ML20207S866

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Forwards marked-up Comments Based on Review of Draft Proposed Rule Re Mfg Registration of Radiation Safety Info for Certain Devices & Sealed Sources.Addl Info Required in Regulatory Analysis & Regulatory Flexibility Certification
ML20207S866
Person / Time
Issue date: 09/12/1986
From: Grimsley D
NRC OFFICE OF ADMINISTRATION (ADM)
To: Cunningham R
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
Shared Package
ML20205D544 List:
References
FRN-52FR2540, RULE-PR-30, RULE-PR-32 AB34-1-12, AB34-2-26, NUDOCS 8703200346
Download: ML20207S866 (1)


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wAsHWGTON, D. C. 20666 AB34-1 PDR SEP 131986 MEMORANDUM FOR:

Richard E. Cunningham, Director Division of Fuel Cycle and Material Safety Office of Nuclear Material Safety and Safeguards FROM:

Donnie H. Grimsley Director Division of Rules a,nd Records

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Office of Administration

SUBJECT:

14ANUFACTURERS' REGISTRATION OF RADIATIO

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SAFETY INFORMATION FOR CERTAIN DEVICES A SEALED SOURCES concerning manufacturers' registraThe Division of Rules and certain devices and sealed sources. tion of radiation safety information forproposed rule package that sets out our specific comments.We have enclosed a marked-up copy of t Addf tional information is required in both the Regulatory Anal Regulatory Flexibility Certification statement to indicate the ysis and the potential economic effect of this proposed rule cost impact and manufacturer in developing and submitting an ave.

The costs incurred by a the NRC that is sufficient for NRC review and inclusion in thrage info be described.

license applications that use information contained in e registry should average savings accruing to a license applicant because of the reg c

Finally, the analyses should indicate the costs incurred b s ry and the manufacturer's submittal vis-a-vis the costs in reviewing multiple sy ry.

license ' applications.

pecific Consission's backfit analysis requirements.We note that th cability of the appropriate language concernin The proper approach and Office of the General Counsel.g this matter should be coordinated with the We have suggested a revision to the Summary statement that is clearly comply with the publication req)uiremen needed to more Register (OFR).

(NUREG/BR-0053 e Federal document does,)w,hy the action is necessary,ld succinctly indica the Susmary paragraph shou the action In addition, we have made additional changes in the ame language an.

0FR pubitcation requirements.d the, presentation of the amendmen y with Our comments in the regulatory text are designed to adopt the tion endorsed by the OFR to impose an obifgation or express a standard conven-this convention, discussed in section 13.27 of the NRC Regul ti prohibition.

In a

ons Handbook, 8703200346 070304 N52h2540 PDR

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