ML20045B303
| ML20045B303 | |
| Person / Time | |
|---|---|
| Issue date: | 04/19/1993 |
| From: | Rogers K NRC COMMISSION (OCM) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| NUDOCS 9306170165 | |
| Download: ML20045B303 (2) | |
Text
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SAMUEL J. CHILK, SECRETARY OF THE C0!44ISSION f
FROM:
C0lHISSIONER R0GERS
SUBJECT:
SECY-93-067 - FINAL POLICY STATEMENT ON TECHNICAL SPECIFICATIONS IMPROVEMENTS VI N VA O y yIM f *!LT APPROVED c<
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i Commissioner Rogers Comments on SECY-93-067 I agree with the Chairman's commendation of the staff, not only i
for their excellent efforts in developing the criteria for selecting technical specifications but also for their efforts to reasonably interact with both industry and the public to achieve the best consensus.
I also share with the Chairman the belief t
that the staff should pursue the rulemaking option.
Besides l
providing a clear and predictable process, both to industry and the staff, rulemaking should reduce the likelihood of unnecessary
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litigation.
However, if rulemaking is pursued, the rule should not be limited to only the prescription of the four criteria.
There are numerous other areas in the regulations related to technical specifications that can be improved.
Witness our 4
recent SRM dated April 16, 1993 on the Regulatory Review i
briefing, where the staff was directed to explore possible mechanisms for achieving legal and administrative efficiencies in 9
the processing of amendments to technical specifications.
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A rulemaking, by its nature, will require about two years before a final rule can be promulgated.
In order to benefit from the significant effort already expended by the staff, I propose that the staff be directed to publish the policy statement as it currently exists - not as a draft policy statement for 90 days 1
comment -
with appropriate modifications based on the SRM.
Included in the Federal Register notice should be a statement to l
the effect that the Commission is initiating a rulemaking action l
to address technical specifications that is intended to be r'
consistent with the policy statement.
The statement should also indicate that comments on the policy statement are welcomed and that they will be considered and addressed during preparation of the proposed rule.
l By issuing the policy statement now the Commission is serving advance notice concerning its position on technical specifications thus allowing industry to get an early start on implementation.
Tne Commission would be getting the benefits of
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both a policy statement and a rulemaking procedure.
[Gil 4(i1(73 h
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