2010/10/18-Comment (40) of Bruce Busby on FR Doc # 2010-25397

The new Part 37 regulations does little in the way of actually creating a more secure environment and mostly will waste millions of dollars and create even more bureaucracy, all without achieving the intended goals. The proposed regulation is unnecessary, and a waste of tax payer money (who support my organization through NIH grants). The total cost of the Part 37 revision should include the costs that the licensees incurred to meet the Increased Controls order. Without including that, the estimate and burden on licensees is out of proportion to the actual risk. The NRC has had in their regulations, specific requirements for the control and security of radioactive material for 20 plus years. Adding new requirements will not actually increase anything other than spending. The proposed regulation is unnecessarily complex, complicated and long. It requires licensees to create new plans, procedures, and policies and install new monitoring equipment beyond what was required by the Increased Controls Order. I would strongly recommend this proposed regulation be reviewed, simplified and shortened. The NRC has failed to adequately look at the costs for licensees with multiple sources and hundreds of users. The proposed regulation adds additional burden to these licesees, beyond the Increased Controls order, and will be financially cripple small companies. The increase in man hours required to meet the new requirements has been underestimated. I completely disagree with the concept of doing Credit History Checks. We have individuals who have lived in multiple countries, and this requirement will be impossible to complete for them. It’s not even a matter of spending excessive amounts of money to comply, it will actually be impossible. I do not agree with making a regulation which is impossible to meet. I also feel the basis described in the background information is flawed, and not realistic for why Credit History Checks are needed. Can the NRC provide some