ML20137R520
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October.29, 1984 yn cQ 4
i MEMORANDUM FOR: Donald B. Mausshardt, Deputy Director j
Office of Nuclear Material Safety and Safeguards l FROM: A. Bert Davis, Deputy Regional Administrator i l Region III i
SUBJECT:
PROPOSED REVISION OF PART 35 i
The purpose of this memorandum is to clarify Region III's position with >
j respect to this proposed revision of Part 35. It is as follows:
Although Region III concurs in Alternative 2, i.e., " Publish the
! proposed revision of Part 35 attached as Enclosure 1," we would
! have preferred the following:
1
" Publish the proposed revision of Part 35 after modifying Section i 35.36 to require that applicants and licensees submit those changes
- to their radiation safety programs which decrease their effectiveness j , for NRC review and approval prior to implementation."
a j We believe this course of action would assure program changes are carefully l considered by licensees and would provide added assurance that programs 4 would not be degraded from a safety standpoint.
4 If you have any questions on our position, please call me.
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! A. Bert Davis
- Deputy Regional Administrator i
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1 i 8509230542 850906 j PDR PR
- 35,50FR30616 PDR 1