ML20029E193
| ML20029E193 | |
| Person / Time | |
|---|---|
| Issue date: | 11/30/1989 |
| From: | Beckjord E NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | Jordan E Committee To Review Generic Requirements |
| Shared Package | |
| ML20028G715 | List: |
| References | |
| NUDOCS 9405170167 | |
| Download: ML20029E193 (16) | |
Text
,
4 l
8(gag jo UNITED STATES t
g NUCLEAR REGULATORY COMMISSION n
E WASHINGTON, D. C. 20555
/
s
'Sy WOV 3 01999
^
MEMORANDUM FOR: Edward L. Jordan, Chairman, Committee to Review Generic Requirements
)
FROM:
Eric S. Beckjord, Director, Office of Nuclear Regulatory.
Research
SUBJECT:
FINAL RULE ON ACCESS AUTHORIZATION This letter responds to your memorandum of September 29, 1989 to James M.
Taylor, Acting Executive Director for Operations, (Enclosure 1) in which you reported the results of CRGR's review of the proposed Final Rule on Access Authorization We have modified the subject rulemaking (Enclosure 2) in the areas that the Committee had identified to be addressed further by the staff.
An advanced copy of the package was submitted to you earlier on November 6, 1989.
Specifically, the areas identified by CRGR have been addressed as follows:
1.
We have modified the supplemental information section of the Federal Register notice to explain clearly the need for the rule for existing plants. We have reexamined our position on some of the exceptions to l
the NUMARC Guidelines.
We have also explored the possibility of issuing a rule that would adopt the existing NUMARC Guidelines without any exceptions. At the next meeting, the staff will be prepared to discuss the results.
2.
The differences in the approaches to maintenance (as exemplified in the Maintenance Policy Statement and the proposed rule) and access authorization are not as fundamental as they may have appeared to be based on the previous transmittal.
In each case, the overall objective is improved effectiveness which will last through the life of the plar.t/ license.
There now exists an industry standard which many but not all licensees have adopted formally in their physical security plans. This rulemaking establishes general. requirements for access authorization.in the NRC's regulations, and the regulatory guide endorses the industry standard.
Because there is no comparable endorsable industry standard for maintenance, we have proceeded along a path providing considerable flexibility.
3.
We agree that the rule previously proposed did not address adequately the issue of unescorted access during cold shutdown. We have modified our position by taking an exception to the Guidelines in the regulatory guide and propose to develop generic guidance on this in the future.
The rule allows for the relaxation of access authorization during cold shutdown provided that there are procedures in the site Physical 9405170167 891221 PDR REVGP NROCRCR.,
MEETING 175' PDR 3
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i 1
5 3 0 1999 2
Security Plan to provide assurance that no tampering has occurred during the relaxation of requirements.
At this time such procedures-would be developed on a case by case basis.
4.
We have removed the exception to the Guidelines which required the 1
written personality test to be both valid and reliable.
5.
Rather than substitute the word " continued" for " continual" as suggested by CRGR, we have re.. sed the rule to simply require
" behavioral observation." This change conforms to the language used in the recent rulemaking on Fitness for Duty. This also avoids a l
potential confusion as the Guidelines use the word " continual" in l
describing the behavioral observation program.
l
\\
L The regulatory guide now has the following four exceptions to the Guidelines i
in its regulatory position, at least two of which could be considered language clarifications:
(i)
A review process for employees of contractors and vendors as well as of licensees.
(ii)
An exception to the requirement for relaxation of access authoriza-l tion during cold shutdown.
l (iii) A modification of the grandfathering provision that would require the access authorization to be in place for at least six months prior to publication of this rule.
(iv)
A modification of the audit period for licensees access authorization programs to require that those parts of the programs conducted by an outside contractor be audited annually.
As required by the CRGR charter, we are providing you with the following information:
The current version of the rule language is included in the draft Federal Register Notice (Enclosure 2-of the Commission Paper).
