ML20154L836
| ML20154L836 | |
| Person / Time | |
|---|---|
| Issue date: | 05/07/1984 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20151C834 | List: |
| References | |
| FOIA-87-714, RTR-NUREG-0801, RTR-NUREG-801 NUDOCS 8603120387 | |
| Download: ML20154L836 (1) | |
Text
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. MAY 0 71964 MEMORANDUM FOR: Harold R. Denton, Director .
Office of Nuclear Reactor Regulation l FROM: William J. Dircks l Executive Director for Operations
SUBJECT:
PUBLICATION OF NUREG 0801, "EVALUATION CRITERIA FOR DETAILED CONTROL ROOM DESIGN REVIEWS"
Reference:
Memo H. R. Nnton to W. J. Dircks dtd April 25, 1984, subject same as above I have thought about this proposed NUREG and its relationship to the industry
. NUTAC documents. Before a decision is made, I believe we should meet to discuss the matter further. We should at least consider the option to endorse, with any acsolutely necessary qualifying modifications or exceptions, those NUTAC document (s) that might provide adequate controls in this area. This approach follows the normal NRC practice of endorsing available industry standards. Such action would be a positive step in the direction of encouraging the industry to take the initiative in proposing responsible technical resolutions which we might be able to accept as meeting NRC reouirements.
Further, we must resist the practice of developing requirements guidance in the context of a NUREG and then, at some later and more convenient time, merely referencing that NUREG in a few sentences added into a Standard Review Plan.
Such a practice would clearly promo'te the development of more and more prescriptive requirements since an almost unlimited volume of text in a NUREG can be used to define a "requirement."
NUREGs, both contractor and staff, are appropriate for describing work done relevant to the development of new requirements, but sheuld not be used as the official expository description of the requirement.
We are comitted to using the Standard Review Plan and Regulatory Guides as the concise, definitive description of what the staff believes is a completely adequate way to meet NRC regulations. A succinct representation of staff position, expressed in a few pages in a Standard Review Plan, augmented by a few more in a Regulatory Guide, should provide the necessary and sufficient exposition of NRC guidance in a given technical area. I am not inclined to depart from this approach without a compelling reason.
Please set up a meeting with me on this sometime in the next two weeks.
(S!pesEmam 1.Di:cks William J. Dircks Executive Director for Operations cc: V. Stello l CRGR Members l Distribution WDircks EDO rf DEDROGR cf VStello JSniezek 0 ,CoxJ .k T . JRoe f
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