ML17018A431

Comment (008) of Nima Ashkeboussi, Senior Project Manager for Radiation and Materials Safety - Nuclear Energy Institute (Nei), Regarding Individual Monitoring Devices for Industrial Radiographic Personnel

ML17018A431
Person / Time
Site:	Nuclear Energy Institute
Issue date:	01/18/2017
From:	Nuclear Energy Institute
To:
References
81FR78732, Docket No. NRC-2016-0182, PRM-34-7
Download: ML17018A431 (3)

Text

PRM-34-7 81FR78732 8 RulemakingComments Resource From: ASHKEBOUSSI, Nima <nxa@nei.org>

Sent: Wednesday, January 18, 2017 3:33 PM To: RulemakingComments Resource

Subject:

[External_Sender] Comments on Individual Monitoring Devices Petition for Rulemaking (Docket No. PRM-34-7; NRC-2016-0182)

Attachments: 01-18-17_NRC_Individual Monitoring Devices PRM.pdf January 18, 2017 Ms. Annette Vietti-Cook Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff

Subject:

Comments on Individual Monitoring Devices Petition for Rulemaking (Docket No. PRM-34-7; NRC-2016-0182)

Project Number: 689

Dear Ms. Vietti-Cook:

On behalf of the Nuclear Energy Institutes[1] members, we appreciate the opportunity to comment on the petition for rulemaking (PRM) requesting that the Nuclear Regulatory Commission (NRC) amend its regulations to authorize the use of modern individual monitoring devices for industrial radiography personnel (Docket No. PRM-34-7; NRC-2016-0182). Specifically, the petitioner seeks authorization to use enhanced electronic personnel monitoring dosimeters and dual-function alarming rate meters and electronic dosimeters. While the PRM focuses on 10 CFR Part 34, emerging monitoring technologies can be adopted by other licensees that would also benefit from revised rule language and related guidance. Therefore, in principle, we support the PRM and recommend that NRC revise the prescriptive language in Part 20 and related guidance documents, such as the NUREG-1556 Series and Regulatory Guide 8.34, to allow a more performance based approach that recognizes the use of emerging personnel monitoring technology to demonstrate regulatory compliance.

Thank you for your consideration of these comments. Please contact me if you have any questions.

Sincerely, Nima Ashkeboussi Sr. Project Manager, Radiation and Materials Safety Nuclear Energy Institute 1201 F St., NW, Suite 1100 Washington, DC 20004 www.nei.org P: 202-739-8022 M: 202-375-0490 E: nxa@nei.org 1

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[1]

The Nuclear Energy Institute (NEI) is the organization responsible for establishing unified industry policy on matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEI's members include all entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect/engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations and entities involved in the nuclear energy industry.

2

NIMA ASHKEBOUSSI Sr. Project Manager, Radiation and Materials Safety 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8022 nxa@nei.org nei.org January 18, 2017 Ms. Annette Vietti-Cook Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff

Subject:

Comments on Individual Monitoring Devices Petition for Rulemaking (Docket No. PRM-34-7; NRC-2016-0182)

Project Number: 689

Dear Ms. Vietti-Cook:

On behalf of the Nuclear Energy Institutes1 members, we appreciate the opportunity to comment on the petition for rulemaking (PRM) requesting that the Nuclear Regulatory Commission (NRC) amend its regulations to authorize the use of modern individual monitoring devices for industrial radiography personnel (Docket No. PRM-34-7; NRC-2016-0182). Specifically, the petitioner seeks authorization to use enhanced electronic personnel monitoring dosimeters and dual-function alarming rate meters and electronic dosimeters. While the PRM focuses on 10 CFR Part 34, emerging monitoring technologies can be adopted by other licensees that would also benefit from revised rule language and related guidance. Therefore, in principle, we support the PRM and recommend that NRC revise the prescriptive language in Part 20 and related guidance documents, such as the NUREG-1556 Series and Regulatory Guide 8.34, to allow a more performance based approach that recognizes the use of emerging personnel monitoring technology to demonstrate regulatory compliance.

Thank you for your consideration of these comments. Please contact me if you have any questions.

Sincerely, Nima Ashkeboussi 1

The Nuclear Energy Institute (NEI) is the organization responsible for establishing unified industry policy on matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEI's members include all entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect/engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations and entities involved in the nuclear energy industry.