The current version of the guidance is included as draft Regulatory Guide 5.XX, Access Authorization Program for Nuclear Power Plants, which contains the NUMARC Guidelines as an appendix (Enclosure 3 of the Ccmmission Paper).
NRR, the sponsoring officc, has concurred in this rule with comments (Enclosure 3). We are in the process of incorporating the cormients which we believe do not alter the overall philosophy of the rule.
HMSS and ADM have also concurred. OE has nonconcurred based on concerns about enforceability (Enclosure 4). 0GC reviewed a previous draft of this rule (August 30,1989) and had no legal objections.
They are in the process of completing their review of the current draft.
3 30 1999 The rule specifies an implementation date of 180 days after the date of publication in the Federal Register.
The Regulatory Impact Analysis (RIA), revised to rel., :t the comments of CRGR, is included (Enclosure 4 of the Commission paper).
l l
The program applies only to nuclear power reactors.
An evaluation of this rule pursuant to 10 CFR 50.109, namely a backfit analysis, is provided as Appendix B in the RIA (Enclosure 4 of the Commission paper).
Finally, based on above considerations, I have determined that:
(a) the proposal would result in a substantial increase in the overall protection of public health and safety, and (b) the direct and indirect costs of implementation, for the facilities affected, are justified in view of this increased protection.
If you have any questions, please call me at x23700 or Dr. Sandra Frattali of ny staff at x23773.
UM Eric S. Beckjor( Director Office of Nuclear Regulatory Research
Enclosure:
- 2. Commission Paper:
Access Authorization for Nuclear Power Plants
l l
l l
i i
3 0 1989 MEMORANDUM FOR:
Edward L. Jordan, Chairman, Committee to Review Generic Requirements FROM:
Eric S. Beckjord, Director, Office of Nuclear Regulatory Research l
SUBJECT:
FINAL RULE ON ACCESS AUTHORIZATION This letter responds to your memorandum of September 29, 1989 to James M.
Taylor, Acting Executive Director for Operations, (Enclosure 1) in which you j
reported the results of CRGR's review of the proposed Final Rule on Access Authorization We have modified the subject rulemaking (Enclosure 2) in the l
l areas that the Committee had identified to be addressed further by the staff.
An advanced copy of the package was submitted to you earlier on November 6, 1989.
)
Specifically, the areas identified by CRGR have been addressed as follows:
1.
We have modified the supplemental information section of the Federal Register notice to explain clearly the need for the rule for existing plants. We have reexamined our position on some of the exceptions to the NUMARC Guidelines. We have also explored the possibility of issuing a rule that would adopt the existing NUMARC Guidelines 4
without any exceptions.
At the next meeting, the staff will be prepared to discuss the results.
2.
The differences in the approaches to maintenance (as exemplified in the Maintenance Policy Statement and the proposed rule) and access authorization are not as fundamental as they may have appeared to be based on the previous transmittal.
In each case, the overall objective is improved effectiveness which will last through the life of the plant / license.
There now exists an industry standard which many but not all licensees have adopted formally in their physical security plans. This rulemaking establishes general requirements for access authorization in the NRC's regulations, and the regulatory guide endorses the industry standard. Because there is no comparable endorsable industry standard for maintenance, we have proceeded along a path providing considerable flexibility.
3.
We agree that the rule previously proposed did not address adequately the issue of unescorted access during cold shutdown. We have modified our position by taking an exception to the Guidelines in the regulatory guide and propose to develop generic guidance on this in the future.
The rule allows for the relaxation of access authorization during cold shutdown provided that there are procedures in the site Physical
2 NOV 3 01999 Security Plan to provide assurance that no tampering has occurred during the relaxation of requirements. At this time such procedures would be developed on a case by case basis.
4.
We have removed the exception to the Guidelines which required the written personality test to be both valid and reliable.
5.
