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j DEC 2 91988
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i MEMORANDUM FOR:
Bill M. Morris, Director, Division of Regulatory Applications, Office of Nuclear Regulatory Research j
FROM:
Charles E. Norelius, Director, Division of Radiation Safety and Safeguards, Region III 4
SUBJECT:
REGION III REVIEW 0F THE PROPOSED RULEMAKING-NOTIFICATION OF INCIDENTS l
Per your request dated December 16, 1988, Region Ill has reviewed the subject i
matter and is providing you with the following comments and recommendation:
In general we feel that the proposed rulemaking has significantly clarified-the current regulations on incident reporting.
This is especially true in the areas of defining "immediate", and clarifying such things as what constitutes damage. We also feel it beneficial that the proposed rulemaking includes costs.for decontamination and disposal efforts since, as in the case of Wright Patterson Air Force Base, the licensee felt that their two million dollar i
expenditure for decontamination and disposal should not have been a consideration in any enforcement action.
The clarification will not only be beneficial to licensees, but also to NRC staff since as evidenced by recent cases such as Wright Patterson Air Force Base and the Comdustrial Roofing Contractors Company, there has been some uncertainty of reportability by NRC staff.
d The only recommendation which we have for you regarding our review of the proposed rule pertains to 30 day follow-up reports.
It appears that the
/ a>A requirements for 30 day reports has been eliminated for immediate notification events as' described in the new sections of Parts 30, 40, and 70.
Since the immediate notification events appear to be ones of greater safety significance (e.g., any event that affects the safety of licensed material or threatens personne1'using licensed material), we feel that a requirement to submit a 30 day report should be included in the regulations to assure that NRC has all available information to evaluate or assess the event.
9007060150 900626 PDR PR 20 55FR19890 PDR D
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Bill-M.. Morris,
If you have any questions or if we can be of any further assistance, please contact Roy J. Caniano of my staff at FTS 388-5721.
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Charles E. Norelius, Director Division of Radiation Safety and Safguards.
cc:
J. J, Mate, NRR R. E. Cunningham, NMSS' l
R. F. Burnett, NMSS M. R. Knapp, HMSS T. M. Novak, AE00 R. L. Spessard, AE0D i
F. Congel, NRR F. Gillespie,.NRR l
C. Kammerer, GPA S. T. Treby, 0GC j
D. H. Grimsley, ARM DDS, DRSS RI, RII, RIV, RV J