ML20055D477
| ML20055D477 | |
| Person / Time | |
|---|---|
| Issue date: | 05/08/1990 |
| From: | Mate J NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | Shelton B NRC |
| Shared Package | |
| ML20055C192 | List:
|
| References | |
| FRN-55FR19890, RULE-PR-20, RULE-PR-30, RULE-PR-40, RULE-PR-70 AC91-1-059, AC91-1-59, NUDOCS 9007060341 | |
| Download: ML20055D477 (8) | |
Text
{{#Wiki_filter:P ts N C % )' \\ e PBR TO: Brenda J. Shelton May 8, 1990 From: Joseph J. Mate
Subject:
Revision of OMB Package for 10 CFR 20.403 Attached per our meeting on Friday May 4. 1990 is a revised supporting statement for the OMB package for 10CFR 20.403. Changes were made on pages 1, 4. and 5. I have also attached the revised Federal Register tiotice since the version you have has been changed. If anything else is needed please advise. W ephJ.kMate R' /DRA/RD3 Enclosures
- 1. Supporting Statement 2
Federal Register tiotice 900626 '~ h g70g34j 20 55FR19890 PDR
t-s Supporting Statement i i
r 4 i i OFFICIAL RECORD COPY 4 l SUPPORT 1HG STATEMENT FOR PROPOSED RULES 10 CFR 20.403, 30.50, 40.60 and 70.50 NOTIFICATIONS OF INCIDENTS Description of the Information Collection The Nuclear Regulatory Commission is proposing to amend its regulations to revise licensee reporting requirements for material licensees regarding the Notifications of Nonreactor Incidents relating to radiation safety. This action is needed to ensure that significant occurrences are promptly reported so that NRC can evaluate whether imediate action is required to protect the public health and safety. The proposed amendment to 10 CFR 20.403, would delete the requirement for licensees to notify the NRC of an incident under cirebmstances specified in the revised 20.403 (a)(3), (6)(4), (b)(3), and (b)(4). In addition, new requirements for material licensees are being provided in 10 CFR 30.50, 40.60 and 70.50. These new requirements specify the type of incidents that material licensees are required to report and when they are to be reported. A. JUSTIFICA110N Need for the Collection of Information l NRC currently requires licensees to notify the agency if certain types of j inciderts occur. This notification is necessary to insure NRC is apprised of the incident so that the agency can determine if immediate action is needed on the part of NRC to protect the public health and safety. The incidents, report requirements, and the criteria are currently spelled out in 10 CFR 20.403. However, the current requirements for reporting are general and not totally clear. This results in misunderstandings and a lack of reporting of incidents by material licensees. The staff has examined the provisions of i 20.403 and decided that revisions are appropriate to better describe reportable events having significant implications for public health and safety. Therefore, NRC is proposing to revise the current requirements by l J amending the applicable regulations. l NRC is proposing to delete some of the reporting requirements from l 10 CFR 20.403 for licensees and add several new tections in other parts of l 10 CFR for material licensees. The parts in 20.403 to be deleted concern the to property (10 CFR 20.403(a)(4)y (10 CFR 20.403(a)(3), and (b)(3), and dama loss of operation of the facilit l ,and(b)(4). These sections are being deleted because the staff believes that these criteria are not necessarily the best way to describe events that pose a hazard to public health and safety or the environment. For example, the periodic loss of operation of a facility is not necessarily related to any potential hazard to the public or environment. The same is true for the cost of repairing damage, which may be high for reasons unrelated to any potential radiation hazard associated with licensed material. The following new sections are being added to Parts 30.50. +0.60 and 70.50. Since the sections that follow are being added to Parts N.50, 40.60 and 50.50 identically, they are only shown once.
) I NRC places the primary responsibility on the licensee for controlling and using licensed material safety. Therefore, it is important that NRC receive reports of events or conditions that threaten the health and safety of individuals using licensed material or that prevent the performance of surveys or other safety related duties necessary to maintain control of licensed material. A new reporting requirement for these types of safety related events has been specifically included to clarify that such events must be reported. A new requirement is also being added for licensees to report contamination events where access to an area must be restricted for more than 24 hours because of contamination. This requirement is intended to capture an event which causes accidental contamination to an area which is in excess of the radiological conditions normally present. Accidental contamination events increase radiation exposure and the risk of ingesting radioactive material. A new reporting requirement requiring licensees to report events in which equipment necessary to prevent uncontrolled releases of radioactive material, to prevent overexposure to radiation, or to mitigate the consequences of an accident is disabled or fails to functions as designed. This includes procedural errors, equipment failure, equipment damage, etc. This notification is necessary where there are no backup systems available in order to protect the health and safety of the public. Notification is not required for an individual component failure if reduadant systems are operable and available to automatically perform the required function. A requirement for licensees to report events that require medical treatment of a radioactively contaminated individual at a medical Such events are highly significant because facility)isbeingadded. internal contamination through open they: 1 indicate safety problems in a licensed o expose medical personnel to radiation and contamination. An evaluation must be performed to determine how to prevent any recurrence. A new requirement has been added to report all fires and explosions involving any device, container, or equipment containing licensed material to ensure such events are promptly evaluated to minimize any spread of contamination and determine the performance of features designed to control licensed material. Fires' involving or damaging licensed material are of particular significance because a fire can cause material in sealed sources to be released, generate airborne radioactive contamination and generate contaminated runoff from water used to extinguish the fire. In addition to the new requirements identified above, the term "immediate l notification" is being defined as a period consisting of not more than 4 hours from the discovery of an event until the time it has to be reported. The i staff believes that 4 hours is appropriate for material licensees because many material licensees do not have the capability to quickly assess and respond to events like reactor licensees. Also, the degree of risk with material licensees is typically much less than with the hazard posed by reactor events. 2 L
