HPPOS-139 PDR-9111210375

Use of “Open Items List” by Inspectors

See the memorandum from J. H. Sniezek to E. L. Jordan dated July 12, 1985. The memo states that open items declared on an inspection report, when based on new staff interpretations of existing positions, are plant-specific backfits in accordance with the policy established by NRC Manual Chapter 0514. The memo is presented in its entirety. The referenced memorandum (R. L. Baer to Branch Chiefs in Regions and NRR, June 12, 1985, Subject: “Proposed Guidelines for Inspecting Radioiodine Sampling Capability per NUREG-0737, Item II.F.1.2”) encloses a draft memorandum to Region Division Directors advising that deviations by licensees from the technical guidance contained (in the draft memorandum) shall be “… held as open items on the inspection report and referred to NRR for evaluation on a case specific basis.” You should note that open items declared on an inspection report, when based on new staff interpretations of existing positions, are plant-specific backfits in accordance with the policy established by NRC Manual Chapter 0514.

Further, in this case, the new interim guidelines for sampling system acceptance are obviously to be applied generically prior to imposition on licensees.

Regulatory references: 10 CFR 2, 10 CFR 50.109

Subject codes: 12.7, 12.19

Applicability: All