ML20199L550
| ML20199L550 | |
| Person / Time | |
|---|---|
| Issue date: | 12/10/1998 |
| From: | Diaz N NRC COMMISSION (OCM) |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20199L527 | List: |
| References | |
| SECY-98-279-C, NUDOCS 9901280049 | |
| Download: ML20199L550 (2) | |
Text
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DEC-10-1998 12:56 NRC 727 363 1339 P.22/04 A F F i R M_ A T I O N VOTE I
RESPONSE SHEET TO:
Jchn C. Hoyle, Secretary FROM:
COMMISSIONER DIAZ
SUBJECT:
SECY-98-279 PARTIAL GRANTING OF PETITION FOR RULEMAKING SUBMITTED BY THE NUCLEAR ENERGY INSTITUTE (PRM-60-82)
X Approved Disapproved Abstain Not Participating l
l COMMENTS:
l See attached comments.
hY SIGNATURQ
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\\0,W DATE Entered on "AS" Yes No
- 82"!82 M 38a" CORRESPONDENCE PDR q q oj > b DO
DEC-10-1998 12*56 NRC 727 353 1339 P.03./04 1
CQMMISSIONER DIA2' COMMENTS ON SECY-98._279 I approve the staff's i=--- =4= den to publish the proposed Direct Final Rule and a companion Proposed Rule in the Federal Register Notice. I note that the permitted QA program changes are programmatic in nature and do not encourage the staff and the industry to be more risk-informed l
in decision making which is what would permit giving reliefin a variety of day-to-day in-plant l
activities such a maintenance, surveillance, and testing, as wcIl as licensee's QA program 4es.
I also approve the staffs proposal to work with stakeholders and yid with a second l
rd==": to develop a voluntary alternative to 50.54(a). The staff should strive to establish a 1
new risk-informed threshold for QA program 4;; without prior NRC approval. I believe that the decision threshold should be # 3.s the cMi = would result in little or no adverse unpact on the overs!1 plant safety. As I have stated beibre, the fimdamental gwi.a should be for the equipment to have "the T !ity to perform the intended safety functions. Upon W
e +;W of the current effort to unake ths 50.59 process more risk-informed, ennaderation should be given to whether the revised 50.59 process could be used by licensees to change their QA programs.
l I tecommend the following additions (in bold) to the proposed 50.54(aX3) language:
l
- 1. ". Safety Analysis Report without prior NRC approval, provided the change does not reduce the comunitments..."
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- 2. 'In addition to quality assurance program Mes involving adminiserettva impnsvements and clar*=d==, spelling corrections..." J I 'c-l J
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