Rather than substitute the word " continued" for " continual" as suggested by CRGR, we have revised the rule to simply require
" behavioral observation." This change conforms to the language used in the recent rulemaking nn Fitness for Duty. This also avoids a potential confusion as the Guidelines use the word " continual" in describing the behavioral observation program.
The regulatory guide now has the following four exceptions to the Guidelines in its regulatory position, at least two of which could be considered language clarifications-(1)
A review process for employees of contractors and vendors as well as of licensees.
(ii)
An exception to the requirement for relaxation of access authoriza-tion during cold shutdown.
(iii) A modification of the grandfathering provision that would require the access authorization to be in place for at least six months prior to publication of this rule.
(iv)
A modification of the audit period for licensees access authorization programs to require that those parts of the programs conducted by an outside contractor be audited annually.
As required by the CRGR charter, we are providing you with the following information:
The current version of the rule langucge is included in the draft Federal Register Notice (Enclosure 2 of the Commission Paper).
The current version of the guidance is included as draft Regulatory Guide 5.XX, Access Authorization Program for Nuclear Power Plants, which contains the NUMARC Guidelines as an appendix (Enclosure 3 of the Commission Paper).
URR, the sponsoring office, has concurred in this rule with comments (Enclosure 3). We are in the process of incorporating the comments which we believe do not alter the overall philosophy of the rule.
HMSS and ADM have also concurred. OE has nonconcurred based on concerns about enforceability (Enclosure 4). OGC reviewed a previous draft of this rule (August 30,1989) and had no legal objections.
They are in the process of completing their review of the current draft.
~~~
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. September 29, 1989 MEMORANDUM FOR:
James M. Taylor Acting Executive Director for Operations FROM:
Edward L. Jordan, Chairman Committee to Review Generic Requirements l
SUBJECT:
MINUTES OF CRGR MEETING NUMBER 169 i
The Committee to Review Generic Requirements (CRGR) met on Wednesday, September 13, 1989 from 1:00-5:30 p.m.
The following items were addressed at the meeting:
i 1.
The Committee reviewed the proposed Revised Final Policy Statement on Maintenance Programs in Nuclear Power Plants.
The Committee recommended
)
in favor of issuing the proposed policy statement, subject to a number of modifications (to be coordinated with the CRGR staff).
This matter is discussed in Enclosure 1.
2.
The Committee considered the proposed Final Rule on Access Authorization, but did not complete their review..The Committee identified a number of areas to be addressed further by the staff when the review of this item is resumed at a future meeting. These matters are discussed in Enclosure 2.
In accordance with the ED0's July 18,1983 directive concerning " Feedback and Closure of CRGR Reviews," a written response is required from the cognizant office to report agreement or disagreement with the CRGR recommendations in these minutes. The response, which is required within five working days after receipt of these minutes, is to be forwarded to the CRGR Chairman and if there is disagreement with CRGR recommendations, to the ED0 for decisionmaking.
Questions concerning these meeting minutes should be referred to Jim Conran (492-9855).
gg gg gy.,
C.J. Heltemes,Jr.
Edward L. Jorda,
hairman Committee to Review Generic i
Requirements
Enclosures:
As stated Distribution: (w/o enclosures)
Central File L. Shao (w/ enc.)
cc w/ enclosures:
PDR (NRC/CRGR)
- 8. Morris-(w/ enc.)
Commission (5)
S. Treby T. King (w/ enc.)
3 SECY W. Little S. Bahadur (w/ enc.) @_
J. Lieberman M. Lesar E. Jordan (w/ enc.)
/,23 P. Norry P. Kadambi (w/ enc.)
J. Heltemes (w/ enc.)
J. Conran (w/ enc.)
Regional Administrators CRGR SF (w/ enc.)
D. Allison (w/ enc.)
CRGR Members M. Taylor (w/ enc.)
