ML20203B414
| ML20203B414 | |
| Person / Time | |
|---|---|
| Issue date: | 03/31/1986 |
| From: | Funches J Office of Nuclear Reactor Regulation |
| To: | Hauber R NRC OFFICE OF INTERNATIONAL PROGRAMS (OIP) |
| Shared Package | |
| ML20198A175 | List: |
| References | |
| RULE-PR-110-MISC AC20-2-06, AC20-2-6, NUDOCS 8607180207 | |
| Download: ML20203B414 (3) | |
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MEMORANDUM FOR: Ronald D. Hauber Assistant Director for International Cooperation Office of International Programs FROM:
Jesse L. Funches, Director Planning and Program Analysis Staff Office of Nuclear Reactor Regulation
SUBJECT:
MINOR AMENDMENTS TO 10 CFR PART 110, " EXPORT AND IMPORT OF NUCLEAR MATERIALS AND EQUIPMENT" i,.
L The Office of Nuclear Reactor Regulation has reviewed the subject rulemaking and concurs in the proposed rulemaking.
This agreement was conveyed in a March 25, 1986 telephone conversation between Mr. Ken Eccleston (x29518) of my staff and Ms. Elai e Hemby of your office.
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G For inclusion in note to Commission The Commission will note that no' backfit analysis has been done for the amendments to Part 110, although the Staff Requirements Memorandum on SECY 85183/183A of December 31, 1985, stated that rules would be subject to-the backfit rule. The backfit provisions-in 10 CFR f 50.109 apply to domestic facilities, while the provisions of Part 110 apply only to export and import of nuclear facilities, material and components.
Accordingly, after discussion with, and agreement of OGC, we have concluded that the backfit rule was not intended to apoly to the regulations in Part 110, or activities subject to that part.
For inclusion in statement of considerations The backfit analysis as required by 10 CFR B 50.109 has been prepared for these amendments, since the regulations in Part 110 apply only to export and import of nuclear facilities, material and components and have no impact on domestic facilities.
C0MMENTS FR0M E L D/ J 0 A'N N A BECKER TO BE A PART OF THE RULEMAKING PACKAGE COMMENTS WERE INCORPORATED INTO THE FINAL RULEMAKING PACKAGE 3/25/86 1
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SUBJECT:
FINAL RULE AMENDING NRC's REGULATIONS FOR THE EXP0RT OF NUCLEAR MATERIAL AND EQUIPMENT (10 CFR PART 110)
RE: COPMERTS FROM-JAMEStTAYLORhl&E.
I CALLED I&E ON THRUSDAY, JANUARY 23 AND WAS ADVISED THAT LEN COBB, X24935, WAS GIVEN ACTION ON THIS RULEMAKING.
PER LEN COBB, I&E HAS NO COMMENTS.
RE: _
ARE NOTED AS FOLLOWS:
1.
Under "SUBMARY" and " SUPPLEMENTAL INFORMATION" sections the word "certain" was added in describing the countries to be deleted from 5110.29 Restricted destinations. We agree with this change because as NMSS also noted all countries which are adherents to the NPT have not been removed from the restricted list because of other Executive Branch and NRC concerns.
2.
Under "Enviromental Impact:
Categorical Exclusion", the part cited was incorrect.
This part has been corrected to read 10 CFR 51.22(C)(1).
(Per telephone conversation with Mike Lesar, Office of Administration, he clso corrected this part.)
3.
Regarding the revision to americium-241 general license.
NMSS notes that the language in this section is somewhat confusing. While we agree with NMSS, I indicated that attempting to revise the language at this point may create more problems than it was worth for this minor revision.
Especially since the part that NMSS has problems with is already in the regulations.
To change the language at this point, IP would be required to clear "new" language with Kay-Ray Company and also all other companies which previously commented on this rulemaking when first initiated.
The Executive Branch would also have to be consulted which may require a lengthy review time.
NMSS agrees that the language can remain as is.
These comments were received by telephone on Thursday, Jan 23 and may or may not be followed up by memo from NMSS.
NQR.
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