ML20137R278
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N c 'Yrtt JUN 141984 HEit0RANDUM FOR: John G. Davis, Director Office of Nuclear fiaterial Safety and. Safeguards FROM: Richard E. Cunninghan, Director Division of Fuel Cycle and Ifaterial Safety
SUBJECT:
SCHEDlfLE CHANGE FOR PART 35 This is a request for written authorization from your office to change the Part 35 schedule that was subaitted on November 21, 1983 and approved by you on December 20, 1983. According to that schedule, the final package was to be sutmitted to you on June 30, 1984 for transnittal to the 'EDO.
There are several reasons for the need to change the schedule: !
- 1. Two schedule advances should have resulted in being thirty days ahead of schedule, with cornwnts due flarch 30 instead of the scheduled April 30. The "For Connent" package was cocpleted two weeks ahead of schedule. Because IIeadquarters cognizant staff and all interested regional staff were given a formal presentation designed to resolve nany expected connents,the connent period was reduced from the planned sixty to forty-five days. Ilowever, two key offices, ELD and RES subnitted their connents five weeks after the due date. Therefore, instead of being thirty days ahead, we were seven days behind.
- 2. The cognizant individuals from these two key offices have both left the agency. There was an orderly transition in RES; the ELD replacenent has been on vacation since he was assigned to the project, but will be returning this week.
- 3. The volume of coment has been nuch greater than expected. ife received 105 pages of coments from twelve IRC offices and eleven Agreement States. Their resolution required extensive editing and preparation of several new explanatory and supporting sections, which are still being written.
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UUN 141984 John rs. Davis 4 Several work days have been consoned in a ralated issue on training and experience standards that has been raised by a large group of physicians. To ensure continuity in agency policy regarding the use of hyproduct naterials in nedicine, the Part 35 workforce has had to play an active role in this issue, ubich has yet to be resolved.
For these reasons the following schedule is proposed:
Finish writing new supporting sections requested by connenters June 29, 1984 P.eceive back froa typing, proof, correct, and receive final copy July 6, 1934
!! ail out for concurrence July 10, 1984 Concurrences due- July 31, 1984 Forward package to Office Director August 3, 1984 There may be one issue that could cause need for a second schedule change. The ELD connents, which were received by nail after
!!r. Klucsik's departure, indicate that his successor, Fr. Dorian, "nay suggest decoupling the licensing from the operating rule and expanding the licensing section to a naw subpart [of the regulation] ...
there nay be a legal problen uith not telling the applicant more than ve do on the regulations." !!r. Klocsik had been an active participant in the preparation of this package for the past ,two-and-one-half years. This is the first notice we received that ELO night want a substantive revision, tie have sought clarification fron fir. Dorian, but he will not be returning fron vacation until the end of this week.
!!e will neet with ELO to discuss these new concerns, and do our best to dissuade thaa fron reco75ending a revision of the licensing section.
However, if they insist on the revision, ubich would represent a significant change in agency policy that affects all IRC licensees, we will h~ ave to plan a nanagenent neeting to discuss this. The revision of Part 35 would be on hold pending the results of the neeting.
' Original Signed by DISTRIBUTION Blchard E. Cunn!ngh'ad NLMcElroy 8Meu .ma u VLHiller DRChapell Richard E. Cunninghan, Director RECunningham Division of Fuel Cycle and futerial Safety NMSS r/f FCML r/f FC Central File 'q DNaussbardt M rwt p7" FCML .V FC FC M
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