ML20212J893

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Submits Comments on Draft Manual Chapter 0517.Comments Also Marked on Encl Draft Manual Chapter 0517.W/o Encl
ML20212J893
Person / Time
Issue date: 07/18/1985
From: Lieberman J
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To: Brady R
Office of Nuclear Reactor Regulation
Shared Package
ML20212J882 List:
References
FOIA-86-215 NUDOCS 8608140426
Download: ML20212J893 (2)


Text

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B, NA JW-J7 July 18, 1985 Note to Richard Brady Office o'f Nuclear Reactor Regulation C0W.ENTS ON DRAFT MC 0517 Larry Chandler and I have reviewed your June 27, 1985 draft manual .

chapter 0517 and offer the following comments:

052, p6 - It is not clear why you are defining the term " safety significance" rather than " safety significant." Use the lat*.er term and utilize the definition from 059, page 11.

053, p7 - Use the definition for wrongdoing from the EDO memo dated -

July 5, 1985.

052, p7 - Add to the end of the paragraph "See Appendix I Part (IV)(6)."

056, p9 - Add the following sentence to the end: "Further guidance on screen-(See also Appendix I Part (VI) ing)is (1) ." found in section 059 below.

057, p9 - Add after the word " circumstances" in the first sentence the following: "(taking into consideration the schedule and or stage of licensing, e.g., low power testing)." In addition, move the last four sentences to a new paragraph at the end of section 055.

058, p10 - Add the following sentence to the end of the first paragraph on page 10: "In determining whether to refer the allegation to a licensee, considt.ation should be given to the Licensee's past record in dealing with allegations, that is, the likelihood that ~

the licensee will effectively identify, investigate, document and resolve the allegation." The last paragraph in 058 needs to be modified. Replace the word " allegation" in the first sentence with

" request for inspection." In the last sentence strike OI and the language thereafter and replace with ' prior to the inspection and providing any information to the licensee, the matter should be coordinated with 01."

059, p10 "Ofice" should be " office" pil "Certail" should be "certain"

- In subparagraph 1, fix the hyphen in the third line wa gelg6860007 9ARDE86-215 PDR k

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_2 Part I, p12 - In the fourth paragraph, second line, add "to the extent permitted by law" after the word " alleger." Make the same change on page 14 in the third paragraph in section 3 at the end of the first sentence.

Part IV, p16 - At the end of section 6 add: "In makin

" Request for Investigation" form (Exhibitmust 3)g be referrals used andthe distributed as indicated on the form." Exhibit 3 should be the form attached to the ED0's July 5, 1985 memo, p17 - Revise section 8 as follows:

" Allegations involving discrimination under section 210 should be entered into the AMS. The OAC ensures that a complainant is advised that any discrimination complaint under section 210 of the Energy Reorganization Act must be filed with the D0L within 30 days of the discrimination. Complaints should be filed.. 20210.

The regional 0AC maintains awareness of... security clearances.

Regional Counsel or OELD/R0ED should be contacted on access problems."

Part VII, p20 - Is section 2 consistent with 01A's recomendations?

Part IX, p24 - Add at the end of section g: "(See 059)."

I have enclosed a marked-up version. If you have any questions on this, please call me or Larry.

James Liebeman, Director Regional Operations and Enforcement Division Office of the Executive Legal Director

Enclosure:

as stated cc: Larry Chandler Distribution ROED rdg

--5AR0ED sub(mu AA/ oSt't)

Liebeman chron Burns infor ELD rdg RH/KC/LC info m

0FC :0EL p:  :  :  :  :  :

NAME : Lie erma c  :  :  :  :  : :

DATE :7/18/85  :  :  :  :  : ,

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