Post TMI Requirements, NUREG-0737 (Generic Letter 80-90)


                              UNITED STATES 
                          WASHINGTON, D.C. 20555 

                               OCT 31, 1980 




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. 


                                  - 2 -

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. 


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

As stated 


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