ML20236U626

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Comments on Advance Notice of Proposed Rulemaking, Radiation Therapy QA & Penalties for Negligence. Ofc Has No Position Re Whether Subj Document Should Be Advance Notice or Proposed Rule
ML20236U626
Person / Time
Issue date: 12/05/1986
From: Kerr G
NRC OFFICE OF STATE PROGRAMS (OSP)
To: Cunningham R
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
Shared Package
ML20235F951 List: ... further results
References
FRN-52FR36942, RULE-PR-35 AC65-1-072, AC65-1-72, NUDOCS 8712030208
Download: ML20236U626 (1)


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"'%. I'g UNITED STATES NUCLEAR REGULATORY COMMISSION g3 Ref: SA/ LAB

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MEMORANDUM FOR: Richari E. Cunningham, Director h p$

Divi'si7n' of Fuel Cycle and Material {p

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, FROM: G. Wayne Kerr, Director

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SUBJECT:

ADVANCE NOTICE OF PROPOSED RULEMAKEG:

). " RADIATION THERAPY QUALITY ASSURANCE AhD PENALTIE3 FOR NEGLIGENCE" f ' , c ,. ,

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' We have reviewed the subject document and we have no position on'whether '

, or not this should he a ANFRM vs a proposed rule. We would however ,like to offer the following comments: ,

r. 1) On page 4. Effect on Agreeme,n_t States, change the last- 'I f ' sentence to read "Thus, sta:e regulatory agencies will be l *. asked to con.nent." ,/ v

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O') , On page 4 of enclosure 1; Effect on the_Aarem_ent State Program, change the last sentence to read "NRC Mill request 4 the Agreement States to implement regulations equivalent to,

!tg  :) those that it implements, as a matter of corgatibility."

3) In: Item 5 of enclosure 8, there should be an elaboration on the' nature of the inconsistencies between a quality assurance ,

program requirement for cobalt teletherapy and the State requirements placed (' on linear accelerators

/, used fo/r therapy. t t

We appreciate the ' opportunity to rcview and omment en this propotal. ~

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<LO y G. Wayne Kety, Director S&)

,s' Office of State Programs ff i

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>, 8712030200 971201 PDR FR- ./

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