ML19242C959
| ML19242C959 | |
| Person / Time | |
|---|---|
| Issue date: | 04/26/1979 |
| From: | Minogue R NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | |
| Shared Package | |
| ML19242C960 | List: |
| References | |
| SECY-79-294, NUDOCS 7908140257 | |
| Download: ML19242C959 (50) | |
Text
p c N e u c M L.:n m April 25,1979 SECY-79-294 UNITED STATES NUCLEAR REGULATORY COMMISSION CONSENT CALENDAR ITEM For:
The Commissioners From:
Robert B. Minogue, Director, Office of Standards Development
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Thru:
Executive Director for Ocerations'
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Subiec*:
REDUCTION OF RADICGRAPHY OVEREXPOSURES Purcose:
To obtain Commission approval to publish amendments to 10 CFR Part 34 as a final rule intended to improve radiography safety and make the regulations on radiography more comcatible with current licensing practices.
Discussion:
In SECY-78-57, " Reduction of Radiography Overexposures " the staff presented the Commission with five actions that could potentially reduce the rate of overexposures among radiographers.
One of these actions was to amend 10 CFR Part 34, " Licenses for Radiography and Radiation Safety Requirements for Radiograchic Operations."
That action is the subject of this paper.
A status report on the other 4 actions is presented in Enclosure "G" The amendments to 10 CFR Part 34 would require several changes in safety procedures intended to improve radiography safety.
How-ever, it is recognited that tne amencments will not eliminate radiography overexposures.
The proposed amendments, which were contained in SECY-78-57, were approved by the Commission and published for public comment on March 27, 1978.
Comments were received from 49 persons.
An analysis of tne public comments is presented in Enclosure "C" The two procosed amencments most strongly opposed were (1) the definition of the sucervision : raciograoner mus gi /e to an assistant raciograoner and (2) an exolicit recuire'ent on surveying tne bouncaries of restricted areas.
Wita respect to the suoervision cuestion, commenters cointec cut tnat the proposed cefinition of suoervision woulc crevent an assistant raciogracner from incecencently concucting surveys of restrictec area bouncaries.
The commenters saic :na. an assistant could readily be trained to make sucn surveys comcetently anc :nat sucn surveys are not critical for preventing averexcosures.
7he staff agrees tnat an assistant raciogracner sncula ::e able to survey restricted area boundaries sitnout ::eing 4atcned.
The wording of the amencment was changec to limit tre recuirement
-for watching the assistant curing surveys to tnat survey per-formed to sncw that tne radioactive source has been returned to its shielded position in the raciograpnic exposure cevice.
The
Contact:
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li0 9 Stephen A. McGuire, SD e 'l
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The Commissioners 2
staff believes that requiring the radiographer to watch the assistant during this survey is critical to safety.
Direct observance is not critical for othe.' surveys.
With respect to surveys, commenters also said the explicit require-ment to survey restricted area boundaries was too inflexible, could increase radiation exposure in many instances, and would be very time consuming and burdensome in many cases.
The staff agrees with these comments.
The proposed amendment removed a great deal of flexibility as to when and how a restricted area survey shoulo be made.
Therefore this amendment has been deleted.
The requirement to survey the boundary would continue to be based on the general Part 20 requirements.
In response to other comments, some of the other amendments have been slightly revised.
The wording of the effective rule is con-tained in the attached F.deral Registe,' Notice (Enclosure "A").
A value/ impact statement'on the amendments is provided in Enclosure "D".
Recommendation:
That the Comnission:
(1) Aoprove publication of the amendments in Enclosure "A";
(2) Note:
(a) That the amendments will be effective in six months; (b) These amendments will have virtually no manpower or dollar costs to the NRC.
Licensing should be made slightly easier for the staff because correspondence on some of these issues should be reduced.
Inspections should be completed in the same time as before.
(c) That in accordance with 10 CFR 51.5(d)(3), neither an environmental imcact statement nor a negative declara-tion need be prepared since the amendments are non-substantive and insignificant from the stanccoint of environmental impact; (d)
That the Succommittee on Energy and the Environment of the House Interior and Insular Affairs Committee, the Subcommittee on Energv and Power of the House Committee on Inter tate and Foreign Commerce, and the Subcommittee on Nuclear Regulation of the Senate Committee on Environment and Public Works will be informed by a letter such as Enclosure "F";
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. (e) That a public announcement sc:h as in Erclosure "B" will be issued when the amencments are filed with the Office of the Federal Register; (f) That each NRC radiography licensee will be mailed a copy of the Federal Register notice; (g) That clearance of the recordkeeping requirements by the General Accounting Office will be obtained prior to the ule becoming effective; and (h) A recordkeeping justification analysis is attached as Enclosure "E".
Coordination:
The Offices of Nuclear Material Safety and Safeguards, Inspection and Enforcement, State Programs, and Adtcinistration concur in the recommendations of this paper.
The Offices of the Executive Legal L' rector and General Counsel have no legal objection.
The Office of Policy Evaluation recommended that "the Commission should act favorably on the proposed final rule as a significant step toward reducing the frequency of radiography overexposures,"
but expressed dissatisfaction with the pace of completing other related actions.
The OPE memorandum is attached as Enclosure "H";
Enclosure "G" has been revised to include target dates for related actions as OPE requested.
The Office of Management and Program Analysis has reviewed the Value/ Impact Statement.
The Paperwork Reduction Subgroup has reviewed the recordkeeping requirements.
The Office of Public Affairs wrote the draft public announcement.
Anticioated Schedulina:
For affirmation at an open meeting.
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Robert.3. Minogue, Director Office of Stancards Develocment
Enclosures:
"A"
- Feceral Recister Notice "B"
- Puolic Announcement "C" - Analysis of Public Comments on Proposed Amendments of 10 CFR Part 34 "D" - Value/ Impact Statement on Amendments of 10 CFR Part 34 "E"
- Recordkeeping Justification "F"
- Draft letter to Congressional Committees "G"
- Status of Actions Dealing with Industrial Radiography "H" - OPE Commencs (i b, e
_4 Commissioners' comments or consent should be provided directly to the Office of the Secretary by c.o.b. Wednesday, May 9, 1979.
Commission Staff Office comments, if any, should be subnitted to the Commissioners NLT May 3,1979, with an information copy to the Office of the Secretary.
If the paper is of such a nature that it requires additional time for analytical review and comment, the Commissioners and the Secretariat should be apprised of when comments may be expected.
This paper is tentatively scheduled for affirmation at an Open Meeting during the Week of May 21, 1979.
Please refer to the appropriate Weekly Commission Schedule, wnen published, for a specific date and time.
DISTRIBUTION:
Commissioners Commission Staff Offices Exec. Dir. for Opers.
Regional Offices ACRS ASLBP ASLAP Secretariat 41 (sr
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