ML20127M127
| ML20127M127 | |
| Person / Time | |
|---|---|
| Issue date: | 09/11/1992 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Dunning T Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20127M067 | List: |
| References | |
| NUDOCS 9301280117 | |
| Download: ML20127M127 (3) | |
Text
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,b UNITED STATES 3 D ? NUCLEAR REGULATORY COMMISSION WASHINoTON, D C. 20555
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\ *"** / SEP 111992 MEMORANDUM FOR: Thomas G. Dunning, Senior Reactor Engineer Technical Specifications Branch Division of Operational Events Assessment Office of Nuclear Reactor Regulation FROM: James H. Taylor Executive Director for Operations
SUBJECT:
DIFFERING PROFESSIONAL OPINION (DPO) - REGULATORY AND TECHNICAL SPECIFICATION REQUIREMENTS FOR ELEClRICAL POWER SOURCES Pursuant to NRC Directive 10.159, I requested that a panel review the subject DP0, make a recommendation and provide the basis for that recommendation to the EDO regarding disposition of the DPO. The review has been completed and the panel's report is enclosed.
I have concluded that one area of your concern, the consistency (i.e.
relationship) between General Design Criteria (GDC) and the Technical Specifications (TS), does need clarification (item 1 below), and should be communicated to both staff and industry (item 2 below).
With respect to your concern with enforcement, our primary focus should be enforcing positions which are supported by accurate interpretations of existing requirements and by safety evaluations. The Regulatory Analysis, performed as part of the proposed generic letter to resolve shutdown and low-power issues, presides the rigorous snalytical justification for improvement of the existing TS at the appropriate facilities. The Shutdown Risk Program is currently providing the appropriate risk-based approach, justification, and process for producing substantial additional protection and improving overall consistency of TS (item 3 below).
I have tasked the Director, Office of Nuclear Reactor Regulation, with the following actions:
- 1. Clarify the relationship between the General Design Criteria and the exceptions to the GDC allowed by the Technical Specifications, include examples, one of which should be the subject of the DPO, the RHR system during cold shutdcwn and refueling.
- 2. Communicate the above clarification to NRC staff and licensees.
Enclosure 8 9301280117 921228 PDR MISC 9301200098 PDR-
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l Thomas G. Dunning SEP 111992
- 3. Assure that the licensee responses to the yet to be issued generic letter on reducing risk during shutdown and low power operations either fully comply with the Model Technical Specifications presented in the generic letter or, if not, that a valid safety evaluation be presented to justify the position taken. This should eliminate or provide a rational basis for the Technical Specification differences from the GDC as identified in the DPO.
- 4. Provide an overall schedule for accomplishing the above actions.
Pursuant to NRC Directive 10.159 and with the initiation of the above actions, this matter is considered closed and will not be considered further absent significant new information.
Original Signed By:
James M. Taylor James M. Taylor Executive Director for Operations
Enclosure:
DP0 Panel Report cc: J. Sniezek P. Bird T. Murley L. Chandler document name:G:\DP01-A,kd1 DISTRIBUTION:
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. WEEKLY INFORMATION REPORT (INPUT)
. The E00 recently made a decision on a Differing Professional Opinion (DPO) concerning regelatory and technical specification (TS)- requirements for electrical power sources. The decision involved initiation of the following actions by the Office of Nuclear Reactor Regulation.
- 1. Clarify the relationship between -the General Design Criteria and the exceptions to the GDC allowed by the Technical Specifications.
- 2. Communicate the above clarification to NRC staff and licensees.
- 3. Assure that the licensee responses to the yet to be issued generic letter on reducing risk during shutdown and low power operations either fully comply with the Model Technical Specifications' presented in the generic letter or, if not, that a valid safety evaluation be presented to justify the position taken. This should eliminate or provide a rational basis for the Technical Specification differences from the GDC as identified in the DPO.
- 4. Provide an overall schedule for accomplishing the above actions.
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Enclosure 10
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