ML20210Q609
| ML20210Q609 | |
| Person / Time | |
|---|---|
| Issue date: | 06/11/1999 |
| From: | Mcgaffigan E NRC COMMISSION (OCM) |
| To: | Vietticook A NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20210Q569 | List: |
| References | |
| SECY-99-036-C, NUDOCS 9908160071 | |
| Download: ML20210Q609 (3) | |
Text
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NOTATION VOTE RESPONSE SHEET TO: Annette Vietti-Cook, Secretary FROM: COMMISSIONER MCGAFFIGAN
SUBJECT:
SECY-99-036 - PROPOSED RULEMAKING ACTIVITY PLAN Approved 'X Disapproved Abstain
~
~Not Participating
- COMMENTS:
See attached comments.
$ <g, 4 SIGNATURE I' ' 'J ll , I'lS $
l DATE/
Entered on "AS" Yes K No 9908160071 990013 t ORRES DE E PDR ovvetro
u i
.; .. l Commissioner McGaffiaan's Comments on SECY-99-036
. I approve the proposed rulemaking activity plan subject to the following corpments. I apologize for my delay in voting.
Comments:
- 1. . NMSS-C3MP-26 (page Clll 6) - lAEA Transportation Standards -- The staff should routinely inform the Commission of its progress in working with the Department of Transportation and *a Intemational Atomic Energy Agency to revise current transportation standards, particularly standards for acceptable levels of removable contamination on packages containing spent nuclear fuel. I eagerly await the staff's proposed rulemaking plan.
2.- NMSS-C3LP-07 (page Clll-8) - Decommissioning Funding Certification -- It is i
. unclear from the write-up whether the rulemaking is limited to " accounting for
- inflation" issues or whether technical issues are also involved. Perhaps the Office of the Chief Financial Officer could provide input to update the 1988 costs
.' ' data.
- 3. NMSS-C3LP-08 (page Clll-9) - Radiography Equipment - This item was moved from a high priority to a low priority in this RAP. The write-up states that the current rule is very prescriptive and often requires' exemptions. Since this rulemaking would be a burden reduction, I suggest that the staff look for efficiency gains in this project so as to move this item from " low priority" to at least a " medium priority" with minimal if any resource increase.
. 4. NMSS-C4A-07 (page CIVA-1) - PRM-20-21 -- The write-up should include a -
status report or, at minimum, describe what information or action is needed to
- allow NRC to make a decision on this 1993 petition.
- 5. NMSS-C4A-19 (page CIVA-2) - PRM-72-03 -- The write up appears incomplete in that it states that the petition has been part/ ally resolved but does not state whether the remaining portions of the petition were denied or not yet resolved.
6.' . NMSS-C4B-19'(page CIVB-2) - Transfer of Part 40 material - Given recent Commission decisions on related issues,~ sentences 6 and 7 under the L
" Objective" section should be deleted and replaced with the following:
"The rule is currently silent on whether specific licensees may transfer unimportant quantities of source material to persons exempt from L lice'nsing for the purpose of disposal of such material. One purpose of
' this rulemaking would be to make explicit whether NRC prior approval of
[ .
such transfers is needed to adequately ensure public health and safety."
_ m SECY-99-036 .
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- 7. . NMSS-C48-29 (page CIVB-5) - Geological and Seismological Characteristics of Spent Fuel Storage Systems -- This item has been moved from the " medium priority" active rule category to the "on hold" category apparently because of the e
lack of available resources. I do not agree that the estimated impact on licensees of 240 hours0.00278 days <br />0.0667 hours <br />3.968254e-4 weeks <br />9.132e-5 months <br /> per amendment and on NRC of 250 hours0.00289 days <br />0.0694 hours <br />4.133598e-4 weeks <br />9.5125e-5 months <br /> per action is
" minimal." Rather, I believe that resource expenditures of this magnitude warrant a continued NRC effort to revise the rule, particularly since the safe storage of spent nuclear fuel will become increasingly important to nuclear power licensees.
Perhaps, an overall resource savings could be realized by combining this rulemaking with the related rulemaking NMSS-C1MP-32-Clarification and Addition of Flexibility to Part 72 (page Cl-30) which is due to the Commission within months of when the subject rule is described due under the approved rulemaking plan.
- 8. A new item should be added to the next rulemaking activity plan to document the staff's efforts to assist the Environmental Protection Agency in identifying efficient disposal altematives for mixed waste containing low-level radioactive waste. I appreciate the update provided in the staff paper and recognize that the current RAP preceded the January 27,1999 Commission direction to the staff on this issue.
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