Guidance for Implementing Standard Review Plan Rule (Generic Letter No. 82-20)

                               UNITED STATES 
                       NUCLEAR REGULATORY COMMISSION 
                          WASHINGTON, D. C. 20555 

                              October 26, 1982 

TO ALL POWER REACTOR LICENSEES/PERMIT HOLDERS, APPLICANTS FOR CONSTRUCTION 
PERMITS 

Subject:  Guidance for Implementing Standard Review Plan Rule 
          (Generic Letter No. 82-20) 

Gentlemen: 

On March 10, 1982, the Commission approved a final rule 10 CFR 50.34(g), 
"Conformance with the Standard Review Plan (SRP)." This rule requires power 
reactor applications docketed after May 17, 1982, to include an evaluation 
of the facility against the acceptance criteria of the Standard Review Plan 
(NUREG-0800). 

The staff has prepared for public comment the enclosed guidance (NUREG-0906)
for licensees to assist in complying with the rule. The guidance document is
intended as an interim measure until the "Standard Content and Format Guide 
for Safety Analysis Reports, Regulatory Guide 1.70," is revised to reflect 
the requirements of the new rule, at which time the guidance in NUREG-0906 
would be incorporated into Regulatory Guide 1.70. 

The guidance document has the following major features: 

     (1)  It identifies the locations in the Safety Analysis Report (SAR) 
          for providing the evaluation required by the SRP rule and provides
          a suggested tabular format for identifying the specific areas of 
          design, analysis, and procedure that are different from the 
          Standard Review Plan. The table includes an identification and 
          summary description of the differences, and a reference to the 
          specific sections of the SAR in which the differences are 
          discussed and evaluated. 

     (2)  For applicants subject to the rule, it modifies the present 
          guidance contained in Regulatory Guide 1.70 that they should 
          provide a discussion in the SAR of their conformance with all 
          applicable Regulatory Guides (SAR Chapter 1.8). The appropriate 
          Regulatory Guides are cited in the acceptance criteria for each 
          individual section of the SRP. Thus, this section (Chapter 1.8) of
          the SAR would be redundant to the evaluation now required by the 
          SRP rule and an unnecessary burden on applicants. 

     (3)  It reaffirms that conformance with the SRP, per se, is not a 
          regulatory requirement, but that the specific acceptance criteria 
          of the SRP define methods acceptable to the staff for satisfying 
          the relevant regulations. However, the guidance document notes 
          that in some instances the SRP acceptance criteria are identical 
          to the requirements of the regulations. Guidance on how to handle 
          this type of difference from the SRP acceptance criteria is 
          included. 

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     (4)  It provides examples of evaluations of differences fran the SRP 
          that the staff considers to be acceptable in technical scope and 
          detail. 

Comments on NUREG-0906 are due by December 20, 1982. 

                              Sincerely,  


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

Enclosure: As stated