ML20246F078
| ML20246F078 | |
| Person / Time | |
|---|---|
| Issue date: | 08/01/1985 |
| From: | Cameron C NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Lichtman G NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| Shared Package | |
| ML20245C214 | List: |
| References | |
| NUDOCS 8905120123 | |
| Download: ML20246F078 (1) | |
Text
_ _- - _ _ _ _ _ _
(
g)G 1 Y
- s. -
l hoteto:=GeiryLichtman,OELD' Proposed Rule, " Retention Period for Records"
Subject:
"h' q,,, (.p.,1. k a-i In response to your request, we have reviewed the recordkee i
d retention periods in the proposed rule. We have no objection to the propo l l period for the one. rule where OELD is listed.asNote that this is the correct
~
140.91, Appendix A' " Conditions" Section 2.
b the citation, rather than that listed in the enclosure forwarded to us y Office of Administration.
d l
On a more general. point, I would caution against eliminating any l
the basis l
retention periods _, such as that in proposed 10 CFR 50.71, pure y o l
that licensees may not currently keep such records. CIhe proposed 550.71 Minutes of CRGR Meeting Number 7 h
does not impose a new recordkeeping' requirement. It merely rev to the_May 16, 1985
" retention open-ended "until tIIe Commission authorizes thefr disposition ified.
period for records that do not have a retention perio recordkeeping requirement, as implied by the CRGR' minutes.
3 Chip cameron Regulations Division E. 'C'nristenbury cc:
'J. Lieberman H. Ragan a pipeles I
l l
i 8905120123 870827 PDR REVGP NRCCRGR MEETING 119 PDC
- 3 1'
July 31, 1995
' ~
- 4. -
Mctt to Cerry Lichtman, OELD, PROPOSED RULE ON RETENTION OF RECORDS I've taken a quick look at the memo from Pat Norry which you distributed to.
OELD Division Directors on July 3,1985, for comment.
I have no particular comments on the advisability of retaining or. eliminating the record-keeping requirements contained on the list; the program offices are in the best position to evaluate the rationale for the particular requirements.
I note that in most instances the licensing office (NRR or HMSS) has been asked to comment on the requirement, though in many instances IE may have a particular interest in the requirement. The inspection program concentrates in part on a review of licensee records to audit compliance with NRC requirements, l
and IE should be asked to comment, therefore, on the requirements as well.
The record-keeping requirement may be the best way in some circumstances of evaluating and ensuring a licensee's routine compliance with a requirement.
Most records are to be kept for at least 3 years (assuming the requirement l
for a record is not eliminated) under the proposed retention period. This frequency appears t.o be sufficient to ensure availability for inspection.
Although the time is less than the five-year statute of limitations which may be applicable to certain enforcement actions, the three-year period t
should be enough to permit the Commission to act on potential noncompliance identified from records or other information and to preserve any relevant records.
ye,g.c;,J I also note that the entry for Part 21 on page 1-2 discites and mischaracterizes the record-keeping requirements.
~7 Stephen G. Burns Deputy Director Regional Operations and Enforcement Office of the Executive Legal Director cc:
E. Christenbury W. Olmstead H. Ragan 4 N3lf@bE.1-f i
m;
.,amee g %,
UNITED STATES NUCLEAR REGULATORY COMMISSION n
I wammorow.o.c.aoses T..
AUG 2 6,1985 NOTE TO: John Philips, Chief Rules and Procedures Branch, DRR/ADM FRON:
Richard A. Dopp, Chief Policy and Operational Support Branch, SEC/ADM
SUBJECT:
CRGR - REC 0fMENDED ACTION ON THE PROPOSED RULE, " RETENTION PERIOD FOR RECORDS" As requested in your July 16, 1985 " Routing and Transmittal Slip'" which forwarded D/ADM's June 21, 1985 memorandum subject as above, I am enclosing:
A completed working chart for those regulatory items under SEC control; L
e i
A brief justification / narrative for each record taquirement and the e
selected retention period.
While SEC agrees that a uniform record retention schedule idea is a good one, in some instances this proposed concept actually creates a requirement to retain records never envisioned or intended by SEC.
In these instances, SEC recommends current, codified regulatory requirements remain.
In no instance did SEC identify record retention requirements that.could be deleted.
While the enclosed worksheet (Enclosure 1) listed SEC, along with NMSS, as th^
cognizant office for certain requirements under 10 CFR Part 73, we really have no cognizance over this rule, save for that of a strictly advisory capacity.
