ML20137Q766

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Concurs W/Proposed Rev to 10CFR35,subj to Listed Comments. Value/Impact Statement Should Indicate Cost to Licensee of Any Info Collection Requirements Imposed for First Time by Regulation
ML20137Q766
Person / Time
Issue date: 08/31/1982
From: Norry P
NRC OFFICE OF ADMINISTRATION (ADM)
To: Cunningham R
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
Shared Package
ML20136D915 List: ... further results
References
FRN-50FR30616, RULE-PR-35 AA73-1, NUDOCS 8509230249
Download: ML20137Q766 (1)


Text

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MEMORANDUM FOR: Richard E. Cunningham, Director / -

Division of Fuel Cycle and Material Safety Office of Nuclear Material Safety and Safeguards FROM: Patricia G. Norry, Director Office of- Administration ..

SUBJECT:

PROPOSED REVISION OF PART 35 Subject to the below comments, the Office of Administration concurs on the proposed revision of 10 CFR Part 35.

The Regulatory Flexibility Act statenient contained in the Federal Register Notice states that the proposed licensing system would reduce the economic burden on licensees. Language should be included in the Regulatory Flexibility Act statement that references the value/ impact statement containing the cost data and setting forth the rationale leading to the stated conclusion. In addition, because of the widely differing conditions under which medical licensees operate and the somewhat speculative  ;

nature of the data contained in the value/ impact statement, language should also be added to the Regulatory Flexibility Act statement that specifically solicits comments from small medical licensees on how the revised licensing system presented in the proposed rule would affect their operations.

Finally, the value/ impact statement should indicate the cost to the licensee.of any information collection requirements that are imposed for the first time by regulation. The costs and benefits of each new information collection requirement should be analyzed separately.

Enclosed is a marked-up copy of the regulations that presents the-language l necessary to make the needed adjustments in the Regulatory Flexibility l Act statement. The mark-up also contains a number of editorial and -

format changes that are suggested to provide greater clarity in the regulation and to conform the document to the publication requirements of the Office of the Federal Register.

t If you have any questions, please contact John D. Philips, Chief, Rules and Procedures Branch, or Michael T. Lesar of his staff on extension 27086. ,

gg92gg249850906 g 35 50FR30616 PDR Patricia G. Norry, Director l Office of Administration 1

Enclosure:

' As stated 1

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