r The agency feels these changes are needed because NRC material licensees do not not always report incidents that the staff believes should be reported. Agency Use of the Information The information provided in the incident reports is used by HRC to insure that the public healt1 and safety is protected to the maximum degree possible. Incidents are reviewed to determine if patterns among certain vendors exist relative to poorly designed or functional items as well as alerting specific types of licensees when a potentially significant problem in a specific area may occur. Notification of licensees may be accomplished orally or in writing depending on the circumstances at the time. NRC's response to the licensee may be immediate or may be delayed due to the need for further evaluation. Reduction of Burden Through Information Technology There are no legal obstacles to reducing the burden associated with this information collection by the use of information technology. NRC encourages the use of such technologies. However, the sporadic nature of the reporting requirement does not lend itself to the use of such current new technologies. Duplication of Other Collections of Information There is no known duplication of information collection requirements within NRC relative to the reporting of the incidents specified in these regulations. The Information Requirement Control Automated System (IRCAS) was searched and no duplication was found. Effort to Use Similar Information There is no known information that is similar to the requirement identified in the proposed amendments. Information is only provided if an incident occurs. Effort to Reduce Small Business Burden The burden on small business cannot be reduced and still maintain the health and safety of the public. Consequence of Less Frequent Collection It is not possible to report less frequently unless the requirement to re> ort to NRC is eliminated. Should incidents not be reported, the public healti and safety would be jeopardized. Circumstances Which Justify Variation From OMB Guidelines incidents that are required to be reported to the NRC under the revisions must be reported in either 4 hours or 24 hours depending on the nature and severity of the incident. This is necessary so that NRC can make a determination as to whether or not immediate action is required on the part of.the agency to protect the public health and safety. 3
Consultation Outside the NRC Hone. Confidentiality of Information None except for proprietary information. Sensitive Questions None. Estimate of Burden to Federal Government The collection of the information requires approximately 4 1/2 hours of NRC staff time per re> ort. The staff time is about 1/2 hour for the headquarters and 4 hours for tie regions. NRC is currently receiving about 90 responses per year under 10 CFR 20.403. This workload, while deleted under 20.403, would be assumed under Parts 30, 40, and 70. If the workload were to double under the proposed revision (worse case scenario), about 180 reports could be submitted. For approximately 180 reports received annually, NRC would expend about 810 hours of work. This includes time for review, coordination, inspection, and any required follow-u At $92.00 an hour, the annual costs would be $74,520 ($92.00 x 810 hours)p. Estimate of Burden The actual cost or estimate of burden on the licensee is difficult to estimate because it is not clear hon great the change in the number of incidents reports will be. Clarification of the rule may elicit responses from licensees who did not realize they were supposed to report certain events, and specification of the requirements may induce licensees to report events which may not have previously been reported. Discussion among the staff covering the latest 3-year period disclosed that only a few cases a year were not reported which NRC felt should have been reported. Consequently, it is ' difficult to estimate exactly whether or not the burden will increasu. Assuming a worst case, the number of incident reports may double from approximately 90 to 180 reportable incidents per year. An average incident report would be about two to three pages in length. The average time to prepare such a report would be approximately 3 to 4 hours. Assuming a maximum total of 180 incident reports, a maximum total of 720 hours per year would be expended. Additional Reporting Burden (Hours) 10 CFR No. of Burden Total Requirement Respondents Per Responses Burden 30.50 30 4 120 40.60 30 4 120 70.50 30 4 120 E 17 33U The above chart reflects the additional burden for all sections of 30.50, 40.60 and 70.50. a 4
cr Reasons for Change in Burden .The burden represented in this package reflects an increase of approximately 335 hours per year for material licensees over the burden estinated in the last -OMB package for the 20.403 regulation. This increase in the burden is due to revised NRC estimates of the actual time it would take the licensee to gather the needed information,-file the report, and provide any follow-up data. The additional 360 hours of operating burden shown on page 4 results from the reporting of an additional 90 incidents that the staff feels may be reported as a result of the rule revisions. Publication for Statistical Use
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+ NUCLEAR REGULATORY COMMISSION 10 CFR Parts 20, 30, 40, and 70 RIN:3150 - AC 91 Notifications of Incidents AGENCY: Nuclear Regulatory Comission. ACTION: Proposad rule.
SUMMARY
- The Nuclear Regulatory Comission (NRC) proposes to amand its regulations to revise licensee reporting requirements regarding the noti-i f".ations of incidents related to radiation safety. This action is needed to ensure that significant occurrences at material licensee facilities are promptly reported to NRC so that the Comission can evaluate whether the licensee has teten the action required to protect the public health and safety and whether generic safety concerns are ident 'fied that may require prompt NRC action.
DATE: The coment period expires 75 days after publication. Corsnents received after this date will be considered if it is practical *,o do so, i but the staff is able to ensure consideration only for coments received on or before this date. ADDRESSES: Mail written coments to the Secretary, U.S. Nuclear Regulatory Comission, Washington, DC 20555, Attention: Docketing and Service Branch. Coments may be delivered to One White Flint North, -[pO Enclosure 4[d Of. 1
-. ~ 1us ~ l,; coments received on the proposed rule, may be examined at the NRC Public Docuinent Room, 2120 L Street NW (Lower Level), Washington, DC. ' ~ ' FOR FURTHER INFORMATION CONTACT: Joseph J. Mate, Office of Nuclear Regulatoly Research, U.S. Nuclear Regulatory Commission, Washington, DC 20555, telephone (301)492-3795. SUPPLEMENTARY INFORMATION:
===. Background=== i Current regulations require that NRC licensees promptly report certain events iny'olving by-product, source, or special nuclear material that cause or threaten to cause the exposure of the whole body to specific levels of radiation, the release of radioactive material in specific concentrations, the loss of use of facilities for e specific duration, or. damage to property in excess of a specific dollar amount. The events are to be reported either immediately or within 24 hours, depending on the' nature and severity of the event as defined in i 20.403. NRC has become concerned that certain provisions of 6 20.403 need to be revised because licensees have not been reporting certain significant events. Two examples of events that were not reported are shown below. 'In both cases,.the licensee was cited for violations. In one case, a fire destroyed a material licensee's building that contained the licensee't moisture density gauge. Damage caused by tte fire rendered'the gauge unusable, although no radioactive material was released. NRC was not notified of the fire. As a result, a potentially 2 Enclosure
1; e significant event was not promptly evaluated by NRC to determine whether [ the damaged gauge might present a hazard to public' health and safety. '~~' In a second case at a licensee's site, a uranium hexafluoride cylinder bulged but did not rupture. The event was not reported to NRC. Again, this meant that NRC was not able to promptly evaluate the potential hazard associated with the incident. After this incident, a uranium hexafluoride cylinder in a similar. situation at another l licensee's site did rupture, causing one death and several injuries. Discussion The existing reporting requirements in 10 CFI, E0.403 are general. The NRC staff has examined the provisions of 9 20.403 and decided that ] revisions are appropriate to better describe reportable events having significant implications for public health and safety. The rule would be a matter of compatibility for the Agreement States. The Agreement States participated in the development of this rule, and their consnents were incorporated as appropriate. In final form, this rule would amend the major revision to Part 20 currently under consideration by the Consnission (51 FR 1092 January 1,1986). Paragraphs (a)(3),(a)(4),(b)(3),and(b)(4)of520.403 that deal with loss of operation and damage to property would be delC 4 because the staff believes these criteria are not the best way to describe events that pose a hazard to public health and safety or the environment. For example, the periodic loss of operation of a facility is not necessarily related to any potential hazard to the public or environment. The same is true for the cost of repairing damage, which may be high for reasons 3 Enclosure
