ML052020424

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Y020050052 - NRC Regulatory Issue Summary 2005-020: Revision to Guidance Formerly Contained in NRC Generic Letter 91-18, Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded
ML052020424
Person / Time
Issue date: 09/26/2005
From: Hiland P L
NRC/NRR/DIPM/IROB
To:
Schulten C. S., NRR/IROB/TSS, 415-1192
Shared Package
ML052020360 List:
References
GL-91-018, TAC MC6479, Y020050052 RIS-05-020
Download: ML052020424 (4)


See also: RIS 2005-20

Text

UNITED STATESNUCLEAR REGULATORY COMMISSIONOFFICE OF NUCLEAR REACTOR REGULATIONWASHINGTON, DC 20555-0001September 26, 2005NRC REGULATORY ISSUE SUMMARY 2005-20

REVISION TO GUIDANCE FORMERLY CONTAINED IN NRC

GENERIC LETTER 91-18, "INFORMATION TO LICENSEESREGARDING TWO NRC INSPECTION MANUAL SECTIONS ONRESOLUTION OF DEGRADED AND NONCONFORMINGCONDITIONS AND ON OPERABILITY

"ADDRESSEESAll holders of operating licenses for nuclear power reactors, including those who havepermanently ceased operations and have certified that fuel has been permanently removed

from the reactor vessel.INTENTThe U.S. Nuclear Regulatory Commission (NRC) is issuing this Regulatory Issue Summary(RIS) to inform licensees that it has revised the guidance contained in two sections of NRC

Inspection Manual Part 9900, Technical Guidance, "Operable/Operability: Ensuring the

Functional Capability of a System or Component" and "Resolution of Degraded and

Nonconforming Conditions," and has combined these two documents into a single document.

The revised inspection guidance reflects relevant changes that have been made to NRC

regulations, policies, and practices, and clarifies selected issues based on operating

experience. This RIS requires no action or written response on the part of an addressee.BACKGROUND INFORMATIONThe NRC staff inspection guidance contained in the two NRC Inspection Manual sectionsdescribed above were initially provided to licensees in Generic Letter (GL) 91-18, issued on

November 7, 1991. The NRC staff revised the guidance in NRC Inspection Manual Part 9900,

Technical Guidance, "Resolution of Degraded and Nonconforming Conditions," and issued it inRevision 1 of GL 91-18 on October 8, 1997. The purpose of Revision 1 of GL 91-18 was to

more explicitly discuss the role of the 10 CFR 50.59 evaluation process in the resolution of

degraded and nonconforming conditions. In the summer of 2003, the NRC staff sought public comment on the technical guidance, whichincluded holding a public workshop in August 2003. The staff revised the guidance based on

the inputs received, and held a second public workshop to discuss it in August 2004.

Subsequently, the NRC staff met several times in 2005 with an industry task force formed by

the Nuclear Energy Institute (NEI), and resolved the comments received from various

stakeholders.ML052020424

RIS 2005-20Page 2 of 3SUMMARY OF ISSUEAttached is a revised NRC Inspection Manual, Part 9900, Technical Guidance, "OperabilityDeterminations & Functionality Assessments for Resolution of Degraded or Nonconforming

Conditions Adverse to Quality or Safety." This guidance supercedes the guidance previously

provided in GL 91-18 and Revision 1 to GL 91-18. The attached inspection manual section provides guidance to NRC inspectors for reviewing theactions of licensees pertaining to the operability of structures, systems, and components

(SSCs) following the discovery of degraded and nonconforming conditions in SSCs. However,

many licensees have found NRC's guidance to be very useful in developing their plant-specific

processes, and therefore the NRC staff is communicating it to licensees as a RIS. The NRC revised its inspection guidance to reflect ongoing regulatory changes, includingimplementation of the revised reactor oversight process, the requirement that licensees

appropriately assess and manage risk related to proposed maintenance activities (10 CFR 50.65(a)(4)), and implementation of the revised change control process in 10 CFR 50.59,

"Changes, Tests and Experiments." The revision also clarifies selected issues in the guidance

based on operating experience and industry feedback. In addition, the NRC concluded that the two inspection manual documents were closely related. The NRC staff therefore combined the documents, and at the same time re-wrote them to make

them clearer and more process-oriented. However, the NRC understands that licensees may

collectively refer to the processes described in the revised Part 9900 as the "GL 91-18 process"

or the "operability determination process (ODP)."BACKFIT DISCUSSIONThis RIS requires no action or written response and, therefore, is not a backfit under 10 CFR50.109. Consequently, the staff did not perform a backfit analysis.FEDERAL REGISTER NOTIFICATIONA notice of opportunity for public comment was published in the Federal Register on August 3,2004 (69 FR 46599), to give interested parties an opportunity to suggest ways for improving the

guidance. The staff concludes that this RIS and the attached NRC inspection guidance are

informational and pertain to a staff position that does not represent a departure from current

regulatory requirements and practices.SMALL BUSINESS REGULATORY ENFORCEMENT FAIRNESS ACT OF 1996This RIS is not a "rule" as defined in 5 U.S.C. 804 and therefore is not subject to theCongressional review provisions of the Small Business Regulatory Enforcement Fairness

Action of 1996.

RIS 2005-20Page 3 of 3PAPERWORK REDUCTION ACT STATEMENTThis RIS does not contain any information collections and, therefore, is not subject to therequirements of the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). The

information collection requirements referenced in Manual Chapter 9900 are approved by the

Office of Management and Budget approval number 3150-0011 which expire February 28,

2007. The NRC may not conduct or sponsor, and a person is not required to respond to, an

information collection unless the requesting document displays a currently valid OMB control

number.CONTACTPlease direct any questions about this matter to the technical contacts listed below, or to theappropriate Office of Nuclear Reactor Regulation (NRR) project manager./RA/Patrick L. Hiland, Chief

Reactor Operations Branch

Division of Inspection Program Management

Office of Nuclear Reactor RegulationTechnical Contacts: Carl S. Schulten, NRRJames M. Trapp, (R-I) 301-415-1192 610-337-5186

E-mail: css1@nrc.govE-mail: jmt1@nrc.gov Randall A. Musser, (R-II)Stephen C. Burton, III, (R-III) 919-362-0601920-388-3156

E-mail: rxm1@nrc.govE-mail: sxb3@nrc.gov Charles R. Stancil, Jr., (R-IV) 817-276-6532

E-mail: crs1@nrc.govAttachment:NRC Inspection Manual Part 9900: Technical Guidance, "OperabilityDeterminations & Functionality Assessments for Resolution of Degraded or

Nonconforming Conditions Adverse To Quality or Safety"Note: NRC generic communications may be found on the NRC public website,http://www.nrc.gov, under Electronic Reading Room/Document Collections.

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