ML20202H517
| ML20202H517 | |
| Person / Time | |
|---|---|
| Issue date: | 12/09/1997 |
| From: | Collins S NRC (Affiliation Not Assigned) |
| To: | Geoffrey Miller NATIONAL FIRE PROTECTION ASSOCIATION |
| References | |
| FACA, NUDOCS 9712100302 | |
| Download: ML20202H517 (8) | |
Text
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9 NUCLEAR REGULATORY COMMISSION E'
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December 09, 1997 George D. Miller, President and Chief Executive Officer National Firo Protection 'sssociation 1 Batterymarch Park Quincy, MA 02269-9101 Dear Mr. Miller.
Thrnk you for your letter of November 7,1997, to Chairman Jackson of the U.S. Nuclear Regulatory Commission (NRC) conceming the fire protection rulemaking effort for nuclear power plants currently being evaluated by the NRC. As you are aware, the staff is considering the development of a more risk-informed regulation to replace the existing determ!nistic and prescriptive reouirements specified in 10 CFR 50.48 and Appendix R to 40 CFR Part 50. The responsibility for this effort has been assigned to the Office of Nuclear Reactor Regulation.
Earlier this year, as part of its strategic assessms. '
J rebaselining efforts, the Commission directed the staff to increase its focus on interaction with industry and professional societies to develop new codes and standards needed to support efficient, effective, and consistent performance of ladustry activities important to safety. These codes, standards and guides would then be endorsed by the NRC. See Staff Requirements Memorandum - Direction Setting issue 13 - The Ro!e of Industry, March 7,1997, a copy of which is enclosed.
On September 11,1997, the Commission airected the staff to develop a schedule for possible expedited rulemaking and to obtain industry feedback on interest in a new rule. The Commission also directed the staff to brief the Commission on all findings, observations, and conclusions related to the rulemaking effort, including industry interaction and comments, and other relevant information. A copy of this cirective is enclosed. The views presented in your letter will La included in the Commission brie'ing tentatively scheduled for March 1998.
Following the briefi ' J, if the Commission directs the staff to proceed with the rulemaking effort or with other approaches to address fire protection issues, the participation of the National Fire Protection Association (NFPA) will be solicited by the staff.
In your letter, you indicated that you wis cd to discuss the views of the NFPA with the Advisory Committee on Reactor Safeguards (ACRS). The ACRS has tentatively scheduled a public meeting of the fire protection subcommittee for January 21-22,1998, to discuss the rulemaking effort. The ACRS staff will contact your staff regarding a possible presentation of NFPA's views 4
on the staffs proposed rulemaking.
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December 09, 1997 G.D. Miller 2
4 Thank you for your interest in the area of nuclear power plant fire protection. We look forward to further interaction with you as may be directed by the Commission.
Sincerely, Samuel J. Collins, Director Office of Nuclear Reactor Regulation
Enclosures:
As stated QlSTRIBUTION:
Central File SPLB P1F PDR SPLB Correspondence File (with diskette)
BSheron GHolahan LMarsh SWest ASingh, ACRS I
PMadden EConnell PMagnanelli(GT 970800)
KBohrer (GT 970800)
JRoe RZimmerman SCollins FMiraglia JCallan JBlaha SBurns RSeale WTravers AThadani HThompson PNorry DOCUMENT NAME: A:\\SECTIONC\\CONNELL\\NFPALTR.WPD
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G.D. Milt;r 2
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Thank you for your interest in the area of nuclear power plant fire protection. We look forward to further interaction with you as may be directed by the Commission.
Sincerely, Samuel J. Collins, Director Office of Nuclear Reactor Regulation
Enclosures:
Asstated DISTRIBUTION:
Central File SPLB R/F PDR SPLB Correspondence File (with diskette) l BSheron GHolahan LMarsh SWest ASingh, ACRS PMadden EConnell PMagnanelli(GT 970800)
KBohrer (GT 970800)
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'FMiraglia JCallan JBlaha SBums RSeale WTravers
' AThadani
- HThompson PNorry.
