ML20141J175

Informs of Issues to Be Addressed Re Patient Release

ML20141J175
Person / Time
Issue date:	06/19/1995
From:	Trottier C NRC
To:	Stewart Schneider NRC
Shared Package
ML20007J296	List: ML20141J014 ML20141J051 ML20141J057 ML20141J066 ML20141J073 ML20141J078 ML20141J082 ML20141J087 ML20141J089 ML20141J091 ML20141J096 ML20141J102 ML20141J108 ML20141J113 ML20141J120 ML20141J122 ML20141J126 ML20141J135 ML20141J142 ML20141J145 ML20141J151 ML20141J157 ML20141J162 ML20141J175 ML20141J180 ML20141J185 ML20141J191 ML20141J195 ML20141J201 ML20141J207 ML20141J208 ML20141J214 ML20141J220 ML20141J225 ML20141J230 ML20141J235 ML20141J242 ML20141J246 ML20141J251 ML20141J255 ML20141J261 ML20141J265 ML20141J272 ML20141J279 ML20141J283 ML20141J292 ML20141J298 ML20141J303 ML20141J308 ML20141J316 ... further results
References
FRN-62FR4120, RULE-PR-20, RULE-PR-35 AE41-2-034, AE41-2-34, NUDOCS 9708150124
Download: ML20141J175 (1)

Text

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Nd hl T From:^Cheryl A.1Trottier: '(CATI):

$ }d_;68' Ak--W-9 To: SXS4 Date: Monday, June 19, 1995 5:00 pm g

Subject:

PATIENT RELEASE

-Stewart, LBefore we send the package to Hugh Thompson there are a couple issues that need to be addressed. The first one is on page 44 of the FRN. It deals with Carol 11 arcus' comment that we should delete requirement to comply with 40 CFR 190 in Part 20. More needs to be stated here. Suggest you go to Kitty for help here.

We need to clearly tell her why we're not going to delete it. I don't know the correct citation on why it is in our regs, but we need to say more than just that we deny the request.

- On page 41 of the FRN, near bottom of page, you make a statement that I believe comes from the guide with the word "must" in the sentence. If we are using "must" here it needs to reference the requirement in the rule. I didn't see such a prescriptive requirement in the rule language and suspect that it's used this way in the reg guide. I first noticed the sentence in the middle of the -

paragraph that says, ". . . when the external dose to others from release of a

-patient doesn't meet the assumptions in 35.75(c) the licensee will need a record of release time to demonstrate that the release criterion has been met." 35.75 says only to keep record of basis for release. We need to be careful with what is required via a rule and what is " required" via reg guide. I did not review the reg guide in detail but think it may go to far in some of these areas.

Last item - don't forget to . check the number of records 10,000 vs.17,000.

Thanks, Cheryl CC: jeg,NKS e

9708150124 970007 PDR PR 20 62FR4120 PDR

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