Rather than modifying the current rule, could an alternative approach be used to achieve NRC objectives?
To obtain individual plant examinations (IPEs) for power reactors, the NRC invoked its authority to require additional information from licensees. This approach might be used to obtain the information produced by an ISA, including information about the items relied on for safety. Could the IPE approach also be used to ensure the establishment of safety programs needed to guarantee the availability and reliability of those items? Another method for achieving NRC objectives is to define needed requirements and incorporate them as conditions in the license. Is this a viable approach? NRC staff initial position: A rulemaking process, including the development of relevant guidance documents, is appropriate for imposing generic requirements. Although NRC has the authority to require licensees to fix any specific safety problem, it is not clear whether the Commission has the authority to impose programmatic requirements without identifying a specific safety issue that would be addressed by th
