ML20042B454

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Summary of Committee to Review Generic Requirements 820224 Meeting.Items Discussed Include Proposed post-CP Change Rule & Proposed Revision 1 to Reg Guide 1.23.List of Attendees Encl
ML20042B454
Person / Time
Issue date: 03/16/1982
From: Stello V
Committee To Review Generic Requirements
To: Dircks W
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
References
RTR-REGGD-01.023, RTR-REGGD-1.023 NUDOCS 8203250331
Download: ML20042B454 (3)


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NEMORANDUM FOR: William J. Dircks Executive Director for Operations d 5 F " /k L~

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Victor Stello, Jr., Chairman t'

Comittee to Review Generic Requirements

SUBJECT:

MINUTES OF CRGR MEETING NO. 8 The Comittee to Review Generic Requirements met on Wednesday, February 24, 1982, from 1-6 p m.

Attendance at the meeting is shown in the Enclosure.

The following matters were considered:

1.

RES (W. Campbell) presented the proposed Post-Construction Permit (CP) Change Rule. The Comittee noted that cost-benefit infomation 1

was not presented and that interof' ice coordination and other staff work remained to be accomplished. Nonetheless, the Committee supported the goal of the proposed rule, which is to assure +. hat post-CP changes having potential safety impacts would be justified by the licensees and forwarded to NRC for consideration early enough to minimize the impact of any subsequent NRC decisions on construction.

Tne extended CRGR discussion brought out several points:

(a) The draft rule proposed that post-CP changes would be permitted unless the change involves a change in the conditions of the CP or "when considered in conjunction with all prior changes would have altered the outcome of the construction permit proceeding." The Comittee felt that the latter criterion would require a judgment virtually impossible to make several years after the CP record is completed. The Qomittee suggested that a more explicit and easily measured criterion would be needed.

(b) The Committee suggested that changes to the current 10 CFR 50.59 should be coordinated with those existing and closely related regulations that also bear on post-CP change considerations, such as 10 CFR 50.55(e) and 10 CFR 21.

(c) It was suggested that the language of the rule should not require the CP holder to obtain a threshold judgment from the NRC in the event that the licensee "cannot determine" whether or not a proposed change woCd have altered the outcome of a proceeding. The Comittee suggested that the rule require the licensee to make the decision and then submit the decision and Qg suonortina ana lysis to NRC for annroval.

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MAR 161982 William J. Dircks The Comittee requested that the proposed rule be resubmitted for further CRGR consideration after staff work has been completed.

The submission should include information addressing the items in Chairman Palladino's memorandum to the EDO dated October 8,1981, and further detailed in the CRGR charter,Section IV.B. disseminated on November 18, 1981.

2.

RES (L. Beratan and L. Brown) presented the proposed Revision 1 of Regulatory Guide 1.23, Meteorological Measurement Program for l

Nuclear Power Plants. CRGR had reviewed the proposed Guide at the meeting on November 19, 1981, and had judged that there was in-sufficient information on the relative costs and benefits to re::omend I

approval at that time.

l During the extensive discussion, some apparent inaccuracies and l

deficiencies came to light regarding instrument accuracies and data i

resolution, system reliability requirements and quality assurance requirements. In addition, the Comittee judged that the Guide i

presented an inadequate discussion of safety benefits and justification of the proposed implementation plan.

In light of these deficiencies, and the fact that the Committee could discern no clear-cut need for the revised Guide, the CRGR recommended that the proposed Revision 1 of Regulatory Guide 1.23 not be issued.

Origim1 sisacq by l

Eictop,StcMop Victor Stello, Jr., Chairman Committee to Review Generic Requirements

Enclosure:

List of Attendees cc: CRGR Members Office Directors Regional Administrators G. Cunningham, ELD Comission (5) l Distribution:

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CRGR MEETING #8 ATTENDANCE 1

(2-24-82)

CRGR Members Vic Stello Don Mausshardt Bob Bernero Ed Jordan Jack Heltemes Joe Scinto Darrell Eisenhut Others Walt Schwink, DEDR0GR Tom Murley, DEDR0GR Tom Cox, DEDR0GR Mat Taylor, DEDROGR Ed Abbott, OCM Howard Wong, IE Tony DiPalo, RES Gerry Tomlin, RES Steve Stern, NRR Bill Shields, ELD Bill Campbell, RES Robert Kornasiewicz, RES Leta Brown, RES Barry Zalcman, IE Irwin Spickles, NRR Jerry Hulman, NRR Steve Ramos, IE Leon Beratan, RES 4