ML20198J932

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Concurs on Rulemaking Plan, Medical Use of Capsules Containing One Uci of C-14 (PRM-35-12), W/Comments
ML20198J932
Person / Time
Issue date: 08/27/1996
From: Lieberman J
NRC OFFICE OF ENFORCEMENT (OE)
To: Morrison D
NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
Shared Package
ML20013E023 List:
References
FRN-62FR32552, RULE-PR-30, RULE-PR-32 AF70-1-070, AF70-1-70, NUDOCS 9801140248
Download: ML20198J932 (1)


Text

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Oc: Morris Trottier g[oarco,%,t UNITED STATES

. . . Jones S File NUCLEAR REGULATORY COMMISSION

{ E WASHINGTON 0.C. 20Mt y

,,; . August 27, 1996 MEMORANDUM TO: David L. Morrison, Director

/} F '70- /

Office of Nuclear Regulatory Research gg FncM: James Lieberman, Director [

Office of. Enfor. cement -

SUBJECT:

CONCURRENCE ON RULEMAKING PLAN: MEDICAL USE OF CAPSULES CONTAINING ONE MICROCURIE OF CARBON-14 (14 C) (PRM-35-12)-

The Office of Enforcement (OE) concurs on the subject rulemaking plan with the following comments:

1. How many capsules will a user be able to have in possession at one cime? The 10 CFR Part 20 Appendix C limit and the 10 CFR 30.71 Schedule B limit are 100 microcuries and each capsule is 1 microcurie. Does this mean that a user could possess 199 capsules at one microcurie each?
2. The subject rulemaking plan allows for a user to be exempt from having a license under 10 CFR Part 35. It is not clear whether the proposed addition of 10 CFR 35.100 will completely address the issue and whether further changes to 10 CFR Part 30 vill be necessary, specifically 5 30.3, Activities requiring license.

Should you have any questions regarding our c>mments please feel free to contact us. The staff contact for the subject rulemaking plan is Mary L. Thomas. Sh i :an be reached at 415-2739.

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