ML20137Q742

Forwards marked-up N Mcelroy 820226 Draft Rev to 10CFR35. Changes Provide Advantage of Objectivity.Review Guided by Considerations of Legal Proprietary

ML20137Q742
Person / Time
Issue date:	03/26/1982
From:	Klucsik J NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	Walker B NRC
Shared Package
ML20136D915	List: ML20136D909 ML20136E266 ML20136E272 ML20136E278 ML20136E295 ML20136E318 ML20136E323 ML20136E492 ML20136E705 ML20136E879 ML20136F099 ML20136F109 ML20136F154 ML20137Q526 ML20137Q531 ML20137Q538 ML20137Q545 ML20137Q557 ML20137Q566 ML20137Q572 ML20137Q579 ML20137Q585 ML20137Q596 ML20137Q605 ML20137Q644 ML20137Q655 ML20137Q660 ML20137Q671 ML20137Q682 ML20137Q688 ML20137Q690 ML20137Q692 ML20137Q695 ML20137Q697 ML20137Q705 ML20137Q710 ML20137Q715 ML20137Q719 ML20137Q721 ML20137Q724 ML20137Q726 ML20137Q734 ML20137Q742 ML20137Q747 ML20137Q760 ML20137Q766 ML20137Q777 ML20137Q783 ML20137Q791 ML20137Q796 ... further results
References
FRN-50FR30616, RULE-PR-35 AA73-1, NUDOCS 8509230239
Download: ML20137Q742 (1)

Text

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MAR 2 g 199g 7[Vgh NOTE T0: Bill Walker FROM: John Klucsik, ELD RE: Revision of Part 35, Recommended Changes to Feb. 26 Draft Attached is a marked up copy of Norm McElroy's February 26, 1982, draft of the Revised Part 35. Accompanying that markup is a set of 8 1/2" x 14" pages which contain changes to the draft which Tom Dorian and I recommend.

j In some cases these changes are required to clarify what would otherwise be an unenforceably vague rule. In other cases we have made suggestions which we believe improve a legally sufficient, but difficult to understand

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structure. By reading through the Feb. 26 draft and making reference to the 81/2" x

14" pages as indicated in the marginal notes to the draft, you will find our

. editorial recommendations include minor changes requiring only the insertion '

or deletion of a few words and those requiring major revisions to a section or subpart.

Approaching the Feb. 26 draft as strangers to the details of byproduct materials use in private medical practice and in the institutional setting could in some cases be a handicap. In this case, however, we believe our

perspective on the proposed rule provides the advantage of objectivity, uninfluenced by any preconceptions which might arise from a more intimate association with the practice or regulation of radiodiagnostics or radiotherapy. Our review has been guided by considerations of legal propriety, the need for a clear relationship between the provisions of the rule and radiation safety, and the need for clarity in the meaning of the proposed rule.

As we discussed in our-last meeting, both Tom and I will be available to meet with you and the members of the task force who have been most active in i the preparation of the draft to discuss these recommended revisions. In the meantime, if you have any questions on the attached materials or any other topic with respect to the Part 35 project, please do not hesitate to call.

M John F. Klucsik Attorney, OELD

Attachment:

As stated.

cc: J. R. Cook D. Bozik N. McElroy T. Dorian 8509230239 850906

' PDR 7 M ao616