ML20133J101

RES Independent Review Board Voting Sheet Re Rulemaking, Reporting Requirements for Safeguards Events. Draft RES Independent Recommendations Should Be Modified as Listed

ML20133J101
Person / Time
Issue date:	07/17/1984
From:	Bassett O NRC - RESEARCH INDEPENDENT REVIEW BOARD
To:	Bernero R NRC - RESEARCH INDEPENDENT REVIEW BOARD
Shared Package
ML20132B800	List: ML20132B797 ML20132B810 ML20132C188 ML20132C192 ML20132C686 ML20132C744 ML20132C763 ML20133H945 ML20133H955 ML20133H959 ML20133H970 ML20133H978 ML20133H992 ML20133J004 ML20133J008 ML20133J018 ML20133J027 ML20133J037 ML20133J059 ML20133J077 ML20133J087 ML20133J098 ML20133J101 ML20133J113 ML20133J120 ML20133J122 ML20133J133 ML20133J141 ML20133J144 ML20133J154 ML20133J162 ML20133J177 ML20133J181 ML20133J188 ML20133J191 ML20133J197
References
FRN-50FR34708, RULE-PR-73 AB46-1-30, NUDOCS 8510180264
Download: ML20133J101 (1)

Text

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RES INDEPENDENT REVIEW BOARD

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VOTING SHEET TO: ROBERT M. BERNER0," CHAIRMAN, RIR8 FROM:

TITLE OF RULEMAKING: "RfpogrwG gqo R&fMT5 NA SAFE 6uMn twg AGREE WITH DRAFT RES REQUEST RIRB INDEPENDENT RECOMMENDATIONS MEETING.

IN DRAFT INDEPENDENT REVIEW PACKAGE.

MODIFY DRAFT RES NOT PARTICIPATING.

X INDEPENDENT RECOMMENDATIONS AS INDICATED BELOW.

COMMENTS AND SUGGESTIONS:

The memorandum from RAMRB, DRAO, RES to RIRB members notes in the sumary analysis that the proposed rule " involves a significant cuestion of policy." I do not agree with this characterization.

The proposed rule appears to try to accomplish a simplification and clarification of safeguards events notification requirements.

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In the proposed RES Staff Review Sumary Sheet," paragraph 2a notes that the rulemaking package does not include the basis for the issue that the present reporting requirements are confusing to the licensees and are difficult to properly implement. The sumary sheet further notes that the NMSS contact stated that the missing justification will be sent

' for review shortly. Nevertheless, the sumary sheet indicates in paragraph

' 3a that "the need for this rulemaking has been established even if it is only to clarify and simplify existing requirements." The sumary sheet further notes in paragraph 3b that "if the rulemaking were to proceed on the sole basis of clarification and simplification...it would be well worth the effort." I believe these statements are not consistent.

I agree that sufficient information has been provided for us to recomend I that the rulemaking" proceed; including the development of the missing justification. _Bu.t I don't see how we can make statements stating that

.. the need for the rulemaking has been established witho.ut this jystification.j i it! H cxvvM O.'E. Bassett /

MEMBER, R!RB I

' 7 l' -t 0510180264 001009 DATE PDR PR 73 SOFR34700 PDR

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