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[c t NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 Ref: SA/ LAB SEP 1 2 1983 MEMORANDUM FOR: Richard E. Cunningham, Director Division of Fuel Cycle and Material Safety Office of Nuclear Materials Safety and Safeguards FROM: G. Wayne Kerr, Director Office of State Programs
SUBJECT:
REVISION OF 10 CFR PART 35 In response to your memo dated August 26, 1983 regarding Part 35, I am designating Lloyd Bolling to serve as a point of contact for this project.
We agree with the concept of having the license applicant submit a radiological safety plan which contains those procedural steps essential to complying with the NRC regulations. The plan would be reviewed and approved by NRC and any changes to the plan would require a license amendment. Operating procedures to implement the plan would also be established and followed by the licensee but these could be modified only to the extent they were consistent with the plan. Changes in the operating procedures would not require a license amendment. In your proposal it is not clear whether a description of the plan or the plan itself would be submitted for review. We believe the plan itself should be submitted.
In view of the strong agreement State interest in this matter, we request you include a 45 day comment period in your schedule for obtaining State comments. This is in keeping with manual chapter 0401.
Based on a phone conversation between Bill Walker and Lloyd Bolling of my staff we are sending your memo of August 26, 1983 and enclosures to the Agreement' States for their input on the concept proposed. In addition, Bill Walker could present this concept in his discussion of Part 35 at the All Agreement State meeting later this month.
.h M G. Wayne err, Director Office of State Programs 8509230647 850906 PDR
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