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'o UNITED STATES p]j E
NUCLEAR REGULATOllY COMMISSION
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a 1450 MARIA LANE, SUITE 210 I
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WALNUT CREEK, CALIFORNIA 94596 J
JUL 2 7 B84 t'
Memorandum For:
Richard E. Cunningham, Director Division of Fuel Cycle and Material Safety From:
Ross A. Scarano, Director Division of Radiological Safety and Safeguards Programs
Subject:
Concurrence and Comments on Proposed Revision of 10 CFR Part 35
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We concur on the proposed revision of 10 CFR Part 35 with the following comments:
1.
35.75, " Release of patients containing radiopharmaceuticals or permanent /u v>MM implants" and 35.404, " Release of patients treated with temporary implanta" state that the licensee shall not authorize " release from iQ 36 e /
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confinement for medical care..." patients who have received radiopharmaceutical or brachytherapy treatments unless certain conditions are met.
We feel that this section should be clarified so that urgent treatments requiring that the patient be moved from his or her private room (such as emergency surgery) are not hampered by this regulation.
This may be accomplished by defining the term " confinement" in the regulation.
2.
35.315(g) requires that each individual.who helped prepare a therapeutic d
dosage of iodine-131 shall have a bioassay conducted within three days.
fc MI Currently, bioassays are not required when iodine-131 is administered in[mhki capsule form'and the capsule is not dropped or crushed.
3.
We believe that a typographical error was made in 35.31(b)(1).
It
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should read as follows: " Investigate overexposures, accidents,. spills, losses, thefts, unauthorized receipts, uses, transfers, and disposals, and other deviations of approved radiation safety practice and implement corrective actions as necessary;".
We appreciated the opportunity to comment on this proposed regulation.
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Ross A. Scarano, Director Division of Radiological Safety and Safeguards Programs 8509230516 850906 PDR PR 35 SOFR30616 PDR
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