U.S. Nuclear Regulatory Commission

Use of "Open Items List" by Inspectors

HPPOS-139 PDR-9111210375

Title: 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