unrelated to any potential radiation hazard associated with licen;ed ~. material. The deleted sections are being replaced with new criteria that will be added to Parts 30, 40, and 70. Criteria for nuclear power reactors are already contained in 6 50.72 of 10 CFR Part 50. The staff believes the new requirements to be edded to Parts 30, 40, and 70 will be more indicative of potentially significant events affecting the health' and safety of the public and the environment. The intent of these amendments is to require prompt notification (either immediately or within 24 hours) to the NRC of events that would require prompt action by the NRC to protect public health and safety or the environment. Prompt NRC actions may include evaluating the potential hazards 'and corrective actions beino taken by the licensee, issuing immediate warnings of generic hazards to other licensees and appropriate organizations, activating the NRC incident response center, or dispatching a response team to the site of tre event. The NRC specifically re. quests public coments on (1) the appropriatenessoftheseamendments,(2)thenumberofreportsthat licensees expect might be generated yearly, (3) how to minimize reports of events that do not require a prompt NRC response without excluding any events that do require prompt NRC actions, and (4) events that would require prompt NRC actions but are not covered under the proposed amend-ments, and how to include these events in the notification requirements. The The proposed amendments for Parts 30, 40, and 70 are identical. discussion that follows is, therefore, organized by the type of requirement rather than by the part of the regulation where it is found. The proposed amendments do not apply to activities reportable under 10 CFR Part 50. The proposed amen 6nents do apply to comercial power reactor licensees fe-activities licensed under Parts 30, 40, and 70. Since the notification 4 Enclosure u
ur he. requirements under Id CFR Part 50 do_ not apply to research and test reactors, the proposed amendments also apply to such reactors possessing material l licensed under Parts ~30, 40, and 70. Inmediate Notification A period of 4 hours would be the maximum time allowed for "inmediate notification" by material licensees. It is intended that licensees will notify the NRC of incidents as soon as possible, but in no case later than 4 hours af ter discovery. This is consistent with some of the immediate reporting requirements specified in 5 50.72 for power reactors. Four hours was used because many smaller material licensees do not have the capability to quickly assess and respond to events that reactor licensees possess and because the degree of hazard posed by nonreactor events is typically much smaller than the hazard posed by reactor events. Control of Licensed Material The primary responsibility for controlling licensed material and using it safely rests with the licensee. It is important that the NRC immediately receive reports of events that prevent or threaten to prevent the licensee from performing safety-related duties necessary to maintain control of licensed material and protect the public. A reporting requirement for these types of events would be included. A similar requirement is currently specified in 10 CFR 50.72 (b)(1)(vi) for reactor t i licensees. l Licensees will need to exercise some judgement in determining when l events require an immediate NRC notification. After an event has been 5 Enclosure
4 l discovered, the licensee must determine what immediate actions are necenary to maintain and verify control of any licensed material involved._ ?.o imediate NRC notification would be required if (1) the event prevented the licensee from performing any of those actions, or (2) the event created a condition that could have prevented any of those actions. In either case, an imediate report is required regardless of tha Aration of the incident that prevented the licensee from performing a appropriate actions. l For example, an imediate NRC notification would be required if a ] filled uranium hexaflouride cylinder bulged or a contair nent showed signs of failing in a way that would injure individuals in the area and prevent imediate actions necessary to maintain and verify control of licensed 1 material. The NRC must be aware of such a puantial hazard so it can assure that appropriate actions are taken. Imediate notification is required only if events or conditions involving licensed material threaten an imediate disabling injury or threaten to prevent imediate protective actions necessary to protect the public or the environment. For example, immediate NRC notification is J not requ, ired if crumbling insulation is exposing licensee personnel to airborne asbestos fibers. Although the condition threatens the health of the workers, it does not threaten an imediate disabling injury or threaten to prevent immediate actions necessary to maintain and verify control of the licensed material In the event of a fire involving licensed material, an imediate NRC notification would be required if workers coulo not secure the licensed i material or assess releases because of the fire. An immediate notifica-tion would also be required if firefighters could not enter the area to combat the fire because of high radiation levels or other radiological 6 Enclosure
L.. ~ ~ hazards. If all imediate actions necessary to control the licensed material and extinguish the fire were performed but the licensed material or its container was still damaged, a 24-hour notification would be required by the proposed reporting requirement for fires and explosions. In the event of an explosion involving licensed material, an imediate notification would be. required if the resulting damage prevented workers from securing the licensed material or assessing releases. If all imediate actions necessary to control the licensed material were performed but the material or its container was still damaged, a 24-hour notification would be required by the proposed reporting requirement for fires and explosions. An imediate notification would also be required if a tornado or other natural phenomenon caused damage that prevented workers from per-forming imediate actions necessary to control licensed material and verify whether any releases had occurred. Contamination Events A n,ew requirement would be added for licensees to report contamination events if access to an area must be restricted for more than 24 hours because of the contamination. This requirement is intended to cover events that cause accidental contamination in excess of the radiological conditions normally present. If the accidental contamination is not cleaned up in a timely manner, personnel entering the area may receive unnecessary radiation exposure and may spread contamination to themselves, others, or other areas, l This requirement is applicable to both unrestricted areas and ) restricted areas where additional restrictions are imposed. For example, 7 Enclosure
