ML20055D317
| ML20055D317 | |
| Person / Time | |
|---|---|
| Issue date: | 01/03/1989 |
| From: | Bangart R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Morris B NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20055C192 | List:
|
| References | |
| FRN-55FR19890, RULE-PR-20, RULE-PR-30, RULE-PR-40, RULE-PR-70 AC91-1-020, AC91-1-20, NUDOCS 9007060170 | |
| Download: ML20055D317 (1) | |
Text
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uNiTEo STATES
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JAN 3 1989 1
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1 MEMORANDUM FOR: Bill M. Morris, Director, Division of Regulatory i
Applications, Office of Nuclear Regulatory Research
-FROM:
Richard L. Bangart, Director, Division,of Radiation j
Safety and Safeguards
SUBJECT:
DIVISIONAL REVIEW OF THE PROPOSED RULEMAKING-NOTIFICATION OF INCIDENTS 3
We offer the following specific comments in response to your December 16, 1988,-
memo. Although our comments relate to the 30.50 addition, they apply also to 2
the Part 40 and 70 additions.
o.- 3
$ 1.f Paragraph -(3) on page 8 requires immediate notification of "Any event or condition that affects the safety of licensed material or threatens personnel.using licensed material...." This is unacceptably vague.
It seems clear enough for major events, but how would anyone know what threshold to use for reporting small events?
7g 2.
Paragraph (b)(2) on page 8 establishes a $2,000 threshold for 24-hour e.s
reporting.
Two thousand dollars seems too low. An event resulting in
$2,000 damage in 1989 dollars is much less significant than an event p
which exceeded this threshold when the original reporting rule was promulgated.
O / M.
3.
Paragraph (4) on page 9 also is too restrictive.
The activation of an d
alarm or safety feature should not necessarily be reported. As in No. 1, L
above, the threshold is not clear.
V l29#
4.
Paragraph (6) on page 9 is also subject to a range of interpretation.
In the byproduct materials case, the distinction between operational and l
nonoperational is not always clear. Additionally, the term "other safety i
barrier" is vague.
The above comments emphasize the importance of developing more detailed guidance (Reg. Guide, BTP, or letter to licensees) for both licensees and the NRC staff on a parallel path with rule promulgation. As has been evident with the existing rule and ongoing rule revision efforts, such a rule is difficult to promulgate without a considerable amount of interpretation being a
necessary to arrive at a full understanding.
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a 20~SSFR19890 PDR Richard L. Bangart, Direktor Division of Radiation Safety and Safeguards
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