ML20042F718

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Carr Response to Miller 900207 Question 3 Re Development of Below Regulatory Concern Policy
ML20042F718
Person / Time
Issue date: 02/07/1990
From: Carr K
NRC COMMISSION (OCM)
To: Geoffrey Miller
HOUSE OF REP., INTERIOR & INSULAR AFFAIRS
Shared Package
ML20042F715 List:
References
CCS, MILLER-900207, NUDOCS 9005090301
Download: ML20042F718 (1)


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QUESTION 3.

What-analyses or assessments have been accomplished on the type of additional enforcement, monitoring and civil and -

criminal penalties that would be necessary to ensure full compliance with NRC laws, regulations, policies, and guidelines in the event BRC exemptions are granted in the future?

l ANSWER.

4 No special analyses or assessments are considered needed at this time because the existing regulatory scheme provides for civil penalties for violation of NRC regulations concerning the disposal of radioactive material and criminal penalties if a licensee willfully violates NRC disposal requirements. - As stated in the Commission's draft exemption policy, licensee programs must l

be defined and implemented to ensure compliance with the constraints, requirements, or conditions associated with any specific exemption promulgated

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through licensing or rulemaking actions.

Regulatory guidance and'information-noticis will ~be' provided to affected ficensees~ ' o e'sure they understarid the~

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requirements. As with other NRC programs, inspections for. compliance with BRC provisions will be conducted. Nevertheless, the existing enforcement and l

penalty mechanisms will be reviewed in conjunction with any proposed rulemaking to implement the BRC policy to ensure that our Enforcement Policy remains adequate to ensure compliance with those NRC regulations.

oOO5090301 900430

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