ML20154S629
| ML20154S629 | |
| Person / Time | |
|---|---|
| Issue date: | 10/02/1998 |
| From: | Diaz N NRC COMMISSION (OCM) |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20154S601 | List: |
| References | |
| SECY-98-199-C, NUDOCS 9810280038 | |
| Download: ML20154S629 (2) | |
Text
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NOTATION VOTE RESPONSE SHEET TO: John C. Hoyle, Secretary FROM: COMMISSIONER DIAZ
SUBJECT:
SECY-98-199 - PROPOSED RULE: 10 CFR PART 31 -
" REQUIREMENT FOR THOSE WHO POSSESS CERTAIN INDUSTRIAL DEVICES CONTAINING BYPRODUCT MATERIALS TO PROVIDE REQUESTED INFORMATION" '
Approved xxf1,. Disapproved Abstain W
Not Participatin COMMENTS:
See attached comments.
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COMMISSIONER DIAZ'S COMMENTS ON SECY-98-199 - PROPOSED RULE: 10 CFR PART 31 " REQUIREMENT FOR THOSE WHO POSSESS CERTAIN INDUSTRIAL DEVICES CONTAINING BYPRODUCT MATER!ALS TO PROVIDE REQUESTED INFORMATION" I approve the publication of the notice of proposed rulemaking for 10 CFR 31.5.
Given the minor scope of this rulemaking, the staff should find ways to finalize the rule before 1 the projected date of July,1999. '
The registr'ation program should be initiated when this rule becomes effective, rather than after !
the automated registration system is completed, in implementing the registration program, the i staff should screen the responses from general licensees and follow up as necessary, ,
commensurate with potential hazards indicated by this information. Additionally, the staff j should be prepared to implement the proposed interim enforcement policy when the revised 10 ,
CFR 31.5 becomes effective.
Information generated during the initial phases of registration should be entered into the existing registration system, and transferred to the new system when it is completed. Capturing this data in parallel with developing the automated registration system will have the collateral benefit of providing current information to assist in identifying system performance requirements.
Regarding the development of the automated registration system, I am concemed that the procurement process being pursued is more of a hindrance than a help. By focusing the "right" people on a major information technology proposal, the CPIC process should streamline procurement and ensure that the most cost effective system is purchased with taxpayer funds, in this light, I agree with Chairman Jackson that the staff should provide the Commission with a set of milestones for development of the automated registration system. Further, I agree with Commissioner McGaffigan that the staff should critically evaluate program needs and consider less expensive altematives to a state-of-the-art system, including the availability of a commercial-off-the-shelf systam that would be sufficiently capable to meet the basic information capture, recording, and response requirements of the device registration program. %
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