ML20050C707
| ML20050C707 | |
| Person / Time | |
|---|---|
| Issue date: | 02/26/1982 |
| From: | Palladino N NRC COMMISSION (OCM) |
| To: | Roth W SENATE, GOVERNMENTAL AFFAIRS |
| Shared Package | |
| ML20050C708 | List: |
| References | |
| NUDOCS 8204090277 | |
| Download: ML20050C707 (2) | |
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..L UNITED STATES j
g NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20566 g
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4 February 26, 1982 CHAIRMAN t
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The Honorable William V.
Roth 2
MAR 2 21982*-
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-Chairman-D 8mm amre caneau l
Committee on Government Operations
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. United States Senate j
Washington, D. C.
20510
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Dear Mr. Chairman:
We have reviewed S. 1833, " Regulatory Burden Reduction Act,"
as requested in your letter of November 25, 1981'and offar L
the following co:cments for consideration by the Committee.
c The NRC continues to support the need for regulatory agencies r
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to understand the economic costs imposed by agency require-
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ments and agrees that an improved procedure for doing this 4
is desirable.
For this reason we support Section 4 but be-lieve the. annual report should include actual cost data for the just completed fiscal year with a comparison to the costs that had been estimated for new regulations in the previous i
year's report.
Significant differences would be explained.
Congressional oversight could be exercised on a selective basis to explore the tradeoff benefits, less expensive alter-1 3
natives and improvements to realistic cost estimation.
We believe this approach would involve a more serious consider-ation by regulatory agencies of the economic costs of their activities and provide a basis for Coniressional oversight J
j of their decisions.
1 We cannot, however, support the mandated 25 per centum com-pliance cost reduction provision in Section 3 (a) without qualifying. language which would exempt major rules and collection of data that, after careful analysis and public comment, are promulgated to protect or further public health and safety.
A majority of NRC's licensees would be covered under Section 2(5) of the Act such as doctors' offices, X-ray clinics, and small transportation' firms who interface directly with the public or are located in densely populated areas.
Data collection from reporting requirements from these businessies is vital in monitoring use, packaging, storage, transport, f
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1 8204090277 820226 l
PDR COMMS NRCC 1
CORRESPOl@ENCE PDR
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2 and disposal of radioactive material.
For this reason we suggest that the 25 per centum reduction figure be used as a goal to be achieved considering the agency's statutory requirements.
j Sincerely, j
i Nunz J.
alladino cc:
Senator Thomas F, Eagleton i
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