ML19239A278

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Responds to 801212 Memo Re Proposed NUREG-0737 Implementation Plan for Operating Reactors.Accepted Review Items Listed & Identified
ML19239A278
Person / Time
Issue date: 12/29/1980
From: Moseley N
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To: Eisenhut D
Office of Nuclear Reactor Regulation
Shared Package
ML19239A281 List:
References
FOIA-81-405, REF-SSINS-0410, RTR-NUREG-0737, RTR-NUREG-737 NUDOCS 8102050595
Download: ML19239A278 (2)


Text

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MEMCRANDUM FOR:

DarrellG.Eisenhut, Director,DihisionofLicensing,NRR FROM:

NormanC.Moseley, Director,DihisionofProgramDevelopment and Appraisal, IE

SUBJECT:

NUREG 0737 IMPLEMENTATION PLAf; FOR OPERATING REACTORS:

OIE COMMENTS We have revi~ewed the proposed plan in your memorandum.of December 12, 1980 and offer the following comments relative to OIE followup.

Your memorandum recognized an important point in the statement that NRR. post-implementation reviews must be by SER to provide an IE inspection index.

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many cases IE may have already verified implementation, in accordance with the licensee's rommitment, before the post-implementation review is done. Thus, we believe that the SER should specifically state whether the licensee's proposal was approved as is or whether any change was made in the licensee's commitment.

A change would require re-inspection to confirm smplementation.

ThememorandumstatesthatDIErehiewitemshavenotyetbeenidentified.

How-ever, the plan indicates that for several items where no plant specific ieview by !:RR is planned, the guidance provided to the licensee by NRR should be adequate for direct implementation and followup verification by IE. We would consider any such cases to be OIE review items because, if NRR does not review the licensee's proposed action for acceptability, IE will have to do so before completing the verification.

Accordingly,inrehiewing_thetableinthepreposedplan,wehaveconsideredany item that NRR will not review to be a request for IE review (although we believe that was not always intended). With this in mind, we have the following comments.

Item I.A.1.3, Part 1 - We accept review responsibility.

ItemI.A.2.1-WebelievetheseitemsareinappropriateforIEreview/herification as stated. They include items that operator license appli; ants must demonstrate on their applications to OLB, and that the text in NUREG 0737 says OLB will check.

IE would merely be checking to see if proper st,bmittals had been made to OLB, NRR.

ItemI.A.3.1-W2.beliehethisitemisinappropriateforIErehiew/ verification as stated.

It involves examining operators, which OLB, NRR will be doing.

ItemI.C.5-Weacceptrehiewresponsibility.

Item 1.C.6-Weacceptreviewjesponsibility.

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u Darrell G. Eisenhut,:sRR DEC 2 S 158D Item II.B.4, Part 1 - This item indicates no licensing action.

It involves program developt int for training by OLB, which would be inappropriate for IE review. Thus, we cannot accept review re.,ponsibility.

Item II.K.2, Item 11 - We accept review responsibility.

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Item II.K.3, Item 22a - We accept review responsibility.

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/Dikector.ormanCf,hoseley

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l,ivision of Program S

Development and Appraisal, IE cc:

V. Stello, IE H. Denton, HRR E. Case, r;RR

1. Cummings, OIA f, Novrk, NRR R. Tedesco, NRR J. Sniezek, IE S. Bryan, IE D. Allison, IE R. Emch, NRR S. Hanauer, NRR D. Ross, NRR R. Vollmer, NRR T. Murley, NRR

.