ML20133J101
| ML20133J101 | |
| Person / Time | |
|---|---|
| Issue date: | 07/17/1984 |
| From: | Bassett O NRC - RESEARCH INDEPENDENT REVIEW BOARD |
| To: | Bernero R NRC - RESEARCH INDEPENDENT REVIEW BOARD |
| Shared Package | |
| ML20132B800 | List:
|
| References | |
| FRN-50FR34708, RULE-PR-73 AB46-1-30, NUDOCS 8510180264 | |
| Download: ML20133J101 (1) | |
Text
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RES INDEPENDENT REVIEW BOARD
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VOTING SHEET TO: ROBERT M. BERNER0," CHAIRMAN, RIR8 FROM:
TITLE OF RULEMAKING: "RfpogrwG gqo R&fMT5 NA SAFE 6uMn twg AGREE WITH DRAFT RES REQUEST RIRB INDEPENDENT RECOMMENDATIONS MEETING.
IN DRAFT INDEPENDENT REVIEW PACKAGE.
MODIFY DRAFT RES NOT PARTICIPATING.
X INDEPENDENT RECOMMENDATIONS AS INDICATED BELOW.
COMMENTS AND SUGGESTIONS:
The memorandum from RAMRB, DRAO, RES to RIRB members notes in the sumary analysis that the proposed rule " involves a significant cuestion of policy." I do not agree with this characterization.
The proposed rule appears to try to accomplish a simplification and clarification of safeguards events notification requirements.
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In the proposed RES Staff Review Sumary Sheet," paragraph 2a notes that the rulemaking package does not include the basis for the issue that the present reporting requirements are confusing to the licensees and are difficult to properly implement. The sumary sheet further notes that the NMSS contact stated that the missing justification will be sent
' for review shortly. Nevertheless, the sumary sheet indicates in paragraph
' 3a that "the need for this rulemaking has been established even if it is only to clarify and simplify existing requirements." The sumary sheet further notes in paragraph 3b that "if the rulemaking were to proceed on the sole basis of clarification and simplification...it would be well worth the effort." I believe these statements are not consistent.
I agree that sufficient information has been provided for us to recomend I that the rulemaking" proceed; including the development of the missing justification. _Bu.t I don't see how we can make statements stating that
.. the need for the rulemaking has been established witho.ut this jystification.j i it! H cxvvM O.'E. Bassett /
MEMBER, R!RB I
' 7 l' -t 0510180264 001009 DATE PDR PR 73 SOFR34700 PDR
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