ML20137R152
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( .* c 799 ROOSEVELT RoAo o, & GL EN E LLYN, ILLINolS 60137
! SEP 2 4 1982 l MEMORANDUM FOR: Richard E. Cunningham, Director, Division of l Fuel Cycle and Material Safety, NMSS FROM: Charles E. Norelius, Director, Division of Engineering and Technical Programs
SUBJECT:
PROPOSED REVISION OF 10 CFR PART 35 In response to your August 17, 1982 memorandum to James G. Keppler, we have the following comment in addition to comments submitted on earlier revisions l of the proposed rule:
Currently, Section 35.14(c) of 10 CFR Part 35 provides for the use of byproduct material under the general license in 10 CFR 31.11 for I_n n vitro uses without the filing of form NRC-483. The proposed Part 35, however, does not include such a provision. We feel that the proposed Part 35 should include this provision to alleviate unnecessary case-by-case filing of form l NRC-483's. The proposed Part 35 should stipulate, however, that any laboratory l
l l using materials under this general license should be designated by the Radia-l tion Safety Committee. This stipulation should alleviate confusion for l licensees, manufacturers, and NRC inspection staff.
3 After your staff's consideration of this comment, we concur with the sending of the rule, in its present form, for public comment.
flya k $.b n k Charles E. Norelius, Director Division of Engineering and Technical Programs cc: R. C. DeYoung, IE P. G. Norry, ADM G. H. Cunningham, ELD ,
G. W. Kerr, SP ]
Regional Administrators i
8509230415 850906 PDR PR 35 50FR30616 PDR l
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