ML20210Q311
| ML20210Q311 | |
| Person / Time | |
|---|---|
| Issue date: | 08/03/1999 |
| From: | Diaz N NRC COMMISSION (OCM) |
| To: | Vietticook A NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20210Q299 | List: |
| References | |
| SECY-97-144-C, SECY-97-304-C, SECY-99-159-C, NUDOCS 9908160006 | |
| Download: ML20210Q311 (2) | |
Text
5 NOTATION VOTE
{
RESPONSE SHEET TO:
Annette Vietti-Cook, Secretary FROM:
COMMISSIONER DIAZ
SUBJECT:
SECY-99-159 - RESPONSE TO STAFF REQUIREMENTS MEMORANDUM (SRM) SECY-97-304, FEBRUARY 5,1998,
" RESPONSE TO SRM: SECY-97-144, ' POTENTIAL POLICY j
ISSUES RAISED BY NON-OWNER, OPERATORS'"
w/ comment Approved Disapproved n d Abstain Not Participating COMMENTS:
See attached comments.
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j COMMISSIONER DIAZ'S COMMENTS ON SECY-99-159
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l I appreciate the staff's continuing refinement of criteria for triggenng a full NRC review of non-owner operator arrangements under s50.80 (Transfer of Licenses). Nonetheless, I disapprove j
issuance of the draft regulatory guide for public comment because, as other Commissioners have noted, additional and, in some cases, fundamental clarifications are needed. For j
instance, the draft guidance does not clearly articulate or illustrate the principle, stated in the I
SECY paper, that consent is required if final decision-making authority is transferred in an area that is expressly or specifically a licensed activity. The guidance should identify and segregate j
with greater cladty the most important examples of a licensed activity that would individually trigger the need for full NRC review and consent. The staff should also address whether it can provide any appropriate bounding of the broad statements of pert!nent types of licensed activity.
I also agree that similar attention should be given to amplificaticq of the areas of activity that will be examined collectively in determining the need for full NRC review and consent. The extra effort to provide specificity and transparency should produce long-term benefits for licensees and operating companies, as well as the NRC and the public generally, w
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