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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UNITED STATES g)

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NUCLEAR REGULATORY COMMISSION y.

WASHINGTON, D. C. 20655

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JUU 91984 o

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*

f Edwin G. Triner, Director Division of Budget and Analysis i

Office of Resource Management

Attachment:

As stated

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