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POLICY ISSUE
INFORMATION

SECY-00-0149

June 30, 2000

• PURPOSE:
• BACKGROUND:
• DISCUSSION:
• Reactor GSIs
• Non-Reactor GSIs
• Assessment of Processes
• CONCLUSION:

PURPOSE:

To provide the annual summary of activities related to generic safety issues (GSIs).

BACKGROUND:

It has been the practice of the staff to provide the Commission with an annual update of the progress made in resolving GSIs. This practice was reinforced by the Commission in a Staff Requirements Memorandum (SRM) of May 8, 1998, in response to SECY-98-030, "Implementation of DSI-22, Research." In this SRM, the Commission directed the staff to provide an annual summary of activities related to open reactor and non-reactor GSIs.

The current structure of the reactor Generic Issues Program was established in the 1980s and was intended to address the resolution of reactor GSIs and environmental issues, improvement in the licensing process, and the elimination of requirements that are overly conservative or unnecessarily restrictive or costly. The NRC process for addressing reactor generic issues from all sources, operational and non-operational, was approved by the Commission in 1983 and is delineated in NUREG-0933, "A Prioritization of Generic Safety Issues."

Up to 1995, the Generic Issues Program focused only on GSIs related to nuclear power plants. However, following a December 19, 1995, Commission briefing on mechanisms for addressing GSIs, the staff was requested to expand the program to include non-reactor GSIs identified by the Office of Nuclear Material Safety and Safeguards (NMSS). The NRC process for addressing non-reactor generic issues from all sources, operational and non-operational, is delineated in NMSS Policy and Procedures Letter 1-57, Rev. 1, October 1997.

In addition to the processes documented in NUREG-0933 and NMSS Policy and Procedures Letter 1-57, Management Directive 8.5, "Operational Safety Data Review," addresses the roles of each affected office in the identification of generic issues resulting from the review of operational data.

In 1998, the staff conducted a self-assessment of the generic issues processes and recommended changes to improve efficiency, timeliness, and clarity. Whereas the original process contained six steps (discussed below), the proposed revised process will contain eight steps with the following changes: (1) the prioritization step, in which the relative priority ranking of high, medium, low, and drop was used to determine whether resources should be assigned to an issue, will be replaced by two steps, initial screening and technical screening, in which a determination will be made to continue work on an issue or drop it; (2) the resolution step will be replaced by two steps, a technical assessment step and a regulations and guidance development step; and (3) the imposition step will be replaced by a regulation and guidance issuance step. A new Management Directive 6.4, "Generic Issue Program," was developed by the staff to institute these changes. The revised process addresses adequate protection issues, substantial safety enhancement, and burden reduction initiatives. The staff is performing a trial application of this new process, as recommended by the Advisory Committee on Reactor Safeguards (ACRS), and is expected to report its findings to the ACRS by the end of 2000. Generic issues identified after March 1999 are being evaluated with the proposed revised process.

DISCUSSION:

Reactor GSIs

The original process for addressing reactor GSIs delineated in NUREG-0933 consists of six steps: identification, prioritization, resolution, imposition, implementation, and verification. Generally, safety concerns associated with operating events, research results, or risk assessments form the basis for the identification of GSIs by the staff, the ACRS, industry, or the public. After a GSI is identified, it is prioritized to determine whether resources should be expended in pursuit of a resolution. GSIs associated with nuclear reactor power plants are prioritized by the Office of Nuclear Regulatory Research (RES) using the methodology of NUREG-0933. The prioritization step is generally completed with a quantitative analysis of the risk reduction potential of the issue and a priority ranking of HIGH, MEDIUM, LOW, or DROP. GSIs with rankings of HIGH or MEDIUM would be able to meet the "substantial increase in the overall protection of the public health and safety" requirement of 10 CFR 50.109 and are selected for resolution. No additional action is taken on reactor GSIs in the LOW-priority and DROP categories.

