ML20055D413
| ML20055D413 | |
| Person / Time | |
|---|---|
| Issue date: | 05/09/1989 |
| From: | Lieberman J NRC OFFICE OF ENFORCEMENT (OE) |
| To: | Rosztoczy Z 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 AC91-1-039, AC91-1-39, NUDOCS 9007060279 | |
| Download: ML20055D413 (3) | |
Text
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MAY 0 9 im PDR 3y Note to:
Zoltan R. Rosztoczy, RES
Subject:
REVISION TO 20.403 I have reviewed your April 26, 1989 draft and have a number of coments on it.
1)
It addresses the original concern about fires and contamination.
~
I have no problem with b(3) and b(6).
2)
Idonotunderstandthedifferencebetweena(3)andb(4). Similar but different phrases are used. What is the threshold for a threat to the health and safety? What safety systems are covered? I appreciate the goal but given the breadth of activities the rule covers, more specificity is necessary to make it understandable and enforceable. 50.72 and 50.73 has many more examples.
I would be inclined to delete a(3) and b(4) as not belonging in Part 20.
I would put them in the substantive rules with guidance for each type of activity.
3)
I would add at the end of the first paragraph on page 4 the following sentence:
"Moreover, if contamination can not be cleaned up within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the matter may be significant and a prompt NRC inspection j
may be required."
4)
Strike the word " occupational" and use " restricted" in the second line of the second parograph on page 4.
The point is that both restricted and non restricted areas are to be covered.
5)
I question whether the reporting requirements at the bottom of page 4 and the top of page 5 are clarifications.
I am not sure what the original requirements were? Maybe they should be stated. Much more guidance is needed on the bottom of page 4.
See coment 2.
1 1
I appreciate the opportunity to comment on this rule change.
I epologize for the delay. Please call me if you have any questions.
YQ n
1 4 sees Lieberman, Director jf.'iceofEnforcement E
I cc:
R. Cunningham, NMSS L. Spessard, AE0D F. Congel, NRR S. Treby, OGC L. Chandler, OGC J. Goldberg, 0GC 9007060279 900626
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l-PDR PR 1
20 55FR19690 PDR
5 l9 MAY 0 9 gg Note to:
Zoltan R. Rosztoczy, RES
Subject:
REVISION TO 20.403 I have reviewed your April 26, 1989 draft and have a number of comments on it.
1)
It addresses the original concern about fires and contamination.
I hsve no problem with b(3) and b(6).
o
[y\\b 2)
Idonotunderstandthedifferencebetweena(3)andb(4).
Similar I
.but different phrases are used. What is the threshold for a threat 9 }gD QM' to the health and safety? What safety syste s are covered? I appreciate the goal but given the breadth of activities the rule e[y covers, more specificity is necessary to make it understandable and enforceable.
50.72 and 50.73 has many more examples.
I would be inclined to delete a(3) and b(4) as not belonging in Part 20.
I would put them in the substantive rules with guidance for each type t
of activity.
3)
I would add at the end of the first paragraph on pape 4 the following
/
sentence:
"Moreover, if contamination can not be c.eaned up within Ob 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the matter may be significant and a prompt NRC inspection may be required."
4)
Strike the word " occupational" and use " restricted" in the second line gt_
of the second paragraph on page 4.
The point is that both restricted and non restricted areas are to be covered.
5)
I question whether the reporting requirements at the bottom of page 4 and the top of page 5 are clarifications.
I am not sure what the original requirements were? Maybe they should be stated. Much more guidance is needed on the bottom of page 4.
See comment 2.
I appreciate the opportunity to comment on this rule change.
I apologize for the delay. Please call me if you have any questions.
N lames Lieberman, Director ffice of Enforcement cc:
R. Cunningham, NMSS L. Spessard, AE00 F. Congel, NRR S. Treby, OGC L. Chandler, OGC J. Goldberg, OGC
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l Section 20.408 also issued under secs. 135,141, Pub. L.97-425, 96 Stat. 2232, 2241 (42 U.S.C. 10155, 10161). For the purposes of sec. 223, 68 Stat. 958, as amended (42 U.S.C. 2273); il 20.101, 20.102, 20.103(a), (b), and (f), 20.104(a) and(b),20.105(b),20.106(a),20.201,20.202(a),20.205,20,207,20.301 20.303, 20.304, and 20.305 are issued under sec.161b, 68 Stat. 948, as amended (42 U.S.C. 2201 (b)); and il 20.102, 20.103(e), 20.401-20.407, 20.408(b), and 20.409 are issued under sec.161o, 68 Stat. 950, as amended (42 U.S.C.
2201(o)).
1 2.
In i 20.403 the introductory text of paragraph (a) is revised and paragraphs (a)(3), (a)(4), (b)(3), and (b)(4) are removed, and new amendments are being added.
i 20.403 Notification of Incidents.
(a)
Immediate notification. Each licensee shall notify the NRC within four hours after discovery of any of the following events involving licensed material:
(3) Any event or condition that poses a threat to the health and safety of r
personnel using licensed material or that prevents the perfonnance of duties
-!!' ty tystdnecessary to maintain and verify control of licensed material c( 7 (includes fires, toxic gas releases, radioactive releases, etc.).
([I p (b) Twenty-four hour notification.
Each licensee shall notify the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the discovery of any of the following events involving licensed
/
material:
~
(3) Any contamination event that results in restriction of access to the contaminated area by workers or the public for more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
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(4) Any event that prevented or could have prevented the fulfillment of the j[
safety function of structures or systems needed to control releases uf radio-active material, to prevent exposure to radiation, or to mitigate the conse-quences of an accident [meLule:. pu mlu ed erms, cya r.d E. l-e, ep evr d~
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[wkle,G wktkk sfM we quh m l aVw 'le pdem %
.ceymd beken.
8 Enclosure I
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