Compilation of the Current Licensing Basis: Request For Voluntary Participation in Pilot Program (Generic Letter 92-03)

March 19, 1992


TO:       ALL NUCLEAR POWER PLANT APPLICANTS AND LICENSEES

SUBJECT:  COMPILATION OF THE CURRENT LICENSING BASIS:  REQUEST FOR VOLUNTARY 
          PARTICIPATION IN PILOT PROGRAM (GENERIC LETTER 92-03)


The U.S. Nuclear Regulatory Commission (NRC) is issuing this letter to 
solicit the industry's participation in a voluntary pilot program to assess 
the advantages and disadvantages of compiling the current licensing basis 
(CLB).  We request that only interested applicants and licensees respond to 
this letter.  In issuing this letter, the NRC is imposing no new 
requirements or staff positions. 

BACKGROUND

The concept of the CLB was first introduced in the regulations, 10 CFR 
50.54(f), as a result of considerations in the development of the NRC's 
backfit rule.  The CLB again became an issue in the Commission's 
deliberations on extending the licenses for plants beyond the original 
contemplated design life.  In 1991, the Commission adopted the plant life 
extension rule, 10 CFR Part 54, which became effective on January 13, 1992.  
A definition of  CLB was set forth in Section 54.3.  Although set out in 
Part 54, that definition represents the staff's understanding of the scope 
of the CLB and should be applicable to all reactor licensees.

To further understand the advantages and disadvantages of compiling the CLB, 
the Commission has directed the NRC staff to solicit the industry's 
participation in a pilot program in which a small number of representative 
licensees would voluntarily compile their CLB and advise the NRC on the 
effort.  As part of the pilot program, the staff would assess the usefulness 
of the compilation with respect to the NRC's regulatory activities.  

The proposed effort also relates to the industry's effort to implement 
design basis reconstitution.  Although these programs should include 
reconstituting that portion of the CLB relating to the design, they do not 
address a significant portion of the CLB, including programmatic areas such 
as quality assurance, training, and maintenance.

Although compiling the CLB may require a significant amount of resources, 
the staff expects that the licensee will thereby reduce the resources it 
will need to devote in the future to (1) conducting document searches needed 
to support regulatory oversight, (2) filing license amendment requests, (3) 
making changes pursuant to Section 50.59, and (4) evaluating backfits 
pursuant to Section 50.109. 

__________________________________
  1. A representative sample might include (1) a facility that was licensed 
in the early 1970s, (2) several facilities that were licensed between 1975 
and 1985, and (3) a facility licensed within the last 5 years. 


9203190187 
.

GL 92-03                            - 2 -              March 19, 1992



Pilot Program Participation

Participation in the pilot program is voluntary.  Licensees wishing to 
participate should respond within 60 days of the date of this letter.  
Although the licensees volunteering need not provide details and schedules 
at this time, the staff desires to complete the pilot program compilation 
within a reasonable time.   The licensee may choose to compile the CLB as a 
single set of documents in one location or by a system which provides a 
reference to documents that can be retrieved easily from several locations.  
Volunteers should select an approach, scope, and format that will be most 
useful to them.  If the staff finds sufficient interest among licensees on 
these or other matters, it will conduct a workshop with those considering 
participating.

The staff anticipates that licensees will use the CLB during their 
participation in the pilot program.  During this time, the NRC staff will 
conduct audits with the participants to determine the usefulness of the 
compiled CLB.  The fees for this audit will not be collected from 
participants under 10 CFR Part 170, but will be included in the general base 
fee under 10 CFR Part 171.  In addition, where the licensee identifies a 
non-willful failure to meet a licensing commitment which could subject the 
licensee to enforcement action, it is our intent to exercise enforcement 
discretion, provided the licensee has taken prompt corrective action 
consistent with the provisions in the enforcement policy for non-cited 
violations.  More significant violations will be handled on a case-by-case 
basis.

If there are any questions on this matter or you have an interest in 
attending or participating in a workshop, please contact the Technical 
Contact or your NRR licensing project manager.  Licensees who wish to 
participate in the pilot program should address their responses to the 
attention of the NRC Document Control Desk.

This request is covered by Office of Management and Budget Clearance Number 
3150-0011, which expires May 31, 1994.  The estimated average number of 
burden hours is 10 person hours for each licensee's response, including 
those needed to assess the request and to respond to the generic letter.  
This estimate of the average number of burden hours pertains only to the 
identified response-related matters and does not include the time needed to 
develop the CLB.  Comments on the accuracy of this estimate and suggestions 
to reduce the burden may be directed to Ronald Minsk, Office of Information 
and Regulatory Affairs (3150-0011), NEOB-3019, Office of Management and 
Budget, Washington, DC  20503, and to the U.S. Nuclear Regulatory 
Commission, Information and Records Management Branch (MNBB-7714), Division 
of Information Support Services, Office of Information and Resources 
Management, Washington, DC  20555.
.

GL 92-03                            - 3 -              March 19, 1992



Since the generic letter does not contain any new or revised regulatory 
requirements, the Backfit Rule, 10 CFR 50.109, does not apply.

                              Sincerely,



                              James G. Partlow, Associate Director
                                for Projects
                              Office of Nuclear Reactor Regulation

Technical Contact:  
D. Wigginton, NRR
(301) 504-1301

Enclosure:
List of Recently Issued Generic Letters