0FC : CRGR:A OD :
AE00 DD
- C/CRG EOD :
NAME :J. nran:cg : CJH mes : EL dan 9M89 DATE :
9/7 /89 9/p89
,3 0FFICIAL RECORD COPY (Enclosure 1)
W.-.gg Q
l l to the Minutes of CRGR Meeting No. 169 l
Proposed Rule on Access Authorization September 13, 1989 1
l TOPIC l
B. Morris (RES) and S. Bahadur (RES) presented for CRGR review the proposed Final Rule on Access Authorization.
(The subject of Access Authorization was considered previously by the Committee at Meeting Nos. 16, 40, 82, and 102.)
i Briefing slides used by the staff to guide their presentation and discussion with the Committee at this meeting are enclosed (Attachment 1).
I j
BACKGROUND l
1.
The documents submitted initially to CRGR for review in this matter were transmitted by memorandum dated August 31, 1989, E. S. Beckjord to E. L. Jordan; that initial review package included the following documents:
a.
Draft Commission paper, dated August 30, 1989, " Access Authorization Program for Nuclear Power Plants" (ADVANCE COPY), and attachments as follows: - Staff Requirements Memorandum, dated April 19, 1989, S. J. Chilk to V. Stello, Jr. - Proposed Federal Notice, dated August 30, 1989 - Draft Regulatory Guide 5.XX, dated August 25, 1989 - Draft Regulatory Analysis, dated August 1989, (includes Backfit Analysis - Appendix E) - Draft Congressional Letter (undated) - Draft Public Announcement (undated) 2.
Just prior to Meeting No. 168, the Committee received a retransmittal of the package of documents listed in 1 above - (see memorandum dated September 11, 1989, E. S. Beckjord to E. L. Jordan).
This later review package contained a revised version of the proposed Federal Register Notice for this proposed action that reflected additional interoffice review comments by NRR, OGC, and ADM.
(The transmittal memorandum and revised Federal Register Notice pages included under this item are enclosed as Attachment 2 to this Enclosure.)
i
. l CONCLUSIONS / RECOMMENDATIONS J
The Committee did not complete their review of this agenda item at Meeting No.
169; the review will continue at a future meeting.
Principal areas of discus-sion at this meeting that need to be addressed further by the staff at the next meeting on this item are identified below:
In view of statements in the package that the proposed rule (and imple-1.
menting Reg. Guide) result in minor impacts on licensees because they essentially only codify and standardize current licensee practices, the Committee questioned the need for a new rule at this time, at least for They also questioned the justification provided for existing plants.
the incremental requirements (i.e., Reg. Guide exceptions) recommended by the staff in this package.
(see further discussion of one specific incremental requirement in item 4 below.) The Committee requested J
specifically that the staff be prepared to discuss at the next meeting on this item the option of issuing a rule that would adopt without any exceptions the existing NUMARC guidelines.
The Committee noted the contrast between the staff's approach to improve-2.
ment of licensees' maintenance programs (as evidenced in the proposed Maintenance Policy Statement also reviewed at this meeting, and in the recent proposed Maintenance Rule) and the main " theme" of this proposed In the case of maintenance programs, the staff Access Authorization Rule.
has emphasized achieving effectiveness, not consistency, in the licensees' In this access authorization package, the main emphasis seems programs.
to be on achieving consistency (standardization) in the licensses' programs.
The Committee noted that, while the greatest risk of plant damage and 3.
release of radioactive materials due to sabotage would seem to be associated with access of large numbers of temporary workers to " devitalized" areas of the plant during cold shutdown, existing access authorization programs seem to afford the least controls / protection in that aspect.
The proposed rule does not seem to address this perceived weakness; in fact, some questioned whether the proposed package represents a relaxation over the status quo in that regard.
The Committee questioned the (incremental) requirement in this package 4.
that the written psychological tests employed by licensees in screening candidates for unescorted access be certified " valid" as well as The information in the package on this point seems to indi-
" reliable."
cate that no currently available tests have been validated for application in testing nuclear power plant workers specifically; and this seemed to indicate that the proposed new rule contains a requirement that arguably could not be met by licensees.
