ML20055D432
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UNITED STATES -
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WASHINGTON, D. C. 20555 Bahadur
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MEMORANDUM FOR:
Eric S. Beckjord, Director Office of Regulatory Research FROM:
Harold R. Denton, Director Office of Governmental s
and Public Affairs
SUBJECT:
COMMENTS ON FROPOSED RULEMAKING' NOTIFICATIONS OF INCIDENTS j
j 10 CFR 20.403 Thank you for the opportunity to review the proposed rulemaking package on notification of incidents which was prepared in response to a request from the Office of Enforcement (0E).
iExcept for one provision of the proposed rule, we concur with your plan to publish it for public coninent. We believe the requirement for immediate notification of events (e.g.,
10 CFR 30.50(a)) is such that it could be read to apply to virtually any unplanned event at a licensee's facility.
If this is not the intent, then considerable interpretation will t
be necessary to determine its applicability to specific events.
We understand that OE has also expressed concern over this
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section.
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In contrast, the criteria for 24-hour notification are clear and l
specific.
{
I A better approach might be to delete from 630.50(a)(1) the
-phrase, "that poses a threat to the health and safety of personnel using licensed material or."
With this change the l
innediate notification requirement would be more in line with those for 24-hour notices. We suggest a meeting of NRC staff involved in this proposed rulemaking would be beneficial to resolve concerns. The-staff contact is Joel Lubenau at extension 20819.
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