination.
This serves two purposes.
First, it assures that the Project Manager is aware of the most current policy or review guidelines on a given j
topic.
Secondly, it allows review branch input to ensure consistency in reviews.
If the Project Manager prepares the safety evaluation, the appropriate review branch will be on concurrence on the final amendment package.
If a j
hearing is requested on an amendment, the technical review branches and the Project Manager will be responsible for supporting the Agency's actions.
Presently it takes six months or longer to issue an amendment.
Under this program, it is anticipated that a typical amendment involving NSHC will be j
issued in two months or less after receipt.
It is recognized that we may now issue a notice for hearing for an amendment which we previously have issued on other plants as a NSHC.
We may even be challenged by the licensees for j
this " apparent" change in position.
The focus of the program is aimed toward j
optimum use of agency resources, recognizing that if an amendment truly involves "no significant hazards considerations," then its respective technical review should not involve a significant amount of NRC review effort, other than the effort which is part of the responsibilities of the assigned PM.
This review process will be periodically audited to determine its effectiveness.
We will consider issuing the program as an NRR Office Letter af ter program experi-ence is obtained.
This program is effective for amendments received after the date of this memorandum. The Project Directors in conjunction with their Project Managers will review amendments in progress before the date of this memorandum to determine which ones would have been placed in Category 2.
The technical review braoches will be consulted on the status of the review; and on a case-by-case basis, it will be decided if the Project Manager is to be assigned the review.
Unless specifically notified otherwise, the technical review branches are to continue reviewing amendments in progress at the agreed upon schedule.
As stated above, the purpose of the program is to allow the technical review branches to focus their limited resources on safety significant issues.
We acknowledge that the program will increase the burden on the Project Manager, and that problems may arise in the initial program implementation.
It will require the support of all personnel to make this program effective.
Origa s u p m sy Frank J n rmplo d
Frank J. Miraglia Richard W. Starostecki Associate Director for Projects Associate Director for Inspection and Technical Assessment t ed DISTRIBUTION:
DRPR r/f Central Files-cc:
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NRC PDR J. Sniezek FMiraglia J. Scinto RStarostecki JThoma j
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' DISTRIBUTION Steven A. Varga, Director Division of Reactor Projects I/II~
Bruce A. Boger, Assistant Director.
for Region I Reactors' Gus C. Lainas, Assistant Director for Region II Reactors Dennis.M. Crutchfield, Director
- 4 Division of Reactor Projects.
III, IV, V and Special Projects Gary M. Holahan, Assistant Director-J l
for Region III and V Reactors Frank Schroeder, Jr., ~ Assistant Director for Region IV Reactors and Special Projects Charles E. Rossi, Director Division of Operational Events Assessment Lawrence Shao, Director Division of Engineering and Systems Technology James E. Richardson, Assistant Director (O
for Engineering i
Ashok C. Thadani, Assistant Director for Systems James G. Partlow, Director Division of Reactor Inspection and Safeguards i
Frank J. Congel, Director Division of Radiation Protection and
. Emergency Preparedness Jack W. Roe, Director i
Division of Licensee Performance and Quality Evaluation l
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ENCLOSURE AMENDMENT REVIEW PROCEDURE Within about 20 working days after a license amendment is received by a Project Manager (PM), the PM should determine that the amendment falls in one of three categories. The Project Manager (PM) should discuss each amendment request with the appropriate technical review Branch Chief or Section Leader. The J
discussion is to accomplish several goals.
First, it is to educate or update the PM on current review guidelines and policy in a given area. Second, it aids the review branches to ensure consistency of approach.
Third, it provides an independent assessment of the amendment as to the adequacy of the submittal and whether or not a detailed technical review is required. This consultation should take less than one man-day of effort.
As reviews are completed, the Project Directorate reading files will also become a valuable source of information on how similar amendments were treated.
I Based on the above discussions, the amendment will be placed in one of three I
categories. Each category is discussed in turn:
Category 1 The package is inadequate based on a general overall review. A letter will be sent to the licensee documenting reasons why the package is inadequate and stating the corrective action the licensee needs to take before resubmittal. The rejection letter is to describe general areas which are either omitted or inadequately addressed in the licensee's submitta).
It is not a detailed technical rejection or a disguised request for additional information, as both of these actions are more appropriate for Category 2 or 3.
This is not a rejection of the licensee's amendment request but is a rejection of the overall adequacy of the request.
For multiplant activities (MPAs) or plant-specific items which are an outgrowth of MPAs, the letter sent to the licensee should request a i
proposed resubmittal date.
If the TAC was opened to cover the entire MPA review, it should remain open until the issues are resolved.
If the MPA includes Tech Specs, the TAC should remain open until the Tech Specs are issued. If a plant-specific TAC (which is not the result of a previous MPA or NRC initiated action) was opened to cover this review and the licensee is not planning to respond in a timely manner fsix months or less) to the rejection letter, then this plant-specific TAC is to be c1csed by the PM.
. Category 2 The package, based on its face value alone, has adequate technical justification to conclude that no detailed specialist review is necessary I
and the amendment involves no significant hazards considerations.
The l
PM prepares the Sho11y notice, performs the safety review, and prepares the amendment package simultaneously.
Thirty days after the Sholly l
notice has been published the amendment should be issued.
This time frame, although not an exact requirement, should be a standard rule of l
thumb. The amendment package should have the concurrence of the appropriate technical review Branch Chief to ensure consistency in i
approach.