q m. ..s a radioactive waste container storage area is normally locked and [ restricted. If a spill contaminated the floor for more than 24 hours and required workers entering the area to wear additional anti-contamination clothing, NRC notification within 24 hours would be required. Another example is a spill of a liquid containinp technetium-99m in F a nuclear pharr.acy. To minimize the dose to workers cleaning up the l spill, areas contaminated with technetium-99m are typically isolated for a short time to allow the technetium to decay. Technetium-99m has a half-life of 6 hours. if the area must be isolated for more than 24 hours, a 24-hour NRC notification would be required. It is important that NRC receive notification of such events because prompt NRC action i may be necessary to ensure that the contamination and cleanup activities are performed in a timely manner. Moreover, if the contamination cannot be cleaned up within 24 hours, the matter may be significant and require prompt NRC on-site presence. Safety Equipment Related Events A. reporting requirement would be added for licensees to report within 24 hours events in which equipment necessary to prevent uncontrolled releases of radioactive material, to prevent overexposures to radiation, or to mitigate the consequences of an accident is disabled or fails to funCcion as designed when it is needed. This reporting requirement includes equipment failure, equipment damage, and procedural errors which cause equipment to fail or be disabled. NRC must be aware of these events to identify potential safety hazards and to ensure that the licensee takes rg;Or.riate actions to protect workers and the public. 8 Enclosure
..( 4 1 .\\ A similar requirement is currently specified in 10 CfR 50.72(b)(2)(iii) l ~ for reactor licensees. Licensees will need to exercise some judgement in determining when an event requires a 24-hour NRC notification. First, the licensee must-determine whether the inoperable equipment was needed to prevent uncon-trolled releases, overexposures, or mitigate the consequences of an acci-dent. Second, the licensee must determine whether the function of the equipment -- or the availability of the function -- was needed when the equipment was disabled or failed to function. A 24-hour notification is not required if neither the function nor its availability was needed when the equipment was inoperable. Third, if the inoperable equipment was an individual component, the licensee must determine whether redundant equipment was operable and available to automatically perform the required function. The following are examples of reportable events: 1.- A malfunctioning interlock on an irradiator chamber door. If the interlock fails, the door could be opened while a source containing several thousand curies is exposed,.resulting in a person _ receiving a-large radiation dose in a very short time. Prompt NRC action may be necessary to warn other licensees of generic safety problems or to ensure 1 i the licensee specifies adequate controls to protect occupational workers and the public. 2. Failure of a high efficiency particulate air (HEPA) filter in a the ventilation system of a fuel fabrication plant. HEPA filters are used to prevent uncontrolled releases of uranium particles when uranium powder is processed ca make reactor fuel. If workers discover that a filter had a hole in it while uranium powder was being processed, a 24-hour NRC notification would be required. The NRC must be aware of 9 Enclosure I l
d u nu-vu - + this event to' ensure that the licensee takes appropriate actions to determine if a release occurred or to independently verify that action is sufficient to protect the public health and safety. 3. Failure of radiography egoipment necessary to retract and lock the source in its safe, shielded position. If a radiography source cannot be retracted and locked'in its camera, prompt
- action would be needed:
to 'msure that appropriate steps are taken by the licensee to recover and ' secure the source. 4. Damage to the shielding in a gauge that exposes the radiation source or that prevents an exposed source from being reshielded. Many nuclear gauges are authorized for use in non-nuclear industries because the sources.are well shielde' and extensive radiation exposure controls. are not required. If a gauge source is left unshielded, prompt NRC action would be needed to ensure that ap;,copriate steps are taken by the licensee to control radiation exposure, reshield the source, and secure the gauge. 5. Failure of a teletherapy timer during treatment. Teletherapy units used to deliver large doses of radiation to cancer patients have timers that automatically close the unit's shutter -- stopping the radi-ation exposure -- after a prescribed treatment is completed. Teletherapy units contain radiation sources that deliver large doses in a short time. If a teletherapy timer failed to automatically close the shutter when required, the attending technician would have to manually activate an electrical backup or mechanical mechanism to close the shutter. Since.no redundant equipment is available to automatically close the shutter, a 24-hour llRC notification of a teletherapy timer failure would be required. l This would permit prompt NRC action to ensure that the licensee takes l appropriate steps to investigate why the timer failed. It might even be i necessary for NRC to warn other licensees of teletherapy units if a generic problem was discovered. 10 Enclosure
i ,-c v oso-o ; Personal Injury Events A requirement would be added for licensees to report within 24 hours events that require medical treatment of a. radioactively contaminated individsal at a medical facility. These events are highly significant because they may (1) indicate safety problems in a licensed operation, (2) risk internal contamination through open wounds, and'(3) expose medi-cal personnel to radiation and contamination. A similar requirement is currently specified in 10 CFR 50.72(b)(2)(v). To ensure that any event of this type occurring at a medical facility is reported, this requirement does not stipulate transporting the injured individual as requisite. However, to avoid numerous reports of insignificant events such as a medical technician puncturing a hand with a syringe containing a radiopharmaceutical, a note is added to clarify that a 24-hour notification is not required if first aid for a superficial injury at a licensee-maintained medical facility is the only treatment rendered. Fires and Explosions A new requirement would be added to report within 24 hours all fires and explosions damaging licensed material or any device, container, or equipment containing licensed material. These event: must be evaluated promptly to minimize any spread of contamination and to determine the-performance of shielding and other features designed to control licensed material. Fires or explosions damaging licensed material are of particu-lar significance because they can cause material in sealed sources to be l L released, generate airborne radioactive contamination, and generate 11 Enclosure p i U s v
Livsu-vij contaminated runoff'from water used to extinguish fires. A second notification is'not required if an immediate notification was made for a fire or explosion (see the discussion above for Control of Licensed Material). Written Reports The proposed rule would require a written report within 30 days of any immediate or 24-hour notification similar to the written report currently required by 6 20.405. Written reports prepared pursuant to other regulations may be submitted to fulf'.11 this requirement'if the report contains all of the iecessary information and the appropriate distribution is made. Environmental Impact: Categorical Exclusion The NRC has determined that this final rule is the type of action described in categorical exclusion in 10 CFR 51.22(c)(2). Therefore, neither an environmental impact statement nor an environmental assessment has been prepared for this proposed regulation. Paperwork Reduction Act Statement The proposed rule amends information collection requirements that are subject to the Paperwork Reduction Act of 1980 (44 U.S.C. 3501 et I seq.). This proposed rule nas been submitted to the Office of Management and Budget for review and approval of'the paperwork requirements. 12 Enclosure L
