ML13330A073

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Responds to Which Expressed Opposition to ACRS Recommendation to Restructure Sep.Role of Licensees in Program Will Expand.Ltr Forwarded to Commissioners
ML13330A073
Person / Time
Site: Millstone, Dresden, Palisades, Oyster Creek, Haddam Neck, Ginna, San Onofre, Yankee Rowe, La Crosse, 05000135  Constellation icon.png
Issue date: 06/18/1980
From: Harold Denton
Office of Nuclear Reactor Regulation
To: Schaffstall R
SEP OWNERS GROUP
Shared Package
ML13330A074 List:
References
TASK-***, TASK-RR NUDOCS 8007100399
Download: ML13330A073 (3)


Text

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N 1 8 980 Mr. Richard E. Schaffstall7" Executive Director SEP Owners Group KMC, Incorporated 1747 Pennsylvania Avenue. N. W.

Washington, D. C. 20006

Dear Mr. Schaffstall:

RE:

SYSTEMATIC EVALUATION PROGRAM (SEP)

This is in response to your letter of February 29, 1980, to the Secretary of the Commission which provided the position of the SEP Owners Group opposing the restructuring of the Program, as recommended by the Advisory Committee on Reactor Safeguards (ACRS) in a letter dated October 11, 1979, to the Chairman of the Commission.

The principal burden of assuring safe operation of the SEP facilities has always rested with the licensees. The establishment of the SEP was not intend ed to absolve them of that responsibility. At the initiation of the SEP, it was the staff's intention that a major burden of the program would be carried out by the-staff in the program's early stages of deciding which of the some 140 issues would require more licensee effort..- This would have the effect of not burdening licensees with the responsibility of the review effort until the NRC.-has decided those issues.

Based on experience to date, the staff has concluded that this is not the most efficient way to complete the program.

As a result of insufficient information in the facility dockets, it has been necessary forthe licensees to assume a greater role in some reviews since they are most familiar with their facilities. We expect that the role o the licensees in the program will have to expand more in the coming months.

Your letter also addressed the Three Mile Island related reviews. In many cases, the requirements resulting from the TMI investigations are being com-.

pleted in parallel with the SEP review. The NRC has concluded that the implementation of TMI Lessons Learned are required in the interest of public health and safety and most cannot be deferred pending completion of the SEP.

Furthermore, it is not expected that the modifications or reviews being imple mented under Lessons Learned will be seriously affected by the conclusions of the SEP reviews.

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OFFICE DATE o.....o..SO.MNP

.TI.OFFIE:.19 PCFORM 318 (9-76) NRCM.,

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.~..GO/EP.Ntr.1ENT.PRI.NTI..

OFFICE: 1979-289-369

Mr. Richard E. Schaffstall

- 2 Your closing statement indicated that, in the conduct of the SEP to date, no issues have been identified that were "unacceptable to public health and safety".

Without debating the meaning of "unacceptable", it should be noted that several changes have resulted from reviews-performed thus far. The intent of these changes has been to provide additional safety margins for the protection of public health-and safety.

In addition, our conIleted reviews have identified a number of facility deficiencies which will have to be resolved as we undertake an integrated assessment of these many topics.

We are forwarding your letter to the Conmissioners so they may see your cournents.

bn the ACRS recommendations.,

Sincerely, Harold R. Denton, Director Office of Nuclear Reactor Regulation DISTRIBUTION:

Docket No. 50-10 NRC PDR 50-10 LPDR 50-10 Docket No. 50-29 NRC PDR 50-29 LPDR 50-29 Docket No. 50-155 NRC PDR 50-155 LPDR 50-155 Docket No. 50-237 NRC PDR 50-237 LPDR 50-237 Docket No. 50-244 NRC PDR 50-244 LPDR 50-244 Docket No. 50-213 NRC PDR 50-213 LPDR 50-213 Docket No. 50-409 NRC PDR 50-409 LPDR 50-409 Docket No. 50-245 NRC PDR 50-245 LPDR 50-245 Docket No. 50-219 NRC PDR 50-219 LPDR 50-219 Docket No.. 50-255 NRC PDR 50-255 LPDR 50-255 Docket No. 50-206:-

NRC PDR 50-206 LPDR 50-206 TERA Attorneys, OELD MGroff SEPB Reading DCrutchfield GErtter (EDO-08513)

NRR Reading DEisenhut WRussell OI&E (3)

HRDenton RVollmer SEP Licensees (11)

EGCase DZiemann SEP Intervenors (16)

RMattson HSmith SEPB Members (12)

DRoss RFraley, ACRS SEP Members (20)

DMuller HBerkoy NRR:DIR

  • SEE ATTACHED YELLOW FOR PREVIOUS CONCURRENCE HR Denton.

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NRCM 240 US. GOVERNMENT PRINTING OFFICE. 1979-289-369

Mr. Richard E. Schaffstall

- 2 Your closing statement indicated that, in the conduct of the SEP to date, no issues have been identified that were "unacceptable to public health and safety".

Without debating the meaning of."unacceptable",

it should be noted that several changes have resulted.from reviews performed thus far. The intent of these-changes-has been to-provide additional-safety margins for the protection of public health and safety.

In addition, our completed reviews have identified a number of facility deficiencies which will have to be resolved during the.

integrated assessment. at the end of the SEP.

k'e are forwarding your letter to the Commissioners so they may see your comments on the ACRS recommendations.

Sincerely DISTRIBUTION:

Docket No. 50-10 NRC POR 50-10 LPDR 50-10 Docket No. 50- 29 NRC PDR 50-29 LPDR 50-29 Docket No.50-155 NRC PDR 50-155 LPDR 50-155 Docket No. 50 237 NRC PDR 50-237 LPDR 50-237 Docket No. 50-244 NRCPDR 524444 LPDR 50-244 Docket No. 50-213 NRCPDR.50-213 LPDR 50-213 Docket No. 50-409

'NRC PDR 50-409 LPDR 50-409 Docket No. 50-245 NR50-D45 0-245 LPDR 50-245 Docket No. 50-219 :

NRC PDR 50-219 LPDR 50-219 Docket No. 50-255 NRC PDR 50-255 LPDR 50-255 Docket No. 50-206 NRC PDR 50-206 LPDR 206..

TERA Attorneys, OELD MGroff SEPB Reading DCrutchfi.eld GErtter (EDO-08513)

NRR Reading-DEisenhut L

WRussell OI&E (3)

HRDenton-RVollmer SEP Licensees (11)

EGCase-DZiemann SEP Intervenors attson HSmith SEPB Members (12) ss RFraley, ACRS SEP Members (20) er HBerkow>

NRR:DIR HRDenton

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