ML20040C514
| ML20040C514 | |
| Person / Time | |
|---|---|
| Issue date: | 01/05/1982 |
| From: | Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20040C507 | List: |
| References | |
| NUDOCS 8201280031 | |
| Download: ML20040C514 (2) | |
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UNITED STATES
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January 5, 1982 l
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4 MEMORANDUM FOR: Victor Stello,' Jr., DeputyiExecutive Director:
i c i-Regionai Operations and Generic Requirements ii
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Richard C. DeYoung. Dimetor i.
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2 Office of Inspection and Enforcement N
SUBJECT:
CRGR REQUIREMENT COORDINATION This is in response to your memorandum dated December. 29,1981 which requested i
(by January 5,1982) comments on a strategy to coordinate requirementsrand! 2.~
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guidance far' the:SPDS, Regulatory Guide 1497 and Regulatory Guidesl.23:withm those'for emergency response. facilities and to negotiate case by case datesi:
l for. completion of these items. We will provide detailed coments by...i 4:
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January,11, 1982 on these proposals.
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In th~e interim, we have a few general thoughts.
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The paper could be read to create a new type of requirement.' If this is.the intent, the relationship to Comission regulations.should be well >
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i thought out in tenns of whether a similar pmcess to rulemaking is a:':H -
appropriate for approval.which allows coordination by offices within' :r
'.3 the agency and consideration by the Commission with input from the " :it 4
H industry and the interested public.
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2.
Some of the. list of " requirements" attached to your memorandum appear to
.be changes to specific items contained as acceptable positions in r Regulatory Guides or in documents'which have been approved by the r 'N!i
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Comission for use in the same manner as Regulatory Guides.: Simultaneous a 1.. :
i changes to these guides should be considered to avoid confusion. Some:
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" requirements" might be better stated as changes to acceptable positions !
-in these guides.
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The Division of Emergency Preparedness is examining the substance of it i
'the proposed changes to current guidance and;Will' provide coments by
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January 11,1982 as discus' sed above. We note that the guidance in the i
i area of emergency planning and response facilities were extensively l
coordinated and discussed within the staff, with the Comission, with.
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the nuclear industryind with the public through :neetings, workshops l
and coment' periods before issuance of NUREG-0654 and HUREG-0696.
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l 8201280031 820112 PDR REVGP NRCCRGR PDR s.
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i Victor Stello, Jr. ' January 5,1982 a
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We agree with your efforts to expedite. installation of the SPDS andiWe;
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recently forwarded a rule change which we.think serves this purpose.,..
c 5; Wd agree w'ith.'the idea of: setting dates on a Plant by plant.basjs pr,9vjdedi ip i
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the negotiated dates.can be kept within reason.
,n 61 We should think through the implications of changiiig' existing guidance ; i.3 i,
and assure that the result' of our current efforts is a reduction..in:a..d i i.
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uncertainty on the part of the. industry. n....c i.,
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.dchardC.DeYoung. Die r
-(Office of Inspection nd Enforcement -
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R. Hinogue H. Denton E. Jordan i
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