ML20196G857
| ML20196G857 | |
| Person / Time | |
|---|---|
| Issue date: | 06/07/1999 |
| From: | Mcgaffigan E NRC COMMISSION (OCM) |
| To: | Vietticook A NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20196G781 | List: |
| References | |
| FRN-64FR14814, RULE-PR-73 SECY-99-008-C, SECY-99-8-C, NUDOCS 9907010284 | |
| Download: ML20196G857 (2) | |
Text
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NOTATION VOTE RESPONSE SHEET TO:
Annette Vietti-Cook, Secretary FROM:
. COMMISSIONER MCGAFFIGAN
SUBJECT:
SECY-99-008 - RULEMAKING PLAN, " PHYSICAL SECURITY / SAFEGUARDS FOR PERMANENTLY SHUTDOWN POWER REACTORS," FOR AMENDMENTS TO 10 CFR PART 73 Approved V
Disapproved Y Abstain Not Participating
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COMMENTS:
See attached comments.
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Commissioner McGaffican's Comments on SECY-99 008 i
I approve. in part, and disapprove, in part, the staff's recommendation to proceed with this rulemaking plan.
I approve the need for rulemaking to address relaxation of physical security requirements for decomissioned reactors and I support Option 3.
However. I disapprove the proposed rulemaking as a stand-alone rulemaking initiative because it is premature to move. forward with this 'or any other decomissioning rulemaking without the i
benefit of the concurrent staff efforts to develop integrated, risk-informed l
requirements for decomissioned reactors.
To proceed now with this proposed L
security / safeguards rulemaking would also be counterproductive and contrary to l
the Commission s guidance in the staff requirements memorandum for the March I
- 17. 1999, public briefing on Part 50 decommissioning. issues ('M990317C).
'I am also concerned about the timely resolution of the zirconium cladding fire I
issue vis-a-iis the integrated review.
While the use of " performance l
. criteria" may account for some site-specific factors, the staff also needs to L
ensure that outstanding generic technical concerns (i.e.. high burnup fuel, j
L high density fuel storage configurations, etc.) are appropriately resolved and coordinated with the integrated review initiative.
j' The integrated rulemaking initiative must also consider application of the j
backfit rule for decommissioning rulemakings, as the Comission directed in the SRM on SECY-98-253 and has emphasized again in the SRM on the March 17.
1999, public briefing on Part 50 decomissioning issues.
l.
.I agree with Chairman Jackson's comments regarding the need to evaluate physical protection requirements -- including vehicle barrier system-- against the existing threat, which should be periodically updated.
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