Preliminary Clarification of TMI Action Plan Requirements (Generic Letter 80-80)


                               UNITED STATES 
                          WASHINGTON, D. C. 20555 

                             September 5, 1980 




Over the past months since TMI-2 accident, the NRC has developed a number of
requirements that must be implemented on operating reactors and on plants 
under construction. The purpose of this letter is to provide you with a 
summary listing of all approved TMI-2 related requirements for operating 
reactors and for applicants for an operating license as we understand them 
today. Also included for many items are proposed revisions or 
clarifications. This letter is for your information and review prior to NRC 
regional meetings to be held during the week of September 22, 1980. It is 
hoped that such a listing will put together in one place a tabulation of all 
such requirements for ease of use. Enclosure 1 contains a listing of all 
approved TMI-related requirements for applicants for an operating license. 
Enclosure 3 to this letter contains revisions and clarifications of the NRC 
position on most of these requirements. 

One of two types of NRC reviews is specified for each requirement listed on 
Enclosure 1. "Pre-implementation review" requires that the licensee proposal
be reviewed and approved by NRC prior to implementation. Post-implementation
review requires that the licensee submit sufficient documentation to permit 
NRC review following implementation reviews. 

To facilitate NRC review on all pre-implementation items, in a time frame 
consistent with the implementation schedule, dates for the submittal of 
required information or documentation for licensees are also listed on 
Enclosure 1. Information or documentation for Operating License Applicant 
requirements is to be submitted four months prior to the expected issuance 
of an operating license or four months prior to the listed implementation 
date, whichever is later. 

A preliminary indication concerning whether the development of Technical 
Specifications to a facility license will be required for each of the action
items is also listed on Enclosures 1 and 2. For those items which require 
Technical Specifications, the proposed Technical Specification should be 
submitted with the required documentation. 


                                    - 2 -        September 5, 1980

Experience with the implementation of these and previous TMI Action Plan 
requirements indicate that the scheduled implementation deadlines in some 
cases may not allow reasonable time for completion of the work required.  In 
some instances, the schedules, review categories, or clarifications have 
been changed from previous correspondence, or the requirement is being 
formally transmitted for the first time.  A summary of these principle 
changes is listed as Enclosure 5.

The licensee/applicant should formally notify the staff as soon as any 
delays beyond the required implementation dates become apparent.  The 
licensee/applicant submittal for these cases should include justification 
for the delay, a discussion of the work that will be completed by the 
required date including any planned compensatory actions, and an indication 
of the date for completion of the required actions.  The staff intends to 
allow case-by-case exceptions only for good cause.

In general, if a completion deadline for a requirement falls later than the 
operating license date for a new plant, that requirement need not be met by 
the newly licensed plant until the completion deadline.  If a completion 
deadline falls before an operating license decision date, that requirement 
is a prerequisite for the new operating license, except when a good cause is 
shown for any such exception.

In view of the complexity and number of issues discussed herein, the NRC is 
planning regional meetings to discuss these requirements.  Such meetings 
which will be similar to those held a year ago on the Short-term Lessons 
Learned requirements, will be principally for the purpose of discussing our 
proposed clarification and revision requirements, and to provide a forum for 
obtaining licensee/applicant feedback.  Licensees and applicants for 
operating licenses are strongly encouraged to attend and participate.  A 
Federal Register Notice is being issued in the near future stating the exact 
time and location of such meetings which will be held during the week of 
September 22, 1980.  To facilitate your review, Enclosure 4 contains a 
listing of previous correspondence sent to licensees/applicants setting 
forth TMI-related requirements.

Although the requirements (Scope and Schedules) contained herein will not be 
put in final form until after consideration of comments received at the 
regional meetings, all licensees and applicants should anticipate that the 
final requirements will closely resemble those identified in the Enclosures.  
As such, utilities should continue plans to implement these requirements.


                                    Darrell G. Eisenhut, Director
                                    Division of Licensing
                                    Office of Nuclear Reactor Regulation

                                  - 3 -                  September 5, 1980 


1.   TMI Action Plan Requirements for Operating Reactors 
2.   TMI Action Plan Requirements for Applicants for an Operating License 
3.   TMI-2 Action Plan Requirements
4.   Correspondence Concerning TMI Related Requirements
5.   Summary of Changes and New Requirements TMI-2 Action Plan Implementation 


                          FEDERAL REGISTER NOTICE 

AGENCY:   U.S. Nuclear Regulatory Commission 


SUMMARY:  As a result of the accident at TMI-2 in March 1979, the NRC has 
          developed a number of new requirements for nuclear power plants. 
          The staff has recently developed a document describing in more 
          detail certain of these requirements that are being implemented at
          operating plants and plants under construction. In connection with
          this document, which clarifies and in some cases revises the scope
          and and schedule of these requirements the NRC will hold regional 
          meetings to explain these requirements in more detail. 


        Region I       September 22, 1980       8:00 a.m. - 5:00 P.M. 
                                                Twin Bridges Marriott 
                                                333 Jefferson Davis Highway 
                                                Arlington, Virginia 

        Region III     September 23, 1980       8:30 a.m. - 5:00 p.m. 

        Region IV &    September 24, 1980       8:30 a.m. - 5:00 p.m. 
        Region V 

        Region II      September 26, 1980       8:30 a.m. - 5:00 p.m. 

        Specific locations will be provided in NRC regional press releases. 


          Jack, W. Roe, Division of Licensing 
          U.S. Nuclear Regulatory Commission 
          Washington, D.C. 20555 
          (301) 492-8102 


                                  - 2 -

SUPPLEMENTAL INFORMATION: The primary purpose of these meetings will be 
     (1) to provide a more detailed explanation of these requirements 
     including revisions; (2) explain the Regulatory approach and schedule 
     to be taken in implementing the requirements; and (3) to obtain 
     industry comments on these requirements including the implementation 

     Persons other than the NRC staff and Licensee Representatives may 
     observe the proceedings but will be permitted to participate in the 
     discussions only as time will allow. 

     Registration of attendees will be conducted prior to each meeting at 
     the designated locations. 

     Comments on the document from interested persons would be welcome. 
     Copies are being furnished to all local NRC Public Document Rooms and 
     it is available for inspection at the Public Document Room in 
     Washington, D. C. (1717 H Street, N. W.). Since many of the 
     requirements have near-term implementation dates and the detailed 
     clarifications, therefore, must be available promptly to the nuclear 
     industry any such comments must be received as soon as practicable. The 
     document is scheduled for finalization in early October 1980. 
     Dated at Bethesda, Maryland, this the 7th day of September, 1980 for 
     the Nuclear Regulatory Commission. 

                                        Darrell G. Eisenhut, Director 
                                        Division of Licensing 
                                        Office of Nuclear Reactor Regulation


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