DOCUMENT NAME: A:\\SECTIONC\\CONNELL\\NFPALTR.WPD
- See previous concurrence SPLB:DSSA-SPLB:DSSA SPLB:DSSA Tech Editor DSSA ACRS EConnell:rmc* KSWest*
. LBMarsh*
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11/19/97 11/19/97 11/19/97 11/19/97 11/20/97 11/19/97
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0FFICIAL RECORD COPY
' Georgs D. Miller, Presidsnt end Chisf Executive Officer J
Nationtl Fire Protsetion Association 1 Batterymarch Park Quincy, MA 02269-9101 l
Dear Mr. Miller:
Thank you for your letter of November 7,1997, to Chairman Jackson the U.S. Nuclear Regulatory Commission (NRC) conceming the fire protection rulema ' g effort for nuclear power plants currently being evaluated by the NRC. As you are aware, t staff is considering the development of a risk-informeri, performance-based regulation replace the existing prescriptive requirements specified in 10 CFR 50.48 end Appendix R to CFR Part 50. The responsibility for this effort has been assigned to the Office of Nuclear actor Regulation.
Earlier this year the Commission directed the staff to crease its focus on interaction with industry and professional societies to develop new des and standards needed to support I
efficient, effective, and consistent performance o ndustry activities important to safety. These codes, standards and guides would then be e orsed by the NRC.
On September 11,1997, the Commission rected the staff to develop a schedule for exped4ed rulemaking and to obta!n industry feedb on interest in a new rule. The Commission also directed the staff to brief the Commiss n on all findings, observations, and conclusions related to the rulemaking effort, including in stry interaction and %mments, and other relevant information. The views presented
- your letter will be included in the Commission briefing tentatively scheduled for March
- 98. Following the briefing, if the Commission directs the staff to proceed with the rulemakin ffort, the participation of the National Fire Protoction Association (NFPA) will be solicited by th staff.
In your letter, you indicat that you wished to discuss the views of the NFPA with the Advisory Committee on Reactor afeguards (ACRS). The ACRS has tentatively scheduled a public meeting of the fire p ection subcommittee for January 2122,1998, to discuss the rulemaking effort. The ACRS ff will contact your staff regarding a possible presentation of NFPA's views on the staffs prop sed rulemaking.
Thank you for our interest in the trea of nvjear power plant fire protection.
Sincerely, Samuel J. Collins, Director Office of Nuclear Reactor Regulation DISTRIBUTION IS ON NEXT PAGE DOCUMENT NAME: A:\\SECTIONC\\CONNELL\\NFPALTR.WPD
- See previous concurrence SPLB:DSSA SPLB:DSSA SPLB:DSSA Tech Editor DSSA ACRS EConnell:rmc* KSWest*
LBMarsh*
BCalure*
GHolahan*
JLarkins*
11/19/97 11/19/97 11/19/97 11/19/97 11/20/97 11/19/97 ADT NRR OCM/SJ BSheron*
SCollins*
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0FFICIAL RECORD COPY d
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George D.~ Miller, Przident cnd Chhf Escutiva Officer Na ' n l Fira Prottetion Assoclition 1 Ba rymarch Park Q uinc, A 02269-9101 Dear Mr.
r:
Thank you for' ur letter of November 7,1997, to Chairman Jackson of tt)e U.S. Nuclear Regulatory Com sion (NRC) concerning the fire protection rulemaking4ffort for nuclear power plants curren being evaluated by the NRC. As you are aware /the staff is considering the development of a
- k-informed, performance-based regulation to' replace the existing
. prescriptive requiremen specified in 10 CFR 50.48 and Append h to 10 CFR Part 50. The
- responsibility for this effo as been assigned to the Office of ar Reacter Regulation.
l Earlier this year the Commissi directed the staff to increate its focus on interaction with.
