ML20035A383
| ML20035A383 | |
| Person / Time | |
|---|---|
| Issue date: | 11/14/1991 |
| From: | Rothschild M NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | Hopkins D NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20034D215 | List:
|
| References | |
| FRN-57FR56287, RULE-PR-31, RULE-PR-32 AD82-1-008, AD82-1-8, NUDOCS 9303250215 | |
| Download: ML20035A383 (1) | |
Text
F f)D g.2 -)
L, pg November 14, 1991 Note to:
Marjorie Rothschild, OGC
SUBJECT:
ADDITIONAL COMMENTS ON PROPOSED RULEMAKING COdCERNING THE ACCESSIBLE AIR-GAP FOR GENERALLY LICENSED DEVICES This is a follow-up to my note to you of November 6, 1991, in which I provided my initial comments on the draft Federal Recister notice of proposed rulemaking. I have now completed my review of that notice and have reviewed the other documents in the rulemaking package (draft regulatory analysis, letter to Congress, and public announcement).
My comments on those documents and suggested revisions are contained in the attached mark-ups. Based on our telephone conversation today, I understand that, consistent with my earlier note, an environmental assessment will be prepared and that the entire package, as revised, will be transmitted to us for review.
With respect to the draft regulatory analysis, my main comment is that the discussion of " Industry Costs" on pp. 9-13 (SS4.1.3.1.1, "The Proposed Action" and 4.1. 3.1. 2, "The Alternative of Relying on Existing Mechanisms") is somewhat confusing. First of all, it is not clear what the " existing mechanisms" or " existing requirements" are. I thought there weren't any existing requirements with respect to gauges having an " accessible air gap." Also, it is not clear that licensees are currently required to take any of the actions discussed in 54.1.3.1.2.
Further, it is also unclear what the difference between these two alternatives is because the actions discussed seem to be the same in both sections.
As reflected in the attached copy of page 10 of the Federal Reaister notice (" Regulatory Flexibility Certification"), I suggest adding a sentence concluding that the potential gain in radiation protection by reducing the frequency and likelihood of unnecessary radiation exposure of workers significantly outweighs the economic impact on small general licensees.
Attachments:
as stated cc w/o attachments:
S.Treby i
lI. <
9303250215 930309
~