ML20055C233

Discusses Proposed Rule on Notification of Nonreactor Incidents

ML20055C233
Person / Time
Issue date:	01/10/1989
From:	Knapp M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Morris B NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
Shared Package
ML20055C192	List: ML20055C191 ML20055C216 ML20055C229 ML20055C230 ML20055C233 ML20055C234 ML20055C246 ML20055C251 ML20055C252 ML20055C254 ML20055C255 ML20055C258 ML20055C261 ML20055D251 ML20055D255 ML20055D257 ML20055D265 ML20055D268 ML20055D279 ML20055D288 ML20055D289 ML20055D294 ML20055D296 ML20055D299 ML20055D305 ML20055D307 ML20055D308 ML20055D311 ML20055D312 ML20055D314 ML20055D316 ML20055D317 ML20055D319 ML20055D327 ML20055D335 ML20055D339 ML20055D349 ML20055D355 ML20055D358 ML20055D360 ML20055D363 ML20055D374 ML20055D377 ML20055D385 ML20055D408 ML20055D413 ML20055D417 ML20055D432 ML20055D438 ML20055D444 ... further results
References
FRN-55FR19890, RULE-PR-20, RULE-PR-30, RULE-PR-40, RULE-PR-70 AC-91-1-23, AC91-1-023, AC91-1-23, NUDOCS 8902270570
Download: ML20055C233 (1)

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.% N l 0 1999 Fiie pt MEMORANDUM FOR:

Bill M. Morris, Director Division of Regulatory Applications Office of Nuclear Regulatory Research FROM:

Malcolm R. Knapp, Director Division of Low-Level Waste Management and Decommissioning, HMSS

SUBJECT:

PROPOSED RULE ON NOTIFICATION OF INCIDENTS After reviewing the proposed rulemaking concerning notifications following non-reactor incidents, we support your action to clarify the reporting requirements currently in place for these incidents. However, we do not agree with the procedure you are reconnending (i.e., removing the current reporting requiremer.ts from Part 20) because it affects not only materials licensees but Part 50 anc 61 licensees. There is a need for low-level waste incident reporting requirementi. The Commission expressed this need in a recent request to NRC Staff which asked that the Staff atsess "...the need for developing a mechanism for reporting weste mishaps, such as beyond the design basis failure of solidified low-level weste...." (see the enclosed Staff Requirements Memo, dated 11/8/88).

Certain waste preparation mishaps can result in poor disposal site performance, may have the potential for excessive radiation exposure and give an indication of the field performance of NRC-certified topical report materials. The details L

of poor material performance for law-level waste forms (such as damages or losses exceeding $2000.00) should be reported by Part 50 and 61 licensees.

We will prepare (by 1/31/89) a list of low-level waste materiel conditions which should be reported under Part 20 by all licensees.

h Malcolm R. Knapp, Director Division of Low-Level Waste Management u, h D p gg m and Decommissioning, NMSS l

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