j industry and professional societ' to develop nsw codes'and standards needed to support efficient, effective, and consistent rformma of inddtry activities important to safety. These codes, standards and guides would t n be endorpe'd by the NRC.
i-On September 11,1997, the Commissio ir ed the staff to develop t. schedule for expedited rulemaking and to obtain industry feedba n interest in a new rule. The Commission also directed the staff to brief the Commissiop n findings, observations, and conclusions related to the rulemaking effort, including industry inter ion and comments, and other relevant information. The views presented i our letter wi be included in the Commission briefing -
tentatively scheduled for February 3 1998. Foll g the briefing, if the Commission directs the staff to proceed with the ru m' aking effort, the pa ipation of the National Fire Protection Association (NFPA) will be s icited by the staff.
In your letter, you indicated that you wished to discuss the v of the NFPA with the Advisory Committee on Reactor' Safeguards (ACRS). The ACRS has to tatively scheduled a public mee' ng of the fire g;'rotection subcommittee for January 21-22,1
, to discuss the rulemaking.
. e# ort. The AC staff will contact your staff regarding a possible esentation of NFPA's views on the staff's oposed rulemaking.
Thank ypd for your interest in the area of nuclear power plant fire protecti Sincerely,
=
Samuel J. Collins, Director Office of Nuclear Reactor Rcgu!ation.
DISTRIBUTION IS ON NEXT PAGE
' DOCUMENT NAME: A:\\SECTIONC\\CONNELL\\NFPALTR.WPD
?See previous concurrence SPLB:DSSA SPLB:DSSA SPLB:D9SA Tech Editor DSSA ACRS EConnell:rmt ' KSWest*
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OFFICIAL RECORD COPY
George D. Millsr, Pr:sident cnd Chief Executiva Officer Na'Jonal Fire Protection Association 1 Batterymarch Park Quincy, MA 02269-9101-
Dear Mr Miller:
. I am res ~
ing to your letter of November 7,1997, to Chairman Jacksca o he U.S. Nuclear il
/
Regulatory C mission (NRC) concerning the fire protection rulemaking ort for nuclear power plants c ently being evaluated by the NRC As you are aware, t' staffis considering
- the development a risk-informed, performance-based regulation to r ace the existing prescriptive requir ts specified in 10 CFR 50.48 and Appendix R 10 CFR Part 50. The res,ponsibility for this ort has been assigned to the Office of Nu r Reactor Regulation.
J On September 11,1997, Commission directed the staff to pvelop a schedule for expedited rulemaking and to obtain i stry feedback on interest in a npw rule. The Commission also directed the staff to brief the mmission on all find;ngs, pations, and conclusions related l.
- to the rulemaking effort, includirr ndustry interaction a comments, and other relevant i
information. The views presented yourletter will be luded in the Commission briefing.
tentatively scheduled for February 1,1998. Followi the briefing,if the Commission directs the staff to proceed with the rulemaking, ort, the rticipation of the National Fire Protection l
Association (NFPA) will be solicited by th4 taff ' accordance with the Commission's direcJon in the enclosed Direction Settirg lasue 13.
In your letter, you indicated that you wis to uss the views of the NFPA with the Advisory Committee on Reactor Safeguards (AC S). The CRS has tentatively scheduled a public meeting of the fire protection subcom ittee for Ja ry 21 22.1998, to discuss the rulemaking effort. The ACRS staff will contact ur staff regardi a pos3ible presentation of NFPA's views on the staff's proposed rulemaki Thank you for yourinteres area of rcelear power nt fire protection.
