ML19247D562
| ML19247D562 | |
| Person / Time | |
|---|---|
| Issue date: | 02/04/1981 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Ahearne J, Gilinsky V, Hendrie J NRC COMMISSION (OCM) |
| Shared Package | |
| ML19247D563 | List: |
| References | |
| REF-10CFR9.7 NUDOCS 8103120053 | |
| Download: ML19247D562 (2) | |
Text
-
.w...,
. m,y*
n m,,,,
.me r Wf & -
4*
y 7,.
FEB 4 8
MEMORANDUM FOR: Chairman Ahearne Comissioner Gilinsky Commissioner Hendrie Comissioner Bradford FROM:
William J. Dircks Executive Dir ector for Operations
SUBJECT:
SYSTEMATIC EVALUATION OF ALL CURRENTLY OPERATING NUCLEAR POWER REACTORS
REFERENCE:
SECY-81-13, same subject, dated January 8,1981 The referenced paper discusses the staff's proposed plan to implement Section 110 of Public Law 96-295, including in particular the "detemination by the Comission of the extent to which each operating facility complies with each rule and regulation identified under paragraph (1) of this sub-section.1 including an indication of where such compliance was achieved by ure of Division 1 regulatory guides and staff technical positions and where compliance was achieved by equivalent means." The staff's proposal is structured in accordance with the Comission's 90-day status report to the Congress 2 which states that the Standard Review Plan (SRP) will be revised "to reference all applicable regulations and those Division 1 Regulatory Guides, staff positions, and other documents currentiy used by the staff to interpret the intent of these regulations, including tie requirements from the TMI acci M +." This revised SRP will then be used as the basis for licensee evaluation of each operating plant and "in areas where the plant deviates from the revised SRP, the licensee will be requested to provide a technical discussion as to the safety significance of such deviation, including a judgment as to whether the alternative provides an equivalent method of meeting the regulation." The staff's proposed plan and draf t final rule recognizes that confomance with the SRP is only one way of detemining compliance with the regulations.
Clearly, the intent of the proposed plan and final rule is the detemination of degree of confomance to particularly significant safety regulations.
Because the plan and the proposed rule state the need to document deviation from the SRP, they appear to elevate the SRP to more of a regulatory status than it should have. The SRP should not be looked on as a regulatory require-ment, and I recomend that we be allowed to develop changes to the proposed plan and final rule to clear up any confusion on this matter.
'a;.
b
, g: -
,/
1Regula tions-of particular significance.- -
l 2 Transmitted September 30, 1330.
- f 8103120053
~
j m f' y
3.p '
,y '
y.
Comissioners I would like the opportunity to discuss these and perhaps other points with the Comission at an early opportunity.
(Sigte$ \\'li;Iitm 1. Ci:u.s William J. Dircks Executive Director for Operations CC: SECY OGC OPE bcc: NRR WJDircks/EDO EKCornell/ DECO TAPc5m/0ED0 9 R/F l.G EDO
. g.
WJDirch/sps 2/4/S1 sp i
eyr
'W
.ma y-g,
'gw
.