ML20053E086
| ML20053E086 | |
| Person / Time | |
|---|---|
| Issue date: | 05/21/1982 |
| From: | Johnson P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-47FR13369, RULE-PR-50 47FR13369-3, NUDOCS 8206070589 | |
| Download: ML20053E086 (2) | |
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DOCKET !!U'.'dOD g ggg Q MEMORANDUM FOR: Samuel J. Chilk, Secretary of the Comission ATTN :
Docketing and Service Branch
)M THRU:
D. M Sternberg, Chief, Reactor Operations Project Branch, Region V FROM:
P. H. Johnson, Reactor Inspector, Region V
SUBJECT:
COMMENTS ON PROPOSED RULE (50.36)
As a whole, I feel the proposed rule is good. The revised rule should allow more flexibility in dealing with changes in license specifications without adversely affecting nuclear safety. However, I have one principal reserva-tion in that present technical specifications requirements regarding the use of procedures are not being retained as Technical Specifications (i.e.,
made a part of the operating license).
Section 6.8 of the Standard Technical Specifications (STS) presently establishes requirements regarding procedures and programs as follows:
6.8.1 - Identifies written procedures which the licensee must establish, implement, and maintain.
6.8.2 - Defines review and approval requirements for 6.8.1 procedures.
6.8.3 - Prescribes methods for issuing temporary changes to 6.8.1 procedures.
6.8.4 - Requires certain other programs (e.g., Radiation Monitoring) to be established, implemented, and maintained.
Of these sections of the STS, I feel it is important that at least Sections 6.8.1, 6.8.2, and 6.8.3 be retained in the Technical Specifications. This would main-tain uniform treatment of procedural requirements (and temporary changes) throughout the industry. Otherwise, one can expect that over the period of a few years, Supplemental Specifications governing the use of procedures will become excessively diverse. This, combined with the movement of industry personnel between sites and utilities, will have an adverse effect on nuclear 95 10 safety.
Differences in areas such as plant design, organizational structures, and review group activites are recognized, and persons being reassigned will 3
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Samuel J. Chilk May 21, 1982 be sensitive to these differences. The nuclear industry currently abides by reasonably standardized requirements regarding the maintenance and use of approved procedures, however, and it is important that uniform industry attitudes in this area be maintained.
In view of the above, I recommend that the title of proposed 50.36(d)(1)(v) be changed to read " Operational Staffing, Procedural Controls, and Reporting Requirements," and that the following sentence be added to the present text of that section:
" Procedural controls are requirements governing the establishment and maintenance of an effective procedures system at an operating facility."
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