ML20237F147

Requests Clarification of Interpretation of Criterion 3 of Plant Restart Criteria as Presented in AL Abercrombie & RW Cantrell Memos & 1223,respectively

ML20237F147
Person / Time
Site:	05000000, Sequoyah
Issue date:	01/27/1987
From:	Myers H HOUSE OF REP.
To:	Harold Denton NRC
Shared Package
ML082310219	List: ML20237D944 ML20237D957 ML20237E102 ML20237E728 ML20237F147 ML20237F176 ML20237F221 ML20237F254 ML20238C111 ML20238C124 ML20238C137 ML20238C160 ML20238C224 ML20238C232 ML20238C256
References
FOIA-87-726 NUDOCS 8712290394
Download: ML20237F147 (2)

Text

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Novak 1

W5'~%

January 27, 1987

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To Harold Denton From Henry Myers Re: Sequoyah Restart Criteria We have recently received information regarding interpretation of Criterion 3 of the Sequcyah Restart Criteria.

Criterion 3, as presented in a December.1,1986 memorandum from A.L. Abercrombie, stated that one consideration as to whether. it would be necessary to resolve a particular item prior to startup was that:

i The item identifies a specific ~ deficiency that'results in a-f ailure to comply with NRC regulations and no variance hes-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):

I The term "NRC regulations" as stated in 'this criterion is-intended to be applied in the. strict. sense of the. NRC ; Code of Federal Regulations.

For example, if an item results in the failure to meet the regulations as-stated in 10 CFR 50.49, Environmental Qualification, or 10 CFR 50.48, Fire

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Protection, the ites must be resolved prior to restart or-en I

exemption (variance) must be approved by' the NRC.

The ~ term "NRC regulations" is not intended to encompass items relating to dev4ations to the Sequoyah -Final Safety Analysis Report (FSAR) or NRC Regulatory Guides.

items should be processed following 10 CFR 50.59 These type requirements for an Unreviewed Safety Question These items are not normally required to be j

Determination.

resolved prior to restart.

i These memoranda raise the following questions:

1.

Can the licensing basis be satisfied by compliance with the letter of 10 CFR. 50 or is the. licensing basis dependent upon FSAR commitments and interpretaticans of the regulations such as regulatory guides, the standard l

review plan and national standards?, If the licensing

-i 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)?.

t 2.

How does the NRC obtain. assurance that a plant would withstand adequately design basis accidents in j

circumstances where the NRC does not know the artent to i

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which a licensee's commitments have been fulfilled beyond the general requirements stated in -10 CFR 50 -

which are made specific through regulatory guides and N

other regulatory documents?-

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WANN87-726 PDR

3.

Is the 10 CFR 50.59 review process = intended to be used to make changes to FSAR com itments?

Is the 10 CFR 50.59 review process-intended to serve as a basis-for meeting FSAR commitments?

4.

Does NRC accept TVA's definition of Criterion 3, as clarified by the December 3 memorandum, as'the basis for an NRC decision on restart of Sequoyah?

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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