ML20207S669
| ML20207S669 | |
| Person / Time | |
|---|---|
| Issue date: | 06/10/1985 |
| From: | Cunningham R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Gillespie F NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20205D544 | List: |
| References | |
| FRN-52FR2540, RULE-PR-30, RULE-PR-32 AB34-1-08, AB34-1-8, AB34-2-22, NUDOCS 8703200158 | |
| Download: ML20207S669 (1) | |
Text
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\...../ JUN 101985 Frank P. Gillespie, Director MEMORANDUM FOR:
Division of Risk Analysis and Operations, NRR ao
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Richard E. Cunningham, Director h Division of Fuel Cycle and Material Safety, NMSS i
SUBJECT:
DRAFT RECOMMENDATIONS TO EDO CONCERNING THE CONTINUANCE REVISIONS TO 10 OF ONG0ING RULEMAKING SPONSORED BY RES:
CFR 30, 32, 40 and 70 - LICENSING OF SOURCES AND DEVICES
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We do not concur with the termination of the rulemaking action. We are in agreement with you that the draft rule, as prepared by the Office of Nuclear Regulatory Research (RES) does not address adequately our regislatory needs. In our meeting with Charles Barlett on March 19, 1986, we indicated how important the rule is to our regulatory program and suggested that the proposed rule be improved, not cancelled.
Mr. Bartlett agreed that RES would review the task, including consideration of wrather alternatives to rulemaking could be identified. RES has not identified any alternatives, and our own review indicates that there are no legal alternatives to rulemaking.
In view of the above, we urge that the rulemaking go forward. We will be happy to meet with your staff to explain how the rule can be developed and modified to meet our needs.
Richard E. Cunningham.. Director Division of Fuel Cycle and Material Safety koj32pplSe8703g4 30 D2FR2540 pyg ,