ML20195C032
| ML20195C032 | |
| Person / Time | |
|---|---|
| Issue date: | 06/17/1988 |
| From: | Browning R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Arlotto G NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| References | |
| REF-WM-1 NUDOCS 8806220097 | |
| Download: ML20195C032 (13) | |
Text
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TICKET WM.88075 l
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JUN 171988 MEMORANDUM FOR:
Guy Arlotto, Director Director of Engineering Office of Nuclear Regulatory Research FROM:
Robert Browning, Director Division of High-level Waste Management Office of Nuclear Material Safety and Safeguards
SUBJECT:
P0TENTIAL PRE. LICENSING RULEMAKING My staff has reviewed your May 6, 1988 memorandum identifying additional issues where pre-licensing rulemaking may be useful. We agree that these issues may be contentious at the time of the licensing hearing and should therefore be resolved, if possible, prior to that time.
Furthermore, we appreciate RES's efforts toward characterizing the timeliness of these issues.
As you know, NMSS, RES and OGC staff have worked to identify a nutrber of candidates for rulemaking. As you can see from the attached briefing charts from our June 14 meeting with RES a'id OGC, several of the issues listed in your memorandum are currently under active consideration for rulemaking.
We look forward to working with you on a more comprehensive review of candidate issues for rulemaking that will include the other issues on your list, along with issues identified in our discussions with DOE, the Center for Nuclear W6ste Regulatory Analysis', and other groups. Thank you for your contributions to date.
Original Signed by Robert E. Browning Robert E. Browning, Director Division of High-level Waste Managen'ent Office of Nuclear Material and Safeguards o
Enclosures:
As stated.
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DISTRIBUTION co*
CENTRAL FILES NHSS RF RBrowning, HLWM MBell, HLWM JBunting, PLSE BJYoungblood, HLOB M om RBallard, HLTR KKalman, HLSE i
Pleast see previous concurrence.*
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OFFICIAL RECORD CDPY z.,g/g/
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TICKET WM-88075 MEMORANDUM FOR:
Guy Arlotto, Director Director of Engineering Office of Nuclear Regulatory Research FROM:
Robert Browning, Director Division of High-level Waste Management Office of Nuclear Material Safety and Safeguards
SUBJECT:
P0TENTIAL PRE-LICENSING RULEMAKING My staff has reviewed your May 6,1988 memorandum identifying additional issues where pre-licensing rulemaking may be useful. We agree that these issues may be contentious at the time of the licensing hearing and should therefore be resolved, if possible, prior to that time.
Furthermore, we appreciate RES's efforts toward characterizing the timeliness of these issues.
As you know, N'4SS, RES and 0GC staff have worked to identir a number of candidates for rulcmaking. Several of the issues listed ir yoJr memorandum are currently under active consideration for rulemaking We look forward to working with you on a more comprehensi., review cf candidate issues for rulemaking that will include the othtr issues on your list, alcng with issues identified in our discussions witi. 00E, the Center for Nuclear Waste Regulatory Analysis, and other groups. Thank you for your contributions to date.
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Robert E. Browning, birector Division of High-level Waste Management Office of Nuclear Material and Safeguards DISTRIBUTION CENTRAL FILES NMSS RF RBrowning, HLWM MBell, HLWM JBunting, HLSE BJYoungblood, HLOB RBallard, HLTR KKalman, HLSE A
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OFFICIAL RECORD COPY
FUTURE RULEMAKINGS WITHIN THE HIGH-LEVEL WASTE MANAGEMENT PROGRAM JUNE 14, 1988 1
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BACKGROUNO:
NMSS, RESEARCH AND OGC STAFF HAVE IDENTFIED j
TO DATE TEN CANDIDATES FOR RULEMAKINGS.
j PURPOSE:
LAYOUT THE ACTIVITIES THAT NEED TO BE ACCOMPLISHED TO SCOPE OUT AND DEVELOP A SCHEDULE FOR EACH RULEMAKING.
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CATEGORIES OF ISSUES b
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REGULATGRY - CONCERN WHAT MUST BE PROVEN I
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TECHNICAL - CONCERN HOW FR00F CAN BE ESTABLISHED 1
l INSTITUTIONAL - CONCERN POSSIBILITY OF OVERLAPPING FEDERAL AGENCY JURISDICTIONS OR REGULATIONS,
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DEFINITION OF RESPECTIVE ROLES 1
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FUTURE RULEHAKINGS AND TASK LEADERS l
GROUNDWATER ~
RULEMAKING (F. ROSS)
ANTICIPATED /.