Sincerely, Samuel J. Collins, D or Office of Nuclear Re r Regulation
-.--Encksmr-A
- 4 DISTRI ON:
BSheron(
GHolahan LMarsh SWest ASingh, ACRS PMadden EConnell PMagna li(GT 970800)
KBohrer(GT 970800) JRoe RZimmerman SCollin
.iraglia JCallan (Blaha SBums RSeale h
- WTravers AThadani HThompson PNorry -
DOCUMENT NAME: A \\SECTIONC\\CONNEU \\NFPALTR.WPD *See previous concurretice SPLB:DSSA SPLB:DSSA SPLB:DSSA Tech Editor DSSA ACRS r.Connell:rmc* KSWest*
LBMarsh*
BCature*
GHolahan*
JLarkins*
11/19/97 11/19/97-11/19/97 11/19/97 11/20/97 11/19/97 a
ADT
-NRR EDO OCM/SJ BSheron SCollins JCallan 11/ /97' 11/ /97 11/ /97 11/ /97 0FFICIAL RECORD COPY
/
G:org] D. Mill:r, Presid:nt cnd Chi;f Ex;cutive Officer
/
N;tional Fire Protection Association
/
1 Batterymarch Park Quinc MA 02269-9101 Dear Mr. $ 'ller I am respond g to your letter of November 7,1997, to Chairman Jackson of tp U.S. Nuclear Regulatory Com ission (NRC) conceming the fire protection rulemakiN effop for nuclear power plants currently b g evaluated by the NG C. As you are aware, the staff is considering the development of a ri -informed, Frfomiance-baseo regulation to replace the existing prescriptive requirements specifie in 10 CFR 50.48 and Appendix R to 10 CFR Part 50. The responsibility for this effort has been signed to the Office of Nuclear Reactor Re lation.
In the enclosed staff require ents memorandum dated Septem r 11,1997, the Commission directed the staff to develop a chedule for expedited rulemaV g and to obtain industry feedback on interest in a new rule. The mmission elso directed tha' staff to brief the Commission on all findings, observations, and conci' ions related to the ru! f aking effort, including industry l
interaction and comments, and oth relevant informat
. The views presert :n your letter will i
be included in the Commission briefin tentatively sch duled for February 13,1998. Following the briefing, if the Commission directs t staff to oceed with the rulemaking effort, the participation of the National Fire Protectio Ass ation (NFPA) will be solicited by the staff in accordance with the Commissica's directio i he enclosed Direction Setting Issue 13.
In your letter, you indicated that you wish to cuss the views of the NFPA with the Advisory Committee on Reactor Safeguards (AC S). The CRS has tentatively scheduled a public meeting of the fire protection subco ittee for Jar. ary 21-22,1998, to discuss the rulemaking effort. The ACRS staff will contact our staff regardi a possible presentation of NFPA's views on the staff's proposod rulemaki Thank you for your interest i the area of nuclear power pla t fue protecticn.
Sincerely, Samuel J. Collins, Directo Office of Nuclear Reactor R ulation Enclosur s: As stated DISJ IPUTION:
BSheron GHolahan LMarsh SWest
/6f" ASingh, ACRS PMadden EConnell PMagnanelli(GT 70000) /A.x KBohrer(GT 970800) 3 Cch s/6wWm u-mv HrAmy/em u e'
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DOCUMENT NAME: A:\\SECTIONC\\CONNELL\\NFPALTR.WPD *see krSIUs concurrence
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it' LBMarshh BCalure*
GHo JLarkins*
11/19 /97 11/19N7 11/$97 11/19/97 11 11/19 /97 ADT NRR EDO OCM/SJ BSheron SCollins JCallan 11/ /97 11/ /97 11/ /97 11/ /97 0FFICIAL RECORD COPY a
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- orga D. Mill:r, Pr:sid:nt cnd Chic 1 Exscutive Officer
/
N 'onil Fire Prot:ction Association
/
1B erymarch Park
/
Quin MA 02269-9101 j
Dear Mr. ' ler,
I am responoi to your letter of Novembei 7,1997, to Chairman Jackson of the U.S/ uclear Regulatory Com ission (NRC) conceming the fire protection rulemaking effort for clear power plants currently be evaluated by the NRC. As you are aware, the staff is con ering the Avelopment of a ris informed, performance-based regulation to replace the pxisting prescriptive reyirementr. specifie 10 CFR 50.48 and Appendix R to 10 CFR Part 50/rhe responsibility for this effort has been a igned to the Office of Nuclear Reactor Regula en.
