ML20132C504
| ML20132C504 | |
| Person / Time | |
|---|---|
| Issue date: | 11/05/1984 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| Shared Package | |
| ML20132C508 | List: |
| References | |
| FOIA-85-507, REF-GTECI-A-03, REF-GTECI-A-04, REF-GTECI-A-05, REF-GTECI-SG, TASK-A-03, TASK-A-04, TASK-A-05, TASK-OR SECY-84-013B, NUDOCS 8411210357 | |
| Download: ML20132C504 (5) | |
Text
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p SECY-84-13B (NEGATIVE CONSENT)
FOR: The Commissioners FROM: William J. Dircks Executive Director for Operations
SUBJECT:
NRC INTEGRATED PROGRAM FOR THE RESOLUTION OF STEAM GENERATOR USI'S - RESPONSE TO COMMISSIONER COMMENTS (MEMO FROM CHILK TO DIRCKS DATED SEPTEMBER 13,1984)
PURPOSE: To respond to Comissioner requests made during the September 10, 1984 briefing by the staff.
BACKCROUND: On September 10, 1984, the staff briefed the Comission on the staff's proposed resolution of the steam generator related Unresolved Safety Issues A-3, A-4, and A-5 (SECY84-13A). The staff proposal included, in part, the issuance of generic letters to PWR licensees and applicants, pursuant to 10 CFR 50.54(f), requesting infonnation concerning their plans and status with respect to implementation of staff recomended actions.
The Comission requested that the staff investigate alternatives to 10 CFR 50.54 letters as a vehicle for obtaining this information. Specifically, the staff was requested to explore the feasibility of obtaining this information through the industry's Steam Generator Owners Group (SGOG). The Comission also requested that the staff prepare a revision to the draft generic letter in SECY 84-13A to address Comissioner coments.
DISCUSSION: SGOG Response As a result of the Comissioner coments, the staff met with representatives of the SG0G on September 20, 1984, to discuss what role the SGOG could play in collecting the needed information from the PWR utilities. The SGOG position on this matter has subsequently been documented by letter which is provided as Enclosure 1.
Contact:
G. M. Holahan, NRR x27415 __ _
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The Comissioners .
In summary, the SGOG believes it would be inappropriate for the SGOG to survey the industry and to report to the NRC on the status of how each licensee's program compares with the NRC recommended actions. The SGOG noted that utility participation in the SGOG is on a voluntary basis.
Not all PWR utilities belong to the SGOG, nor is the SGOG in a position to speak for the entire PWR industry. The SGOG also stated that some of the NRC recomended actions (e.g., Coolant Iodine Activity Limit), while apparently brought to light by the Ginna tube rupture incident, are not within the scope of issues nonnally addressed by the SGOG, Issuance of 10 CFR 50.54(f) Letters As indicated to the Comission on September 10, 1984, the staff believes that the industry, as a whole, has made significant progress in upgradin their steam generator programs. gThe theSGOG effectiveness has also of expressed this sentiment in their October 1,1984 letter (see Enclosure 1). However, while most plants appear to be confonning to this general trend, the staff does not have sufficient infonnation to conclude that all plants are implementing programs which are adequately effective.
The staff has concluded that infonnation from each PWR licensee and applicant concerning the status of how their programs compare with the NRC recomended actions, including any plans and schedules they have for implementing these actions, is needed as part of the technical resolution of the USIs. 10 CFR 50.54(f) is the regulatory authority normally invoked by the staff to ensure that all licensees provide complete and timely infonnation regarding specific
, safety issues. It has been the staff's experience that
} where10CFR50.54(f)isnotinvoked,someutilitieswill j not be responsive to staff requests for information.
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With regard to utilizing the SGOG to collect the needed
( infonnation, the staff notes that the SGOG would have no official sanction by which to require utilities to i provide the infonnation.
1 Revisions to Proposed Generic Letter
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The staff has revised the proposed generice.g.,
asEnclosure2,toeliminateobjectionablelanguage letter, p(rovid j
"... compliance with the staff recomended actions ) contained in the SECY 84-13A version. References to proposed Technical Specifications have also been eliminated, since Technical Specification changes would be premature before the overall
!- evaluations are completed.
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The Commissioners The proposed generic letter has also been clarified with respect to how the information to be collected would be used by the staff. Specifically, this information would be used to evaluate the overall effectiveness of. plant-specific programs to prevent and mitigate the occurrence of steam generator tube ~ ruptures. To this end, the staff would employ the staff recomended actions as review guidance. The staff recognizes, however, that plant-specific programs may differ from some of the specifics in the staff recomended actions, yet still be adequately effective.
The plant-specific evaluations would be documented in a NUREG report (i.e., a separate report from NUREG-0844, which describes the staff's technical resolution of USIs A-3,A-4,andA-5). On the basis of this NUREG report, the staff will determine what, if any, regulatory actions are necessary. If generic actions are needed, they will be reviewed by CRGR prior to implementation.
In the meantime, however, pending public coment and final publication of NUREG-0844, the staff has concluded that it should proceed with issuance of the generic letter for purposes of collecting the needed information. The staff notes that the industry has already comented extensively on the initial staff proposals, and these coments have been considered by the staff in developing the staff recommendations now before the Commission. Notwithstanding any public coments which may be received pertaining to the sufficiency of the staff's proposed resolution of the USIs, the staff believes that the infonnation it is proposing to collect from industry will ultimately be needed as part of the USI resolut. ion.
RECOMMENDATION: That, the Comission:
(1) Acorove issuance of the generic letter (2) Note that the staff intends to issue the letter within 30 days of the date of this otherwise by the Comission. paper unless instructed
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William J. Dircks Executive Director for Operations
Enclosures:
- 1. Letter from SG0G dtd 10/1/84
- 2. Revised Generic Letter in 84-13A e
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'O SECY NOTE: In the absence of instructions to the contrary, SECY will notify the staff on Wednesday, November 21, 1984 that the Commission, by negative consent, assents to the action proposed in this paper.
DISTRIBUTION:
Commissioners OGC OPE OI OCA OIA OPA
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