Protecting People and the EnvironmentUNITED STATES NUCLEAR REGULATORY COMMISSION
GL80090
UNITED STATES
NUCLEAR REGULATORY COMMISSION
WASHINGTON, D.C. 20555
OCT 31, 1980
TO ALL LICENSEES OF OPERATING PLANTS AND APPLICANTS FOR OPERATING LICENSES
AND HOLDERS OF CONSTRUCTION PERMITS
Gentlemen:
SUBJECT: POST TMI-REQUIREMENTS
On September 5, 1980. the NRC staff sent you a draft clarification letter
regarding approved TMI Action Plan items. During the week of September 22,
1980, four regional meetings were held to provide a more detailed
explanation of these requirements and to obtain industry comments concerning
these items. Based on these discussions and other comments received, the NRC
has revised its requirements regarding these items. It is the purpose of
this letter to set forth those requirements.
This letter incorporates in one document all TMI-related items approved for
implementation by the Commission at this time. This document is being
published as NUREG-0737. Enclosures 1 and 2 contain an itemized listing of
OR and OL requirements including implementation schedules, applicability,
method of implementation review and licensee submittal dates. Enclosure 3
contains more detailed clarifications of most of the NRC positions including
the identification of any changes from previous requirements and guidance.
Most of the items in the attached document have already been issued as
requirements by previous correspondence. Those items that are being issued
as requirements for the first time by this letter are identified by an
asterisk in Enclosures 1 and 2. Additional guidance on the Emergency
Response Facilities, Section III.A.1.2, will be forwarded separately in the
near future.
Licensees and applicants should note that the set of requirements identified
in the enclosures do not constitute the total set of TMI-related actions in
the TMI-2 Action Plan, NUREG-0660. Rather, as noted above, the enclosures
are a compilation of those items that have been specifically approved by the
Commission for implementation. Upon further staff development of criteria
and planning, additional items will be issued. For example, in the
relatively near future, the staff expects to issue further criteria on
emergency operational facilities (NUREG-0696), auxiliary feedwater system
improvements (derived from NUREG-0667) and instrumentation (Regulatory Guide
1.97, Revision 2). In general, the implementation of those requirements will
be carefully examined to ensure that they do not unnecessarily impact any of
the requirements in this letter.
8012160050
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The requirements herein(which include the requirements from NUREG-0694) are
applicable to applicants for operating licenses and such applicants are
expected to meet the same schedule of implementation as indicated for
operating reactors. Operating license reviews being finalized over the next
few months will be handled on a case-by case basis. Any item which the
implementation date is prior to the expected ate of issuance of an operating
license will be considered to be prerequisite to obtaining that license. For
such items, applicants must submit information or documentation four months
prior to the staff's scheduled issuance of its Safety Evaluation Report for
four months prior to the listed implementation date, whichever is later.
A large number of post-TMI requirements require the installation of a number
of control room indications. It is important that licensees and applicants
give consideration to human factor engineering considerations in planning
for the installation of such new control room equipment. In the coming
months, the NRC will be requiring human factors engineering reviews of
control room designs as part of Action Plan Item I.D.1, and such an effort
at this time may reduce the potential for later modifications. As an example
of possible considerations, licensees and applicants might well consider at
this time whether some control panel indications are of lesser safety
significance and can be moved to other locations in the control room.
It is expected that the requirements contained herein will be met. However,
it is recognized that licensees have proceeded with implementation of some
of these items prior to issuance of these clarifying criteria. The staff
will consider requests for relief from various aspects of these criteria.
Such requests should explain the need for relief, include a clear
description of design features of the proposed installation, and provide a
safety or rationale supporting the adequacy of the proposed installation. A
licensee or applicant seeking relief from any element of our criteria should
submit for relief, along with supporting justification, in the response to
this letter.
Accordingly, pursuant to 50.54(f) operating reactor licensees are requested
to furnish, within forty-five (45) days of this letter, confirmation that
the implementation dates indicated in Enclosure 1 will be met. For any date
that cannot be met, furnish a proposed revised date, justification for the
delay, and any planned compensating safety actions during the interim. After
our evaluation of your response the NRC staff will take action, as necessary
to assure that such requirements and commitments are appropriately
enforceable. This may include, as needed issuance of a Confirmatory or
Show-Cause Order.
Sincerely,
Darrell G. Eisenhut, Director
Division of Licensing
Office of Nuclear Reactor Regulation
Enclosures:
As stated