ML19260C770
| ML19260C770 | |
| Person / Time | |
|---|---|
| Issue date: | 01/08/1980 |
| From: | Hanrahan E NRC OFFICE OF POLICY EVALUATIONS (OPE) |
| To: | Ahearne J, Gilinsky V, Kennedy R NRC COMMISSION (OCM) |
| Shared Package | |
| ML19260C771 | List: |
| References | |
| REF-10CFR9.7 NUDOCS 8001240242 | |
| Download: ML19260C770 (2) | |
Text
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UNITED STATES g
NUCLEAR REGULATORY COMMISSION U
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WASHINGTON, D. C. 20555 O
January 8, 1980 MEMORANDUM FOR:
Chairman Ahearne Commissioner Gilinsky Commissioner Kennedy Commissioner Hendrie Commissioner Bradford d
FROM:
Edward J. Hanrahanc.
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SUBJEC1:
TMI ACTION PLAN -- PREREOUISITES FOR RESUMPTION OF LICENSING While the staff has done admirably the necessary job of putting together an integrated action plan, your " approval" of the entire action olan is neither necessary nor sufficient to end the licensing cause.
It is not nece.ssarv for you to approve every item in the plan -- much less accrove them to tne level of detail provided in some cases.
Some tasks, while desirable, may not be necessary and, in light of resource constraints, may well be forgone.
Accroval of the plan is not sufficient, as the olan may not contain all actions that will be necessary and some of ne ac' ions will actually have to be comoleted before licensing can resume.
(" Licensing" is taken to mean the review process, as opposed to the final step in that process, i.e., license issuance.)
The staff itself recognizes the action plan to be "incomolete" and "too soecific for Commission approval," but orocoses that another draf t of the entire plan be prepared before you consider approving it.
Such an all-or-nothing approach may be so impractical as to delay indefinitely the resumption of licensing.
On the one hand, the clan may never be complete (rather only asymotonatically approach comoletion) and, on the other hand, it is not yet clear what level of detail is needed for Commission approval.
An alternative to revising and approving the entire plan is a chased accroach wher.eby, using the action olan as a basic reference, the staff extracts only thoss necessary actions, in order of plant priority, at a level of detail for each task appropriate for Comnission approval, that would be sufficient to resume licensing, as resources become available.
Thus, we would start with the need to resume OL licensing and define what tasks should be extracted from the plan for that purpose and condensed or elaborated to the appropriate level of detail.
}g}Q 277 CONTACT:
Al Kenneke, OPE 634-3295
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' Ta'The Comission -
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d The staff now has given you a list of near-tem operating license " requirements" which need to be refined so that their detail is at the desired level for
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Commission approval, thus giving the tem "recuirement" some fuller degree of legal standing by getting the Commission's stamp of approval prior to its y
application within the context of adjudication.
Thus specific actions might be i
defined in tems of (1) very broad policy objectives, i.e., leaving implementation fully to the staff; (2) policy objectives and orogram description, i.e., leaving S
program implementation to staff (e.c., by regulatory guides), or (3) specific I
licensing r~equirements and/or criteria, i.e., leaving little flexibility in
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interpretation and implementation.
As such aporoval is eouivalent to rulemaking If (however it is actually promulgated), the content of a particular recuirement should only be as specific as necessary to accomplish the safety objective without elim).,ating desired flexibility in interpretation and implementation.
]3 As the pause was instituted in large part to assure full staff attention to identifying and implementing lessons learned on operating reactors, there also '
needs to be a clear signal thatyou believe all the necessary OR actions have been identified and implemented sufficiently to pemit diverted resources to turn to other tasks.
The resumption of OL licensing can be seen as the beginning of the end to the pause.
Once OL licensing activities have resumed, attention can turn to the CP process. As the latter was the focus of the Congressional (and Kemeny Comission) " moratorium" debate, the pause may not be fully ended until b
the CP process has resumed.
But that step is not so urgent, and it seems to me its postponement to deal with the hichest priority plants will ultimately be the most expeditious way of resuming the full range of licensing activities.
E; r
i cc: Leonard Bickwit Sam Chilk Lee V. Gossick Harold Denton Victor Stello i
Robert Minogue 1
Roger Mattson Howard Shapar 1
m 1930 278
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