i in the enclosed staff require. nts memorandum dated September 1) 1997, the Commission directed the staffic denlop a edule for expedited rulemaking and to obtain industry feedback en in'erest in a new ru';. T,Me Co mission also directed the staff fo brief the Commission on all findings, observations, and conclur ns related to the rulem ' $ effort, including industry interaction and comments, and other levant information.
views presented in your letter will be included in the Commission briefing ntatively scheduje for February 13,1998. Following the briefing,if the Commission directs the taff to p: ace,ed with the rulemaking effor1, the paiticipas 'n of the National Fire Protection sociatiort (NFPA) will be solicited by the staff in accordarme with the Commission's direction i the eric!osed Direction Setting issue 13.
/
In your letter, you indicated that you wished to di's ss the views of the NFPA with the Advisory l
Comraittee on Reactor Safeguards (ACRS).j he A S has tentatively scheduied a public T
meeting of the fire protection subcommittee for Janua 20-21,1998, to discuss the rulemaking j
effort. The ACRS staff will contact your slaif regarding ossible presentation of NFPA's views l.
on the staff's proposed rulemaking.
Thank you for your interest in the, area of nuclear power plant protection.
/
Sincerely, Samuel J. Collins, Director Office of Nuclear Reactor Regul ion Enclosure stated '
DISTRIBtfTION:
BShej6n GHolahan LMarsh SWest ASirigh, ACRS PMadden EConnell PMagnanelli(GT 9708 Q(
pEfohrer (GT 970800)
~ DOCUMENT NAME: G:\\SECTIONC\\CONNELL\\NFPALTR.WPD *See pcevious concurrence SPLB:DSSA SPLB:DSSA SPLB:DSSA Tech Editor DSSA AC MEConnell:rme KSWe LBMarsh BCalure*
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, i.etpg/www.ntc gov NRC/ STRATEGY /SRMYrm13 txt httpitwww nrc gov NRC/ STRATEGY,SRM'stm13.txt B
6 March 7-1997 MEMORANDUM TO:
L.
Joseph Callan Executive Director for Operations FROMt John C. Hoyle, Secretary
/s/
SUBJECT:
STAFF REQUIREMENTS - COMSECY-5 5-062 -
STRATEGIC ASSESSMENT ISSUE PAPER:
THE ROLE OF INDUSTRY (DSI 13)
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The NRC should move as expeditiously as possible, within budget constraints, to evaluate on a case by case basis initiatives proposing further NRC reliance on industry activities as an alternative for NRC regulatory activities.
Staff guidance should be developed to describe tne process and the general decision l
criteria NRC would use for evaluating proposals. (Option 1)
The staff should explore wnether other public agencies provide models or informative experiences regarding this type of process and general decisional criteria.
In addition, tha staff's development of decisional criteria should include consideration of the effects on public access to information on safety-significant industry activities if tha NRC relies on an industry activity as a substitute for Nhc regulatory action.
Accreditation and certification programs for licensee activities can be considerad in the context of. Option 1.
In adde. ion, the NRC should increase its focus and emphasis on interacting with both industry groups and professional societies and technical institutes to develop new codes, standards, and guides needed to support efficient, effective, and consistent performance or industry activities important to safety. These codes, standards and guides would then be endorsed by the NRC.
(Option 4)
The staff should develop an implementation plan for pursuing Option 4 that addresses the following:
1) the need to streamline and simplify the NRC's internal process for endorsing codes and standards within a year after they arc issued by a professional society.
Consideration should be given to the American Society of Mechanical Engineers' recommendation to maximize concurrency in the professional society process and the NRC regulatory process.
2) internal performance indicators to ensure timely update of gegulations and regulatory guides.
3) the degree to which the currer.t backfit rule implementation unnecessarily impedes the adoption of updated codes and standards.