L/ovu-uij Public' reporting burden for this collection of information'is estimated to average 4 hours per response, including the time for reviewing instructions, searching existing data sources, gathering und j maintaining the data needed, and completing and reviewing the collection of information. Send coments regarding this burden estimate or any other aspect of this collection of information, including suggestions for j reducing this burden, to the Information and Records Management Branch (MNBB-7714), U.S. Nuclear Regulatory Commission, Washington, DC 20555; 8 andtothePaperworkReductionProject(3150-0014,3150-0017,3150-0020, i and3150-0009), Office of Management and Budget, Washington, DC 20503. 4 Regulatory Analysis l The Commission has prepared a draft regulatory analysis on this proposed regulation. The analysis examines the costs and benefits of the alternatives considered by the Comission. The draft analysis is avail-able for inspection in the NRC Public Document Room,.2120 L ttreet NW (LowerLevel), Washington,DC. Single copics of the draft analysis may beobtainedfromJosephJ. Mate, telephone.(301).492-3795. The Commis-sion requests public comments on the draft regulatory analysis. Coments on the draft analysis may be submitted to the NRC as indicated under the ADDRESSES heading. Regulatory Flexibility Certification Based on the information available at this stage of the rulemaking proceeding and in accordance with the Regulatory Flexibility Act, 5 13 Enclosure. l
L / ovo-vi j -- a U.S.C. 605(b), the Commission certifies that, if promulgated, this rule will not have a'significant economic impact on a substantial number of small entities. The proposed rule affects approximctely 9,100 licensees monitored by HRC under 10 CFR Parts 20, 40, and 70. The licenses are issued to academic institutions, medical institutions, and industrial entities. The proposed rule is being' issued in order to reduce misunderstandings by material licensees and te clarify the types of events that must be reported to NRC. No report would be required of i licensees unless there is an incident involving licensed material that 1 meets the requirements specified in the proposed amendments. Since the revised reporting requirements are essentially the same as the current reporting requirements, Qe impact on licensees should be minimal. L Backfit Analysis The NRC has determined that the backfit rule,10 CFR 50.109, does not apply to this proposed rule 'and therefore a backfit analysis is not I required because the amendments that apply to power reactors (deletion of 10 CFR'20.403 (a)(3), (a)(4), (b)(3), and (b)(4)) involve only a l l relaxation of requirements. List of Subjects in 10 CFR Parts 20, 30, 40, and 70 10 CFR PART 20 t 1. Byproduct material, Licensed material, Nuclear materials, Nuclear power plants and reactors, Occupational safety and health, Packaging and 1 14 Enclosure. l
^ L/590-01J containers, Penaltyi Radiation protection, Reporting and recordkeeping requirements, Specie.1 nuclear material, Source material, Waste treatment and disposal. 10 CFR PART 30 Byproduct material, Government contracts, Intergovernmental relations, Isotopes, Nuclear materials, Penalty, Radiation protection, Reporting and recordkeeping requirements.- 10 CFR PART 40 Government contracts. Hazardous materials-transportaticr., Nuclear materials, Penalty, Reporting and recordkeeping requirenants, Source neterial, Uranium.1 10 CFR PART 70 Hazardous materials-transportation. Hv;1 ear materials, Packaging and containers, Penalty, Radiation protection, Reporting and recordkeeping requirements, Scientific equip ant, Security measures, Special nucleat-material. For the reasons set out in the preamble and under the authority of the Atomic Energy Act of 1954, as amended, the Energy Reorganization Act of 1974, as amended, and 5 U.S.C. 553, the HRC is proposing to adopt the following amendments to 10 CFR Parts 20, 30, 40, and 70. 15 Enclosure-
i/byu-Ulj PhRT 20 - STANDARDS FOR PROTECTION AGAINST RADIATION 1. The authority citation for Part 20 continues to read as follows: AUTHORITY: Secs. 53, 63, 65, 81, 103, 104, 161, 68 Stat. 930, 933, 935, 936, 937, 948, as amended (42 U.S.C. 2073, 2093, 2095, 2111, 2133, 2134, 2201); Secs. 201, as amended, 202, 206, 88 Stat. 1242, as amended, 1244, 1246 (42 U.S.C. 5841, 5842, 5846). Section 20.408 also issued under Secs. 135, 1.41, Pub. L. 97-4?.5, 96 Stat. 2232, 2241 (42 U.S.C. 10155, 10161). ForthepurposesofSec.223,68 Stat.958,asamended(42U.S.C. 2273);il20.10'1,20.tJ2,20.103(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 $$ 20.102, 20.103(e), 20.401-20.407, 20.408(b), and 20.409 are issued under Sec. 1610, 68 Stat. 950, as amended (42 U.S.C.2201(o)). 6720.403-[ Amended] 2. In 5 20.403, the semicolon and the word "or" following paragraph (a)(2)areremovedandaperiodisinserted,andthesemicolon and the word "or" following paragraph (b)(2) are removed and a period is inserted,andparagraphs(a)(3),(a)(4),(b)(3),and(b)(4)areremoved.- 16 Enclosu're
L/byu-ulj s. i PART 30'- RULE OF GENERAL APPLICABILITY TO DOMESTIC LICENSING OF BYPRODUCT MATERIAL j 3. The authority citation for Part 30 is revised to read as follows: AUTHORITY: Sec. 81, 82161,182,183,186, 68 Stat. 935, 948, 953, 954, 955, as amended, Sec. 234, 83 Stat. 444, as amended (42 U.S.C. 2111, 2112, 2201, 2232, 2233, 2236, 2282); Secs. 201, as amended, 202, 206. 88 Stat.1242, as amended, 1244,1246(42U.S.C.5841,5842,5846). Section 30.7 also issued under Pub. L. 95-601, Sec.10, 92 Stat. 2951(42U.S.C.5851). Section 30.34(b) also issued under Sec.184, 68, Section 30.61 c io issued under Stat.954,asamended(42U.S.C.2234). 2 Sec.187, 68 Stat. 955 (42 U.S.C. 2237). For the purposes of Sec. 223, 68 Stat. 958, as amended (42 U.S.C. 2273); 55 30.3, 30.34(b)(c) and (f), and 30.41(a) and (c), and 30.53 are issuedunderSec.161b,68 Stat.948,asamended(42U.S.C.2201(b));and 55'30.6,30.9,30.36,30.50,30.51,30.52,30.55,and30.56(b)and(c) are issued under Sec. 1610, 68 Stat. 950, as amended (42 U.S.C. 2201(o)). 4. Section 30.8(b) is revised to read as follows: S 30.8(b) The approved information collection requirements contained in this part appear in $$ 30.15, 30.19, 30.20, 30.32, 30.34, 30.36,.30.37, 30.38, 30.50, 30.51, 30.55, and 30.56. 5. A new 5 30.50 under Records, Inspections, Tests, and Reports is added te read as follows: 17 Enclosure. I 1 ,___J
L i ovu-ui,i 5-30.50 Notification requirements. (a)- Immediate notification. Each licensee shall notify the NRC as soon as possible but not later than 4 hours af ter the discovery of any event involving licensed material that prevents or threaten to prevent immediate protective actions necessary to maintain and verify control of licensed material (includes fires, explosions, toxic gas releases, etc.). (b) Twenty-four hour notification. Each licensee shall notify the NRC within 24 hours after the discovery of any of the following events involving licensed material: (1) Any contamination event that restricts access to the contaminated area by workers or the public for more than 24 hours. i -(2) Any ever' in which equipment necessary to prevent uncontrolled releases of radioactive meterial, or to prevent overexposures to radiation, or to mitigate the consequences of an accident, is disabled or fails to function as designed when it is needed. Notification is not required when an individual component is disabled or fails to function if redundant equipment is operable and available to automatically perform the required function. (3) Any event that requires medical treatment of a radioactively contaminated individual at a medical facility. Notification is not required if first aid at a licensee-maintained medical facility for a superficial injury is the only treatment rendered. (4) Any fire or explosion damaging any licensed material or.any device, c7ntainer, or equipment containing. licensed material. (c) Preparation and submission of reports. Reports filed with the HRC pursuant to this section must have the names of persons who have received exposure to radiation stated in a separate part of the report. 18 Enclosure.