Upon completion of the prioritization step, all reactor GSIs that meet the requirement of substantial increase in public health and safety are assigned for resolution by the RES Director, with the majority of these assignments made to RES. The Office of Nuclear Reactor Regulation (NRR) is assigned those reactor GSIs that require extensive interface with operating plants. Resolution of a reactor GSI requires a cost-benefit analysis of a proposed solution after consideration of the options to improve safety. Some action is taken on those for which the cost-benefit analysis shows that "the direct and indirect costs are justified in view of this increased protection" (10 CFR 50.109). The ACRS normally reviews the prioritization and resolution of GSIs associated with nuclear power plants. The schedules for the resolution of GSIs allow adequate time for ACRS review and resolution of ACRS comments.

In the imposition step, the staff issues requirements that may result from the resolution of the GSI, and the affected licensees are required to prepare schedules for implementing these requirements. Implementation covers the step in which the affected licensees perform actions on their operating plants to satisfy the commitments made during the imposition step. Finally, verification is accomplished by NRC inspection of licensee actions.

RES is responsible for: (1) resolving GSIs through the conduct of research; (2) tracking the status of all generic issues through the identification, prioritization, and resolution steps in the agency-wide Generic Issue Management Control System (GIMCS); and (3) documenting the prioritization and resolution results in NUREG-0933 and making it publicly available on the NRC Website. In addition to resolving some GSIs, NRR is responsible for managing the imposition, implementation, and verification of those GSIs that result in new requirements. Tracking GSIs through these final three steps is accomplished with the Safety Issues Management System (SIMS).

The following is a summary of the activities related to reactor GSIs since the last report to the Commission in SECY-99-185. All GSIs identified before March 1999 continue to be evaluated in accordance with the original process.

• One new reactor GSI (187 - The Potential Impact of Postulated Cesium Concentration on Equipment Qualification in the Containment Sump) was identified for initial screening using the proposed revised process. This new GSI is scheduled to complete technical screening by December 2000.
  
  
• One GSI was prioritized with a HIGH priority (156.6.1 - Pipe Break Effects on Systems and Components)
  
  
• Six GSIs (three HIGH priority and three MEDIUM priority) were resolved with no new or revised requirements for licensees (Attachment 1). The resolution of these six GSIs was reported to Congress in monthly reports on the Reactor Generic Issue Program. Currently, seven HIGH-priority reactor GSIs remain to be resolved and the schedules for the resolution of these issues are listed in Attachment 2.

Non-Reactor GSIs

For non-reactor GSIs, NMSS is responsible for managing all six steps of the program described above, in accordance with the guidelines of NMSS Policy and Procedures Letter 1-57, Rev. 1. The status of the unresolved GSIs is tracked by RES in the GIMCS.

The following is a summary of the activities related to non-reactor GSIs since the last report to the Commission in SECY-99-185:

• No new non-reactor GSIs were identified for prioritization.
  
  
• Two GSIs (one HIGH priority and one MEDIUM priority) were resolved with no new or revised requirements for licensees (Attachment 1). Currently, four non-reactor GSIs remain to be resolved and the schedules for the resolution of these issues are listed in Attachment 2.
  
  
• NMSS is conducting an office-wide review of all the safety issues that have arisen in the past 18 months to determine whether they should be resolved and tracked as GSIs. Those safety issues identified as GSIs will be entered into the GIMCS. NMSS will manage these GSIs using the six-step process, and propose a resolution schedule for the "high" and "medium" GSIs. The outcome of this ongoing effort will be incorporated into the next annual summary report on activities related to GSIs.

Assessment of Processes

The ACRS was briefed on the revised process and the new Management Directive 6.4, and ACRS comments were incorporated. Consistent with the ACRS recommendation, the staff is implementing a trial application of the new directive.

CONCLUSION:

Since the last report to the Commission in July 1999, the staff prioritized and resolved a combined total of seven reactor and two non-reactor GSIs. The staff will continue to use the processes of NUREG-0933 and NMSS Policy and Procedures Letter 1-5, Rev. 1, as well as the procedures of Management Directive 8.5, to identify, prioritize, and resolve reactor and non-reactor GSIs until the new process delineated in Management Directive 6.4 is approved by the Commission. The staff will continue to provide an annual update to the Commission and will inform the Commission of any significant results of the ongoing assessment.

ATTACHMENT 1

GSIs Prioritized and Resolved Since July 16, 1999

ATTACHMENT 2

Unresolved GSIs as of June 14, 2000