ML20196E397
| ML20196E397 | |
| Person / Time | |
|---|---|
| Issue date: | 10/15/1998 |
| From: | Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM) |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20196E395 | List: |
| References | |
| SECY-98-185-C, NUDOCS 9812030148 | |
| Download: ML20196E397 (2) | |
Text
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NOTATION VOTE l
RESPONSE SHEET TO:
John C. Hoyle, Secretary FROM:
CHA!RMAN JACKSON i
l
SUBJECT:
SECY-98-185 - PROPOSED RULEMAKING - REVISED REQUIREMENTS FOR THE DOMESTIC LICENSING OF SPECIAL NUCLEAR MATERIAL Approved Disapproved xx Abstain Not Participating COMMENTS:
See attached comments.
t l
M Shir ey.fn Jackson SIGNATURE October 15, 1998 DATE i
Entered on "AS" Yes No f
- "a 28Mll
!a! 2 CORRESPONDENCE PDR e
f Chairman Jackson's Comments on SECY 98-185 l
l l disapprove the staffs proposet to publish the proposed rule amending 10 CFR Part 70. The staff should take an approach to stakeholder interaction on the proposed rule like that used for the revision of Part 35, such as placement of the draft rule text onto the intemet and iterate s.s comments come in over a four month period of time. At the end of the four months, the staff should revise its draft rule and present it to the Commission for review. To guide the staff in its review and revision of the rule text, I provide the following comments:
I support the need for an ISA. The staff should decide what is fundamental for our regulatory purposes for inclusion as part of a license or, minimally, as an executive summary which would be docketed and updated, as appropriate. I also support the requirement for the licensee to develop baseline criteria, a preliminary ISA, and a l
decommissioning ISA.
l I oppose inclusion of a backfit provision in Part 70, based on the belief that minimal inc eases in safety at modest cost could be justified on a cost benefit basis.
l The staff should clarify the basis for its use of chemical safety and chemical i
consequence criteria in the rule in terms of how it ties into nuclear safety.
Regarding the industry's concem about the prescriptive nature of the Standard Review Plan (SRP), I agree with the staffs position of publishing an SRP that clearly delineates one acceptable approach to meet the regulations. Licensees always have the option of devising their own custom program to demonstrate compliance with the regulations. I believe the lack of a published acceptance criteria, that sets out clear expectations, l
creates confusion and may be more costly to licensees. Nonetheless, the staff should l
exaraine whether the SRP can be made to match the performance based nature of the i
reguiations a bit more.
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