ML20211H660
| ML20211H660 | |
| Person / Time | |
|---|---|
| Issue date: | 03/30/1999 |
| From: | Jensen E NRC |
| To: | Au M, Patricia Holahan NRC |
| Shared Package | |
| ML20211H604 | List: |
| References | |
| FRN-64FR33178, RULE-PR-72 AF80-2-012, NUDOCS 9909020143 | |
| Download: ML20211H660 (1) | |
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f3Iricia Eng - Meeting on Part 7fMiscellaneous Chang;s Rule Pags il l
From: E. Neil Jensen Z'30 r/e-F-3 # 63
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To: Markley Au, Patricia Holahan p; 3,O Date: Tue, Mar 30,1999 8:30 AM l
Subject:
Meeting on Part 72 Miscellaneous Changes Rule OGC would like to request a meeting to discuss the problem presented by the mutually contradictory changes to the written report requirements in two ongoing rulemakings. The problem, in brief, is as follows:
The Part 72 Miscellaneous Changes proposed final rule intends to add 72.75(d)(2)(l) to the regulations on two grounds: (1) to make the Part 72 written report requirement consistent with the written report requirement in 50.73(b)(2)(J); and (2) to clearly inform licensees of information necessary for staffs review.
4 The draft proposed rule amending 50.72 and 50.73 deletes 50.73(b)(2)(J) and substitutes for it: "For each human performance related problem that contributed to the event, the licensee shall discuss the cause(s) and circumstances." The draft proposed rule deletes the present requirement on the ground that --
" Experience has indicated that these requirements are overly complicated and somewhat confusing."
Thus, the Part 72 rulemaking says that the detailed information is necessary for staff's review while the Part 50 rulemaking says that the very same information requirement is overly complicated and somewhat confusing. It could be that NMSS staff needs more detailed information than does NRR staff or it could be that both sides of the house can agree on the same requirement. This is what needs to be discussed. The goal would be to achieve agreement on what each office needs to accomplish its mission before final review of either rulemaking package by the EDO and Commission.
Accordingly, we request that you set up a meeting to discuss the above problem.
CC: Dennis Allison, Francis Young, Geary Mizuno, Ke..
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