The Committee also noted in this context that (a) NRC consultant's expert opinion as presented in the review package seems to indicate that currently available written psychological test methods are expected to produce high false positive indications, and (b) NRC employees requiring unescorted access are routinely certified as adequately stable by their supervisors without the need for written test results based on close observation of behavior over a period of time.
J a
For:
The Commissioners From:
James M. Taylor, Acting Executive Director for Operations
Subject:
ACCESS AUTHORIZATION PROGRAM FOR NUCLEAR POWER PLANTS
Purpose:
To obtain Commission approval of a notice of final rulema king.
Issue:
Establishment of Nuclear Regulatory Commission (NRC) regulations for granting unescorted access authorization to personnel at nuclear power plants.
Background:
On August 1,1984 (49 FR 30726), the Comission published a proposed rule that would require an access authorization program at nuclear power plants. Major elements of the proposed program included requirements for background investigations and psychological assessment and the develop-ment and implementation of a behavioral observation program.
Comments received from industry groups, including the Nuclear Management and Resources Council (NUMARC), the Edison Electric Institute, and later, the Atomic Industrial Forum, and KMC, Inc., suggested the rule be withdrawn, and proposed that it be replaced with an industry-developed initiative to commit voluntarily to industry guidelines for an access authorization program. The Commission directed the staff by memorandum dated June 25, 1986, to cooperate with industry in developing, for Commission approval, a policy statement endorsing NUMARC guidelines entitled " Industry Guidelines for Nuclear Power Plant Access Authorization Programs" (hereafter referred to as "the Guidelines"). On March 9, 1988 (53 FR 7534), the Commission published a proposed policy
Contact:
Dr. Sandra Frattali, RES 492-3773
4 t
The Commissioners 2
statement endorsing Revision 8 of the Guidelines.
The Federal Register notice requested public comments regarding the policy statement vs. the rulemaking option.
In SECY 89-98, staff reported on those public comments to the Commission.
The Commission subsequently decided to proceed with a rule-making, and by memorandum dated April 19, 1989 (Enclosure 1),
directed the staff to prepare a final rule to require access
' authorization programs at nuclear power plants. The rule would specify the major attributes required by the program.
It would be accompanied by a regulatory guide endorsing the latest version of the Guidelines, with appropriate exceptions, as one acceptable means of complying with the rule. The. staff has prepared for the Commission's approval the notice of final rulemaking (Enclosure 2) and the regulatory guide (Enclosure 3).
A new regulatory analysis which includes a backfit analysis (Enclosure 4) has also been prepared.
Discussion:
Licensees continue to differ from each other in their access authorization programs in both their commitments in their Physical Security Plans and their actual practices. The present rulemaking and associated regulatory guide will specifically accomplish the following:
Clearly define a standard acceptable to the NRC for establishment of access authorization programs for existing and future plants.
' Require those licensees not currently committed to and implementing the major attributes for access authorization programs to improve their program to the level of the rest of the industry.
Provide assurance that. access authorization programs will meet an acceptable standard for the lifetime of the plant and facilitate an effective inspection and enforcement process.
Establish an idustry-wide standard on access authorization programs that would allow reciprocity in granting access authorization thus eliminating duplicative efforts and resulting in significant savings.
The Commissioners 3
The rule codifies the three basic elements of background investigation, psychological assessment, and behavioral observation as the attributes required by an access authorization program.
In addition, the rule also allows grandfathering of access authorization, temporary access authorization, transfer of access authorization, reinstatement of access authorization and relaxation of access authorization during cold shutdown and refueling.
Furthermore, the rule requires a review procedure when denying or revoking access authorization. The associated regulatory guide provides a program acceptable to the NRC for complying with the require-ments of the rule.
It endorses, with appropriate exceptions,
" Industry Guidelines for Nuclear Power Plant Access Authorization Programs, Revision BB," the latest version of the Guidelines, which is provided as an appendix in the regulatory guide.