t/b90-01,1 Reports made by licensees in respone to the requirements of this section I' must be made as'follows: (1) Licensees shall make reports required by paragraphs (a) and (b) of this section by telephone to the NRC Operations Center.I To the extent that the information is available at the time of notification, the t information provided in these reports must include: (1) The caller's name and call back telephone number; (ii) A description of the event, including date and tine; (iii)Theexactlocationoftheevent; (iv) The isotopes, quantities, and chemical and physical form of the licensed material involved; and (v) Any personnel radiation exposure data +/ailable. (2) Written report.- Each licensee who makes a report required by paragraph (a) or (b) of this section shall submit a written follow-up report within 30 days of the initial report. These written reports must be sent to the U.S. Nuclear Regulatory Comission, Document Control Desk, i Washington, DC 20555, with a copy to the appropriate NRC Regional office listed in Appendix 0 of 10 CFR Part 20. The reports must include the following -- (i) A description of the event, including the probatle cause and the manufacturer and model number (if applicable) of any equipment that failed or malfunctioned; (ii) The exact location of the event; j (iii) The isotopes, quantities, and chemical and physical form of the licensed material involved; 1 The commercial telephone nunber for the NRC Operations Center is (202) 951-0550. 19 Enclosure f, ab~ -
L7590-01J 4 (iv) Date'and time of the event; (v) ' Corrective actions taken or planned and the results of any evaluations or assessments; and (vi) The extent of exposure of individuals to radiation or to + radioactive materials. '(3) The provisions of 6 30.50 do not apply to Licensees subject to the notification requirements in 5 50.72. They do apply to research and test reactors possessing material licensed under Part 30. PART 40 - DOMESTIC LICENSING OF SOURCE MATERIAL 6. The authot :ty citation for Part 40 is revised to read as follows: AUTHORITY: Sees. 62, 63, 64, 65, 81,161,182,183,186, 68 Stat. 932, 933, 935, 948, 953, 954, 955, asamended, Secs.11e(2),83,84, Pub.L. . 95-604, 92 Stat. 3033, :s amended, 3039, sec. 234, 83 Stat. 444, as amended (42.U.S.C.'2014(e)(2),2092,2093,2094,2095,2111,2113,2114, 2201, 2232, 2233, 2236, 2282); Sec. 274, Pub. L. 86-373, 73 Stat. 688 (42 U.S.C.2021); Secs.201,asamended, 202, 206, 88 Stat.1242, as amended, 1244,1246(42 U.S.C.5841,5842,5846);Sec.375,92 Stat.3021,as amended by Pub. L. 97-415,96 Stat.2067(42U.S.C.2022). L Section 40.7 also issued under Pub. L. 95-601, Sec. 10, 92 Stat. 2951(42U.S.C.5841)Section40.31(g)alsoissuedunderSec.122,68 l l Stat.939(42U.S.C.2152). Section 40.46 also issued under Sec.184, 68 Stat.954,asamended(42U.S.C.2234). Section 40.71 also issued under Sec.187,68 Stat.955(42U.S.C.2237). l L 20 Enclosure - l
. l /690-01.1 for the purposes lof Sec. 223, 68 Stat. 958, as amended (42 U.S.C. 2273); $6 40.3,'40.25(d)(1)-(3), 40.35(a)-(d), and (f) 40.41(b) and-(c), 40.46,40.51(a)and(c),and40.63areissuedunderSec.161b,68 Stat. 948, as amended (42 U.S.C. 2201(b)); and 65 40.5, 40.9, 40.25(c), (d)(3), and (4), 40.26(c)(2), 40.35(e), 40.42, 40.60, 40.61, 40.62, 40.64, and 40.65 are issued under Sec. 1610,68 Stat.950,asamended(42U.S.C. 2201(o)). -7. Section 40.8(b) is revised to read as follows: 540.8(b) The approved information collection requiremt.nt: contained in this part appear in SS 40.25, 40.26, 40.31, 40.35, L>.42, 40.60, 40.61, 40.64, 40.65, and Appendix A. 8. A new 6 40.60 under Records, Inspections, Tests and Reports is added to read as follows: 6 40.60 Notification requirements. (a) Immediate notification. Each licensee shall notify the NRC as soon as possible but not later than 4 hours after discovery of any event L involving licensed material that prevents or threaten to prevent L immediate protective actions necessary to maintain and verify control of licensedmaterial(includesfires, explosions,toxicgasreleases,etc.). (b) Twenty-four hour notification. Each licensee shall notify the NRC within 24 hours after the discovery of any of the following events involving licensed material: (1) 'Any contamination event that restricts access to the contaminated aret by workers or the public for more than 24 hours. 1 i 21 Enclosure. l
L7590-01,1 Any event' in which equipment necessary to prevent uncontrolled (2) releases of rad'ioactive material, or to prevent overexposures to radiation, or to mitigate the consequences of an accident, is disabled or fails to function as designed when it is needed. Notification is not-required when an individual component is disabled or fails to function if redundant equipment is operab'.e and available to automatically perform the required function. (3) Any event that requires medical treatment of a radioactively contaminated individual at a medical facility. Notification is not required if first aid at a licensee-maintained medical facility for a significant injury is the only treatment rendered. (4) Any
- ire or explosion damaging any licensed material or any device, container, or equipment containing licensed material.