SEC defers to NMSS' views regarding this regulation..We have concentrated our efforts on 10 CFR Parts 25 and 95, of which we are singularly responsible.
, Please call me or Larry Himnelsbach of my staff on X24129 if you have any questions or need additional information.
p: Ric ard A. Dopp, Chief Policy and Operational l
Support Branch, SEC/ADM l
Enclosures:
As stated l
C' 3
7' I [.p,
UNITED STATES
'q,,
NUCLEAR REGULATORY COMMISSION g
WASHINGTON. O. C. 30806 g$
t AUG 5 1985 NOTE T0: John Philips, RPB/DRR FROM:
Richard Dopp, POSB/SEC l
SUBJECT:
RETENTION PERIOD FOR RECORDS I
Reference is made to your July 30, 1985 note to me, subject as above.
Please be advised that the Division of Security yields to NMSS through (h), since NMSS is principally responsible for this regulation.
Please give me or Larry Himelsbach, of my staff, a call on X24129 if you have any questions'or need additional information.
Richird Dopp, POSB/SEC R. C. O'Connell, NMSS cc:
d
& CL.L.L C 3 M ? Of um
o.
L
/
UNITED STATES
~ ~
8 NUCLEAR REGULtJORY COMMISSION c,
r.
F-REGION I
\\e....
J 431,ARu AVENUE uma or enussiA.PamusvovANIA 1M06 SEP 0 91985 MEMORANDUM FOR:
John Philips, Chief, Rules and Regulations Branch, Office of Administration FROM:
Jay M. Gutierrez, Regional Counsel, Region I
SUBJECT:
CRGR-RECOMMENDED ACTION ON THE PROPOSED RULE, " RETENTION PERIODS FOR RECORDS"
REFERENCE:
Memorandum from P. Norry to Regional Administrators, dated August 13, 1985 This will confirm our telephone conversation of September 9,1985, relative to the above subject wherein you indicated that you would inform me if during program office reviews of the current record retention requirements it is recommended that a record retention requirement be deleted.
In the event such a recommendation is made, I will check with the appropriate regional staff to determine if the region has an independent need for such a requirement. ble agreed that absent a recommendation that a requirement be deleted, Region I should take no further action in response to the referenced request.
ay M.
ierrez j
Regional Counsel 1
w nu-e w
- ea ROUTING - REQUEST l
~
0.o
,, ok a m sta,.
HANM.
_tk cod b. %
g,,, $( g 9
]
Q&
APPROVE w
FORWARo b
b W
k
$. A Kw :(ui ;
neTuaw O KEEPORotSCARoMdw w gg#,h3;,
.Eview wira q;,,,
f,,
pp, east,Ak
=~
e nse UNITfD ST ATES
[o NUCLEAR REGULATORY COMMIS$10N
.p REGION H e
101 GAARIETTA STREET,NN.
I ATLANTA. GEORGIA 30323
\\.=6..*
April 2 1986 MEMORANDUM FOR: Patricia G. Norry Director I
Office of Administration FRON:
J. Nelson Grace Regional Administrator l
SUBJECT:
REQUEST FOR REVIEW AND CONCURRENCE OF PROPOSED RULE " RETENTION PERIODS FOR RECORDS" Region II has reviewed the information provided with your memorandum dated March 11, 1986. In reviewing your memorandum, we were pleased to observe that comments made by us in our October 3,1985 memorandum were incorporated into your proposal.
Region II concurs that the Office of Nuclear Reactor Regulation (NRR) issue a Generic Letter that would provide guidance to licensees for revising their Technical Specifications to conform with the rule and would include model Technical Specifications to follow for achieving this conformance.
The recordkeeping requirements included in the proposed rule are acceptable to Region II.
If you have any questions, please contact me or G. A. Belisle at FTS 242-5596.
G. h J. Nelson Grace cc:" R. Stephen scotts IR E i
e*
e
unna2 smas
[.
Ig 5 co 7.7-
[
tucteAn neoutAtony couwssum A b/fl namou m s
- n.. =mv..
etaw sLLvn. slows.es seist
~
l March 19, 1986 MEMORANDtM FOR:
Patricia G. Norry, Director Office of Administration FROM:
James G. Keppler, Regional Administrator, Region III
SUBJECT:
REQUEST FOR REVIEW AND CONCURRENCE OF PROPOSED RULE,
" RETENTION PERIODS FOR RECORDS" As requested in your memorandum dated March 11, 1986, Region III has reviewed and concurs in the Proposed Rule, " Retention Periods for Records."
