ML20128M221

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Forwards Cost Analysis Group Review Comments on Proposed Rule 10CFR39 Re Well Logging Operations.Minor Rewording of Section 3.1 Suggested
ML20128M221
Person / Time
Issue date: 07/19/1984
From: Triner E
NRC OFFICE OF RESOURCE MANAGEMENT (ORM)
To: Tse A
NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
Shared Package
ML20127B584 List:
References
FRN-50FR13797, RULE-PR-19, RULE-PR-39 AB35-1, NUDOCS 8505310608
Download: ML20128M221 (1)


Text

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s** *'*% UNITED STATES Agg i

y. NUCLEAR REGULATORY COMMISSION

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g) WASHINGTON, D. C. 20655

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MEMORANDUM FOR: Anthony N. Tse j Transportation and Material Risk Branch 4 Office of Nuclear Regulatory Research j FROM: Edwin G. Triner, Director l Division of Budget and Analysis ,

Office of Resource Management  ;

l

SUBJECT:

CAG REVIEW 0F PROPOSED NEW RULE 10 CFR 39 ON WELL-LOGGING OPERATIONS Attached, as you requested, are the Cost Analysis Group's (CAG's) review comments on your proposed new rule 10 CFR 39 on well-logging I operations. If you have any questions regarding these coments, please l ccntact John Clark, of my staff on extension X29868.

Separately from our cost analysis review, we note that in Section 3.1 r of the regulatory analysis you state that the current rules applying to l

well-logging or the " status quo" are " unacceptable". Since the current rules have been in effect for some time you are implying here that NRC's rules regarding well-logging operation have been unacceptable for some ,

years. You make enough points in Sections 3.1 and 3.2 to show that your I proposed alternative is su)erior to the status quo, but we think it might be inappropriate to tenn t1ese present NRC practices as l " unacceptable".

M* ,

' Edwin G. Triner, Director Division of Budget and Analysis i Office of Resource Management

Attachment:

As stated

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