(c) Preparation and submission of reports. Reports filed with the NRC pursuant to this section must have the names of persons who' have received exposure to radiation stated in a separate part of the report. Reports made by licensees in response to the requirements of this section must be made as follows: (1)' Licensees shall make reports required by paragrapns (a) and (b) of this section by telephone to the HRC Operations Center.2 To the extent that the information is available at the time of notification, the information provided in these reports must include: (1) The caller's name and call back telephone number; (ii) A description of the event, including date and time; 2 The connercial telephone number for the HRC Operations Center is (202)951-0550. 22 Enclosu're
L/o90-uij (iii) The exact location of the event; (iv) Thel isotopes, quantities, and chemical and physical form of the licensed material involved; and (v) Any personnel radiation exposure data available. (2)- Written report. Each licensee who makes a report required by paragraph (a) or (b) of this section shall submit a written follow-up report within 30_ days of the initial report. These written reports must be sent to the U.S. Nuclear Regulatory Comission, Document Control Desk, Washington, DC 20555, with a copy to the appropriate NRC regional office listed in Appendix D of 10 CFR Part 20. _The reports must include the following -- (i) A description of the event, includ4*)g the probable cause and the manufacturer and model number (if applicable) of any equipment that failed or malfunctioned; (ii) The exact location of the event; (iii) The isotopes, quantitias, and chemical and physical form of the licensed material involved; (iv) Date and time of the event; (v) Corrective actions taken or planned and the results of any evaluations or assessments; and (vi) The extent of exposure of individuals to radiation or to radioactive materials. The provisions of $ 40.60 do not apply to licensees subject to (3) the notification requirements in 5 50.72. They do apply to research and test reactors possessing material under Part 40. 23 Enclosure
[7590-01] PART 70 - D'OMESTIC LICENSING OF SPECIAL NUCLEAR MATERIAL 9. The authority citation for Part 70 is revised to read as follows: AUTHORITY: Secs. 51, 53, 161, 182, 183, 68 Stat. 929, 930, 948, 953, 954, as amended, Sec. 234, 83 Stat. 444, as amended (42 U.S.C. 2071, 2073,2201,2232,2233,2282); Secs.201,asamended, 202, 204, 206, 88 Stat.1242, as amended, 1244, 1245, 1246, (42 U.S.C.'5841, 5842, 5845, 5846). Sections 70.1(c) and 70.20a(b) also issued under Secs. 135, 141, Pub. L. 97-425,96 Stat.2232,2241(42U.S.C.10155,10161). Section 70.7 also 1: sued under Pub. L. 95-601, sec.10, 92 Stat. 2951 (42 U.S.C. 5851). Section 70.21(g) also issued under Sec. 122, 68 Stat. 939 (42 U.S.C.2152). Section 70.31 also issued under Sec. 57d, Pub. L. 93-377, 88 Stat. 475 (42 U.S.C. 2077). Sections 70.36 and 70.44 also issued under Sec.184, 68 Stat. 954,. as amended (42 U.S.C. 2234). Section 70.61 also issued under Secs.186,1B7, 68 Stat. 955 (42 U.S.C. 2236, 2237). Section 70.62 also issued under Sec. '108, 68 Stat. 939, as amended (42 U~S.C.2138). For the purposes of Sec. 223, 68 Stat. 958, as amended (42 U.S.C. 2273); 55 70.3, 70.19(c), 70.21(c), 70.22(a), (b), (d)-(k), 70.24(a) and (b),70.32(a)(3),(5),(6),(d),and(1),70.36,70.39(b)and(c), 70.41(a),70.42(a)and(c),70.56,70.57(b),(c) and(d), 70.58(a)-(g)(3), and (h)-(j) are issued under Sec.161b, 68 Stat. 948, as amended (42 U.S.C. 2201 (b)); $$ 70.7, 70.20a(a) and (d), 70.20b(c) and (e), 70.21(c), 70.24(b), 70.32(a)(6), (c), (d), (e), and (g), 70.36, 70.51(c)-(g), 70.56, 70.57(b) and (d), and 70.58 (a)-(g) (3) and (h)-(j) c are issued under Sec. 1611,68 Stat.949,asamended(42U.S.C.2201(i)); L 24 Enclosure l 4
L/wo-ulj and $9 70.5', 70.9, 70.20b(d) and (e),- 70.38, 70.51(b) and (i) 70.50, 70.52, 70.53,' 70.54, 70.55, 70.58 (g)(4), (k), and (1), 70.59, and-70.60(b)and(c)areissuedunderSec. 1610, 68 Stat. 950, as amended (42 U.S.C.2201(o)).
