ML20132F450
| ML20132F450 | |
| Person / Time | |
|---|---|
| Issue date: | 12/16/1996 |
| From: | Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM) |
| To: | Rossin A STANFORD UNIV., STANFORD, CA |
| Shared Package | |
| ML20132F454 | List: |
| References | |
| NUDOCS 9612240268 | |
| Download: ML20132F450 (5) | |
Text
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- j# "%g*, UNITED STATES 3 NUCLEAR REGULATORY COMMISSION Distribution
, I o WASHINGTON, D.C. 206W0001 JTay1or j JMilhoan
%, f December 16, 1996 HThompson
.,,,, JBlaha CHAMMAN 00 d' KCyr, OGC CPaperiello, NMSS Regional Administrators GT96696 ED0 r/f Mr. A. David Rossin Center Affiliated Scholar Center for International Security and Arms Control at Stanford 24129 Hillview Drive Los Altos Hills, California 94024
Dear Mr. Rossin:
I am responding to your letter of September 3,1996, which sets forth your views regarding the treatment of margin in the Commission's regulatory activities. After your letter was received, members of the staff talked with you to clarify your concerns related to the impact of regulatory activities on margin. The Commission has an initiative underway that is, among other matters, reexamining the current practices related to the maintenance of margin during a plant lifetime and the need for regulatory review when margins are changed. Your concerns will be considered as part of the staff developraent of regulatory positions in these areas.
As you may know, the staff recently found that, at some plants, plant conditions had been modified such that the plant was no longer in compliance with regulatory requirements. As a result, the staff is reviewing the requirements for maintaining plant design bases and the guidance for complying ,
with those requirements. In connection with these efforts, the staff intends l to work i.ith the industry and others to obtain a broad spectrum of views. !
Thank you for your interest and views on these matters.
Sincerely, b
I 9612240268 961216 PDR COMMS NRCC CORRESPONDENCE PDR l
l
[0riginatedBy: J. Birmingham, NRR]
. . ._ . _ _ ~ . - _ . . _ __ _ .
~
Mr. A. David Rossin Center Affiliated Scholar Center for International Security
/#
and Arms Control at Stanford
! 24129 Hillview Drive I Los Altos Hills, CA 94024
)
Dear Mr. Rossin:
/
I i I am responding to your letter of September 3,1996, which sets forthuryo/
j views regarding the treatment of margin in the Commission's regulatory i activities.
Pursuant to 10 CFR 50.59, a licensee may make changes to its facfi ity or i proceduresasdescribedinitsFinalSafetyAnalysisReport(F)AR)withoutNRC 3 approval if it determines that such changes do not involve ap unreviewed safety question or a change in a technical specification. s provided in 10 CFR 50.59, an unreviewed safety question is considered o exist if, among
, other things, the margin of safety as defined in the b3sis for any technical
- specification is reduced. If a licensee proposes to odify its facility or
- procedures as described in the FSAR, in a way that uld involve a reduction j in the level of margin established by the license and considered in NRC
! licensing reviews, then NRC review and approval the proposed change is required.
Recently, the NRC found that, at some plant , modifications to plant design bases documented in the safety analysis re ort (SAR) and in plant technical specifications (TSs) had not been implem ted in complete accordance with
! 10 CFR 50.59. The staff found that so plant conditions were modified to such a degree that the plant was no 1 ger in compliance with NRC regulatory
{ requirements. Accordingly, the sta has focused and will continue to focus j its inspection and oversight activ) ties on plant modifications and on changes
- in licensee-established design and operating margins, as well as on the
- reviews made to support them, ensure regulatory requirements are met.
Thank you for your interest nd views on this matter.
Sincerely,
]
Shirley Ann Jackson EDO CONTROL:GT96696 DOCUMENT NAME g G:\JLB\ROSSIN.LTR 0FFICE Tech Ed* PGEB PGEB PGEB NAME BC41ure JBirmingham FAkstulewicz 0Matthews DATE 10/01/96 10/17/9 ,
10/17/96 10/18/96 D:DRPMk YDU NAME / SBurns lP TMartin " Oj d@ia JTbT@s DATE 10/21/960 10/J8'/96 10 @ 96 104W96
/ Sk 0FFICIAL RECORD COPY
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E' v*z ACTION N S pec.m M w s l l EDO Principal Correspondence Control to #,57 M%a. .Tawes FROMs DUE: 09/27/96 EDO CONTROL:(GT96696.1
_ DOC DT:' 09/03/96 FINAL REPLY:
- A. DI.vid Rossin TO
l
' Chairman Jackson 2
FOR SIGNATURE OF : ** PRI **
CRC NO: 96-0981
' Chairman Jackson DESC:
ROUTING: !
MARGIN AS !! SED IN THE REGULATORY SENSE Taylor !
Milhoan i Thompson Blaha Paperiello,NMSS DATE: 09/17/96 ASSIGNED TO: CONTACT:
NRR Russell SPECIAL INSTRUCTIONS OR REMARKS:
(Coordinate with OGC. ;
ACTION NRR RECEIVED: SEPT MBER 17 g 1996 NRR ACTION: ADPR: . GRIME 5 00E TO RR DIRECTOR'S OF
/ /
NRR ROUTING: l,R USSELL "AIRAai.IA BY/M/ M '
M ANI _
ZIMMERMAN /
- MARTIN B0HRER
$ . OFFICE CF THE SECRETARY 4
, i , CORRESPONDENCE CONTROL TICKET PAPER NUMBER: CRC-96-0981 LOGGING DATE: Sep 16 96 i
ACTION OFFICE: EDO/OGC ~
4 AUTHOR: A DAVID ROSSIN
- AFFILIATION: CALIFORNIA ADDRESSEE: CHAIRMAN JACKSON j LETTER DATE: Sep 3'96 FILE CODE:
SUBJECT:
MARGIN--REGULATORY l
ACTION: Signature of Chairman
, DISTRIBUTION: CHAIRMAN l SPECIAL HANDLING: SECY TO ACK CONSTITUENT:
NOTES: hbk Mf DATE DUE: Sep 30 96 SIGNATURE: . DATE SIGNED:
AFFILIATION:
1 i
EDO -- GT96696