Can you change Rulemaking at the NRC?

http://www.regulations.gov/#!documentDetail;D=NRC-2009-0044-0002

DEADLINE IS (Submit comments by) July 17, 2013.

This page will give you some idea to the level of bureaucracy involved in the participation process of updating or improving the process of making or changing existing rules. Titled: Revisions to the Petition for Rulemaking Process

Who has the time? Somebody needs to do it. How do we begin to simplify this rule changing process?
Anyone?

Here is a link to the only public comment to a document (PDF) title
Bungled Entrance Guard PRM 2008 TMIA

Here is another example of over-regulation in a document titled

NRC Enforcement Policy (PDF) here is the full URL

http://www.regulations.gov/contentStreamer?objectId=09000064811dd8be&disposition=attachment&contentType=pdf

See Page page 54 Health Physics
Three levels of violations for annual exposure to radiation 25, 10 and 5 rems to an employee.

See Page 79 for list of penalties up to $140,000

Also this is a comment post from Robert Steinhaus that is an eye opener.

“The NRC annual fee to operate a nuclear reactor of any technology and of any size in FY2013 is $4,780,000. 

It requires about 200,000 hours (estimate) for NRC to evaluate a new technology reactor design.

NRC currently charges $277 / hour for staff evaluator time which means that any small company wanting to bring to market a new technology small modular reactor has to expect to pay about $55.4 million dollars in fees upfront just for NRC to look at their design and give it consideration in a reactor design certification.
http://www.regulations.gov/contentStreamer?objectId=090000648121e059&disposition=attachment&contentType=pdf

Large upfront fees charged by NRC tend to limit participants in the nuclear industry. Charging large fees to evaluate and approve new reactor technology tends to slow the pace of nuclear innovation and limit industry participation to only the largest, well established firms. Nuclear startups, with great new ideas, but only moderate resources are effectively shut out; over time few new nuclear reactor concepts really have a chance to reach commercial reality. The agile young nuclear startups and their revolutionary ideas are by and large unable to handle the large NRC fees for design certification and licensing. Regulatory mandated long delays prevent good nuclear startups with industry revitalizing ideas from bringing their fine designs to market.

Note: The typical size of the engineering document package required to apply for a reactor design certification is 17,000 engineering detailed pages. This is a stack of office paper that is 5′ 6″ tall if neatly stacked. A nuclear startup applying for design certification for a new technology reactor must pay the full cost of preparing the detailed reactor certification document package before it can be submitted to NRC. 
(17,000 pages is about seven times the length of the complete Holy Bible)”

 

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