ML20137R520

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Clarifies Region III Position Re Proposed Rev to 10CFR35. Publication After Modifying Section 35.36 to Require That Applicants & Licensees Submit Changes to Radiation Safety Program Which Decrease Effectiveness Preferred
ML20137R520
Person / Time
Issue date: 10/29/1984
From: Davis A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Mausshardt D
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
Shared Package
ML20136D915 List: ... further results
References
FRN-50FR30616, RULE-PR-35 AA73-1, NUDOCS 8509230542
Download: ML20137R520 (1)


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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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35,50FR30616 PDR 1