- 10. Section 70.8(b) is revised to read as follows:
The approved information collection requirements contained in this part appear in 65 70.19 70.20a, 70.20b, 70.21, 70.22, 70.24, 70.32, 70.33, 70.34, 70.38, 70.39, 70.50, 70.51, 70.52, 70.53, 70.57, 70.58, 70.59, and 70.60
- 11. A new f 70.FJ under Special Nuclear Material Control, Records, Reports and Inspect'.ons is added to read as follows:
5 70.50 Notification requirements. (a) Immediate notification. Each licensee shall notify the NRC as soon as possible but not later than 4 hours after the discovery of any event involving licensed material that prevents or threaten to prevent immediate protective actions necessary to maintain and verify control of 11 censed material (includes fires, explosions, toxic gas releases, etc.). (b) Twenty-four hour notification. Each licensee shall notify the NRC within 24 hours after the discovery of any of the following events involving licensed material: (1) Any contamination event that restricts access to the contaminated area by workers or the public for more than 24 hours. (2) Any event in which equipment necessary to prevent uncontrolled releases of. radioactive material, or to prevent exposure to radiation, or to mitigate.the consequences of an accident is disabled or fails to function as designed when it is needed. Notification is not required 25 Enclosu're l l
1
- kk
\\(O 84 8 /,,[NYg,f+4 IMAGE EVALUATION d 47,,7 Y. $/ TEST TARGET (MT-3) / 4 % W = t L E'- 1.0 'd BE L14 y 8y BE i,i [m EM l.8 l.25 'l 1.4 g 4 150mm e 4 6" _ Qgy*/i,t# %g,,,,, /4% = ,g% y 6
L7590-01J I when an individual component is disabled or fails to function if redundant equipment is operable and available to automatically perform 'the required function. (3) Any event that requires medical' treatment of a radioactively contaminated individual at a medical facility. Notification is not ( required if first aid at a licensee-maintained medical facility for a superficial injury is the only treatment rendered. (4) Any fire or explosion damaging any. licensed material or any device, container, or equipment containing licensed material. (c) Preparation and submission of reports. Reports filed with the NRC pursuant to this section must have the names of persons who have received exposure to radiation stated w a separate part of the report. Reports made by licensees in response to the requirements 6f this section must be made as follows: (1) Licensees shall make reports required by paragraphs (a) and (b) of this section by telephone to the NRC Operations Center.3 To the extent that the information is available at the time of notification, the -information provided in these reports must include: - (i) The caller's name and call back telephone number; (ii) A description of the event, including date and time; (iii) The exact location of the event; (iv) The isotopes, quantities, and chemical and physical form of the licensed material involved; and (v) Any personnel radiation exposure data available. The commercial telephone number for the NRC Operations Center is 3 (202)951-0550. l l 26 Enclosure l
r [7590-01] 4 (2) Written report. Each licensee who makes a report required by paragraph (a) or (b) of this section shall prepare a written followup report within 30 days of the initial report. These written reports must be sent to the U.S. Nuclear Regulatory Commission, Document Cortrol Desk, Washington, DC 20555, with a copy to the appropriate NRC regional office. listed in Appendix 0 of 10 CFR Part 20. The reports must include the following -- (i) A description of the event, including the probable cause and the manufacturer and model number (if applicable) of any equipment that failed or malfunctioned; (ii) The exact location of the event; (iii) The isotopes, quanth.es and chemical and physical form of the licensed material involved; (iv) Date and time of the event; (v) Corrective actions taken or planned and the results of any evaluations or assessments; a d (vi) The extent of exposure of individuals to radiation or to radioactive' materials. 1 ~ (3)^ The provisions of 6 70.50 do not-apply to licensees subject to the notification requirements in 6 50.72. They do apply to research and test reactors possessing material Itcensed under Part 70.
- ay of Af.j/
,1990. d of Dated at Rockville, Maryland, this ad / For the Nuclear Regulatory Commission. J esM. Taylor / xecutive Director for Operations l-l l 27 Enclosure i
q Approved For Publication The Commission delegated to the EDO (10 CFR 1.31(a)(3)) the authority to develop and promulgate rules as defined in the APA (5 U.S.C. 551 (4)) subject to the limitations in NRC Manual Chapter 0103, Organization and Functions, Office of the Executive Director for Operations, paragraphs 0213, 038, and-0310. The enclosed rules, entitled " Notifications of Incidents," will amend 10 CFR 20.403 and establish 10 CFR 30.50,10 CFR 40.60, and 10 CFR 70.50. These amendments are needed to ensure-that significant incidents are promptly reported to NRC so that the agency can evaluate whether immediate action is required to protect the public health and safety. These proposed rules do not constitute a significant question of policy, nor l do they amend regulations contained in 10 CFR Parts 7, 8, or 9 Subpart C concerning matters of policy. I, therefore, find that these rules are within the scope of ny rulemaking authority and am proceeding to issue them. / /bd & Wh Date ' Ja sM.Taylg ecutive Director for Operations L l l l:
- ?
C Q \\; P B R-me 8 UNITED STATES 0 NUCLEAR REGULATORY COMMISSION o I \\.....)1 - wanworow.o c. mass MAY I1 Iggr MEMORANDUM FOR: Richard E. Cunningham, Director Division of Fuel Cycle, Medical, Academic and Comercial Use Safety Office of Nuclear Material Safety and Safeguards Robert Alexander, Chief Radiation Protection and Health Effects Branch Office of Nuclear Regulatory Research i FROM: James Lieberman, Director Office of Enforcement 1 1
SUBJECT:
10 CFR 20.403(b)(3) - TWENTY-FOUR HOUR NOTIFICATIONS OF INCIDENTS In a recent escalated enforcement case (EA 87-54 Comdustrial Roofing Con-tractors, Inc. there were differing (b (3) states:o inions within the NRC staff r 10CFR20.403()(3). Section 20.403 Each licensee shall imediately report any events involving byproduct, have caused or threatens to cause a loss of one day or mort o operation of any facilities affected. In the Comdustrial case, a fire destroyed the licensee's building which contained a moisture density gauge. The gauge was-dama pd by the fire such that it was no longer useable but the radioactive material in the gauge was not affected. The NRC was never notified of the fire and found out about the fire only as a result of an NRC inspection that took place about 4 months after the fire. i The NRC staff was divided on whether a violation of 20.403(b)(3) should cited. Some NRC staff believed that a violation of 20.403(b)(3) did not occur because the gauge containing the licensed material did not cause or threaten to cause the loss of one day or more of operation. (Seeattached page from old IE inspector's handbook.) In addition, the gauge's value was 1 estimated to be less than $2,000. (See 20.403(b)(2).) Other NRC staff believed a violation of 20.403(b)(3) did occur because the gauge was unusable and it was the licensee's only gauge. OGC supports this view. Thus, operations involving the gauge were lost for more than one day. gQ3/WW 4
g s ( Richard E. Cunnin ham
- I III
-2. Robert Alexander Since this appears to be a recurring problem I recomm!nd'this reporti i requirement be clarified and/or notice be given to licensees that whenever licensed material is damaged such that it cannot be used it must be re i .Please call me or Ed Flack of my staff after you have had a chance to co -i this matter. OdginalSitoed BV i ' James Lisbennan James Lieberman, Director Office of Enforcement
Enclosure:
As stated cc: J. Goldberg, OGC Distribution J. Lieberman~, OE E. Flack OE OE Files J. Taylor, ED0 ( 1 i l 0% OE. / EFlack JL4 berman 54pt/87 St. 87 L. J}}