ML20059J705
| ML20059J705 | |
| Person / Time | |
|---|---|
| Issue date: | 11/18/1993 |
| From: | Selin I, The Chairman NRC COMMISSION (OCM) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| NUDOCS 9402010140 | |
| Download: ML20059J705 (2) | |
Text
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RELEASED TO THE PDR NOTATION V0T(
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RESPONSE SHEET
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SAMUEL J. CHILK, SECRETARY OF THE COMMISSION FROM:
THE CHAIRMAN
SUBJECT:
SECY-93-285 - PROPOSED RULEMAKING - NEW PART 76, " CERTIFICATION OF GASEOUS DIFFUSION PLANTS" w/ comments APPROVED x in part DISAPPROVED ABSTAIN NOT PARTICIPATING REQUEST DISCUSSION COMMENTS:
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RELEASE VOTE
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November 18, 1993 DATE n
WITHHOLD VOTE
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ENTERED ON "AS" YES
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CHAIRMAN'S COMMENTS ON SECY-93-285 I want to commend the staff effort on preparation of this significant document for Commission consideration.
I am impreTsed with the high quality of the technical standards proposed.
The staff is to be commended for preparation of the proposed new rule in a short period while maintaining a well thought out, quality product.
I agree with Commissioner Remick's comments on backfit, training, scope, definition and detectors in the proposed rule and approve the publication of the proposed rule as modified by Commissioner Remick's comments.
However, I have additional concerns regarding the procedural requirements and defer my vote on the procedural aspects of the proposed rule until supplemental information is provided by the staff.
I agree with Commissioner Remick that NRC should be procedurally performing a two step process, assessment / approval of a base or an initial application which would be separate from the annual-certification process.
However, I believe that the staff should consider the option of moving forward with the technical requirements of the rule if feasible while resolving the issues surrounding the procedural requirements.
The procedural requirements as outlined in'the proposed rule are cumbersome and unwieldy, given the expected timeframe for completion of the annual certification.
The annual certification should be the evaluation of the changes from the initial application.
For the annual certification, NRC should have a process that is flexible enough to allow an interim report for those instances when issues are not yet resolved.
While I support the need for flexibility, I believe that we need to develop a predictable regulatory environment for the annual certification which addresses the status of the Corporation whether it is operating under a certificate of compliance, compliance plan or an interim stage.
I have one minor comment on the definition of " work" in Section 76.4.
I would like an explanation as to the necessity for a new definition because I have not found where this term is used in the draft Part 76.
The term " worker" (which is defined in Part
- 19) is used throughout the proposed regulation and the term
" working area" is used in Section 76.35(a) (4).
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