ML20041C623

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Submits Comments Re 7th Meeting of Committee to Review Generic Requirements on 820203.Minutes Do Not Reflect Full Scope of Discussion on SRP Rule & May Be Misleading on Emergency Response Issue Re Ofc Director Concurrence
ML20041C623
Person / Time
Issue date: 02/24/1982
From: Eisenhut D
Office of Nuclear Reactor Regulation
To: Stello V
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
Shared Package
ML19291F701 List:
References
NUDOCS 8203020394
Download: ML20041C623 (2)


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UNITED STATES y

-"h NUCLEhR REGULATORY COMMISSION 4

,j WASHINGTON, D. C. 20555 I

J February 24, 1982 l

MEMORANDUM FOR:

Victor Stello, Jr., Chairman Conunittee to Review Generic Requirements FROM:

Darrell G. Eisenhut, Director Division of Licensing

SUBJECT:

MINUTES OF CRGR MEETING #7 Having reviewed the minutes of CRGR Meeting No. 7 dated, February 18, 1982, I offer the following cont.ents:

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1.

RE: SRP Rule l

i I note that the minutes do not reflect that the CRGR had discussions concerning:

a.

The safety benefit to utilities through an SRP standardized, systematic design verification I

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review, b.

That CRGR members discussed several options or

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variations to the Rule as proposed; for example,

[i applying it to " future" applications only, or limiting it to " safety significant" SRP items, and

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c.

The credibility of the industry estimates of up to 134 man-years additional resources required per plant.

In addition, I note that the tone of the minutes puts too much emphasis on the issue of resources and not l

enough on the benefits, particularly when recognizing j

that the benefits from any Rule of this type would be hard to quantify and that almost any new Rule will require resources. The question therefore is not just how many additional resources are required; rather its whether the benefits warrent the expenditure of such resources.

For future plants several years away, I believe the balance to be in favor of having an SRP Rule - for out-plants the expenditure of such resources will be minimized and the resources will less likely need to be diverted i

l from other on-going upgrades at operating reactors.

8203020394 820226 PDR REVGP NRCCR

2.

RE:

Emergency Response Facility Issues I believe the minutes may be misleading. Thr.

January 29, 1982 document was concurred in by the Office Directors with comments. Your February 11, 1982 memorandum transmitted a revised final version of that document which you characterized as "a reconciliation of NRR, IE, CRGR, DEDROGR and industry comments."

I therefore believe that you shouldn't characterize it as the document carrying Office Director concurrence unless you later request such concurrences.

I,-

Darrell G. Eisenhut, Director Division of Licensing cc: R. Bernero 1

J. Heltenes E. Jordan D. Mausshardt T. Murley J. Scinto W. Schwink e

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