ML20138B858
| ML20138B858 | |
| Person / Time | |
|---|---|
| Issue date: | 03/21/1997 |
| From: | Diaz N NRC COMMISSION (OCM) |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20138A938 | List: |
| References | |
| SECY-97-035-C, SECY-97-35-C, NUDOCS 9704290296 | |
| Download: ML20138B858 (2) | |
Text
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NQT-ATION VOTE RESPONSE SHEET TO:
John C. Hoyle, Secretary FROM:
COMMISSIONER DIAZ j
SUBJECT:
SECY-97-035 - PROPOSED' REGULATORY-GUIDANCE RELATED TO IMPLEMENTATION OF 10 CFR 50.59 (CHANGES, TESTS AND EXPERIMENTS)
Approved Disapproved Abstain i
'Not Participating Request Discussion COMMENTS:
1 av 0 /J "
7 t
SIGNATURE )
/
Release Vote
/ V/
3-1 ~O DATE Withhold Vote
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/
Entered on "AS" Yes
/
No I
E l E l'd E l a 3 e l
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L.s.; v ; y 9704290296 970425 PDR COMMS NRCC CORRESPONDENCE PDR p,
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i COMMISSIONER DIAZ' COMMENTS ON SECY-97-035 I agree with the staff recommendation with the following modifications and comments.
I approve the issuance of the proposed regulatory guidance and the discussion of the policy issues and options related to the implementation of 10 CFR 50.59 for a 60-day public comment period. Although the 50.59 policy issues discussed in this paper are closed linked to some of the issues raised in SECY-97-036," Millstone Lessons Leamed, Part 2," the far reaching implication of these policy issues and its potential rulemaking activities make it appropriate and timely to be issued for public comment. The definition, content, and update requirement for licensing basis, design bases, and the FSAR are directly linked to the interpretation and implementation of 50.59. Therefore, the policy issues raised in SECY-97-036 that have a potential for rulemaking should also be issued for public comment.
. For the short term, I recommend that we provide clarification of the rule regarding the definitions used in determining an unreviewed safety question, and to clarify whether small increases in the l
probability and consequences of an accident or malfunction, as well as small reductions in the margin of safety are acceptable in determining whether the licensee proposed changes constitute an unreviewed safety question.
l For the long term, I recommend that we reevaluate the requirements set forth in 10 CFR 50.59, taking into consideration its ties with other regulatory requirements, such as Appendices A and B to 10 CFR 50, and develop an integrated approach that includes clear, consistent definitions and i
risk considerations.
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