ML20024D890
| ML20024D890 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 07/21/1983 |
| From: | Scinto J NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20024D886 | List: |
| References | |
| NUDOCS 8308080360 | |
| Download: ML20024D890 (1) | |
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July 21,1983 Note to Mr. Crutchfield
SUBJECT:
BIG ROCK POINT 1 --CONTAINMENT INTEGRATED LEAK RATE TEST EXEMPTION (0 ELD # 834 877)
I do not agree with this package. We appear to be giving an exemption from an interpretation of the requirements of the regulation without any basis for concluding that it is an accurate interpretation of the regulation. We concede that the matter is in dispute between us and the licensee and simply presume that we are ~ right.
Presuming that we are right, we therefore ~ give them an exemption from the applicable regulation. We need alot more than that.
It is incorrect to give an exemption from " current staff criteria" as to how to, calculate a test result. Page 2.
We don't give exemptions
.from staff criteria. We give exemptions from requirements of regulations.
The question is simply is the requirement at issue a correct application of the regulation or isn't it? If we are ready to articulate and explain why the requirement at issue is required by the regulation, then set that forth and grant an exemption from that requirement to the regulation if you believe it to be warranted..But then it's completely inappropriate for the cover letter to-suggest that the staff intends to consider further the licensees arguments that our current criteria isn't correct.
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