Can the agency give examples of the kinds of escalated issues that might arise, which the industry will need to address?
In light of the past attention to license renewal and the extensive plans for monitoring passive components, the NRC staff anticipates that such issues will be rare and exceptional. For such issues, the agency has the capability, at a moment’s notice to bring together an intra-agency review involving the NRR Division of Operator Reactor Licensing (DORL) and Division of License Renewal (DLR), the Office of Enforcement (OE), the Office of the General Counsel (OGC), and the applicable regional office. For example, if a change to a commitment uses an AMP method of detection or acceptance criteria that the staff has not yet reviewed, and the process is proven to be ineffective in fulfilling the original commitment, the change may well be a potential safety issue subject to escalated enforcement if it constitutes a violation by license condition, or if the licensee failed to follow a change process required by regulation. The change may also be a violation of 10 CFR 54.29(a), a standard for
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