NRC: Staff Requirements - SECY-03-0100 - Rulemaking Plan on Post-Fire Operator Manual Actions

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September 12, 2003

MEMORANDUM TO:	William D. Travers Executive Director for Operations
FROM:	Annette L. Vietti-Cook, Secretary /RA/
SUBJECT:	STAFF REQUIREMENTS - SECY-03-0100 - RULEMAKING PLAN ON POST-FIRE OPERATOR MANUAL ACTIONS

The Commission has approved the staff's recommendation to proceed with rulemaking, as described in Option 3, to revise fire protection program requirements contained in Appendix R of 10 CFR Part 50 and the associated guidance. In addition, the Commission has approved the staff's plan to develop an interim enforcement policy to deal with these compliance issues until the rulemaking is processed and the regulations and guidance are formally revised. The staff should leverage its past experience to develop the general acceptance criteria and expedite this rulemaking effort.

The staff estimate of 3 FTE to conduct the rulemaking and associated activities appears high for this relatively straightforward rule change.

The interim enforcement policy should be clear that it in no way obviates the need for licensees to continue documenting the technical feasibility of their operator manual actions. Likewise, the revised inspection guidance should ensure that inspections conducted during the interim period are done in an objective and consistent manner. Clearly, communications will be an essential component throughout this effort

cc:	Chairman Diaz Commissioner McGaffigan Commissioner Merrifield OGC CFO OCA OIG OPA Office Directors, Regions, ACRS, ACNW, ASLBP (via E-Mail) PDR