Revision 88 incorporates the changes and clarifica-tions made by NUMARC in response to public comments on the proposed policy statement.
The public has had the opportunity to comment twice on the technical and policy issues involved in this rulemaking, once in 1984 on the proposed rule, and again in 1988 on the proposed policy statement. Extensive public comments were received on both occasions. The response to the public comments on the proposed rule of 1984 was included in SECY-85-381 as part of the Insider Safeguards Rules and is available in the public document room.
The comment period on the proposed policy statement was scheduled to expire on May 9, 1988.
However, comments received subsequent to that date were also considered.
The Federal Register notice addresses the public comments on the proposed policy statement including the Guidelines. The sumary of public comments also includes, where applicable, a discussion of the public comments on the proposed rule.
Exceptions to the Guidelines The regulatory guide endorses, as one means of complying with the rule, the Guidelines, Revision 88, with exceptions or additions in four areas:
review process, relaxation during cold shutdown, grandfathering, and frequency of the audit of utilities' programs.
The Guidelines include a review process specifically for permanent employees of the licensee. The rule provides for a review process for all employees adversely affected by a denial of access authorization by their employer, whether licensee or contractor. The regulatory guide affirms the
1 The Commissioners 4
I review process as provided for by the rule and includes an exception in the regulatory position. The justification for this requirement is given in the statement of considerations included in the Federal Register. notice.
The Guidelines provide for relaxation of the unescorted access authorization requirements during refueling or maintenance outages in which all or part of a nuclear power plant is in cold shutdown, refueling, or devitalized status.
The i
relaxation of requirements for access authorization as allowed in the Guidelines combined with devitalization of parts or all of the facility could allow one or more individuals with minimal clearance unescorted access to vital plant equipment.
)
The Guidelines' requirements for " thorough visual inspection" prior to start-up and " appropriate procedures" to assure proper functioning of systems are intended to provide assurance that the function of vital equipment is not impaired during this period when control of the access to the devitalized areas was reduced. Although the general intention of the provisions of the Guidelines is appropriate, (i.e., that access requirements can be reduced because the potential consequences of sabotage are reduced when a facility is in cold shutdown or defueled),
the Guidelines do not provide clear guidance on actions required.
to insure proper functioning of ecuipment in both the protected and vital areas prior to startup. Therefore, an exception i
which eliminates this section of the Guidelines is included in I
the regulatory position.
The rule provides for a relaxation of access authorization when a nuclear power plant is in cold i
shutdown during refueling or major maintenance provided that there are NRC approved procedures in the site Physical Security Plan that provide meaningful assurance that no tampering occurred during the relaxation of requirements.
The i
staff intends to study further the issue of compensatory measures for safeguards after devitalization and issue generic guidelines based on the results.
Provisions currently in the licensee's Security Plan for relaxation of access controls and necessary compensatory measures are not affected.
The Guidelines allow grandfathering of any individual holding a valid access authorization either on the date of the implementation of the rule or anytime during the previous 365 day s.
This would allow for the possibility of grandfathering 1
without either a complete screening or a sufficient meaningful period of behavioral observation.
To eliminate this possibility, only those individuals may be grandfathered who have had an uninterrupted access authorization for at least 180 days on the
The Commissioners 5
date the final rule is published in the Federal Register. An exception to the Guidelines is included in the regulatory position.
The Guidelines provide for an evaluation of the utilities' access authorization programs every two years.
In the past, the staff has noted significant problems associated with contracted screening services of inadequate or incomplete programs for screening individuals working at nuclear power reactors. Based on the fact that these observations were not isolated instances, the staff has concluded that licensees need to closely monitor these programs and that a 12-month period would be the minimum audit frequency necessary for any part of the program conducted under contract. This would enable the licensee who conducts under contract any part of its access authorization program to identify problems, and to take timely corrective action before the program is severely subverted. As required by the rule, an exception to the Guidelines is provided in the regulatory guide which requires a yearly audit of any part of the licensee's program which is conducted under contract.
