ML20136B185
| ML20136B185 | |
| Person / Time | |
|---|---|
| Issue date: | 11/07/1984 |
| From: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Olmstead W NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| Shared Package | |
| ML19310G510 | List:
|
| References | |
| FRN-48FR36358, RULE-PR-2 AB78-1-011, AB78-1-11, NUDOCS 8511200153 | |
| Download: ML20136B185 (2) | |
Text
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g % UNITED STATES
'E - ~') NUCLEAR REGULATORY COMMISSION h.. REGION IV
[ ~ 611 RYAN PLAZA DRIVE, SUITE 1000
, ARLINGTON, TEXAS 76011 November 7, 1984 MDiORANDUM FOR: William J. Olmstead Director and Chief Counsel Regulations Division, OELD FROM: Robert D. Martin Regional Administrator, Region IV
SUBJECT:
NRC STATEMENT OF POLICY ON INVESTIGATIONS, INSPECTIONS AND ADJUDICATORY PROCEEDINGS--INITIATION OF RULDIAKING TO ESTABLISH PROCEDURES FOR RESOLVING CONFLICTS CONCERNING THE DISCLOSURE OR NONDISCLOSURE OF INFORMATION Pursuant to your request, we have reviewed the draft Federal Register notice of proposed rulemaking containing proposed amendments to 10 CFR Part 2. This response represents the comments of both myself and the other RIV addressee, William Brown, Regional Counsel.
Our comments are as follows:
- 1. In the Supplementary Information section and in Section 2.795n(b) of the proposed rule, reference is made to the fact that informa-tion can be released when the investigation or inspection "is . Q, qy completed." Since it has been a problem in the past in deter- ,
mining exactly when an investigation or inspection is considered * } pt p#{' 3 to be completed, we suggest that for purposes of the proposed t'/ f-rule the term " completed" should be defined. fvF]p Y u .3 ,
- 2. Several sentences in the proposed rule are so cumbersome and d" ./I ).
long as to be confusing. For example: eg -
- a. Sec. 2.795b is one sentence which is 12 lines long with 9 " ors" and 6 " ands."
- b. The first sentence of Sec. 2.795g(a) is 9 lines long and the very next sentence, while only 5 lines long, contains 7 " ors."
- c. Sec. 2.795n(b) is 12 lines long and contains 9 " ors."
gl 153 851115 2 M 36358 PDR
1 r
- 3. The second sentence of Sec. 2.795h is not clear. It would appear some part of it may be missing.
- 4. It is not clear how this proposed rule is supposed to dovetail with the Freedom of Information Ac in all its aspects.
o ert D. Martin Regional Administrator
'cc: Thomas Murley, Regional Administrator, RI James O'Reilly, Regional Administrator, RII James Keppler, Regional Administrator, RIII
' John Martin, Regional Administrator, RV 1
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