ATED PROCESSIS AND EVENTS RULEMAKING (J. TRAPP)
DEFINITION OF "SJBSTANTIALLY COMPLETE CONTAINMENT" RULEMAKING (C. PETERSON) l DISTURBED ZONE RULEMAKING (T. VERMA)
DESIGN BASIS ACCIDENT DOSE LIMIT RULEMAKING (R. NEEL)
EMERGENCY PLANNING CRITERIA RULEMAKING (W. WALKER)
WASTE CONFIDENCE (R. MACDOUGALL)
CONFORM PART 60 TO EPA STANDARD (D. FEHRINGER)
CRITERIA FOR CONTAINMENT OF "GREATER THAN CLASS C" LOW-LEVEL WASTE IF IT G0ES INTO REPOSITORY (C. PETERSON)
IMPLEMENTING THE EPA STD. (D. FEHRINGER) k
l-SCHEDULE BRIEF, DGC, RES, SL'S, AND LEADS JUNE 14, 1988 LEADS DEVELOP SCOPE, MILESTONES AND JUNE 24, 1988 4
TIMEFRAMES FOR RULEMAKINGS BRIEF BRANCH CHIEFS ON SCOPE AND TIMEFRAMES JUNE 27, 1988 a
FOR RULEMAKINGS l
BRANCH CHIEFS AGREE ON PRIORITIZATION OF JUNE 29, 1988 l
RULEMAKINGS DEVELOP SCHEDULE FOR RULEMAKINGS JULY 01, 1988 BRIEF THOMPSON ON SCHEDULE JULY ll, 1988
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TRANSMIT TO EDO JULY 15, 1988 0
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l-SCOPE i
DEFINE PURPOSE OF RULEMAKING AND REGULATORY UNCERTAINTY TO j
BE RESOLVED 4
- CLARIFICATION, RULE AS WRITTEN MAY BE UNCLEAR
- NEED TO LAYOUT FINDINGS THAT NEED TO BE MADE; DETERMINE WHAT MUST BE PROVEN TO DEMONSTRATE COMPLIANCE 4
DEFINE WHAT ACTIVITIES NEED TO BE CONDUCTED TO RESOLVE THESE UNCERTAINTIES CONSIDER ANY LINKAGE WITH OTHER RULEMAKINGS OR OTHER ACTIVITIES 1
l CONSIDER PART 60 RULEMAKING RECORD; BACKGROUND AND INTENT OF RULE i
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i TIMING J C MILESTONES FOR RULEMAKINGS WHEN WILL RULEMAKING BE NEEDED IN REPOSITORY PROGRAM?
LOJK AT BROAD AND DETAILED SCHEDULES TO DETERMINE WHEN UNCERTAINTY NEEDS TO BE RESOLVED (BASED ON CURRENT SCHEDULES AND INFORMATION PROVIDED IN CDSCP)
LAYOUT MILESTONES, TIMEFRAMES AND RESOURCES NEEDED TO DEVELOP THE REGULATORY POSITION AND TECHNICAL BASIS FOR THE PROPOSED RULE, INCLUDING IDENTIFICATION OF SIGNIFICANT INPUTS FROM OTHER GROUPS.
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Rulemaking Timeline 1
4 Publish Publish EDO Approval Proposed Final Rule Process Rule 4
6 Months to 2 Years 4
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PRODUCT SCOPE - ONE PAGE WRITEUP THAT DESCRIBES THE FOLLOWING:
- PURPOSE OF RULEMAKING
- REGULATORY UNCERTAINTY TO BE RESOLVED
- LINKAGE WITH ANY OTHER RULEMAKINGS OR ACTIVITIES
- SIGNIFICANT INFORMATION FORM PART 60 RULEMAKING RECORD PERTINENT TO THE RULEMAKING 1
- TIMEFRAME IN WHICH RULEMAKING IS NEEDED
- RESOURCE 5 TO DEVELOP REGULATORY POSITION i
AND TECHNICAL BASIS FOR PROPOSED RULE MILESTONES AND TIMEFRAMES
- COMPLETE ATTACHED SHEET
PROJECT TITLE:
TECHNICAL SUPPORT FOR RULES AND AMENDMENTS PROJECT MANAGER:
W. WALKER' TASK LEADER:
TASK TITLE:
SUPPORT STAFF:
CONTRACTOR:
MILESTONES TIMEFRAME (WEEKS)
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FUTURE RULEMAKINGS, TASK LEADERS AND PPSAS NUMBERS L60056 GROUNDWATER TRAVEL TIME RULEMAKING (F. ROSS)
L60057 ANTICIPATED / UNANTICIPATED PROCESSES AND EVENTS RULEMAKING (J. TRAPP)
L60058 DEFINITION OF "SUBSTANTIALLY COMPLETE CONTAINMENT" RULEMAKING (C. PETERSON)
L60059 DISTURBED ZONE RULEMAKING (T. VERMA)
L60060 DESIGN BASIS ACCIDENT DOSE LIMIT RULEMAKING (R. NEEL)
L60061 EMERGENCY PLANNING CRITERIA RULEMAKING (W. WALKER)
L60062 WASTE CONFIDENCE (R. MACDOUGALL)
L60063 CONFORM PART 60 TO EPA STANDARD (D. FEHRINGER)
L60064 CRITERIA FOR CONTAINMENT OF "GREATER THAN CLASS C" LOW-LEVEL WASTE IF IT GOES INTO REPOSITORY (C. PETERSON)
L60065 IMPLEMENTING THE EPA STD. (D. FEHRINGER) i t
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