NRC Generic Letter 92-03, Compilation of the Current Licensing Basis: Request for Voluntary Participation in Pilot Program

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March 19, 1992

TO: ALL NUCLEAR POWER PLANT APPLICANTS AND LICENSEES

SUBJECT: COMPILATION OF THE CURRENT LICENSING BASIS: REQUEST FOR VOLUNTARY PARTICIPATION IN PILOT PROGRAM (GENERIC LETTER 92-03)

The U.S. Nuclear Regulatory Commission (NRC) is issuing this letter to solicit the industry's participation in a voluntary pilot program to assess the advantages and disadvantages of compiling the current licensing basis (CLB). We request that only interested applicants and licensees respond to this letter. In issuing this letter, the NRC is imposing no new requirements or staff positions.

BACKGROUND

The concept of the CLB was first introduced in the regulations, 10 CFR 50.54(f), as a result of considerations in the development of the NRC's backfit rule. The CLB again became an issue in the Commission's deliberations on extending the licenses for plants beyond the original contemplated design life. In 1991, the Commission adopted the plant life extension rule, 10 CFR Part 54, which became effective on January 13, 1992. A definition of CLB was set forth in Section 54.3. Although set out in Part 54, that definition represents the staff's understanding of the scope of the CLB and should be applicable to all reactor licensees.

To further understand the advantages and disadvantages of compiling the CLB, the Commission has directed the NRC staff to solicit the industry's participation in a pilot program in which a small number of representative licensees would voluntarily compile their CLB and advise the NRC on the effort. As part of the pilot program, the staff would assess the usefulness of the compilation with respect to the NRC's regulatory activities.

The proposed effort also relates to the industry's effort to implement design basis reconstitution. Although these programs should include reconstituting that portion of the CLB relating to the design, they do not address a significant portion of the CLB, including programmatic areas such as quality assurance, training, and maintenance.

Although compiling the CLB may require a significant amount of resources, the staff expects that the licensee will thereby reduce the resources it will need to devote in the future to

(1) conducting document searches needed to support regulatory oversight,

(2) filing license amendment requests,

(3) making changes pursuant to Section 50.59, and

(4) evaluating backfits pursuant to Section 50.109.

__________________________________

1. A representative sample might include

(1) a facility that was licensed in the early 1970s,

(2) several facilities that were licensed between 1975 and 1985, and

(3) a facility licensed within the last 5 years.GL 92-03March 19, 1992

Pilot Program Participation

Participation in the pilot program is voluntary. Licensees wishing to participate should respond within 60 days of the date of this letter. Although the licensees volunteering need not provide details and schedules at this time, the staff desires to complete the pilot program compilation within a reasonable time. The licensee may choose to compile the CLB as a single set of documents in one location or by a system which provides a reference to documents that can be retrieved easily from several locations. Volunteers should select an approach, scope, and format that will be most useful to them. If the staff finds sufficient interest among licensees on these or other matters, it will conduct a workshop with those considering participating.

The staff anticipates that licensees will use the CLB during their participation in the pilot program. During this time, the NRC staff will conduct audits with the participants to determine the usefulness of the compiled CLB. The fees for this audit will not be collected from participants under 10 CFR Part 170, but will be included in the general base fee under 10 CFR Part 171. In addition, where the licensee identifies a non-willful failure to meet a licensing commitment which could subject the licensee to enforcement action, it is our intent to exercise enforcement discretion, provided the licensee has taken prompt corrective action consistent with the provisions in the enforcement policy for non-cited violations. More significant violations will be handled on a case-by-case basis.

If there are any questions on this matter or you have an interest in attending or participating in a workshop, please contact the Technical Contact or your NRR licensing project manager. Licensees who wish to participate in the pilot program should address their responses to the attention of the NRC Document Control Desk.

This request is covered by Office of Management and Budget Clearance Number 3150-0011, which expires May 31, 1994. The estimated average number of burden hours is 10 person hours for each licensee's response, including those needed to assess the request and to respond to the generic letter. This estimate of the average number of burden hours pertains only to the identified response-related matters and does not include the time needed to develop the CLB. Comments on the accuracy of this estimate and suggestions to reduce the burden may be directed to Ronald Minsk, Office of Information and Regulatory Affairs (3150-0011), NEOB-3019, Office of Management and Budget, Washington, DC 20503, and to the U.S. Nuclear Regulatory Commission, Information and Records Management Branch (MNBB-7714), Division of Information Support Services, Office of Information and Resources Management, Washington, DC 20555.

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GL 92-03March 19, 1992

Since the generic letter does not contain any new or revised regulatory requirements, the Backfit Rule, 10 CFR 50.109, does not apply.

Sincerely,

James G. Partlow, Associate Director for Projects Office of Nuclear Reactor Regulation

Technical Contact:

D. Wigginton, NRR (301) 504-1301

Enclosure:

List of Recently Issued Generic Letters