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fy h Y 00f W.M.Morrison,kssistantDirectorforGeneralEngineering MEMORANDUM FOR:
Standards, Division of Engineering Standards, SD 4
FROM:
James H. Sniezek, Director, Division of Resident and Regional Reactor Inspection, IE
SUBJECT:
STANDARD REVIEW REQUEST - PROPOSED RULEMAKING AND ASSOCIATED (AITS H07003156H07) t.w9 g,g/d REGULATORY GUIDE 1.89 The Division of Resident and Regional Reactor Inspection has reviewed the subject Standard and submits the following ccmments:
1.
Prior to issuing the rulemaking and associated regulatory guide, we recommend that NUREG-0588 be revised and reissued promptly so that a basis for comparative review of R.G. 1.89 can be accomplished.
Reason: Paragraph 2, Enclosure B, Value Impact Statement, states that there is a proposed revision to IEEE 323-1974 which is based upon the technical material of NUREG-0588.
Draft R.G. 1.89, Enclosure D, is also based upon the technical content of NUREG-0588 and endorses IEEE 323-1974. The reissue of NUREG-0588 will incorporate comments to the present issue. The Commission paper draft, page 2, has been prepared assuming that NUREG-0588 has been revised and reissued.
2.
R.G.1.89 should be revised, if necessary, following the reissuance of NUREG-0588, if the reissue contains changes to the present document.
3.
The contents of the proposed revision to IEEE 323-1974 should be considered in R.G. 1.89.
4.
We understand that the rulemaking and R.G.1.89 will be issued together and that R.G.1.89 will be a specific part of the rulemaking document.
This should be clearly stated. For example, the last paragraph on page 3, Enclosure A discusses backfit considerations, R.G. 1.89, paragraph D addresses backfitting.
The rulemaking document, page 3, Enclosure A, should reference R.G.1.89, paragraph D for backfitting implementation.
4t JaTsH'.Sniezek, ctor Di ision of Resident and egional Reactor Inspection Office of Inspection and Enforcement cc:
R. B. Minogue, RES N. C. Moseley, IE T. E. Murley, NRR 8211100037 821014 PDR FOIA CURRAN 82-426 PDR
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@ an os7 MEMORANDUM FOR:
W. M. Morrison, Assistant Director for General Engineering Standards, Division of Engineering Standards, SD 4
FROM:
James H. Sniezek, Director, Division of Resident and Regional Reactor Inspection, IE
SUBJECT:
STANDARD REVIEW REQUEST - PROPOSED RULEMAKING AND ASSOCIATED REGULATORY GUIDE 1.89 (AITS H07003156h07) u.
y gw[i The Division of Resident and Regional Reactor Inspection has reviewed the subject Standard and submits the following comments:
I 1.
Prior to issuing the rulemaking and associated regulatory guide, we recommend that NUREG-0588 be revised and reissued promptly so that a basis for comparative review of R.G. 1.89 can be accomplished.
Reason: Paragraph 2, Enclosure B, Value Impact Statement, states that there is a proposed revision to IEEE 323-1974 which is based upon the technical material of NUREG-0588.
Draft R.G.1.89, Enclosure D, is also based upon the technical content of NUREG-0588 and endorses IEEE 323-1974.
The reissue of NUREG-0588 will incorporate comments to the present issue. The Commission paper draft, page 2, has been prepared assuming that NUREG-0588 has been revised and reissued.
2.
R.G. 1.89 should be revised, if necessary, following the reissuance of NUREG-0588, if the reissue contains changes to the present document.
3.
The contents of the proposed revision to IEEE 323-1974 should be considered l
in R.G. 1.89.
4.
We understand that the rulemaking and R.G. 1.89 will be issued together l
and that R.G.1.89 will be a specific part of the rulemaking document.
This should be clearly stated. For example, the last paragraph on page 3, Enclosure A discusses backfit considerations, R.G.1.89, paragraph D addresses backfitting.
The rulemaking document, page 3, Enclosure A, should reference R.G. 1.89, paragraph D for backfitting implementation.
s*
J Ys H. Sniezek, ctor Di ision of Resident and gional Reactor Inspection Office of Inspection and Enforcement cc: