ML20127C194
| ML20127C194 | |
| Person / Time | |
|---|---|
| Issue date: | 10/05/1984 |
| From: | Olmstead W NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Gillespie F NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20127B584 | List:
|
| References | |
| FRN-50FR13797, RULE-PR-19, RULE-PR-39 AB35-1, NUDOCS 8410230554 | |
| Download: ML20127C194 (1) | |
Text
_ __
[
Io,, UNITED STATES >
j y g NUCLEAR REGULATORY COMMLSSION g :; E WASHINGTON D. C. 20555
\*****/ 1 October 5, 1984 1
MEMORANDUM FOR: f 'Gillespie, Director ,
s Division of Risk Analysis and-(peration Office of Nuclear Regulatory 'P.esearch FROM: MlliamJ.Olmstead Director and Chief Counsel, Regulations Division Office of the Executive Legal Director
SUBJECT:
PROPOSEDRULEONWELL-LOGGINGOPERATIOUS (10CFRPART39)
We are not pretacei as yet to concur on the preposed rule. Our corrections are noted on the enc'osed mark-up. We suggest that all the information collection requiremenis be located in one section of Part 39, perhaps in s 39.8, rather than di:.9eraed throughout the various sections; the allusion in s 39.8 to the various requiremerts is inadequate. Current inspection priority is three years for. well 16ggers; thus, the two-year records maintenance provisions are too short. In light of various legal problems we have had recently with several licensees, the provision in new $ 39.16 should be added. Section 39.101 should be modified as indicated.
The Federal Register rarely allows, cmss re*erence to another agency's regulations. You should check with it the 'efr:rence to 49 CFR Parts 171 to 178 on page 39. Note that a date certain must be inserted in 5 39.65(c) on page 51,'that the aY'iusion to the revision in section 5 on page 58 is unclear, and that several sections in Part 30 are not mentioned in section 5 on that '
page.
Since an identification plaque described in 6539.15(b)(4)(iii)maybecovered in time by sand, mud and debris. we suggest that 9 39.15(b) be modified to indicate that a statement should be filed with whatever ccunty office keeps land records describing the items-indicated in 6 39.15(b)(4)(iii)(C) to (G).
We have no comments on the environmental assessment.
You should check with the ED0's office to find out whether they want to send the paper to the Comission.. If the paper covers a "significant" policy question -- and promulgation of a new Part is probably such a question --
the ED0 should send the rule to the Commission.
A William J. @ mstead h7 T/l k Director and Chief Counsel g
Regulatichs DiNision A
Office of the Executive Legal Director cc: J. Davis, NMSS L. Barry, RM W. Kerr, SP T. Murley, Region I R. DeYoung, IE - J. O'Reilly, Region II P. Norry, ADM J. Keppler, Region III C. Heltemes, Jr., AE0D J. Collins, Region IV J. Fouchard, PA J. Martin, Region V
<