ML19240B463
| ML19240B463 | |
| Person / Time | |
|---|---|
| Issue date: | 04/01/1981 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML19240B464 | List: |
| References | |
| CON-FIN-B-0755, CON-FIN-B-755 NUDOCS 8104130464 | |
| Download: ML19240B463 (2) | |
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UR 1 13p MEMORANDt'M TOR:
Victor Stello, Jr., Director Office of Inspection & Enforcement FROM:
Harold R. Denton, Director Office of Nuclear Reactor Regulation
SUBJECT:
DIFFERING PROFESSIONAL OPINION
Reference:
V. Stallo's Memorandum to H. Denton, " Differing Professional Opinion", dated February 18, 1981 We have examired your memorandun dated 7ebruary 18, 1981, and have concluded that, in a technical sense, there is no <iiffering professional opinion. We share your centre.1 concern that improvemote to the compressed air systems in operating plants may be warranted. Howeve, it is apparent that differences of opinion may exist as to the extent of any needed improvements, the criteria upon which any improvements must be based, and the li::ensing mechanism for implementing improvements, should such a need exist.
It is important to note thnt the purpose of the Standard Review Plan (SRP) is to provide Staff guidance during licensing reviews for those plants which have applied Sr cps and OLs. Likewise, it is also important to note that, even thouf me SRP sets a standard which NRR considers acceptable for licensing purposes, the licensees may propose equivalent standards which also meet the licensing requirements of 10 CFR Part 50. Therefore, the SRP is not a justifiable mechanism for requiring bai.kfits to operating plants which have already been approved through the licensing process.
To resolve our shared (not differing) central concern, the following measures have already been initiated by the Operating Experience Evaluation Branch (0EEB) i of the Division of Eafety Technology (DST):
1.
Under an existing technical assistance contract, "Special Studies of Reactor Operating Expertence" (FIN B0755), with ORNL, DEEB is initiating a case study on the loss, or impainnent, of compressed air systems in operating mactors.
M 2.
Because of IE's shared Interest in the compressed air systems, Mr. Riggs
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(0EEB) has contacted R. K essel of your staff. Mr. Kiessel has assured gp' us that IE will cooperate with our contractor and assist them in obtaining
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information that may not be available in the LERs.
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the contractor's study are avail!tble OEEB will recommend a risk assessment by the Reliability & Risk Assessrcent Branch (RRAB) of DST.
The results from the RRAB will then be factored into an overall prioritintion method being developed by the Safety Program Evaluation Branch (SPEB) of DST to discern the relative worth of various potential efforts to reduce the risk ir nuclear reactors.
We believe the e.bove actions provide a systematic engineering, and licensing, approach toward esteblishing realistic criteria upon which the need for improvements to the compressed air systems can be based.
In addition, the above approach will help NRR establish the priority of any backfit require-ment, and thereby assist in determining a realistic schedule for implementation of any subsequent backfits to the comp essed air systems in all phases of the licensing process for nuclear power plants.
The above discuss'.,n should help clarify the purpose and intent of the SRP, and also provide your staff with inforraction on the measures already being taken eithin NRR as to your staff's specific concerns on the compressed air systems ir nuclear power plants. We trust that this reply will also resolve those concerns expressed in your N,1randum dated February 18, 1981 regarding the " Differing Professiona7 Opntan".
Dricini sipu :y
- 11. R. Dooton Harold R. Denton, Director Office of Nuclear Reactor Regulation Di',tribution Copies:
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