ML19308B945
| ML19308B945 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/18/1977 |
| From: | Huberman B NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Rehm T NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML19308B919 | List: |
| References | |
| RULE-RM-50-12, TASK-TF, TASK-TMR SECY-77-126, NUDOCS 8001170652 | |
| Download: ML19308B945 (2) | |
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION:
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WAsHIN3 TON, D. C. 20555 k $(:
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January 18, 1977 f
s MEMOPR OUM FOR: Thomas A. Rehn, BenHubermanI'Q FROM:
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SUBJECT:
DRAFT PAPER ON PETITION FOR RULEMAKING BY THE ATIRTIIC COUNTY CITIZENS COUNCIL FOR ENVIRONMENT MEb ki=
- m Although I egree with the recom= ended action (page tour of the draft),. I have some basic proble=s with the paper itself and the proposed Notice of Denial of Petition.
I reco:: mend the draft paper be revised. The revision should:
- avoid the i=plicatien that present practice contrasts sharply with the prototype concept by pointing out that, in fact, successive nuclear power plants have usually been preceded by near-prototypes with deconstration recuired for new safety-related features;
- discuss the safety ce:-its of this current evolutionary approach;
- admit t. hat exact prctotype testing may result in added assurance of safety, but concentrate on the cost-benefit argument, i.e.,
that the possible increase in safety for an exact prototype is over-balanced by the incre= ental costs in time, resources, and flexibility for f=p rovement ;
- emphasize that petitioners are addressing only licenses issued under
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Appendix M of 10 CFR Part 50;
- point out that nacufacturing licenses will be conditioned, i.e., NRC 4+-
is involved in regulating the manufacturing process itself; and
- avoid a purely defensive posture.
The Notice of D e'al should:
- delete all substantive coc=ents on OPS;
- 11=it discussion to %-"ufacturing licenses; and i:::
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O JL CONTACT:
OQh Ji= Beckerley (OPI) 634-1643 Enclosure "E"
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thomas A. Teh= -
' note that EC will conduct surveillance of each manufacturing licensee's operations.
I suggest that, at your earliest convenience, we nret with appropriate staff to discuss the above points in greater detai..
cc: Peter Strauss
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