ML18051A998

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SRM-M180208: Discussion of Potential Changes to the 10 CFR 2.206 Enforcement Petition Process
ML18051A998
Person / Time
Issue date: 02/20/2018
From: Annette Vietti-Cook
NRC/SECY
To:
References
Download: ML18051A998 (1)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 20, 2018 IN RESPONSE, PLEASE REFER TO: M180208 MEMORANDUM TO: Victor M. McCree Executive Director for Operations FROM: Annette Vietti-Cook, Secretary /RA/

SUBJECT:

STAFF REQUIREMENTS - DISCUSSION OF POTENTIAL CHANGES TO THE 10 CFR 2.206 ENFORCEMENT PETITION PROCESS, 9:00 A.M., THURSDAY, FEBRUARY 8, 2018, COMMISSIONERS CONFERENCE ROOM, ONE WHITE FLINT NORTH, ROCKVILLE, MARYLAND (OPEN TO PUBLIC ATTENDANCE)

The Commission was briefed by Emily Hammond, Glen Earl Weston Research Professor, George Washington University Law School; Ellen Ginsberg, Vice President, General Counsel and Secretary, Nuclear Energy Institute; David Lochbaum, Director, Nuclear Safety Project, Union of Concerned Scientists; Samuel Miranda, Petitioner; and the NRC staff on the current status of the 10 CFR 2.206 enforcement petition process and potential changes to the process.

As the staff prepares a draft final Management Directive, the staff should (1) evaluate whether the petitioner should have an opportunity to pose clarifying questions of the licensee during the initial meeting, facilitated by the Petition Review Board Chairman; (2) consider whether to provide a mechanism for the petitioner to request an informal EDO review of a director's decision; (3) further clarify when a streamlined director's decision is appropriate; (4) clarify the language for the initial screening process for determining whether a request for action is within the scope of 10 CFR 2.206; and (5) ensure that the Management Directive clearly articulates the responsibility of the staff to promptly file director's decisions with the Office of the Secretary.

The staff should also make a redline/strikeout version of the proposed changes to Management Directive 8.11 available to the Commission and external stakeholders. The draft final Management Directive should be provided to the Commission for information.

cc: Chairman Svinicki Commissioner Baran Commissioner Burns OGC CFO OCA OIG OPA ODs, RAs, ACRS, ASLBP (via E-Mail)

PDR