ML20137R520
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October.29, 1984 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:
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" 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."
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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.
If you have any questions on our position, please call me.
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[ hivI<-4 w A. Bert Davis Deputy Regional Administrator i
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