ML20043C092

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Discusses RES Plans for Developing Proposed Exemption Policy Statement
ML20043C092
Person / Time
Issue date: 02/13/1989
From: Beckjord E
NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
To: Stello V
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
Shared Package
ML20042C963 List: ... further results
References
FRN-53FR49886, RULE-PR-CHP1 NUDOCS 9006040025
Download: ML20043C092 (5)
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Text

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MEMORANDUM FOR: Victor Stello Jr., Executive Director for Operations 4

FROM:

Eric S. Beckjord, Director, Office of Nuclear Regulatory Research

SUBJECT:

RES PLANS FOR DEVELOPING PROPOSED EXEMPTION POLICY STATEMENT AND FOR RESPONDING TO EPA'S LETTER TO CHILK/BECKJORD At the public meeting on January 12, 1989 and in follow-up coment letters (enclosure), the EPA expressed the view that, as proposed, the regulatory 1988 advance notice would not l

exemption policy published in the December 12,ity of man's environment."

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" adequately protect public health and the qual EPA also stated their belief that it is premature to establish generic numbers for defining below regulatory concern (BRC) criteria. They invited the.NRC, through the EPA /NRC Interface Council, to work jointly with EPA to develop a instrespg,[j framework for a regulatory exemption policy that would be in the

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On the matter of interaction between the two agencies, we plan, ions with as we l_

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develop the proposed policy statement, to continue our interact U)f41 q,"4 j v..

EPA staff on an "as needed" and somewhat informal basis. Specifically:

Upp 1)' copies of revised drafts of the proposed policy statement being

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the staff's reconnendation for a Unless we hear from you to the contrary, we propose to follow the plan described above.

l Eric S. Beckjord, Director Office of Nuclear Regulatory Research l

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RES plans, for the record, to develop and send to EPA a written response to their comments - specifically addressing those coments where apparent misunderstanding exists.

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The aforementioned response will also be included in the analysis of public coments which will be included in the Comission paper containing the staff's recomendation for a proposed exemption policy.

Unless we hear from you to the contrary, we propose to follow the plan described above.

I Eric S. Beckjord, Director Office of Nuclear Regulatory Research

Enclosure:

Comment letters Distribution:

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i MEMORANDUM FOR: Victor Stello Jr., Executive Director for Operations FROM:

Eric S. Beckjord, Director, Office of Nuclear Regulatory l

Research l

SUBJECT:

RES PLANS FOR DEVELOPING PROPOSED EXEMPTION POLICY STATEMENT AND FOR RESPONDING TO EPA'S LETTER TO CHILK/BECKJORD At the public meeting on January 12, 1989 and in follow-up coment letters

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(enclosure), the EPA expressed the view that, as proposed, the regulatory exemption policy published in the December 12, 1988 advance notice would not

" adequately protect public health and the quality of man's environment." EPA also stated their belief that it is premature to establish generic numbers for defining below regulatory concern (BRC) criteria. They invited the NRC, through the EPA /NRC Interface Council, to work jointly with EPA to develop a framework for a regulatory exemption policy that would be in the " mainstream of other national and international concepts."

In order to attempt to meet the 3

Comission's schedule for developing a proposed exemption policy and to respond to EPA's comments, the following plan is proposed:

a.

On the matter of interaction between the two agencies, we plan, as we develop the proposed policy statement, to continue our interactions with EPA staff on an "as needed" and somewhat informal basis. Specifically:

(1) copies of revised drafts of the proposed policy statement being developed by the staff and other pertinent information will be sent to l

EPAforcomment,ashasbeendonetodateand(2)meetingswithEPAstaff will be held monthly or on an "as needed" basis (our last meeting was held i

on January 25,1989). A proposal for a more formal interactive process i

will be highlighted in the Comission paper transmitting the staff's revision of the proposed policy. We are currently planning that this i

more formal interaction would comence following publication of the proposed policy statement in the Federal Register. The implementation of a formal interactive process would provide a means for EPA to express their views in the development of the final policy statement but would not slow down staff efforts to get the revised policy before the Comission l'

on schedule. The Comission paper is currently scheduled to go to the i

L Comission on April 28, 1989.

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