ML20128M944
| ML20128M944 | |
| Person / Time | |
|---|---|
| Issue date: | 01/07/1993 |
| From: | Curtiss J NRC COMMISSION (OCM) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| 2.206, NUDOCS 9302220404 | |
| Download: ML20128M944 (2) | |
Text
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NOTATION - V0TE.
RELEASED TO THE PDR
- ,p//7/95 &
- RESPONSE SHEET j , , , ,8a[o', ,, , , , , , ,,ip;a;s,,,,j T0: SAMUEL J . CHILK, SECRETARY OF THE COMMISSION FROM: C0ftiISSIONER CURTISS
SUBJECT:
SECY-92-415 - REVIEW 0F THE C0tetISSION'S REGULATIONS AND PRACTICE GOVERNING CITIZEN PETITIONS UNDER 10 CFR 2.206 FOR INSTITUTING PROCEEDINGS AGAINST LICENSEES x x APPROVED in part DISAPPROVED in part ABSTAIN NOT PARTICIPATING .
REQUEST DISCUSSION COMMENTS:
See attached comments.
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Commissioner Curtiss' comments or. SECY-92-415:
The General Counsel makes a number of persuasive points in support of the recomendation that the agency consider undertaking an evaluation of how the 10 CFR 2.206 process has been 3 implemented and whether additional steps should be taken to improve the effectivc ass of public participation in the Commission's regulatory processes. Indeed, the recommendation to hold a public workshop on this matter may be the most effective way to proceed. I would prefer to reserve judgment, however, on the need for holding such a workshop, as well as on the scope of the issues to be addressed in any reevaluation of the 2.206
]} process, until I have had an opportunity to review the background paper. Accordingly, I agree with Commissioner de Planque's B suggestion that the Commission be provided the background paper prior to moving forward with plans for the workshop.
With regard to the issues that might be considered if such an effort were undertaken, I would note at this point that given the extensive attention that has been devoted to the 2.206 process in
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--- the context of Part 52 including the initial discussions that j took place at the time that Part 52 was promulgated, as well as the legislative and judicial deliberations that subsequently took place concerning the use of 2.206 in the Part 52 context, I would be most hesitant to reopen those discussions at this time.
Rather, if there is a need to evaluate the way in which the agency handles 2.206 petitions, I believe it would be wise to limit the focus of that effort to the enforcement-type 2.206 petitions, with the Part 52 licensing-type 2.206 process explicitly excluded from this undertaking.
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