Amendments whf th can be classified as Category 2 must clearly satisfy the "no significant hazards considerations" requirements.
Specifically, they must (1) not involve a significant increase in the probability or consequences of an accident previously evaluated, (2) not create the possibility of a new or different kind of accident from any accident previously evaluated, and (3) not involve a significant reduction in a margin of safety.
Examples of amendments which would usually be classified as Category 2 include the examples of "no significant hazards considerations" found in the Sholly procedures.
Amendments involving these examples should require
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little detailed technical review effort.
For ease of reference, they are repeated as follows:
1.
A purely administrative change to technical specifications; for example, a change to achieve consistency throughout the technical specifications, correction of an error, or a change in nomenclature.
2.
A change that constitutes an additional limitation, restriction, or control not presently included in the technical specifications, e.g.,
a more stringent surveillance requirement, 3.
For a nuclear power reactor, a change resulting from a nuclear reactor core reloading, if no fuel assemblies significantly different from those found previously acceptable to the NRC for a previous core at the facility in question are involved.
This assumes that no significant changes are made to the acceptance criteria for the technical specifications, that the analytical methods used to demonstrate conformance with the technical specifications and regulations are not significantly changed, and that NRC has previously found such methods acceptable.
4.
A relief granted upon demonstration of acceptable operation from an operating restriction that was imposed because acceptable operation was not yet demonstrated.
This assumes that the operating restriction and the criteria to be applied to a request for relief have been established in a prior review and that it is justified in a satisfactory way that the criteria have been met.
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5.
Upon satisfactory completion' of construction in connection with an operating facility, a relief granted'from an operating restriction i
that was ' imposed because the' construction was not yet completed satisfactorily. This is intended to-involve only restrictions where it is justified that construction has been completed satisfactorily.
6.
A change which either may result _in some increase to the probability U
or consequences of a-previously analyzed accident or may reduce in some way a safety margin, but.where the results of the change are clearly._within all acceptable criteria with respect to the system or component specified in the Standard Review Plan, e.g., a change resulting from the application of a small refinement of a previously used calculational model-or design method.
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~ A change to conform a licerse to changes in the regulations, where the Ifeense change results in very minor changes to facility operations' clearly in keeping with the regulations.
8.
A change'to a license to reflect a minor adjustment in ownership shares anong co-owners already shown in the license'.
9.
A repair or replacement of a ma,ior component or system important to safety, if the following conditions are met:
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a.
The repair or replacement process-involves practices which have' been successfully implemented at least once on similar components or systems elsewhere in the nuclear industry or'in other industries and does not: involve.a significant increase in a
the probability or consequences of an accident previously_
j evaluated or create the possibility of'a new'or different kind of accident from any accident _ previously evaluated;_ and 1
b-The repaired or replacement component or system does not result in a significant change in its safety function or.a significant reduction in any safety limit (or limiting condition of operation) associated with the component or system.
10.
An expansion of the storage capacity of a spent fuel pool when all of the following are satisfied:
a.
The storage expansion method consists of either replacing existing racks with a design which allows closer spacing between stored spent fuel assemblies or placing additional racks of the original-design on the pool floor if space permits; b.
The storage expansion method.does not involve rod consolidation j
or double tiering; c.
The Keff of the pool is maintained less than or equal to 0.95; and d.
No new technology or unproven technology is utilized in either the construction process or the analytical techniques necessary.
- to justify the expansion.
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4 There may be proposed amendments which would possibly fit within the language of one of the examples, but which would in f act involve complex technical issues.
For example, there may be a review invol-
' ing a spent fuel pool reracking which clearly fits the examples above vbut the review is so complicated that the Project Manager cannot reason-ably be expected to conduct the review.
In such cases the review will be treated as a Category 3.
Although the same general principles apply to reload amendment requests, because of the specialized nature of the issues addressed, it is expected that PMs may well need the assistance of Reactor Systems' Branch in even a fairly routine reload application.
Therefore, categorization of reloads should be based on the complexity of the matters involved rather than on 1
whether the assistance of the technical review branch specialists is needed.
Similarly, in processing emergency TS changes it is common practice to ob-tain the views of the Region concerning the status of the plant and the cir-cumstances leading up the emergency request and the technical branches for adequacy of the proposal. There is no intent to affect such practice.
Cate-l gorization of emergency requests should be based on the complexity of the issues involved rather than on the basis of contact with the Region oc the technical branches.
Category 3 The amendment requires a detailed specialist review.
The PM, after consulting with the appropriate review Branch Chief, will notice the amendment with an opportunity for hearing.
Simultaneously, a work l
request will be generated sending the package to the technical review branches. Note for purposes of this procedure, the resources available in the Regions, with the exception of the resident inspectors, are to be i
l considered a technical review branch.
The PM and resident inspector are important technical resources but fall in a different category than specialized technical reviewers.
Work on the amendment request will then proceed in the normal fashion.
l The Project Manager and assigned reviewer will negotiate a mutually I
acceptable schedule for the review. All contact with the licensee will be via the Project Manager.. The safety evaluation will be formally transferred by the reviewer to the Project Manager via a memorandum signed by the appropriate Branch Chief or other authority if so determined by NRK Office Letter 101, Delegation of Signature Authority.
The Project Manager will prepare and issue the formal amendment or denial as appropriate.
If a hearing is requested and granted, the Project Manager will work with OGC to assure necessary staff support is provided.
Issuance of the amend-ment would await the outcome of the hearing process, or as otherwise advised by OGC.
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