ML20237F176

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Forwards H Myers to H Denton Re Plant Restart Criteria,For Consideration
ML20237F176
Person / Time
Site: 05000000, Sequoyah
Issue date: 01/29/1987
From: Kammerer C
NRC OFFICE OF CONGRESSIONAL AFFAIRS (OCA)
To: Harold Denton
Office of Nuclear Reactor Regulation
Shared Package
ML082310219 List:
References
FOIA-87-726 NUDOCS 8712290412
Download: ML20237F176 (1)


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January 29, 1987

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TY W MEMORANDUM FOR: Harold Denton, Director Office of Nuclear Reactor Regulation FROM:

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SUBJECT:

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CONGRESSIONAL STAFF MEMORANDUM ON SEQUOYAH RESTART l

We are forwarding the attached memorandum from the majority staff l

of the House Interior Comittee for your consideration.

Attachment:

January 27, 1987, memorandum from Henry Myers to Harold Denton Re: Sequoyah Restart Criteria cc:

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OIA OI TVA Program Staff l

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January 27, 1987 To Harold Denton FromHenryMyersp Re: Sequoyah Restart Criteria We have recently received information regarding interpretation of Criterion 3 of the Sequoyah Restart Criteria.

Crit;erion 3, as presented in a December 1, 1986 memorandum from A.L. Abercrombie,

.i stated that one consideration as to whether it would be necessary to resolve a particular item prior to startup was that:

The item identifies a specific deficiency that results in a failure to comply with NRC regulations and no variance has-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):

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 Protection, the item must be resolved prior to restart or an exemption (variance) must be approved by the NRC.

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

These type items should be processed following 10 CFR 50.59 requirements for an Unreviewed Safety Question Determination.

These items are not normally required to be resolved prior to restart.

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 interpretations of' the regulations such as regulatory guides, the standard review plan and national standards?

If the licensing _

basis cannot be satisfied by compliance with the letter of 10 CFR 50, which of such regulations require further elaboration to establish the licensing basis (or to support the restart decision)?

2.

How does the NRC obtain assurance that a plant would withstand adequately design basis accidents in circumstances where the NRC does not know the extent to 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 m..

other regulatory documents?

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Is the 10 CFR.50.59 review process intended to be used to make changes to FSAR commitments?.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 wheth3r particular issues need be resolved prior to rescart?

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......o February 9, 1987 MEMORANDUM FOR:

Tom Rehm. A stant to EDO FROM:

Steve Kent CA

SUBJECT:

Dr. Myers' Request Dr. Henry Myers, Science Advisor to the House Interior Subcommittee on Interior and Insular Affairs, has asked that we provide the Subcommittee with a list of amendments (since January 1,1985) to licensing documents for each of the following TVA plants:

a)

Browns Ferry 1, 2 and 3 9 Mf " / "

b)

Sequoyah 1 and 2 2 2 M3 ?>d c)

Watts Bar 1 and 2 M / M' d)

Bellefonte 1 and 2 9Y>/4VI Please send the lists to Fred Combs in our office. Thanks.

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