ML20203G408

Informs That Crockett & T Rothschild Reviewed Draft Final Rule Entitled Informal Small Entity Guidance & Offer Concurrence If Change Made That Would Cause Rule to More Closely Track Statute

ML20203G408
Person / Time
Issue date:	04/18/1997
From:	Crockett S NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	Meyer D NRC OFFICE OF ADMINISTRATION (ADM)
Shared Package
ML20203G270	List: ML20203G263 ML20203G344 ML20203G372 ML20203G387 ML20203G408 ML20203G420 ML20203G447 ML20203G458
References
FRN-62FR26219, RULE-PR-2 AF68-2-006, AF68-2-6, NUDOCS 9803020302
Download: ML20203G408 (1)

Text

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Poe UNITED STATES ,

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NUCLEAR REGULATORY COMMISSION WASHINGTON, D C. 2MM-9001

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April 1% !W)

OFF6Cr OF THr g6, .

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GE NE RAL COUNSE L hiEhtORANDUhi TO: David hicycr, Chief Rules Review and Directives Branch OfBce of Administration FROht: Steven Crockett C'

< Senior Attomey, OGC

SUBJECT:

YOUR REQUEST FOR COhih1ENT AND CONCURRENCE ON A FINAL RULE ENTITLED "lNFORh1AL ShiALL ENTITY GUIDANCE" Ily memorandum on April 8,1997, you asked for comments and concurrence on a dran fmal rule that amends s2.810 to provide a toll free telephone number for smcil entities to use to call the NRC for informal adv;ce about regulations that may affect them.

Trip Rothschild and I have reviewed the draft and concur in it, if you will nnke the changes we have penciled on to the attached drafl. The main change we are asking for would cause the rule to track more closely the statute. Your draft, while concise and readable, inadvertently removes some of the flexibility that the statute gives the agency. At the cost of greater length, we want to recover some of that 11exibility. We have also restored one other aspect of the statute. There the "information and advice" are about complhmcc with statutes and regulations, but.in your draft the information and advice are about the statutes and regulations themselves. The statutory

- language focuses our information and advice on the main point: how to be in compliance.

Thank you for the opportunity to comment.

Attachment:

As stated i

9003020302 980225 PDR PR h

2 62Fh26219 PDR

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