ML20137L139

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Responds to 851121 Request to Review NRC Policy Statement on Guidelines for Review of Agreement State Programs.Criteria for Review & Evaluation of Status of Elements of Program Should Be Included in Policy Statement
ML20137L139
Person / Time
Issue date: 01/17/1986
From: Harold Denton
Office of Nuclear Reactor Regulation
To: Kerr G
NRC OFFICE OF STATE PROGRAMS (OSP)
Shared Package
ML20137L143 List:
References
NUDOCS 8601270281
Download: ML20137L139 (1)


Text

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JAN 17 IS86 MEMORANDUM FOR: G. Wayne Kerr, Director Office of State Programs FROM: Harold R. Denton, Director Office of Nuclear Reactor Regulation

SUBJECT:

NRC POLICY STATEMENT ON GUIDELINES FOR REVIEW 0F AGREEMENT STATE PROGRAMS - REQUEST FOR REVIEW Although NRR has no direct role in the Agreement State Programs, we have read with interest the Policy Statement and suggest the following comments for your consideration. We recognize that comments of an editorial nature might be helpful in any revision of the document but have focused our review on the scope of the Policy Statement itself.

The subject Policy Statement identifies the elements (" indicators") in an Agreement State Program that the NRC considers as having a direct bearing on health and safety (Category 1) and as providing essential technical and adminis-trative support (Category 2). Further, it provides guidelines for the states in the development and implementation of their programs. Although there is a discussion of how the NRC would use the categories to determine effectiveness-of a state's program, the Policy Statement does not address the criteria that the NRC uses to evaluate the acceptability or proposed programs and the effectiveness of programs already in place. We are aware that the Office of State Programs has prepared guidance for the Regional Agreement State Officers in their review activities. Therefore, we recommend that criteria by which the NRC reviews and evaluates the status of the elements of an Agreement State's Program be included in the Policy Statement, and, further, that there be a discussion of the means by which the determination is made that the program does or does not meet the fundamental goal of the program, i.e., protecting the public health and safety.

If you have questions about these comments and wish to discuss them further, please contact Faith Brenneman, ORAS, x28053. Originaisi m a 3 Darrell c. zu,;c.a Harold R. Denton, Director l Office of Nuclear Reactor Regulation DISTRIBUTION YELI'1W TICKET 859324 f Central File w/ incoming FBrenneman l NRC PDR w/ incoming MVirgilio j NSIC w/ incoming GHolahan ORAS Rdg HDenton/DEisenhut DMossburg w/ folder PPAS  ;

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