ML20138J450
| ML20138J450 | |
| Person / Time | |
|---|---|
| Issue date: | 01/03/1997 |
| From: | Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM) |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20138J441 | List: |
| References | |
| SECY-96-147-C, SECY-96-249-C, NUDOCS 9702070267 | |
| Download: ML20138J450 (2) | |
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NOTATION VOTE l RESPONSE SHEET
! TO: John C. Hoyle, Secrotary l
FROM: CHAIRMAN JACKSON
SUBJECT:
SECY-96-249 - STAFF RESPONSE TO SRM ON ,
SECY-96-147 REGARDING REDUCING NEED FOR l l
EXEMPTIONS AND CONSISTENCY OF THE EXEMPTION PROCESS l
I;ubject Approved X cVm m ent) Disapproved _. Abstain Not Parc1cipating Request Discussion COMMENTS:
See attached comments.
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- S F, NATURE l l
Release Vote /g/ January 3,1997 DATE .
l Withhold Vote / /
l Entered on "AS" Yes XX No i
l 9702070267 970129 PDR COMMS NRCC CORRESPONDENCE PDR 1
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CHAIRMAN JACKSON'S VOTE ON SECY-96-249 I concur with the following staff recommendation and conclusions contained in SECY-96-249:
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No changes to the special circumstance provisions currently I contained in 10 CFR 50.12 are needed. ,
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The current general criteria for considering specific ;
exemptions requested by materials licensees are adequate.
I . The internal processes for the evaluation of exemption requests are adequate.
l I continue to believe and agree with Commissioner McGaffigan that we should apply the regulatory criteria for exemptions objectively and without a preconceived notion that exemptions l should be either readily available for anyone who seeks an ,
exemption, or, conversely, limited and circumscribed. I !
here*ofore have repe=tedl emphasized that it ps + i ular l regulations are unclear or difficult to comply witn such that they engender an inordinate volume of exemption requests, we
! should oromotiv seek to modify and correct these regulations, and in the interim period before the completion of the corrective
! rulemaking, grant those exemptions that are properly justified l under our exemption criteria.
While I concur with the staff's conclusion regarding the adequacy of internal process requirements for 10 CFR 50.12 requirements, I believe that more explicit staff guidance should be available to ensure quality and consistency of exemption packages. This guidance could be supplemented by using prior precedents as examples and lessons learned from the current concurrence i process.
l Candidate rulemaking activities resulting from reviews of experience with exemptions should continue to be noted and progress reported in the semiannual updates of the Rulemaking Activity Plan.
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