ML20197D344
| ML20197D344 | |
| Person / Time | |
|---|---|
| Issue date: | 10/15/1997 |
| From: | Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM) |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20197D326 | List: |
| References | |
| SECY-97-173-C, NUDOCS 9712290033 | |
| Download: ML20197D344 (2) | |
Text
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. NOT ATION VOTE RESPONSE SHEET TO: John C, Hoyle, Secretary FROM: CHAIRMAN JACKSON
SUBJECT:
SECY-97-173 - POTENTIAL REVISION TO 10 CFR 50.65(a)(3) OF THE MAINTENANCE RULE TO REQUIRE LICENSEES TO PERFORM SAFETY ASSESSMENTS w/ comments Approved x Disapproved Abstain Not Participating Request Discussion COMMENTS:
SEE ATTACHED COMMENTS.
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_ SIGNAirURE /
Release Vote / X / October 15, 1997 DATE
- - -Withhold Vote / /
Entered on "AS" Yes 'X No l
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Comments on SECY 97-173 -
l agree with the staff's plan to develop rulemaking for 10 CFR 50.65 with the following comments:
. ' The staff should not expend resources to evaluate alternative 1, as current agency practice ~
precludes crediting licensees' voluntary efforts as offsetting the potential need for regulation.
. ~ The staff should consider, under alternative 2, rephrasing the passage of interest to read: [
'in perfarming monitoring activities and pc;c:;lcll;c maintenance activities (to include thoso action'l required to preserve orrestore safety;teliability; and availability of plant structures, systems; and components within the scope of this rule), an assessment, appropriate to the circumstance, of the totalplant equipment that is out of service sketM shall be taken into -
account to determine the overall effect on performance of safety functions.'
'i he staff should report to the Commission on whether this approach, combined with regulatory guidance defining the phrase " appropriate to the circumstance," would provide the desired level of enforceability for weak programs or program execution. : It is not the inter't of this comment that quantitative criteria be required in establishing what is
' appropriate to the circumstance',' SECY 97-173 describes a number of weaknesses identified by the staff in the course of maintenance rule inspections.- The findings indicate that the staff has been able to identify both effective and ineffective programs; irr. plying that the staff has a sense of whai programmatic attributes are ' appropriate to the circumstanco."
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- 1. The statements of consideration for the Maintenance Rule include the following comments regarding the assessments referred to in 10 CFR 50.65(a)(3): 'The level of sophistication with which such assessments are performed is expected to vam based upon the circumstances involved. The assessments may range from simple deterministic judgements to the use of on-line Imng PRA*
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