ML20205S425
| ML20205S425 | |
| Person / Time | |
|---|---|
| Issue date: | 03/09/1988 |
| From: | Grimsley D NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| To: | Morris B NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20195E797 | List: |
| References | |
| FRN-53FR32914, RULE-PR-20, RULE-PRM-20-15 AC14-1-27, NUDOCS 8811110064 | |
| Download: ML20205S425 (2) | |
Text
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _
AC44-1 4 aLi..n,/: 4 y 2 f[e.., '
'o o
g g
UNITED STATES NUCLEAR REGULATORY COMMISSION W ASHINGTON, D. C. 20555 D j k ..... # MAR 9 1988 MEMORAN9UM FOR: Bill M. Morris, Director Division of Regulatory Applications Office of Nuclear Regulatory Research FROM: Donnie H. Grimsley, Director Division of Rules and Records Office of Administration and Resources Management
SUBJECT:
DRR REVIEW OF PR'0 POSED RULE TO ALLOW ONSITE INCINERATION OF SLIGHTLY CONTAMINATED WASTE '
i OIL AT NUCLEAR POWER PLANTS (10 CFR PART 20)
As requested in your February 24, 1988, memorandum, the Division of Rules and Records (DRR) has reviewed the subject rulemaking package. A DRR-marked copy is enclosed for your information.
At the time of receipt of the petition for rulemaking (PRM-20-15), the co-petitioners were identified as Edison Electric Institute (EEI) and Utility Nuclear Waste Management Group (UNWMG). In several places in the rulemaking packages (e.g., on pp.1 and 2 of the draft Comission paper and on pp.1 and 2 of the Federal Register notice), the second petitioner is referred to as Utilities Waste Management Group, while on page 1 of the Regulatory Analysis and page 2 of the Environmental Assessment, the longer name has been used for the group. Unless there has been a name change since the petition was originally received by the NRC, we recomend consistency in the references to the group. If the name of the group has been changed, that should be mentioned as well.
The Recomendation se: tion of the Comission paper has been rewritten to reflect more closely the preferred style found in the EDO Procedures Manual and to add several more entries to the Note section.
The analysis of coments appears to be rather brief in comparison with other typical analyses of coments, especially when one considers that EE!/UNWMG f submitted a single-spaced 10-page analysis of coments to the NRC on July 5, o While the majority of the coment letters gave the petition a
? rubber-stan.p approval, there were several specific coments made, notably by d g)6 4 Applied 1985. Science and Engineering and the Tennessee Valley Authority.
The CFR has begun using an Optical Character Recognition (OCR) scanner for typesetting lengthy documents whenever possible. Use of the OCR scanner avoids the necessity of rekeying the document text and thereby precludes the possibility of numerous typographical errors resulting from the printing process. Many of the fornat adjustments indicated on the enclosed marked copy are intended to facilitate the use of the OCR scanner for this document.
i 0011110064 001104 PDR PRM PDR t nn 2 0. . 1. 'J. - - - # n
J Bill M. Morris MAR 0 1933 In order to assist you in preparina the list of documents relevant to the proposed rule that is required by NRC's regulatory history pr0cedures, ycu should place the designator "AC14-1" in the upper right-hand corner of each document concerning the proposed rule that is forwarded to the N#;laar Documents System (NUDOCS).
Our comment in the regulatory text is designed to adopt the standard convention endorsed by the Office of the Federal Register to impose an obligation or express a prohibition. In this convention, discussed in section 13.25 of the NRC Regulations Handbook, "shall" is used to impose an obligation on an individual or legal entity capable of performing the required action and "must" is used as the mandatory form when the subject is an inanimate object.
The Records and Reports Management Branch, Division of Information Support Services, ARM, is the office that perfonns the review of the Paperwork Reduction Act Statement (PRAS) and any related reporting and/or recordkeeping requirements. They have indicated to us that there may be a problem with the statement in this package; however, we have not gotten a final decision from them. We, therefore, recomend that you coordinate the PRAS with them for any future revisions of the rulemaking package.
Other coments are noted marginally. If you have any questions, please have a member of your staff call David L. Meyer, Chief, Rules and Procedures Branch, DRR, ARM, on extension 27086 or Sarah Wigginton on extension 27752.
M Dannie H. Grimsley, Director Division of Rules and Records Office of Administration and Resources Management
Enclosure:
As stated
-