ML20043C005
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NOV1 Iggg MEMORANDUM FOR: Thomas E.- Murley, Director, NRR Robert M. Bernero, Director, NMSS Harold R. Denton, Director, GPA William C. Parler, General Counsel, OGC 1
Patricia G. Norry, Director. ADM FROM:
Eric S. Beckjord. Director, RES l
SUBJECT:
OFFICE REVIEW REQUE'ST: FINAL POLICY STATEMENT ON " EXEMPTIONS FROM REGULATORY CONTROL" i
Your assistance is requested in reviewing the enclosed policy statement on Exemptions From Regulatory Control (Enclosure 1), which RES has written to comply with Comission directives given in the Staff Requirements Memorandum of October 13, 1989 (Enclosure 2). Given the November 30, 1989, SECY suspense L
date, the Acting Executive Director for Operations has asked for office concurrence, or comment on any fundamental di.sagreements, by November 9,1989.
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The Acting E00 has scheduled a meeting to discuss and resolve any issues on this date. The Offices should be prepared to discuss the draft at that meeting.- Alternative text to satisfy concerns and issues, keeping. in mind the Comission's directives, would be greatly appreciated.' Editorial. comments on the present draft should be provided directly to William Lahs (Ext. 23774) as soon as practical.
The following is a summary of this request:
1.
Title:
Final Policy Statement on " Exemptions From Regulatory Control."
2.
RES Task' Leader: WilliamR.Lahs(ext.23774).
.3.
Cognizant Individuals: HMSS - M. Bell, K. Dragonette, R. Cunningham NRR - F. Congel, L. Cunningham L
OGC - R. Fonner GPA - K. Schneider ADM - M. Lesar Ll l
Because 6f the tight time schedule, initial comment from the cognizant 3
Note:
Tn3Tviduals is being solicited with this request.
4.
Requested Action: Concurrence, or statement addressing fundamental disagreenents.
5.
Requested Completion Date: November 9, 1989.
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~9006010175 891130 PDR PR CHP1 53FR49886 PDC
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Hultiple Addresses NOV I gggg f'
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Background:
' The revised final policy contains five sections as directed In tne 5RM. The' introduction (Section 1) contains Considerable material j
included in previous, staff. proposals (i.e., SECY-89-184). A mcjor addition-calls-for this policy to supersede the Comission's March 16, 1965, policy statement on the use of byproduct and source material in consumer products.Section II is a new section which includes definitions of Section III contains the basic elements of policy terms and concepts.
the policy: Dual individuhl dose criteria (10 mrem and 1 mrem per year) and a collective dose criterion (1000 person-rem per year per practice).
Individual doses less than 0.1 mrem per year will not be included in the collective dose assessment. The other major change-involves deletion of the justification of practice as a principle-in the exemption'decisionraking-process.Section IV is a general discussion on policy implementation, requested in the SRM. Finally,Section V is a significant addition which describes the information needed to support the exemption decisiormaking.
process. Much of this section reflects thoughts expressed in the implementa-tion plan which'was developed in support of 10 CFR Part 2 Appendix B.
O GITAT 57NEBY 7
M bir.T.
ic. Beckjord, Director V Office of Nuclear Regulatory Research u
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Enclosures:
1.
Final Policy Statement on Exemptions From Regulatory Control 2.
SRM dated October 13, 1989 bec:
E. S. Beckjord T. P. Speis B. M. Morris Z. Rosztoczy D. Cool W. Lahs DISTRIBUTION:
RE5 Files DRA Subj-l DRA RF l'
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i-RE :DRA RPHEB RE :DRA/RPHEB R'E /DRA:DD RES/D RES/DD R
WRLahs:jmm DCool ZRo toczy BMMorris TPSpeis E ehkjord p/.{/89
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