ML20236X033

Provided Clarification of Item 14 in user-need Memo,As Listed

ML20236X033
Person / Time
Issue date:	10/02/1996
From:	Persinko A NRC
To:	Au M NRC
Shared Package
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References
FRN-63FR31364, RULE-PR-72 AF80-1-006, AF80-1-6, NUDOCS 9808070065
Download: ML20236X033 (1)

Text

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From: Andrew Persinko I To: TWD2.TWP9.MLA -'

Date: 10/2/96 3:57pm j Subjects item 14 in user-need memo '

You requested clarification of item 14 in our user need memo. Item 14 said "

Part 72.216 is inconsistent with 72.72 and 72.75; reporting requirements for site-specific license are different than for general license - they should be the same.'

The discrepancies that I found are as follows:

1. 72.216 tells general licensees to make initial and written reports per

! 72.74 and 72.75 (which are the requirements for specific licensees) except for l

events specified in 72.75 (a) (2) and (3) [ ERROR: THE REGULATION SHOULD SPECIFY 72.75 (b) (2) and (3) -- NEEDS TO BE CORRECTED) for which the initial report shall be made under 72.216 (a) , which then refers to 50.72 (b) (2) (vii) .

l Essentially, the regs tell general licensees to do everything that a specific licensee would do except for: (1) defects in spent fuel SSCs; and (2) reductions in effectiveness of spent fuel storage confinement systems - these 2 items are to be initially reported per 50.72 (b) (2) (vii) This reg calls for an initial 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> report --WHICH IS THE SAME AS FOR A SPECIFIC LICENSEE IN 72.75,SO WHY THE EXCEPTION?.

So, for the initial notification for these two cases, 72. 21E (c) takes exception with referring you to 72.75 and instead refers you to 72.216 (a) and

(b) which refers you to 50.72 (b) (2) (vii) which then specifies the same l requirements for initial notification as 72.75. You trace the initial reporting requirements out across a few different regulations for a general licensee, and you end up reporting the same as for a spacific licensee. Quite confusing - why refer someone to 2 different regulations only to end up with the same end result? Needs to be more straightforward.

2. 72. 216 (c) says that written reports shall be made per 72.74 and 72.75 and takes no exception for written reports as it does for initial reports for defects and reductions in effectiveness. Therefore, there are three regulations describing the written reports for these two cases: (1) 72.75, (2) 72.216(b), and (3) 50.72 (b) (2) (vii) . Luckily, the requirements for written reports are the same in 50.72 (b) (2) (vii) and 72.216(b) -- both of these regs say report per 72.4. Therefore, the inconsistency is that one reg (72.4) says to send the written report to the Director of NMSS, and the other reg (72.75) says to send the report to the NRC's Document Control Desk. Consistency should be achieved by revisino 72.4 to say that written info /recorts should be sent to the NRC Document control desk as is specified in 72.75.

l CC: TWD2.TWP9.RCA, EXE, FIY 9808070065 980804 PDR PR 72 63FR31364 PDR 0 (' 3 C] 7006 ' .