W[ James G. Ke % L ppler Regional Administrator cc:
Scott, ADM H. R. Denton, NRR J. G. Davis, NMSS
/
J. M.. Taylor, IE G. H. Cunningham, ELD Regional Administrators a*
i
1 js**%,%
uomo svares wuct. man neoui.Avony commission j
namon w sti avam naza onsva,surve isso
-.ov.m. -i SEP 111985 i
i MEMDRANDUM FOR: ' John D. Phillips, Chief, Rules & Records Branch, Division of Rules & Records, Office of Administration
~
FROM:
William H. Foster, 01 rector, Division of Resource Management and Administration, Region IV
SUBJECT:
CRGR-RECOMMENDED ACTION ON THE PROPOSED RULE, " RETENTION PERIODS FOR RECORDS" In response to your memorandum dated August 13, 1985, and subsequent telephone conversation between you and Connie Dollar of my staff,. Region IV provides the following comments. Reference is made to Enclosure 2, page 6, rule page 19, part 40.26(c)(2) and page 7, rule page 23, Appendix A to Part 40.I.
It is our proposal that _the retentica period for these two parts be consistent. We recommend a 3 year retention period for these parts. We have no further comments regarding Enclosure 2, but request that we be provided a copy of the final draft for comment after all changes have been incorporated.
If you should have any questions or comments, contact me on (FTS) 728-8273.
/dof&c William H. Foster, Director Division of Resource Managerent and Administration
Enclosures:
Pages'6 and 7 cc:
R. D. Martin R. P. Denise R. L. Bangart R. D. Smith C. A. Dollar
-~,,/
W l A. b W J W ~
t
lI ii
!)I I
7 nc on ie
'tr
- s cf ie fi l i
te sg ua JP r
s ew n) e iO i
kF v
wR
_e oaU l
tH(
. l y
. f ido n
. t s
o 1
t e
a v
d e
a n
n s
e e
ru ed m
ts um vn o
oa c
n cr t
e i
o R
' t em a
e ee R
sm t
n ae ze
.il 5
s 5
5 m
.nf s
5 s
5 o
R u
R gf t
..oO u
M r
f R
s C
g n
n o
o s
i i
ri d
s s
e mr e
s s
tn oe r
i i
me me fo' rf i
ai f s n
mh mh t
n a
ot ot sc.
sa g
C C
s red rr r
s s
do ee.
ee.
o.
alse at ht i
ht e
d est.
e e
yen _
yf rn tae tae r
.. i f e o
o ns ns e
e m
- i iin li n p
eht we t
t w
a me ime rcc
.t
- c
, trc trc e
+
hao Aa e
neI nef r
Ted Td 5s UtI UtI o
f t
d n
o o
i r
)
r e
rg P
l on c
u afi t
o l
f w
n I
o rdo nr 0g n
o enl r oi
- 4. i t
t t
tal o ie e
o sh Oe n
Wb m
e mdfr.
st.
r t
e en t
n e
s s sf o nso s
o f
l s
asrsi uei ei.
n e
r eant ort c
I n
a gseaI CfI n0d o
i e
n s yr s rs e2e c
t y
oo te l eo r s pe p
ih p eti o
s e
l i n o
vss tts frv t
w ssiti nuI eae r
o t'
AIfid Uad ipr d
t l
f I
o ir s
e.
e l
l p
fg e
c on.
u r
a a
it nf u
f t
n nl s onr o
c e
ol e eo s
e e
f ft ft t
i at nr tts ews f.
oa oa n
a y
t t
o1 m
m e
r l
t tfs tdc a
d no aeu tf et at e
r e n mtd pr f;
s r
o mso reo ie s ;
o ;
nf pr n
c uni ol r et e
cot f pp ca a ;
s ;
i i
oin ne em r r D r e
ts t
T
/
Dte Idl n
ct a
t y
y s
i o
) ee
)fi
):
)b
)b a
i 2pr 3or 1 ;
z J
e t
(s t
t (f
tr tr r
)ne l rs.
) :
lo
)o c
a a
a
.ce cI t eeus a-r te te l
S
(
s tfde t
1 c 1c
/
6 ya 5snc 1
y s
- 2. l w
- 3. n i f
- 6. b
- 6. r
- 6. r t
i a
e u
u e
ra 0ar 0rne 0r 0o 0o t
P 4do 4 tid 4 o 4s 4s ac i
d 2e n
1 c wa 9
0 1
1 1
I I P 1
2 2
2 2
t w