ML20137R203
| ML20137R203 | |
| Person / Time | |
|---|---|
| Issue date: | 04/29/1985 |
| From: | Asselstine J NRC COMMISSION (OCM) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20136D915 | List:
|
| References | |
| FRN-50FR30616, RULE-PR-35 AA73-1, NUDOCS 8509230429 | |
| Download: ML20137R203 (1) | |
Text
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$lJLs N 0"T A T I 0 N V0TE cc: WDircks JRoe
(~) RESPONSE SHEET g[f)(p o
T0: SAMUEL J. CHILK, SECRETARY OF THE COMMISSION
'D Y ,p FROM: COMMISSIONER ASSELSTINE bV'hj
SUBJECT:
SECY-84-485 - PROPOSED REVISION OF 10 CFR PART 35
" MEDICAL USE OF BYPRODUCT MATERIAL" APPROVEDx as maairied DISAPPROVED ABSTAIN NOT PARTICIPATIl!G REQUEST DISCUSSION COMMENTS:
I do not agree with the proposed Section 35.36 which would allow licensees to make changes to their radiation safety program without prior regulatory review and approval. I would retain the license amendment process which
{') would require review of all m6difications to a license.
I believe that all licensees, including physicians, should be required to have a formal ALARA review of their radiation safety programs. One of the physicians at the March 20, 1985 Commission meeting thought it was a prudent measure, and I agree. The proposed rule should be modified as such.
I agree with Commissioner Zech's suggestion to solicit public comment on his three questions concerning medical misadministiration. I also agree with Commissioner Bernthal's suggestion that we receive comment on NRC's enforcement role and responsibilities in the area of medical misadministration.
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SECRETARIAT NOTE: PLEASE ALSO RESPOND TO AND/OR COMMENT ON OGC/0PE MEMORANDUM IF ONE HAS BEEN ISSUED ON THIS PAPER.
NRC-SECY FORM DEC. 80 -
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