ML20137Q889 - Revision history

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2024-12-12T03:22:16Z

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	i gn Rio UNITED STATES		i gn Rio UNITED STATES
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	MEMORANDUM FOR: Richard E. Cunningham, Director h Division of Fuel Cycle and Material Safety FROM: L. I. Cobb, Director Division of Fuel Facilities, Materials and Safeguards		WN 2 1982
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			,p MEMORANDUM FOR: Richard E. Cunningham, Director h
			Division of Fuel Cycle and Material Safety FROM:
			L. I. Cobb, Director Division of Fuel Facilities, Materials and Safeguards

	==SUBJECT:==		==SUBJECT:==
	PROPOSED REVISION OF 10 CFR PART 35 We have some reservations regarding the proposed revision of the rule and the justification as it is written.		PROPOSED REVISION OF 10 CFR PART 35 We have some reservations regarding the proposed revision of the rule and the justification as it is written.
	For example, (1) we question the statement about a reduction in regulatory and administrative burden on the industry in the face of such a prescriptive rule; (2) It seems inconsistent to say that "... safety technology is now fully developed and safety requirements are 'well defined ...", and then incorporate all these details into the regulations; (3) We don't understand the use of an automated management information system (MIS) as a justification for the rule change.		For example, (1) we question the statement about a reduction in regulatory and administrative burden on the industry in the face of such a prescriptive rule; (2) It seems inconsistent to say that "... safety technology is now fully developed and safety requirements are 'well defined...", and then incorporate all these details into the regulations; (3) We don't understand the use of an automated management information system (MIS) as a justification for the rule change.
	U -0ther specific comments are noted on the enclosed marked-up copy of the draft revision. We will be glad to meet with you and discuss them at greater length.		-0ther specific comments are noted on the enclosed marked-up copy of the draft U
			revision. We will be glad to meet with you and discuss them at greater length.
	L. I. Cobb, Director Division of Fuel Facilities, Materials and Safeguards		L. I. Cobb, Director Division of Fuel Facilities, Materials and Safeguards

	==Enclosure:==		==Enclosure:==
	As stated CONTACT: H. Karagiannis 49-27910 1		As stated CONTACT:
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2020-07-01T01:02:38Z

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← Older revision		Revision as of 21:02, 30 June 2020
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			i gn Rio UNITED STATES
			# [o,, NUCLEAR REGULATORY COMMISSION g I 4
			WASHINGTON, D. C. 20555 ^
			g
			!~} 5 ij [' p, '
			U %, ,/ WN 2 1982 ,
			, S.e, ,7 ;B';>
			,ely i e ,'
			i i ,p D' & ,l$
			MEMORANDUM FOR: Richard E. Cunningham, Director h Division of Fuel Cycle and Material Safety FROM: L. I. Cobb, Director Division of Fuel Facilities, Materials and Safeguards

			==SUBJECT:==
			PROPOSED REVISION OF 10 CFR PART 35 We have some reservations regarding the proposed revision of the rule and the justification as it is written.
			For example, (1) we question the statement about a reduction in regulatory and administrative burden on the industry in the face of such a prescriptive rule; (2) It seems inconsistent to say that "... safety technology is now fully developed and safety requirements are 'well defined ...", and then incorporate all these details into the regulations; (3) We don't understand the use of an automated management information system (MIS) as a justification for the rule change.
			U -0ther specific comments are noted on the enclosed marked-up copy of the draft revision. We will be glad to meet with you and discuss them at greater length.
			L. I. Cobb, Director Division of Fuel Facilities, Materials and Safeguards

			==Enclosure:==
			As stated CONTACT: H. Karagiannis 49-27910 1
			'I['7
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			y l h(f]L W l g d S[v x;/ we Q v.
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			ggp,/Y' 8509230305 050906 O PDR PR /% -
			35 50FR30616 PDR /
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			(/}}

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2020-06-16T20:14:37Z

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{{Adams
| number = ML20137Q889
| issue date = 06/02/1982
| title = Discusses Proposed Rev to 10CFR35.Statement Re Reduction in Regulatory & Administrative Burden on Industry & Use of Automated Mgt Info Sys as Justification for Rule Change Questioned
| author name = Cobb L
| author affiliation = NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
| addressee name = Cunningham R
| addressee affiliation = NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
| docket =
| license number =
| contact person =
| case reference number = FRN-50FR30616, RULE-PR-35
| document report number = AA73-1, NUDOCS 8509230305
| package number = ML20136D915
| document type = INTERNAL OR EXTERNAL MEMORANDUM, MEMORANDUMS-CORRESPONDENCE
| page count = 1
}}

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