ML20137R624

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Forwards Draft Independent Review Package & Voting Sheets of RES Independent Review Board Members.Members Voted 4 to 0 That NRC Should Proceed W/Human Uses of Byproduct Matls - Revs to 10CFR35, Sponsored by NMSS
ML20137R624
Person / Time
Issue date: 07/27/1984
From: Bernero R
NRC - RESEARCH INDEPENDENT REVIEW BOARD
To: Minogue R
NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
Shared Package
ML20136D915 List: ... further results
References
FRN-50FR30616, RULE-PR-35 AA73-1, NUDOCS 8509230596
Download: ML20137R624 (2)


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l JUL 2 7 B64 MEMORANDlM FOR: Robert B. Minogue Director Office of Nuclear Regulatory Research J

FRCH: Robert M. Bernero Chairinan RES Independent Review Board

SUBJECT:

MINUTES OF RIRB DELIBERATIONS FOR OMOING RULEMAKING SPONSORED bf NHSS i The rulemaking review package received June 1, 1984 (Mail Control j RES-841230A), states:

...the Office of Nuclear Material Safety and Safeguards

has reviewed the on-going rulemaking activities listed i below. On the basis of our review, we recormend the l approval of continued activity on these rules."

Enclosed is the draft independent review package as prepared by responsible

RES staff and considered by the RES Independent Review Board.

Also enclosed are the voting sheets of the RIRS rmbers that reflect their deliberations. As indicated, the RIRB members voted 4 to O that t

the kRC should proceed with " Human Uses of Byproduct Material - Revisions to 10 CFR Part 35." sponsored by MSS. By their concurrence in these sinutes, the RIRB members reconstend that the RES independent recocinendation read, as proposed by one RIRB megaber, as follows:

Although RES agrees that MRC should proceed with this ongoing ruismaking, the Consission paper and supporting documents such as the regulatory anelysis should be modified to state that this consolidation of widely dispersed requirements will result in a greater degree of safety along with cost savings by not requiring a license amendment every time a procedure is changed. The Coonission paper, as now written, would indicate that there is little incentive for continuing on with this rulemaking since it states on page 9 of the Cossetssion paper that the effect of

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selecting the reconnended alternative would be that the staff does not expect any change in worker or public dose or signiff-cant cost or savings.

Robert M. Bernero, Chairman RES Independent Review Board

Enclosures:

1. Draft independent review package for

"}kanan Uses of Byproduct Material-Revisions to 10 CFR Part 35"

2. Voting sheets of RIRB merabers Distribution RAMitB/r/ f RES Cent. File Cnron/ Circ

.aao N GArlotto KGoller 0Bassett RBernero

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