Staff Requirements Memorandum
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The NRC has approved the Staff's recommendation that the NRC delegate to the staff the making of the 10 CFR 52.103(g) acceptance criteria finding for all Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC), irrespective of the pendency of any hearing. Given the lack of clarity regarding processes for ITAAC hearings, the Staff, the Office of the General Counsel, and the Office of Commission Appellate Adjudication should develop a range of options for ITAAC hearing formats for Commission review and approval. These options should ensure that, in practice, the actions of the Commission in determining adequate protection during the period of interim operation cannot be construed as prejudicing the staff’s findings with respect to ITAAC closure. Procedures related to the conduct of ITAAC hearings should be developed, deliberated, and resolved within the next 12 to 18 months.