ML20140E744
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UNITED STATES y s. "%,$*g NUCLEAR REGULATORY COMMISSION r g wAsmuaTou. o.c. 2osss MAY 1 1985 - 1 MEMORANDUM FOR: William J. Dircks Executive Director for Operations FROM: Robert B. Minogue, Director Office of Nuclear Regulatory Research
SUBJECT:
CONTROL OF NRC RULEMAKING: RES INDEPENDENT REVIEW 0F ONGOING RULEMAKING SPONSORED BY NMSS Based on our independent review of the ongoing rulemaking " Revised Criteria and Procedures for Determining Eligibility for Access to or Control Over Special Nuclear Material," (10 CFR Part 11), sponsored by NMSS, RES recommends that this rulemaking should continue. The basis for our recomendation is as follows.
The proposed rule ainends 10 CFR Part 11 requirements for using only NRC clearance fonns when requesting special nuclear material access authorizations. These revisions will allow utilization of other federal agency clearance fonns for current active federal clearances based upon -
equivalent investigations for the purpose of granting NRC special nuclear material access authorizations. Specific considerations are:
o The number of licensed fuel facilities having fannula quantities of special nuclear material has been reduced significantly. All of the remaining facilities have requirements to varying degrees for NRC and/or DOE personnel access authorizations.
o The levels of NRC and DOE personnel access authorizations are the same
("Q" and "L") and they are based upon the same type of investigations.
Therefore, investigative data on file with either of these two agencies would be acceptable for granting the comparable level of access to special nuclear material, o An amendment to effect the changes to the rule would achieve all the objectives of the Comissions' special nuclear material access program and at the same time not require licensees to duplicate efforts and expenditures for equivalent investigations and application data which have already been accomplished to satisfy requirements for other federal agencies.
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4 William J. Dircks , 2 MAY 1 1985 t
o The estimate of reduced licensee burden is $1,599,900 per year industrywide o The estimate of reduced cost to the Federal Government is $'10,170 per year. -
The Director of MMSS, recomends that' this rulemaking continue.
The complete RES independent review package has been sent to OEDO (Attn:
DEDROGR) and to the Director, NMSS.
N Robert B. Minogue, Director Office of Nuclear Regulatory Research *
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e RES INDEPENDENT REVIEW PACKAGE O
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RES INDEPENDENT REVIEW BOARD VOTING SHEET TO: F. P. GILLESPIE, CHAIRMAN, RIRB -
FROM: K. R. Galler, Member, RIRB TITLE OF RULEMAKING: Revised Criteria and Procedures for Determining Cligibility for Access to or Control over SNM (Part 11)
/ AGREE WITH RECOPNENDATIONS IN RES RULEMAKINC REVIEW PACKAGE MODIFY RECOMMENDATIONS IN NOT PARTICIPATING.
RES RULEMAKING REVIEW PACKAGE AS INDICATED BELOW COPNENTS AND SUGGESTIONS:
t-K. R. Goller MEMBER, RIRB 4/L2 /W DAIE l
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RES INDEPENDEt3 REVIEW BOARD VOTING SHEET T0: F. P. GILLESPIE, CHAIRMAN, RIRB ,
G. A. Arlotto, Member, RIRB
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FROM:
TITLE OF RULEMAKING: Revised Criteria and Procedures for Detennining Eligibility for Access to or Control over SNM (Part 11)
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REQUEST RIRB AGREE WITH RECOMMENDATIONS IN RES RULEMAKING REVIEW MEETING.
PACKAGE
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MODIFY RECOMMENDATIONS IN NOT PARTICIFATING.
RES RULEMAKING REVIEW PACKAGE AS INDICATED BELOW COP 91ENTS AND SUGGESTIONS:
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,s RES INDEPENDENT REVIEW BOARD gV0 TING SHEET TO: F. P. GILLESPIE, CHAIRMAN, RIRB ,
FROM: W. M. Morrison, Member, RIRB TITLE OF RULEMAKING: Revised Criteria and Procedures for Determining Eligibility for Access to or Control over SNM (Part 11)
REQUEST RIRB AGREE WITH RECOPMENDATIONS MEETING.
IN RES RULEMAKING REVIEW PACKAGE
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MODIFY RECOMMENDATIONS IN NOT PARTICIPATING.
RES RULEMAKING REVIEW PACKAGE AS INDICATED BELOW COMMENTS AND SUGGESTIONS:
Straight Approval.
VWWA W. M. Morrison MEMBER, RIRB l
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- 3. W. M. Morrison, Member, RIRS g K. R. Goller, Member, RIRB
- a. G. A. Arlotto, flember, RIRB A -
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We are at step III.'C.2, "RIR3 deliberations," of the .
RES independent review procedufes fo'r the attached .
specific ongoing rulemaking sponsored by NM S S.
F Please evaluate the . attached dra'ft independent review package and provide RAllRB with your voting sheet indicating your. position on the rulemaking.
'Your response by c.o.b. R 2S E will assist in RES' making independent reconsnendations to the EDO in a timely manner.
so sect ese this seem as a ntcono of approvels, sencueroness, esposeis, ,
esentonces, and simiter actmens !
M pionne, erg. symbol, Agency /PosQ Reem ha.--4tdg RAMRB staff pnene me. !
443-7885 l' seen-see pomas 41 (mov. 7-76)
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t DRAFT RES INDEPENDENT REVIEW PACKAGE i
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MEMORANDUM FOR: William J. Dircks Executive Director for Operations FROM: Robert 8. Minogue, Director Office of Nuclear Regulatory Research i
SUBJECT:
CONTROL OF MRC RULEMAXING: RES INDEPENDENT REVIEW OF ONGOING RULEMAXING SPONSORED BY NMSS
_ Based on our independent review of the ongoing rulemaking " Revised Criteria and Procedures for Detensining Eligibility for Access to or Control Over Special
- - Nuclear Material," (10 CFR Part 11), sponsored by NMSS, RES reconsnends that this ,
rulemaking should continue. The basis for our recosamendation is as follows.
The proposed rule amends 10 CFR Part 11 requirements for using only NRC clearance forms when requesting special nuclear material access authorizations. These revisions will allow utilization of other federal
- agency clearance forms for current active federal clearances based upon
- equivalent investigations for the purpose of granting NRC special nuclear
!. material access authorizations. Specific considerations are:
l < :
l o The number of licensed fuel facilities having formula quantities of 3 j special nuclear material has been reduced significantly. All of the !
- ~ remaining facilities have requirements, to varying degrees for NRC '
l and/or DOE personnel access authorizations, o The levels of NRC and DOE personnel access authorizations are the same '
- ("Q" and "L") and they are based upon the same type of investigations.
Therefore, ~1nvestigative data on file with either of these two agencies would be acceptable for granting the comparable level of access to special nuclear anterial. ;
o An amendment to effect the changes to the rule would achieve all the '
objectives of the Comissions' special nuclear material access program i and at the same time not require licensees to duplicate efforts and i expenditures for equivalent investigations and application data which i have already been accomplished to satisfy requirements for other !
federal agencies. ,
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. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...............1 cas> y ccefecu sie no.sopf acu o 4o _.._ __OFFICI AL. RECORD._ COPY __ _ __.__.____ __ ! '
William J. Dircks 2 o The estimate of reduced licensee burden is $1,599.900 per year industrywide o The estimate of reduced cost to the Federal Government is $'10,170 per year. --
The Director of NMSS, recocraends that' this rulemaking continue.
The complete RES independent review package has been sent to OEDO (Attra:
DEDROGR) and to the Director, K4SS.
Robert 8. Minogue, Director Office of Nuclear Regulatory Research -
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