ML20037D680
| ML20037D680 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 07/22/1981 |
| From: | Johari Moore NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Paulson W NRC |
| Shared Package | |
| ML20037D678 | List: |
| References | |
| NUDOCS 8108280153 | |
| Download: ML20037D680 (1) | |
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a July 22, 1981 Note to Walt Paulson Project Manager Big Rock Point COMMENTS ON PACKAGE RE BIG ROCK POINT PROBABILISTIC RISK ASSESSMENT This package is being sent back for discussion of the comments listed below.
Third paragraph, first page. This paragraph should be restructured per our discussion to show whether or not this item is actually being deferred or has been deferred.
First full paragraph, second page.
I would suggest more Staff justificiation for deferring these iterr.s. While we mention whattConsumers basis is, we make no mention why we agree with them t. sat deferral of these items does not represent a risk to the health and safety of the public.
Since NUREG-0737 is viewed by the Commission as a requirement, though it is not yet a rule, our justification for deferring NUREG-0737 items should be equivalent to that for granting an exemption.
Second paragraph, second page. As we discussed the " assumption" that certain requirements have been satisfied should not be the basis for granting a deferral, if that is what this paragraph is doing.
It should be made clear exactly what the Staff's position is at this time with regard to the Technical Support Center.
Third paragraph, second page.
If the Staff is deferring the primary meteorological system past July 1,1932, and the 1982 implementation date is contained in NUREG-0654, then this deferral should be by means of an exemption.
Please note the Staff may be reuuired at the very least to explain the relevance of each of the deferred items to the pending spent fuel pool expansion proceeding, since Intervenors have previcusly mentioned these potential deferrals in their pleadings before tha Licensing and Appgal Boards.
For this reason the justification for each item's deferral shoul xb de very clear and be supportable.
Janice E. Moore Counsel for NRC Staff 8108280153 810812 PDR ADOCK 05000155 P
PDR L