ML20203N416
| ML20203N416 | |
| Person / Time | |
|---|---|
| Issue date: | 12/13/1984 |
| From: | Fitzgerald J NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | Cunningham G NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| Shared Package | |
| ML20203N408 | List: |
| References | |
| FRN-48FR36358, RULE-PR-2 AB78-1-057, AB78-1-57, NUDOCS 8610080261 | |
| Download: ML20203N416 (1) | |
Text
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>M8h j g[$ UNITED STATES h[p i
[ p, NUCLEAR REGULATORY COMMISSION 9
'E WASHINGTON, D. C. 20656 *
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5
%o . ,,,, gY December 13, 1984 MEMORANDUM FOR: Guy Cunningham, III Executive Legal Director FROM: JamesA.Fitzgeraldf(
Assistant General Counsel
SUBJECT:
NRC STATEMENT OF POLICY ON INVESTIGATIONS, INSPECTIONS AND ADJUDICATORY PROCEEDINGS --
PROPOSED AMENDMENTS TO 10 CFR PART 2 This supplements our memorandum to you dated December 11, 1984 ;
by addressing the Part 0 issues. OGC has no objection to the ;
proposed changes to 10 CFR Part 0, but notes that Part 0 does i not have comparable provisions relating to the unauthorized disclosure of information subject to protective orders issued under 10 CFR 2.790. We believe that unauthorized disclosure of protected information, whether it be safeguards information, l proprietary information, or the names of confidential sources should be subject to uniform sanctions. Accordingly, we recommend that either the proposed amendments to Part 0 be expanded to include unauthorized disclosure of information ~
covered by protective orders issued under 2.790 or that the l proposed rule not modify 10 CFR Part O. I We also note that any changes to Part.0 must be approved by the Office of Government Ethics prior to promulgation of a final rule. They have suggested that OGC send them the proposed rule at the same time that it is sent to the Federal Register.
Finally, we note that the amendments to Part 0 do not cover contractor personnel. Accordingly, if Part 0 is amended, 1 consideration should be given to placing language in NRC ]
contracts which would subject contractors to sanctions for <
knowingly disclosing names of confidential sources. l i
8610080261 860930 PDR PR 2 48FR36358 PDR i
Contact:
Trip Rothschild, OGC, 41465
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