ML20209B960
| ML20209B960 | |
| Person / Time | |
|---|---|
| Issue date: | 02/16/1983 |
| From: | Eisenhut D Office of Nuclear Reactor Regulation |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20209B956 | List: |
| References | |
| FOIA-86-729 NUDOCS 8303030728 | |
| Download: ML20209B960 (2) | |
Text
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- k4 NUCLEAR REGULATORY COMMISSION I [g hs5 (j), oI.. WASHINGTON, D. C. 20555 - Enclosure #1
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February.16,1983 MEMORANDUM FOR: Harold Denton, Director '
Office of Nuclear Reactor Regulation
,FROM:~ Darrell Eisenhut, Director Division of Licensing '
PROPOSED FINAL RULES: (10 CFR 50.72 AND 50.73,
SUBJECT:
IMMEDIATE NOTIFICATION AND NEW LER SYSTEM)
We. support AE00 and the Commission's 1983 PPG in going forward with these rules at this time 1(i.e.. Alternative 3).- However, we believe' a strong caveat, extensive editorial ~ re-wo,'rk, and a. slightly delayed effective date are needed.
We find fhat the proposed rules by themselves would.not satisfy our infonnational needs regarding operational safety. -Thus, we are concerned about the advisability of eliminating the current legal requirement for licensees to provide the needed
'infonnation and of depending upon an industry system,'which _is voluntary to supply this infonnation, and which also continues to face difficulties in becoming operational .-
.The AE0D monitoring of the progress being made in developing the INP0/NPRDS to date has been excellent. However, additional action is appropriate and necessary.
We believe that the " forward" of the LER rule must be revised to include a strong caveat which makes it explicitly clear that we are relaxing the reporting requirements with the. expectation that sufficient utility cooperation, participa-tion and support of NPRDS will be forthcoming and that, if the system is not operational at a satisfactory level'in a reasonable time, remedial NRC action in the form of rulemaking will become necessary.
We note that the Commission's 1983 Policy and Planning Guidance includes the decision to go forward with an LER rule. We support this policy decision.
We believe that some reporting requirements (e.g. setpoint drifts) have become excessive and burdensome, and that the-benefits of a revised reporting system that is consolidated and integrated are substantial, both to the industry and to the NRC. We support the AE00 recommendation for Alternative Number 3, i.e.
going forward with rulemaking at this time.
In order to minimize the loss of data, we recommend that the effective date of the LER rule be several months subsequent to its publication date.
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Harold Denton We are concerned about the present quality of both proposed rules. They seem to' lack editorial clarity, need to be better coordinated, and may not be effective in accomplishing their objectives. We recommend extensive rework before proceeding to CRGR. Additionally, we find the Regulatory Analyses to be weak, especially in the areas of identifying what requirements the rules eliminate and explaining what NPRDS will provide. ,
Specific comments are provided by the enclosures to this meno.
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\ - I RUS11. AuL Darrell Eisenhut, Director Division of Licensing
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Enclosures :
- 1. Memo: Minners to Ros'ztoczy,1/11/83
- 2. Memo: Brinkman to Halahan,1/26/83 ,
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