ML20149F764
| ML20149F764 | |
| Person / Time | |
|---|---|
| Issue date: | 08/30/1994 |
| From: | Calvo J Office of Nuclear Reactor Regulation |
| To: | Morris B NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20149C780 | List: |
| References | |
| FRN-61FR52388, RULE-PR-20, RULE-PR-32, RULE-PR-35, RULE-PR-36, RULE-PR-39 AF46-1-010, AF46-1-10, NUDOCS 9409140316 | |
| Download: ML20149F764 (1) | |
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dm MEMORANDUM T0: Bill M. Morris, Director Division of Regulatory Applications Office of Nuclear Regulatory Research FROM: Jose A. Calvo, Acting Director Division of Radiation Safety and Safeguards Office of Nuclear Reactor Regulation ,
SUBJECT:
REQUEST FOR RULEMAKING - 10 CFR PART 20 NOTIFICATIONS In consultation with representatives of NMSS and AE0D, we have determined that a revision in the requirements for prompt notification in 10 CFR Part 20 is needed. The background-for~this-determination is provided in the enclosed
'N docume3ts ras follows: x Enclosure 1 notes current inconsistencies and suggest the requirements be changed so that licensees are required to provide the prompt notifications only to the NRC Operations Center.
closure 2 provides agreemept from AE00 iwith_the-suggestifflom NRR.
Enclosure 3 provides agree /ent from NMSS with the suggestion from NRR. l This requested rulemaking has low priority.
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' Jose A. Calvo, Acting Director :
Division of Radiation Safety l and Safeguards Office of Nuclear Reactor Regulation
Enclosures:
As stated .
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.....* MAY 2 61994 MEMORANDUM FOR: Frederick Combs, Chief Operations Branch Division of Industrial and Medical Nuclear Safety 1 3
Office of Nuclear Materials Safety and Safeguards ;
Kenneth E. Brockman, Chief Incident Response Branch Division of Operational Assessment Office for Analysis and Evaluation i of Operational Data
- FROM: LeMoine J. Cunningham, Chief Radiation Protection Branch
. Division of Radiation Safety and Safeguards
- Office of Nuclear Reactor Regulation
SUBJECT:
APPARENT INCONSISTENCIES AS.T0 WHOM IS NOTIFIED WHEN PROMPT NOTIFICATION IS REQUIRED i The purpose of this memorandum is to solicit your views concerning apparent inconsistencies 10 CFR Part 20 requirements for prompt notification of the NRC under certain specified circumstances. The apparent inconsistencies are in the different specifications of point (s) of contact for notifications of the NRC as (a) the Regional office, (b) the Operations Center, and (c) both the Regional Office and the Operations Center.
The prompt notification requirements in question are contained in the following sections of 10 Part 20:
{ 20.1906(d), under " Procedures for receiving and opening packages,"
which, for all licensees, requires immediate notification of the Regional Office.
5 20.2201(a)(?). under " Reports of theft or loss of licensed material,"
which, for all licensees, requires telephoned reports to the NRC Operations Center.
I 20.2202(d), under " Notification of Incidents," which, for power reactor licensees, req" ires only reports to the NRC Operations Center but, for all other lisensees, requires both a telephoned report to the i NRC Operations Center and a telegram, mailgram or facsimile to the Regional Office.
We are not aware of the reasons, if any, for these differences.
Contact:
John Buchanan (301) 504-3184 J i % i %os w my
5 O, Addressees 2 We suggest that the burden on licensees would be reduced slightly, and that licensee procedures would be simplified somewhat, if 10 CFR 20.1906(d),
20.2201(a)(2), and 20.2202(d) were revised to have the same requirement - for licensees to provide the specified notifications and reports to the NRC Operations Center, only.
Do you know of any reasons for the differences noted above in the three sections of 10 CFR Part 207 Do you agree with the suggestion that the requirements should be made consistent by requiring only notification / reports to the NRC Operations Center? Do you have any other thoughts concerning this matter?
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LeMoine J. Cunningham, Chief Radiation Protection Branch Division of Radiation Safety and Safeguards Office of Nuclear Reactor Regulation DISTRIBUTION:
Central Files PRPB R/F PRPB S/F FCongel EButcher LJCunningham TEssig JWigginton JBuchanan PMcKee Acting Chief, PEPB DCool, T9C24 SWeiss, 11B20 JJoyner, RI RAnderson, TTC JLieberman, 7H5 J
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NAME db4AN ,JfGINTON ! HAb DATE 05/t(/94 05/24/94 05/M4 i Document name: PROMPT. REP 1
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I From: Kenneth E. Brockman (KEB)
To: TW4:HMS1:BB1:WN4:WN5:JDB2 l Date: Monday, July 18, 1994 12:09 pm
Subject:
Memorandum dated 5/26/94 -Reply l I didn't get a copy of the original (or, I don't remember it!!)
l We have looked at your proposals and fully support simplifying the reporting requirements and simplifying the licensees jobs. I believe that since the Duty Officers man our Operations Center 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day that they would be the
! logical choice for initial notification. Follow-up notifications (similar to
! those required in 50.73) should be submitted, in writing, to the appropriate Office in the NRC.
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Hopefully, you can make progress in this area. I would bet that you will find similar inconsistencies in Parts 30, 40, 70 et al.
You have our total support!!
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o%' ...../ M. 211994 MEMORANDUM FOR: LeMoine J. Cunnir.gham, Chief Radiation Protection Branch Division of Radiation Safety
- and Safeguards, NRR i 1
FRON: Frederick C. Combs, Chief l
- Operations Branch Division of Industrial and i Medical Nuclear Safety, NMSS
SUBJECT:
APPARENT INCONSISTENCIES AS TO WHOM IS NOTIFIED WHEN PROMPT I l
j NOTIFICATION IS REQUIRED
! We have reviewed your memorandum dated May 26, 1994, regarding inconsistencies as to whom is notified when prompt notification is required. We are not aware l' of any reasons for the reporting location differences noted in your memorandum. We agree with your suggestion that the requirements should be 4 made consistent by requiring notification / reports to the NRC Operations Center.
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Please keep us informed of any further action tha is Xaken to revise the regulations to address your concerns. ,
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Frede(rick C.(Combd Chief Operatiohs Branch 1
Division of Industrial and Medical Nuclear Safety, NMSS i
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