Background Reinvestigation In the congressional hearing resulting from the GA0 report regarding NRC's security programs, a commitment was made by the NRC to consider a reinvestigation element in the access authorization program.
In order not to delay this rulemaking by introducing an element not previously included for public comment, it was decided to proceed with a separate rulemaking.
A proposed rulemaking to amend 10 CFR 73.57, " Requirement for a Criminal History Check," requiring a new criminal history check every five years, is being initiated by RES.
If additional requirements for a background reinvestigation for access authorization are determined to be desirable, they can be considered as that rulemaking proceeds.
Recommendations: That the Commission:
1.
Ap3 rove the amendments set forth in Enclosure 2 for pualication in final form in the Federal Register.
2.
Certify that this rule, if promulgated, will not have a significant economic impact on a substantial number of small entities, in order to satisfy the requirenants of the Regulatory Flexibility Act, 5 U.S.C. 605(b).
l The Commissioners 6
Note:
a.
That a regulatory guide (Enclosure 3) will be issued as final in conjunction with these amendments.
b.
That the regulatory analysis (Enclosure 4) will be placed in the NRC Public Document Room, c.
That the appropriate Congressional Committees will be informed of the Commission's action (Enclosure 5).
d.
That a public announcement will be issued (Enclosure 6),
e.
That copies of the notice will be distributed by IRM to affected licensees and other interested parties.
i f.
That the Chief Counsel for Advocacy of the Small Business Administration will be informed of the certification and the reason for it as required by the Regulatory Flexibility Act.
g.
That the Office of the General Counsel has no legal objections.
Scheduling:
It is recommended that this paper be considered at an open.
session.
James M. Taylor Acting Executive Director for Operations
Enclosures:
1.
SRM - April 19, 1989 2.
Federal Register Notice 3.
Regulatory Guide 4.
Regulatory Analysis 5.
Draft Congressional letter 6.
Draft Public Announcenent J
The Commissioners 6
Note:
a.
That a regulatory guide (Enclosure 3) will be issued as final in conjunction with these amendments, b.
That the regulatory analysis (Enclosure 4) will be placed in the NRC Public Document Room.
c.
That the appropriate Congressional Committees will be informed of the Commission's action (Enclosure 5).
d.
That a public announcement will be issued (Enclosure 6).
e.
That copies of the notice will be distributed by IRM to affected licensees and other interested parties.
f.
That the Chief Counsel for Advocacy of the Small Business Administration will be informed of the certification and the reason for it as required by the Regulatory Flexibility Act.
g.
That the Office of the General Counsel has no legal objections.
Scheduling:
It is recommended that this paper be considered at an open session.
James M. Taylor Acting Executive Director for Operations
Enclosures:
1.
SRM - April 19, 1989 2.
Federal Register Notice 3.
Regulatory Guide 4.
Regulatory Analysis 5.
Draft Congressional letter 6.
Draft Public Announcenent Offc: RDB:DRA:RES RDB:DRA:RES RDB:DRA:RES D:NRR OGC ADM Name: SFrattalicb DHopkins SBahadur murley WParler PNorry Date:
11/ /89 11/ /89 11/ /89 11/ /89 11/ /89 11/ /89 Offc: DRA:RES DRA:RES DD/R:RES DD/GRI:RES D:RES ED0 Name:
Rosztoczy Morris DFRoss TPSpeis ESBeckjord JTaylor Date:
11/ /89 11/ /89 11/ /89 11/ /89 11/ /89 11/ /89 0FFICIAL RECORD COPY
I l
Enclosures l
1.
SRM - April 19, 1989 l
2.
Federal Register Notice 3.
Regulatory Guide 4.
Regulatory Analysis 5.
Draft Congressional Letter 6.
Draft Pubite Announcement l
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Enclosure I m
SRM - April 19, 1989 J
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