ML20147E064
| ML20147E064 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 04/22/1987 |
| From: | James Keppler NRC OFFICE OF SPECIAL PROJECTS |
| To: | Myers H HOUSE OF REP., INTERIOR & INSULAR AFFAIRS |
| Shared Package | |
| ML082310196 | List: |
| References | |
| FOIA-87-726 NUDOCS 8801210010 | |
| Download: ML20147E064 (5) | |
Text
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E Dr. Henry Myers,' Science Advisor Comittee on Interior and Insular Affairs United States House of Representatives Washington, O. C.
20515
Dear Dr. Myers:
The purpose of this letter is tr *espond to the inquiries contained in your note to Mr. Harold Denton dated ';nuary 27, 1987.
In that note, you discussed Criterion 3 of the Seouoyah Restart Criteria.
I, note that TVA has subitted the criteria for evaluating which issues need to be evaluated prior to restart as part of the Sequoyah performance plan and the staff is currently completing its review of this criteria.
Criterion 3 is intended to ensure that deficiencies which result in non-compliances with regulations are corrected if the NRC has not approved an exemption. Of particular concern to you was the clarification of Criterion 3 contained in a December 23, 1986 memorandum f rom R. W. Cantrell.
In that clarification it was stated that NRC regulations meant the Code of Federal Regulations, Title 10 (10 CFR) and not items such as Regulatory Guides or deviatiors from the Sequoyah Final Safety Analysis' Report. As a result of your review of this information, you identified four questions the answers to which are provided in the enclosure.
I trust that this information, resolves the concerns you identified.
Sincerely, James G. Keppler, Director Office of Special Pro,iects
Enclosure:
As stated DISTRIBUTION,
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Dr. He'nry Myers,' Science Advisor
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Committee on Interior and Insular Affairs
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United States House of Representatives Uashington, D. C.
20515
/
Dear Dr. Myers:
The purpose of this letter is to respond to the inquiries conta ed in your note to Mr. Harold Denton dated Jan'uary 27, 1987.
In that nn., you discussed Criterion 3 of the Sequoyah Restart Criteria.
Thas & teH ee-centained.
in an H I Aboreremb4emmemorandum dated December 1, 1986, nd are used by the Tenneuaa Valley.Autho.rity to determine issues that need
- o. be-resal.ved prior to rest rt o bSeeJcy=h. Criterion 3 is intended to ens re that deficiencies which result in noncompliance 5 with regulations are c rected if the NRC has not approved an exemption. Of particular concern t you was the clarification of Criterion 3 contained in a December 23, 1986 me randum from R. W. Cantrell, in that clarification it was stated that NRC reg ations meant the Code of Federal Regulations, Title 10 (10 CFR) and not ems such as Regulatory Guides or deviations from the Sequoyah Final Safety A alysis Report. As a result of your review of this information, you identif d four questions the answers to which are provided in the enclosure.
I trust that this information resolves t concerns you identified.
Sincerely, James G. Xeopler, Director Office of Special Projects
Enclosure:
As stated DISTRIBUTION Occket File
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CONGRESSIONAL STAFF MEMORANDUM ON
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From Henry Myers Re: Sequoyah Restart Criteria We have recently received information reg'arding interpretation of Criterion 3, as Criterion 3 of the Seguoyah Restart criteria.1986 memorandum from A.L. Abercrombie, presented in a December 1, stated that one consideration as to whether it woul to resolve a particular item prior to startup was that:
The item identifies a specific deficiency that results in a failure to comply with NRC regulations and no variance has been approved by the NRC.
The foregoing item was clarified in an attachment to a December 23, 1986 memorandum from R.W. Cantrell (B01 '86 1222 001):
The term "NRC regulations" as stated in this criterion is i
intended to be applied in the strict sense of the NRC Code For example, if an item results in of Federal Regulations.
the failure to meet the regulations as stated in 10 CFR 50.49, Environmental Qualification, or 10 CFR 50.48, Fire Protection, the item must be resolved prior to restart or an exemption fv.ariance) must be approved by the NRC.
The term "NRC regulations" is not intended to encompass items relating to deviations to the Sequoyah Final Safety These type Analysis Report (FSAR) or NRC Regulatory Guides.
items should be processed following 10 CFR 50.59 requirements for an Unreviewed Safety QuestionThese items are not n Determination.
resolved prior to restart.
These memoranda raise the following quastions:
Can the licensing basis be satisfied by compliance with 1.
the letter of 10 CFR 50 or is the licensing basis dependent upon FSAR commitments and interpretations of the regulations such as regulatory guides, the standard If the licensing review plan and national standards?
j basis cannot be satisfied by compliance with the letter of 10 CFR 50, which of such regulations require further
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elaboration to establish the licensing basis (or to support the restart decision)?
How does the NRC obtain assurance that a plant would 2.
withstand adequately design basis accidents in
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to circumstances where the NRC does not know the extent
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which a licensee's commitments have been fulfilled beyond the general requirements stated in 10 CFR 50
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which are made specific through regulatory guides and
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Is the 10 CFR 50.59 review process intended to be used to make changes to FSAR commitments?
Is the 10 CFR 50.59 review process intended to serve as a basis for meeting FSAR commitments?
Does MRC accept TVA's definition of Criterion.3, as 4.
clarified by the December 3 memorandum, as the basis
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for an NRC decision on restart of Sequoyah7 What is the NRC's position with respect to whether the other criteria.specified in TVA's December 1, 1986 memorandum are adequate and sufficient for determining whether particular issues need be resolved prior to restart?
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