4) whether greater use should be made of all available codes and standards (not just ASME and IEEE standards) in our regulations and regulatory guides.
5) whether che intent of Public Law 104-113 ir being fully a? dressed in all of our regulatory requirements and guides.
6) where there are needs for new codes, standards, and guides and recommendations for areas of emphasis. The NRC's initial activities in pursuing option 4 should include standards development in Probabilistic Risk Assesamont (PRA) as discussed I of 2 I1/19 97 06 56 16
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in the PRA Framework Document (SECY-95-280),
7) an assessment of the required NRC resources and anticipated periods for commitment of such resources.
l f
1 (EDO)
(SECY Suspense:
8/29/97) l This Direction Setting Issue (DSI) is closely related to DSI-11, Operating Reactor Program Oversight, and DSI-12, Ris k~In f o rmed, Performance-Based Regulation. The staff should ensure tha' implementation plans developed for these issues are mv.ually compatible and do not create duplicate activities, cc: Chairman Jackson Commissioner Rogers Commissioner Dieus Commissioner McGaffigan l'
Comraissioner Diaz K. Cyr (OGC)
D. Rathbun
('CA)
O H. Bell (OIG)
A. Galunte (CIO)
R. Scroggins (CFO)
F.. Jordan (SARSC)
J. Silber (SARSC) 4
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. httpEwhwntc gorHRC/...NRC-PDR/1997-127stm txt httpfwwwnre gooNRC FEDWORLDNRC PDR/1997127stm txt September 11, 1997 MEMORANDUM TO:
L. Joseph Callan Executive Director fer Operations f
FROM:
John C.
Hoyle, Secretary
/s/
SUBJECT:
STAFF REQUIREMENTS - SECY-97-127 -
DEVELOPMENT OF A RISK-IMFORMED, PERFORMANCE-BASED REGULATION FOR FIRE PROTECTION AT NUCLEAR POWER PL\\NTS This is to advise you that the Commission has reviewed the subject paper and agreed on the following approach.
The staff should finalize the current research and study by the end of this year, as noted in the paper. The staff should then obtain OGC feedback on the backfit implications and industry feedback on interest in a rule and present this it. formation in a briefing to the Commission. The briefing should incorporate all findings, observations, and conclusions to that point, including, but not limited to, PRA and fire modeling results, fire protection functional inspection (s) results, IPEEE (fire) results, backfit determinations, industry interaction and cot.ments, and other relevant information.
(EDO) (SECY Suspense:2/13/98)
The staff shoAld provide the Commission a schedule for expedited rulemaking.
(EDO) (SECY Suspense: 10/10/97)
The staff should expedite the resolu'clon of issues necessary to formulate a proposed rule which will eliminate the need for most of the 850 exemptions granted under current rules and which takes a more risk-informed (as opposed to deterministic) and a more performance-based (as opposed to prescriptive) approach where that is appropriate and justifiable.
However, the staff should not force-fit risk-informed, performance-based elements into areas that are not amenable to such approaches.
In the development of the a fire protection rule and pecformance objectives the staff should fully consider and develop an approach consistent with the current state of fire modeling and PRA usage in fire protection programs.
The responsibility for this rulemaking effort should be shifted from Research to NRR in accordance with the guidance in DSI-22.
The staff should continue co coordinate additional research (performed cooperatively with industry, if possible) as necessary to complete any longer term items, or improvements to regulatory guidance in support of further risk-informed efforts. The staff should assess the current regulatory requirements so as not to eliminate current requirements that continue to be appropriate during the transition to more risk-informed fire protection requirements.
The Commission should be informed of significant policy and technical issues that arise as a result of staff efforts that impact the schedule.
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Chairman Jackson Commissioner Dicus Commissioner Diaz Commissioner McGaffigan OGC CIO CFO OCA OIG Office Directors, Regions, ACRS, i.CNW, ASLBP (vie E-Mail:
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