ML20207T134

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RES Independent Review Board Voting Sheet Re Rulemaking, Rev to 10CFR30,32,40 & 70 Licensing of Sources & Devices. Recommends Mod of RES Rulemaking Review as Indicated
ML20207T134
Person / Time
Issue date: 08/28/1985
From: Goller K
NRC - RESEARCH INDEPENDENT REVIEW BOARD
To: Gillespie F
NRC - RESEARCH INDEPENDENT REVIEW BOARD
Shared Package
ML20205D544 List:
References
FRN-52FR2540, RULE-PR-30, RULE-PR-32 AB34-1-26, AB34-2-40, NUDOCS 8703230237
Download: ML20207T134 (1)


Text

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RE5 INDEPENDEG1 F.! VIEW BOARD VOTING SHEET 4

TO: F. P. GILLESPIE, CHAIRMAN, RIRB FROM: K. R. Goller, Member, RIRB TITLE OF RULEMAKING:

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AGREE WITH REC 0pmENDATIONS IN RES RULEMAKING REVIEW M

  • PACKAGE .

MODIFY RECOMMENDATIONS IN NOT PARTICIPATING.

X RES RULEMAKING REVIEW '

- PACKAGE AS INDICATED BELOW ,

J CO W NTS AND SUGGESTIONS:

i' An important precedent is about to be set here and RIRB should consider carefully what this is.

Essentially the only reason given for recomending terminating this rulemaking is inadequate RES resources. In any case, terminating a rulemaking for .

this reason alone should be very carefully considered, including the possibility of transferring lead responsibility to another office. In this case, however, the " user" office has indicated willingness to assume such responsibility.

Therefore, it would be very bureaucratic to follow through with this independent l review and terminate this rulemaking and then perform another review to initiate

the same rulemaking by another office. Instead, why not set a precedent that the consideration of the transfer of lead responsibility for a rulemaking (for any reason and at any time) is part of an independent review of a rulemakirig 1

' and that such a transfer and approval of continuing the rulemaking can result directly from a recommendation to this effect coming out of an independent review.

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! B703230237 870304 52 2540 PDR l

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