ML20056A324
| ML20056A324 | |
| Person / Time | |
|---|---|
| Issue date: | 06/25/1990 |
| From: | Curtiss J NRC COMMISSION (OCM) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| NUDOCS 9008060383 | |
| Download: ML20056A324 (2) | |
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N 0 T A T I.0 N VD*T.6...........'"f fiELEASED TO THE PDR RESPONSE SNEET *
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TO:
SAMUEL J.-CHILK, SECRETARY 07 THE COMMISSION FROM:
COMMISSIONER CURTISS
SUBJECT:
- INDIVIDUAL PLANT EXAMINATION FOR SEVERE ACCIDENT VULNERABILITIES DUE TO EXTERNAL EVENTS (IPEEE)
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APPROVED X/in part DISAPPROVED X/in part ABSTAIN
-NOT PARTICIPATING REQUEST DISCUSSION.
C0lHENTS:
I See attached comments, 1
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SIGNATURE E
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RELEASE VOTE
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June 25, 1990 DATE WITHHOLD' VOTE
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YES. l/
?dfo3 ENTERED ON "AS" No 9
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Commissioner Curtiss' comments on SECY-90-192:
I agree with the recommendation of Commissioner Remick that the proposed IPEEE letter, together with the guidance document, should be issued in draft form at this point, with a directive to the staff to submit the final version of the letter to the Commission for our review before issuing it in final fstm.
Additionally, prior to the issuance of this letter in final form, I would request the Office of General Counsel to undertake an analysis of the backfit issue raised by the Nuclear Utility Backfitting and Reform Group (NUBARG), focusing in particular on their argument that where it is unclear at the outset whether a backfit will follow an information request, such cases should be resolved in favor of conducting a backfit analysis under section 50.109 (See J.etter from Nicholas S.
Reynolds to Edward L. Jordan, I
April 13, 1990, p. 6).
If, as the language accompanying the 1985 i
amendments to section 50.54 (f) seems to suggest, a backfit analysis is called for in a case such as this, we should either undertake such an analysis or, if such an analysis makes no sense for information requests of this nature, we should revisit the existing regulation (or the accompanying Statements of Consideration) and modify the approach that was endorsed in 1985.
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