ML20141J157

Submits Comments in Response to 950412 Memo Which Transmitted Draft FRN Discussing Changes to Regulations to Address Criteria for Release of Patients Administered Radioactive Matls

ML20141J157
Person / Time
Issue date:	04/19/1995
From:	Treby S NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	Morris B NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
Shared Package
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References
FRN-62FR4120, RULE-PR-20, RULE-PR-35 AE41-2-031, AE41-2-31, NUDOCS 9708150113
Download: ML20141J157 (1)

Text

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NUCLEAR RE0"LATORY COMMISSION cc : -

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WASHINC L D.C. 20666-0001 McGuire ggg I

~ Morris T

FHe April-19l19951 dnT orrict or THE 79(

otNERAL CoVNstl MEMORANDUM 10:

Bill Morris, Director Division of Regulatory Applications, RES FROM:

Stuart A. Treby Assistant General Counsel for Rulemaking and Fuel Cycle

SUBJECT:

_~

, i CRifERIA FOR RELEASE 0F PATIENis ADMINISTERED RADIDACTIVE c MATERIALS We have the following comments in response to your April 12, 1995 memorandum which transmitted a draft fed'iral register notice discussing changes to the regulations to address the referenced subject.

1.

-When this rule package is finalized, it will be necessary to verify that the language being used for the rule is consistent with the current status of Part 20.

The definitions of

• occupational dose" and "public dose" proposed for Part 20 in this package are not the same as appear in the rulemaking package currently before the Commission, if the Commission approves the changes currently before it, the changes in your April 12, 1995 Jackage could inadvertently undo the changes now being considered by tie Commission.

2.

You specifically requested comment on whether written instructions should be provided to patients along with oral instructions on methods for keeping exposures ALARA.

While we see no legal imperative for one option or the other, we note that there appears to be practical considerations that would favor issuance of the written instructions.

We assume that patients leaving the hospital typically receive a number of instructions concerning health care and, in addition,- are concerned with signing release papers and making other arrangement associated with leaving the hospital.

These events may prevent the patient from adequately focusing on the oral instructions, Further, the nature of the treatments involved may indicate that the individual will not be as alert, due to health problems, as might be desirable when providing written instructions.

Providing written instructions that the patient, or members of the patient's family, can review at a later time would seem to be a beneficial effort to assure the goals of the instructions to the patients are achieved.

9708150113 970807 2062N4120 PDR RO CYb 3 Ch u D___ 65L l