ML20003B911
| ML20003B911 | |
| Person / Time | |
|---|---|
| Issue date: | 12/30/1980 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Kolsky K ICF, INC. |
| Shared Package | |
| ML20003B912 | List: |
| References | |
| NUDOCS 8102260110 | |
| Download: ML20003B911 (2) | |
Text
'
[
4'o UNITED STATES
[
3 c( h NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555
%..v /.. C g
o I
.../
DEC 3 01980 cn o m,,
a\\
A g( M bM RB 0 4190I"h Mr. Kenneth Kolsky E
ICF Incorporated 2
1850 K Street, N.W.
{
pom oi Suite 950
- ca.wsssa Washington, D. C.
20006
Dear Mr. Kolsky:
4 8
I am responding to Mr. Paul Brown's letter dated December 8, 1980 in which he reauested my coments on a study of the development of the Second Memo-randum of Understanding between NRC and EPA and the impact of the Memorandum on the licensing of nuclear power plants.
I have found the study to be a clearly expressed and complete review of the events leading to preparation of the Second Memorandum of Understanding. The only improvements that might be made to this part of the study would be to credit the NRC staff with insight as to the importance of interagency coopera-tion and with a willingness to work closely with their EPA counterparts, to delete the names of the individuals involved since each acted as a representative of his respective organization rather than as an individual, and.to delete the third paragraph on page 3-108 since the premise of the paragraph en staff con-tinuity is not supported by the facts presented.
The remainder of the study discusses first, on a qualitative basis, the various l
benefits of the Memorandum to the Federal agencies, the industry, and the public.
I This part of the study adequately expresses the advantages that have resulted i
from the Memorandum.
I find the remainder of the study, in which an attempt is made to quantify the impact of the Memorandum on licensing time saved to be much less convincing. Those who are involved in nuclear plant licensing recognize the many interrelated factors that enter into conducting a licensing review and to attribute time saved to any single factor such as the Memorandum is overly simplistic.
I suggest that the credibility of the study would be improved if the quantitative analysis of time saved were deleted.
l l
l l
8102 260 ll0 -
Mr. Kenneth Kolsky Should you have any further questions concerning the Second Memorandum of Understanding, I suggest you call Mr. Daniel R. Muller, Assistant Director for Environmental Technology who has been involved continuously in its develop-ment and implementation.
Sincerely, (Signe$ T'!im 1. Dir:ks William J. Dircks Executive Director for Operations f
A
.v.-
e,
,,.-w
.,-e-
-y
-