ML19210C927
| ML19210C927 | |
| Person / Time | |
|---|---|
| Issue date: | 10/11/1979 |
| From: | Scarano R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Purple R NRC OFFICE OF STANDARDS DEVELOPMENT |
| References | |
| NUDOCS 7911200320 | |
| Download: ML19210C927 (2) | |
Text
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UNITED STATES
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s,(, '%i NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 y
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'C7 1 1 :379 l1EMORANDUM FOR: Robert A. Purple, Assistant Director Radiological Health & Safeguards Standards Office of Standards Development FROM:
Ross A. Scarano, Chief Uranium Recovery Licensing Branch Division of Waste Management
SUBJECT:
URANIUM RECOVERY LICENSING BRANCH (WMUR)
REVIEW OF DRAFT MSHA REGULATIONS Enc 1csed are our coments on tiSHA's draft regulations on occupational radiation protection of uranium mill workers. In general, MSHA should strive for more consistency with our existing regulations (10 CFR 20).
If your staff has any questions on our comments, please, have them contact fir. John Linehan of my staff.
/
,M' Ross A. Scarano, Chief Uranium Recovery Licensing Branch Division of Waste Management
Enclosure:
As stated 37 (; '
_b 7911200
a ENCLOSURE s
COMMENTS ON DRAFT MSHA REGULATIONS 1.
Page 2 - Definition of airborne radioactivity area - (ii) is much more restrictive than the definition in 10 CFR 20, which allows averaging over the number of hours in any week, not just eight (8) hours, during which individuals are in an area.
2.
Page 3 - If these regulations are to apply to mill workers, it is suggested that the words "no miner" should be changed to "no individual working in a mill".
3.
Page 3 - For both external radiation and airborne radioactivity there should be requirements to keep exposures as well as radiation levels as low as reasonably achievable as well as requirements for evaluations of engineering controls, etc. to try to keep levels below some fraction of the absolute limits.
4.
Page 3 - MPC for Th-230 rather than natural thorium should be specified.
5.
Pace 4 - Item (b) on air sampling for radon daughters reads as if, based on one sample, the concentration of radon daughters is less than or equal to 0.10 WL then no additional air sampling is necessary.
It is recommended that a minimum frequency of at least monthly be adopted.
6.
Page 5 - Paragraph (2).
It is questionable how one could determine if an employee has accumulated an exposure on the order of 1/12 of a WLJi times the number of months of exposure, if one only has to initiate recording exposures in areas in excess of 0.3 WL.
7.
Page 5 - Paragraph (4).
It is suggested that this be made consistent with 10 CFR 20 which requires personnel monitoring equipment if an individual receives or is likely to receive a dose in any calendar quarter in excess of 25% of the applicable values.
8.
Table 1 - Criteria for which personnel should submit samples for urinalysis is inconsistent witn Regulatory Guide 8.22.
In addition, there is no mention of in-vivo lung counting.
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