ML20236H812

From kanterella
Jump to navigation Jump to search
Staff Requirements Memo Re Secy 98-105, RM Plan:Energy Compensation Sources for Well Logging & Clarifications - Changes to 10CFR39. Advises That Pr Package Should Clearly State That Change Would Allow Abandonment of Sources
ML20236H812
Person / Time
Issue date: 06/25/1998
From: Hoyle J
NRC OFFICE OF THE SECRETARY (SECY)
To: Callan L
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
References
FRN-64FR19089, REF-10CFR9.7 AG14-1-007, AG14-1-7, SECY-98-105-C, NUDOCS 9807070365
Download: ML20236H812 (2)


Text

_.

8

{

[pKfG UNITED STATES

[;

t, NUCLE AR REGULATORY COMMISS,lg,,,,,,,

  1. o

{

W ASHINGT ON. D.C. 20555 June 25, 1998 7/

7 j

OFFICE OF THE M

f g

l-secnerany MEMORANDUM TO:

L. Joseph Callan Ex set for O rations l

FROM:

John. Ho tary

SUBJECT:

STAFF REQUIREMENTS: dECY 98-105 - RULEMAKING PLAN:

ENERGY COMPENSATION SOURCES FOR WELL LOGGING AND CLARIFICATIONS - CHANGES TO 10 CFR PART 39 The Commission did not object to the staff's proposed Rulemaking Plan to modify well-logging requirements to accommodate the use of new well-logging technology and otherwise to improve, clarify, and update 10 CFR Part 39. However, in implementing the Rulemaking Plan, the staff is directed to accomplish the following:

1.

The proposed rule package should clearly state that the change to section 39.77 (item 2 on page 2 of the Rulemaking Plan) would allow immediate abandonment of sources without prior NRC approval if a delay could cause an immediate threat to workers due to I

a possible fire or explosion, and that NRC would be notified after the fact.

2.

The proposed rule package should address whether there is adequate justificahon, including cost-benefit, for performing vibration tests on sealed sources manufactured after July 14,198g. The proposal to incorporate in Part 39 a generic exemption procedure allowing sealed sources manufactured before July 14,1989, implies that the i

vibration test is unnecessary for the older model sources because of the ruggedness of their design.

3.

The proposed rule package should provide a tech'n'ical basis for differentiating the leak test requirements for stainless steel plated sources (ECSs) from non ECS sources (item 5 on page 4 of the Rulemaking Plan) and compare the health risk associated with leakage from each. Altematively, if the technical basis for exemoting ECSs from the i

leak test requirement is due to a more robust design that increases confidence that the sources will not leak, rather than an insignificant amount of radioactive material i-

. contained in the source, the staff should state this rationale more clearly and provide 1 g' l

adequate support in the proposed rule.

l j

(EDO)

(SECY Suspense: 3/31/99)

,j qu c411 6L9M l

,E ' Tl y.

L q _. t e T 3 7 SECY NOTE:

This SRM and SECY-98-105 will be made publicly available 5 working days from the date of the final SRM.

9807070365 980625 i

PDR 10CFR PT9.7 PDR 3

1

i.\\/

cc:

Chairman Jackson Commissioner Dieus Commissioner Diaz Commissioner McGaffigan OGC CFO CIO OCA OlG Office Director, Regions, ACRS, ACNW, ASLBP (by E-Mail)

POR DCS I

j l

l l

l l

C_

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _