ML19242C965
| ML19242C965 | |
| Person / Time | |
|---|---|
| Issue date: | 04/26/1979 |
| From: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| To: | |
| Shared Package | |
| ML19242C960 | List: |
| References | |
| SECY-79-294, NUDOCS 7908140268 | |
| Download: ML19242C965 (18) | |
Text
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[7590-01]
Title 10 - Energy CHAPTER I - NUCLEAR REGULATORY CCMMISSION PART 34 - LICENSES FOR RADIOGRAPHY AND RADICGRAPHY SAFETY REQUIREMENTS FOR RADIOGRAPHIC OPERATIONS Amendments of Radiography Regulations AGENCY:
U.S. Nucleat Regulatory Commission.
ACTION:
Final rule.
SUMMARY
The Nuclear Regulatory Commission is publishing as effec-tive rules several changes in its regulations on industrial radiog-raphy.
The rule changes were originally published for public comment on March 2, 1978, and have been revised after consideration of the comments received.
These amendments require several procedural changes intended to improve radiography safety.
The changes are also intended to formalize as regulations current licensing practices.
The amend-ments apply to industrial radiograchy operations uring radioactive isotope sources licensed by the Nuclear Regulatory Commission.
dFFECTIVE DATE:
(6 months from publication date).
NOTE:
The Nuclear Regulatory Commission has submitted this rule to the Comptroller General for such reviews as may be appropriate under the Federal Reports Act, as amended, 44 U.S.C. 3512.
The date on 1
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which the reporting requirement of this rule becomes effective, unless advised to the contrary, accordingly reflects inclusion of the 45-day period which that statute allows for such review (44 U.S.C. 3512(c)(2)).
FOR FURTHER INFORMATION CONTACT:
Dr. Stephen A. McGuire Office of Standards Development U.S. Nuclear Regulatory Commission Washington, D.C.
20555.
(301-443-5970)
SUPPLEMENTARY INFORMATION:
On March 27, 1978, the Nuclear Regulatory Commission published for public comment amendments to Part 34 of its regulations (43 Federal Register 12715).
Forty-nine public comments were received.
In response to thase comments, some of the proposed amendments have been deleted or substantially reworded.
The individ-ual amendments are discussed by section belnw.
6 34.2 New definitions for " source changer," now used in g 34.22 and s 34.28 and " permanent radiographic installation," now used in 5 34.29, are given.
s 34.ll(d)
The proposed amencment specified that internal inspections would be required at intervals not to exceed three months.
The predominant comment was that this frequency was too restrictive.
The NRC believes the proposed frequency is appropriate in view of the importance of management audits of radiographer performance.
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The NRC has :onsistently observed that a strong management commitment to safety is necessary if radiographic operations are to be conducted safely.
Frequent checks of the performance of radiographers are a necessary part of that commitment.
The effective rule therefore retains the proposed frequency for internal inspections.
9 34.22 The proposed amencment specified securing (not necessarily locking) the sealed source in its shielded position in crankout radiographic exposure cevices each time the source is returned to that position.
Some commenters questioned the effectiveness of such a recuirement.
Other commenters thought the requirement should not be limited to crankout devices only.
On consideration, the NRC believes the small effort to secure the source is worthwhile since this prevents the source from moving out of its shielded position if the device or the crank is moved.
The NRC also has extended the requirement to devices other than crankout devices since the safety considerations with such devices are similar to those for crankout devices.
? 34.28 The proposed amendment specified that radiographic exposure devices, storage containers, and source changers be maintained at intervals not to excced three months.
The main comment was that this scnedule was too restrictive.
The NRC agrees that more flexi-bility in scheduling can be permitted with little or no loss in 3
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effectiveness of the regulation.
In response the schedule is changed to "at intervals not to 'xceed three months or prior to the first use thereafter." This allows somewhat more flexibility for equipment which may be used only infrequently.
j 34.29 The proposed amendment specified the requirement of audible and visible alarms on entrances to permanent radiographic installations.
Commenters did not object particularly to having the alarm.
- However, commenters objected strongly to requiring that the alarm alert another individual besides the individual attempting entry.
The NRC agrees that warning another individual is not necessary for radiography sources if other means of limiting access of unauthorized personnel are provided.
The rule has been rewritten so that a second person besides the radiographer is not required if the licensee cho, sis to limit access of unauthorized personnel into the high radiation area by locking or maintaining direct surveillance as required by s 20.203(c)(2)(iii) or (4) and s 34.41.
Note that personnel access may be controlled by direct surveillance under S 20.203(c)(4) since a permanent radiographic installation coes not mean that there is a permanent hign raciation area (i.e., 30 days or more).
Some commenters objected to not allowing an automatic source retraction device to substitute for the alarm.
As written in effective form, the new s 34.29 allows an automatic source retraction device to substitute for the alarm system.
If the installation has a source 4
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retraction device meeting the requirements of S 20.203(c)(2)(i),
6 34.29 does not apply.
Other commenters objected to not allowing locked entrances to the installation as a substitute for the alarm.
The NRC does not agree with this comment.
Many overexposures have occurred when a radiographer unlocked the door to an installation and approached an exposed source without using a survey meter.
Therefore, permanent installations must have an alarm even if locking of all entrancas is planned.
It should be noted that the alarm system required in 9 34.29 is aimed more at protecting the radicaracher nimself than at unauthorized personnel.
For this reason, the equirements in g 20.203(c) and 9 34.41 on presenting such access by unauth rized personnel remain completely unchanged.
@ 34.31 The amendment proposed to require written and field examina-tions for both radiographers and radiographers' assistants.
The comment was made that oral examinations should be adequate for raciographers' assistants.
In view of the high degree of super-vision required for an assistant in the new s 34.44, the final rule has been cnanged to permit oral testing of assistants.
The final rule also requires that ccpies of written tests and the dates of oral and field examinations be retained for three years.
9 34.33 The NRC proposed to amend 5 34.33 to require annual accuracy checks on pocket dosimeters, with a +30% accuracy criterion.
The 5
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NRC also proposed to state that after an individual's pocket dosim-eter had gone off-scale, the individual would be prohibited from further radiographic operations until the magnitude of the exposure had been evaluated.
Commenters said the accuracy check has little purpose at would not recuce radiation exposures.
The NRC now believes that since the pocket dosimeters are being manufactured to the stringent requirements of American National Standard N13.5-1972, " Performance Specifications for direct Reading and Indirect Reading Pocket Dosimeters for X-and Gamma Radiation," that the proposed regulation is not necessary, parti-cularly since defects in the dosimeters are generally either in a safe direction or else render the dosimeter completely unusable.
Commenters strongly objected to requiring that an individual with an off-scale dosimeter be removed from work since such action would be very costly and since dropping causes most dosimeters to go off-scale.
The NRC has decided to delete this proposed require-ment since it would do little to improve worker safety because the worker would not be restricted from work until after the expnsure had alreacy occurred.
In addition, it would be quite burdenseme.
Licensees should note, however, that under s 20.201, " Surveys," they are recuired to make evaluations of the radiation nazards incident to tne use of a radioactive source.
Thus it is required 1 hat the licensee evaluate the situation to determine the cause of the off-scale dosimeter before allowing the worker to.esume work in a restricted area.
If an over-exposure has occurred, the important thing is to correct the hazard to prevent a repeat of the incident.
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9 34.41 The existing wording of this section will not be changed.
The proposed wording would have eliminated locking of doors as a substitute for direct surveillance to prevent unauthorized personnel from entering high radiation areas.
The comment was made that locking is a very practical means of limiting access by unauthorized personnel in many instances such as shipbuilding.
The NRC agrees that locking can be more effective than direct surveillance in preventing unauthorized entry into a high radiation area.
In many cases, such as areas that have multiple entry points, a momentary lapse of attention could allow someone to walk into the high radiation area unnoticed.
Locks are a mechanical means not dependent on the constant attention of the radiographer.
Therefore, the NRC will permit locking as an acceptable alternative.
The section therefore will not be changed.
@ 34.43 The proposed amendment of this section explicitly stated that the radiation survey to determine that a sealed source has returned to its shielded position after a radiographic exposure must irclude a survey of the source guide tube.
Commenters sa that sucn action is impractical in some situations, for example, when the cable runs tnrough a shielded wall as in a permanent installation, througn concuits between different areas, or when the device or guide tuce is suspended on scaffolding.
The NRC recognizes that sometimes the entire guide tuce
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may not be accessible and that thue are other survey techniques to demonstrate adequately that the source has returned to its shielded position.
The requirement to survey the guide tube does not mean that inaccessible portions must be surveyed.
For example, if the guide tube runs through a thick concrete wall at a shielded facility, one need only survey to the wall.
There would be no need to pull the guide tube out of the wall to make the servey.
If the guide tube runs through a cable tray in a submacine under construction, it is only necessary to survey to the point where the guide tube enters the wall.
If the guide tube is suspended on a scaffold, it is not necessary to climb up to the guide tube.
The survey can be made frca the ground.
A requirement to survey the entire circumfs-rence of the radio-graphic exposure device remains.
This requirement means that the survey instrument should completely circle the device, especially the front of the device.
It does not mean that the bottom of the device need be surveyed.
The proposed amendment of this section would also have adced a specific requirement for surveying the perimeter of the restricted area.
Numerous c0mmenters said tnat the proposed wording was too inflexible for many situations, too vague, and potentially hazardcus.
The NRC has accepted this view.
The requirement to survey restricted area boundarys will remain within the more general requirements of 5 20.201, " Surveys." The proposed change is deleted.
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9 34.44 The proposed amerdment defined in 6 34.2 the supervision that a radiographer must give a radiographer's assistant.
This proposed chr.ng' met with stronger opposition than any other of the proposed changes.
Many commenters expressed their belief that radicgraphers' assistants should be allowed to conduct routine surveys such as those of restricted area and radi4 tion area boundaries without being watched by a radiograuher.
The NRC agrees that an assistant radiog-rapher can quickly be trai. ad to use a survey meter competently and can safely perform many of the less critical surveys, such as a survey of the boundity of the restricted area.
The NRC also recog-nizes th.at prohibiting an assistait from independently performing such surwys would greatly decrease the usefulness of the assistant and place a large economic burden on licensees.
Therefore, the amendment has been reworded so that tne only survey during which the radiograpMr must watch the assistant is the survey to de:armine that the sealed source has returned to its shielded position after use.
The rau ographer should be watching the assistant to the extent that he is able to see tnat the assistant is carrying out his assigned functions in accordance with the instruction he has received.
The requirements are being placed in a new $ 34.44 It is more accropriate to include these requirements in a new section rath_
than with the definitions ia 5 34.2 as was proposed.
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Accendix A No commenters objected to a proposed requirement that radiog-rapners be instructed in case histories of radiography accidents.
A recent NRC report, NUREG-0495, "Public Meeting on Radiation Safety for Industrial Radiographers," discusses such case histories.
Anyone wishing more detail on the development of these amend-ments may obtain an " Analysis of Public Comments on Proposed Am.end-ments of 10 CFR Part 34" or a "Value/ Impact Statement. on Anendments of 10 CFR Part 34" by writing to Dr. Stephen A. McGuire, Occupational Health Standards Branch, Office of Standards Development, U.S.
Nuclear Regulatory Commission, Washington, D.C. 20555 within twelve months of this notice, or writing the NRC's Public Document Room thereafter.
In addition, a complete set of the public comments is available for inspection in the Public Document Room.
Pursuant to the Atomic Energy Act of 1954, as amended, the Energy Reorganization Act of 1974, as amended, and Sections 552 and 553 of Title 5 of the United States Code, the following amendments of Title 10, Chapter I, Code of Federal Regulations, Part 34 are published as a document subject to codification.
1.
New paragracns (g) and (b) are added to read as follows:
s 34.2 Definitions.
x x
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(g)
" Source changer" means a device designed and used for replacement of sealed sources in radiographic exposure devices, including those also used for transporting and storage of sealed sources; (h) " Permanent radiographic installation" means a shielded installation or structure designed or intended for radiography and in which radiography is regularly performed.
2.
Paragraph (d) of 34.11 is amended to read as follows:
& 34.11 Issuance of specific licenses for use of sealed sources in radiocrachy.
n x
x x
x (d) The applicant will have an internal inspection system adequate to assure that Commission regulations, Commission license provisions, and the applicant's operating and emergency procedures are followed by radiographers and radiographers' assistants; the inspection system shall include the performance of internal inspec-tions at intervals not to exceed three months and the retention of records of such inspections for two years; 3.
Section 34.22 is amended to read as follows:
$ 3a.22 Lockina of radiograchic exoosure devices, storace containers, and source changers.
(a) Each radiographic exposure device shall have a lock or outer locked container designed to prevent unauthorized or accidental 11 Enclosure "A"
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removal of the sealed source from its shielded position.
The exposure device or its container shall be kept locked when not under the direct surveillance of a radiographer or a radiographer's assistant or as other-wise may be authorized in g 34.41.
In addition, during radiographic operations the sealed source assembly shall be secured in the shielded position each time the source is returned to that position.
(b) Each sealed source storage container and source changer shall have a lack or outer locked container designed to prevent unauthorized or accidental removal of the sealed source from its shielded position.
Storage containers and source changers shall be kept locked when containing sealed sources except when under the direct surveillance of a radiographer or a radiographer's assistant.
4.
Section 34.28 is amended to read as follows:
6 34.28 Insoection and maintenance of radiographic exposure devices, storage containers, and source changers.
(a) The licensee shall check for obvious defects in radiographic exposure devices, storage containers, and source changers prior to use each day the equipment is used.
(b) The licensee shall conduct a program for inspection and maintenance of radiographic exposure devices, storage containers, and source changers at intervals not to exceed three months or p ior to the first use thereafter to assure proper functioning of components important to safety.
Records of these inspections and maintenance shall be kept for two years.
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5.
A new @ 34.29 is added to read as follows:
6 34.29 Permanent radiocrachic installations.
(a) Permanent radiographic installations having high radiation area entrance controls of the types described in @ 20.203(c)(2)(ii),
(2)(iii), or (4) shall also meet the following special requirement.
(b) Each entrance that is used for personnel access to the high radiation area in a permanent radiographic installation to which this section applies shall have both visible and audible warning signals to warn of the presence of radiation.
The visible signal shall be actuated by radiation whenever the source is exposed.
The audible signal shall be actuated when an attempt is made to enter the instal-lation while the source is exposed.
(c) The alarm system shall be tested at intervals not to exceed three months or prior to the first use thereafter of the source in the installation.
Records of the tests shall be kept for two years.
6.
Section 34.31 is amended to read as follows:
s 34.31 Trainina.
(a) The licensee shall not permit any indivicual to act as a radiographer until such individual:
(1) Has been instructed in the subjects outlined in Acpencix A of this part; (2) Has received copies of and instruction in NRC regulations contained in this part and in the applicable sections of Parts 19 and 13 Enclosure "A" hlb Obi
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20 of this chapter, NRC license (s) under which the radiographer will perform radiography, and the licensee's operating and emergency procedures; (3) Has demonstrated competence to use the licensee's radio-graphic exposure devices, sealed sources, related handling tools, and survey instruments; and (4) Has demonstrated understanding of the instructions in this paragraph (a) by successful completion of a written test and a field examination on the subjects covered.
(b) The licensee shall not permit any individual to act as a radiographer's assistant until such individual:
(1) Has received copies of and instruction in the licensee's operating and emergency procedures; (2) Has demonstrated competence to use, under the personal supervision of the radiographer, the radiographic exposure devices, sealed sources, related handling tools, and radiation survey instru-ments that the assistant will use; and (3) Has demonstrated understanding of the instructions in this paragraph (b) by successfully completing a written or oral test and a field examination on the subjects covered.
(c) Records of the above training, incluaing copies of written tests and dates of oral tests and field examinations, shall be main-tained for three years.
7.
Section 34.43 is amended to read as follows:
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6 34.43 Radiation surveys.
(a) At least one calibrated and operable radiation survey instrument shall be available at the location of radiographic opera-tions whenever radiographic operations are being performed.
(b) A survey with a radiation survey instrument shall be made after each radiographic expasure to determine that the sealed source has been ret:trned to its shielded position.
The entire circumfer-ence of the radiographic exposura device shall be surveyed.
If the d
radiographic exposure device has a source guide tube, the survey shall include the guide tube.
(c) A record of the survey required in paragraph (b) shall be maintained for two years when the survey is the last survey prior to locking the radiographic exposure device and ending direct surveil-lance of the operation.
8.
A new e 34.44 is added to read as follows:
@ 34.44 Sucervision of radiograohers' assistants.
Whenever a radiographer's assistant uses radiographic exposure devices, uses sealed sources or related source handling tools, or conducts radiation surveys required by s 34.J3(b) to cetermine that the sealed source has returned to the shielded position after an exposure, he shall be under the personal supervision of a radicg-rapher.
The personal supervision shall include (1) the radiog-rapher's personal presence at the site wnere the sealed sources are being used, (2' the ability of the radiographer to give immediate 15 Enclosure "A" c'6 063
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assistance if required, and (3) the radiographer's watching the assis a,t's performance of the operations referred to in this section.
9.
Appendix A is amended to read as follows:
APPENDIX A I.
FUNDAMENTALS OF RADIATION SAFETY A.
Characteristics of gamma radiation B.
Units of radiation dose (mrem) and quantity of radioactivity (curie)
C.
Hazards of exposure to radiation D.
Levels of radiation from licensed material E.
Methods of controlling radiation dose 1.
Working Time 2.
Working distances 3.
Shielding II.
RADIATION DETECTION INSTRUMENTATION TO BE USED A.
Use of radiation survey instruments 1.
Operation 2.
Calibration 3.
Limitations B.
Survey techniques C.
Use of personnel monitoring equipment 1.
Film badges and thermoluminescence dosimeters 2.
Pocket dosimeters 16 Enclosure "A"
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III. RADIOGRAPHIC EQUIPMENT TO BE USED A.
Remote handling equipment B.
Radiographic exposure devices C.
Storage containers IV.
INSPECTION AND MAINTENANCE PERFORMED BY THE RADIOGRAPHERS V.
CASE HISTORIES OF RADIOGRAPHY ACCIDENTS 10.
The second senteace of the citation of authority is amended to read as follows:
AUTHORITY:***For the purposes of Sec. 223, 68 Stat.958 as amended; 42 U.S.C 2273 $9 34.ll(d), 34.25(c), 34.26, 34.27, 34.28(b), 34.29(c),
34.31(c), 34.33(b), and 34.43(c) issued under Sec. 1610., 68 Stat. 950, as amended, 42 U.S.C. 2201(o).
(Sec. 81, 161, Pub. L.83-703, 69 Stat. 935, 948; Sec. 201, Pub. L.93-438, 88 Stat. 1242 (42 U.S.C. 2201, 5341).)
Dated at Washington, D.C. this _ day of
, 1979.
For the Nuclear Regulatory Commission.
Samuei J. Cnlix Secretary of tne Commission 17 Enclosure "A" A ', 6 (j n b
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DRAFT PUBLIC ANNGUNCEMENT NRC AMENOS REGULATIONS ON RADIOGRAPHY The Nuclear Regulatory Commission is changing its regulations to help improve radiography safety and to make the regulations on radiography more compatibi. with current licensing practices.
The regulations apply to radiography using radioactive sources licensed by the NRC; they do not affec.t the medical or industrial uses of X-rays, which are regulated by the varicus States.
The changes, which are to Part 34 of the Commission's regulations, are:
(1) A radiographer must be physically present at the radiography site and watching when a radiographer's assistant perforns source manipulation or conducts radiation surveys to show that the source has been returned to its shielded position in the radiographic exposure device.
(2)
Internal inspections of a radiographer's regulatory performance must be conducted quarterly by the licensee.
(3) The radioactive source in a radiographic exposure cevice must be secured in its shielced position eacn time the source is returned to that position.
Radiation surveys to ensure that the radioactive source has returned to its shielded position must include a survey of the entire circumference of the device and a survey cf tne source guide tube if the device has a guide tuce.
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(4) Radiographic exposure devices must be checked for obvious damage each day before use and must be comprehensively inspected and maintained each quarter.
(5) Permanent radiographic installations must in most cases have alarms so that anyone entering the radiographic room will be warned 4# the entry is being attempted while the source is exposed.
(6) The training requirements state that a written and a field examination must be given to test radiographers' understanding of the training, that either a written or an oral test and a field examination must be given to radiographers' assistants and that records of the train-ing must Le maintained for three years.
(7) The list of subjects for training radiographers is expanded to incluce study of past radiography accidents.
The amendments will be effective on (6 months following publication in the Federal Register on
).
They were published in the Federal Register in proposed form on March 27, 1978, for public comment.
Among the changes made as a result of the comments received were:
(1) the proposed requirements were changed to allow an assistant radiog-rapher to concuct surveys of restricted area boundaries independently--
without sucervision by the raciograpner--and (2) proposed specific require-ments regarding the survey of restricted area coundaries were deleted, although the more general survey requirements in Part 20 of the regula-tions will continue to apply.
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ENCLOSURE C 3
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ANALYSIS OF PUBl.IC COMMENTS ON PROPOSED AMENDMENTS OF 10 CFR PART 34 (43 Federal Register 1271.5, March 27, 1978)
Forty nine public comments on the proposed amendments of Part 34 were received.
This is a large number of comments for an amendment which affects only industrial radiography.
The comments were generally detailed and well thought out.
Comments were received from all segments of the radiography industry, with larger radiography companies parti-cularly well represented.
A list of the commenters is at the end of the analysis.
In the discussion the comments are referred to by their number in that list.
6 34.2(d)
"(d)
' Personal supervision' of a radiogracher's assistant by a radiographer means supervision in which the radiographer is physically present at the site where sealed sources are being used and watching the assistant wnen the assistant uses radiographic exposure devices, sealed sources or related source handling tools, or radiation survey instruaents in radiography."
Public Commencs:
The proposed definition of the " personal sucervision" a radicgrarher must give an assistar.t radiographer received a fairly large numcer of coposing comments.
1 Enclosure "C" 4 2 (;
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Commenters thought an assistant radiographer should be able to conduct surveys of restricted area and radiation area boundaries witnout being watched by the radiographer (3, 4, 12, 14, 16, 17.
'4, 25, 30, 48).
They said reading a survey instrument is simple enough that it can be learned very quickly, and surveying a 2 mR or a 5 mR in an hour boundary is not particularly hazardous.
It was pointed out that with the proposed wording an assistant radiographer could still place film by himself, but he would now be prohibited from using a survey meter wnile doing so (3).
The pro-posed rule would be a hardship for jobs like shipbuilding or ship maintenance where assistants survey boundaries and maintain surveillance out of the sight of the radiographer (14, 17, 24, 48).
Commenters also thought that the proposed definition was too restriccive in that it did not allow the radiographer to take the training, experience, and competence of the assistant radiographer into account (3, 4, 14, 23, 30, 48).
Some assistant radiographers remain assistants for many years (3, 14).
Scme comments suggested the wording saying " physically present" instead of " watching" (2, 12, 16, 45).
Staff Recommendation:
The staff agrees that an assistant snculd be acle to survey restrictad area and raciation area boundaries withcut being watched.
The wording should be enanged to allcw radiographers' assistants to perform surveys without being watched, except for the surveys required in S 34.43(b) to cetermine that the sealed source has returned to its shielded position after each exposure.
2 Enciosure "C"
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It is rare for radiographers' assistants to remain assistants for many years, and when this occurs, it is usually related to some particular employment policy used by the employer to classify employees.
It is not because it takes that long to become a radiographer.
The change is being made by adding a new g 34.44 because this is really a requirement, not merely a definition.
$_34.2(h)
"(h)
" Permanent radiographic installation" means a shielded installation or structure in which radiography is regularly performed."
Public Comments:
What is " permanent"? (23)
Staff Recommendation:
The existing wording seems adequate.
No change is recommended.
S 34.ll(d)
"(d) The applicant will have an adequate internal inspection system to assure that Commission regulations, Commission license provisions, and the applicant's operating and emergency procedures are followed by radio-graphers and radiograpner's assistants; the inspection system shall incluce the performance of internal inspections at intervals not to exceed three months and the retention of records of such inspections for two years."
Public Comments:
In general, commenters objected to the procosed wording for being too restrictive and difficult to fit to the operation of specific comcanies 3
Enclosure "C" 46 072
(21, 22, 23, 25, 28, 31, 44).
Commenters said audit frequency should be in the administrative procedures (21).
" Quarterly does not fit our opera-tion since type and volume of work fluctuate considerably"(22).
"As RSO I perform a visual audit every place I go on a 365 day a year basis and take corrective action immediately; quarterly audits look good on paper and are worth about as much"(23).
"Our present audit program is every 3 months and we have found it too restrictive for effective control; an effective audit program must contain random unannounced audits"(28).
This commenter recca-mended audits "each calendar quarter." Another commenter said, "The fre-quency of management inspections should allow for the nature and the amount of radiography being performed at a given site, the findings of previous inspections at the site, the number of radiographers at the site, the experience and past performance records of the individual radiographers involved, and the anticipated duration of work at the site"(31).
Other commenters thought the internal inspections should be on the radiographers but not assistants since assistants have so little responsi-bility (25, 43).
The proposed rule was thought to be unclear with respect to whether each radiographer had to be inspected (2, 42).
Staff Recommendation:
The staff does net agree that the regulation as procosed may allow too little flexibility in scheduling because of the importance of these management audits.
The staff has consistently noted tnat a strong management commit-ment to safety is a critical factor in obtaining safe working conditions.
4 Enclosure "C" U I' l-
Operations in wnich the management actively fosters a safe workolace operate safely.
Operations in which management pays little attention to safety consistently show high accident rates.
The quarterly frequency for the internal inspections is considered appropriate based on years of observation.
The staff does not agree that a daily unrecorded inspection is really adequate.
There is no way to judge how thorough or careful it was, or even that it was done at all.
The rule does not state that each radiograpner must necessarily be inspected each quarter.
S 34.22
"(a) Each radiographic exposure device shall have a lock or outer locked container designed to prevent unauthorized or accidental removal of the sealed source from its shielded position.
The exposure device or its container shall be locked each day when its use is terminated and shall remain locked until its use is resumed.
In addition, during radio-graphic operations using crankout type radiographic exposure devices the sealed source shall be secured in its shielded position each time the source is returned to that position by lacking the exposure device or tne crankaut control or by otter suitacle means.
"(b)
Eacn sealed source storage container and source enanger shall have a lock or other locked centainer designed to prevent unauchorizec or accidential removal of the sealed sourca from its shielced oosition.
Storage containers and source changers snall be kent locked wnen containing sealed scurces exceot wnen under the direct surveillance of a raciogracner or a radiograpner's assistant."
5 Enclosure "C"
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Public Comments:
Some commenters thought the rule on securing the source would detract from proper use of the survey meter and could in some cases result in overexposures (4, 43, 47).
Others said the regulation would be unenforeacle and ineffective and should be rewritten and emchasis placed on training (4, 21, 26, 32, 43, 44).
One person said that sometimes the job can be done faster and just as safely without locking (23).
One comment pointed out that many devices can be locked with the source in the exposed posi-tion; only one type of device prevents removal of the source, and it has been criticized because it is inconvenient and unsafe in certain apclications (43).
Some commenters thought that securing the source should apply to all devices, including pipeliners (2, 3, 34, 42, 45).
One comment said the rule shou'ld be clarified to indicate that a key is not needed to secure the device (6).
Staff Recommendation:
Pipeline type devices reportedly have been involved in incidents recorted to Louisiana, and they should be included.
This requirement, similar to the requirement to survey after each radiograchic excosure, is difficult to enforce unless the inscector can observe an actual operation.
However, with such observations by an NRC inscector or in an internal comcany audit, the regulation is enforceable.
It is true tnat some devices can be locked with tne source excosec if the source or source assemoly has been disconnected from the drive caele, but this is rare.
Since 1971, among 42 radiography overexposure incicents 6
Enclosure "C"
.:0 075
reported to NRC causing whole body exposures over 5 rem or extremity exposures over 75 rem not a single one involved a source " pill" becoming disconnected from the source assembly and only three involved tne source assembly beccming disconnected from the drive cable.
Thus the number of situations where securing the source assembly would allow the source to be exposed and cause an overexposure is small.
The wording of the regulation has been changed to add " assembly" to show that securing the " assembly" is required, not securing the " pill." Also the words on " locking" were deleted so as not to imply that the " securing" requires a key.
The staff does not believe that the requirement to secure the source assembly will detract frcm making the survey.
The securing takes only a few seconds once the. radiographer has approached the exposure device as it must be in order to make the survey.
Note that a change in proposed 5 34.43(c) to reduce vagueness requires a similar change in this section.
Therefore, locking will be a requirement when " direct surveillance" is ended rather than "each day when its use is terminated."
i 31.23
"(a)
The licensee shall check for ocvicus defecca in radieg-racnic exposure devices, storage containers, and source cnangers prior to use each cay the equipment is used.
"(b)
The licensee 3nall conduct a program for inspection anc maintenance of radiographic exposure devices, storage containers, and source changers at intervals not to exceec tnree acnths to 7
Enclosure "C"
/> ' (.
OT6
assure proper functioning of comoonents important to safety.
Records of these inspections and maintenance shall ba kept for two years."
Public Comments:
One commenter objected to routine quarterly maintenance saying, "We have done more damage and caused more problems by our maintenance than has been gained.
When a problem develops the problem is fixed.
What is gained by working on a good smooth working device?" (23).
Some commenters thought the schedule was too restrictive, especially for equipment that might not be uced during a quarter (25, 31, 36, 46).
Some thought the inspections should be required for controls and guide tubes as well (32, 43).
Some thought the requirement involved too much record keeping (21, 23).
One comment suggested delet' ion of the word " obvious" in paragraph (a)
(2).
Another commenter said that use of defective equipment should be prohibited until it is repaired (43).
Staff Recommendation:
To provide for seldom used equipment reword the scheduling to "at intervals not to exceed three months or prior to the first use thereafter."
There should be little chance of doing more harm than gccd if the mainten-ance is cone in accordance with the manufacturer's recommencations.
s 3a.29 "Each entrance to a permanent radicgraonic installation shall have visible and audible warning signals.
The visible signal shall be actuated by radiation whenever the source is exposed.
The audible signal shall be 8
Enclosure "C" U, I
actuated when an attempt is made to enter the installation while the source is exposed.
The audible signal shall warn an individual entering the installation of the hazard and shall make at least one other individual who is familiar with the activity aware of the entry.
With respect to permanent radiographic installations, this requirement supersedes the recuire-ments in S 20.203(c)(2).
The alarm system shall be tested at intervals not to exceed three months.
Records of the tests shall be kept for two years."
Public Ccements:
Numerous and diverse comments were received on this amendment, but relatively few of the comments opposed its intent.
The ccmments are numbered belcw so that they can be ccmpared with the Staff reccmmendations.
1.
One ccament objected to the alarm requirement because it would encourage dependence on the alarm instead of the survey meter with less safety as a result; the comment also said alarms fail in a nonsafe manner, wnereas a properly trained individual would be more likely to note an inoperable survey meter (2).
Another comment said people would become oblivious to the light and bu::er in short order, and that many bad over-ex;:csures have occurred at installations witn such interlocks (23).
2.
Two cements said tnat cirect surveillance of the entrance snould be an acceptacle suostitute for the alarm (18, 27).
3.
Ano'.her comment said these alarm systems were ccmolex co cesign and expensive to install and maintain (21).
9 Enclosure "C"
{' ? N 0?O
4.
Several comments opposed requiring that the alarm alert both the individual attempting to enter the installation and at least one other individual, saying that it in effect creates a two man team rule for such installations (5, 24, 25, 26, 46).
5.
Some comments stated that their installations had large equipment entrances which are locked from the inside after the equipment is brought in.
They said alarms should not be required on these entrances (17, 37).
6.
Several ccmments objected to not allowing autcmatic retraction devices as described in S 20.203(c)(2)(i) (24,32, 37) or locking to control access as described in 5 20.203(c)(2)(iii) (24, 32).
7 One comment objected to the alarm because at his installation the operators crank the sources from inside the vault, but behind a shielded wall, and they would thus be setting off the alarm repeatedly (6).
8.
One ccmment said they now use a short alarm at the start of each exposure to warn anyone accidently remaining in the vault.
The comment said the dual alarms could be confusing (10).
9.
One ccament said the alarm would cause difficulties for blind pecole, who are now effectively used for some very low energy raciograpny where uncovered fila is used in a darkened room (10).
10.
One ccament said it should ce accectacle to occasiona]ly use a field device in a permanent installation wncse regular source is ecuipoed with an autcmatic retraction device (37).
11.
One ccmment said that remote outdcor bay areas with no shielding should also have alarms wnen the areas are permanently established (47).
10 Enclosure "C" r; n,,
b.
12.
One comment said the test interval of "not to exceed three months" was too restrictive because they prefer to test the first weeks of every quarter, which can be slightly longer than 3 months (31); another comment said the test should not be required if the installation is not used at this frequency (36).
Staff Recommendation:
1.
Reduced reliance on the survey meter may be an occasional conse-quence of the alarm system for permanent installations.
Failure to survey would still be a violation of the regulations.
There is no intent to substitute proper surveys with the alarm.
However, it must be recognized that many radiographers do not perform the required surveys.
In a recent questionairre sent to experienced radiographers by the University of Lowell only about 1/5 of the 37 radiographers replying said they always surveyed, about 3/5 said they usually surveyed, and about 1/5 said they usually surveyed only when they were being watched.
The alarm on per-manent installations will help the substantial number of re.:iographers who do not always survey.
2.
Direct surveillance is not considered adequate for these situa-tions where an alarm system can be easily and inex::ensively installec.
Most overexacsures involve the raciogracher himself wno mistakenly enters the installation when tne source is exposec.
3.
The cost of a gamma alarm is $720 from Cosimeter Corcoration f
America or 5900 from Saird Atomic.
Installation is not difficult:
plug-ging in the unit and mounting and connecting the detector, alarm, lignt, 11 Enciosure "C"
<16 000
and door switch or photo tube.
This is not very expensive nor difficult to install.
4.
Upon reconsideration, wa,ning the "other individual" should not be necessary.
Normally the person entering will be the radiographer, the assistant, or a plant worker familiar with the purpose of the cell.
In fact, among the overexposures at permanent installations between 1971 and 1977, only radiographers, their assistants, or their helpers were involved.
(It is possible that some uncadged workers were overexposed and that this was neve: detected or reported since there were no badges to measure the dose.
The lack of this situation evar being recorted, however, dces suggest that it is rare).
It should only be necessary to alert the radiographer, who would be trained to react properly in this situation.
The section is revised accordingly.
5.
It is reasonable that la ge equipment entrances that are locked should not require alarms.
The rule should be revised to state that "Each entrance... used for personnel accass during radiographic operations" should have the alarm.
6.
Aut.:matic retraction should be an acceptable substitute for an alarm because it also avoids exposure in the case of accidental entry wnile the source is exposed.
That provision is adced.
Locking would not seem acceptable for these cases where an alarm can be easily and inex-pensively installed.
The radiographer could forget to retract tne scurce, inlock the door, and fail to use his survey metar; nerc: fore, locking will not be included as an alternative to the alarm.
12 Enclosure "C"
(, -l, U C' '
7.
Proper placement of the alarm trip would eliminate this licensee's problem.
8.
The dual alarms should not create confusion.
In both cases the alarm means the source is exposed and personnel should respond by getting out of the exposure rocm.
9.
The alarm should not cause difficulties for blind people.
It would not be a constant alarm.
It would sound only if someone tried to enter the exposure rcom while the source was exposed.
10.
It sounds reasonable to occasionally use a portable field device without an alarm in a permanent installation equipped with automatic retraction of the permanent source.
This situation, however, should be treated as a license exception because it is too complicated to deal with in the regulations.
11.
It us not intended to require alarms on unshielded installations such as large outdoor bay areas since there are no walls to limit personnel accest and channel people past alarm activators.
Such radiography should be treated as field radiography.
12.
The. coment is reasonable.
More scheduling flexibility is desirable for facilities used only occ&sionally.
The staff suggests the a! arm be tested "at intersals not to exceed tnree months or prior to its first use tnereafter."
s 34.31
"(a)
The licensee shall not permit any person to act as a radio-gracher until such person:
x x x 13 Enclosure "C" im -
"(2) Has received copies of and instruction in NRC regulations con-tained in this part and in the applicable sections of Parts 19 and 20 of this chapter, NRC license (s) under which the radiographer will perform radiography, and the licensee's operating and emergency procedures; a
- x
"(b) The licensee shall not permit any person to act as a radio-grapher's assistant until such person:
s x x
"(3) Has demonstrated understanding of the instructions in this paragraph (b) by successfully completing a written and field examination on the subjects covered.
"(c)
Records of the above training including copies of the tests shall be maintained for as long as the individual works for the 1,icensee as a radiographer or a radiographer's assistant."
Public Ccements:
Scme commenters did not want to have to issue radiograohers copies of the regulations or the license since keecing their copies up te date can be a burden if there are a large numcer of emcloyees.
They said it is management's respcnsibility to see the regulations are folicwed (24, 27).
Scme commenters thought it should be acceptable to give an oral examination to assistant radicgrarhers in view of their limited res-ponsibilities (3, 31).
One ccamenter did not think training recorcs should have to be keot for as long as the individual is an empicree (21).
14 Enc 1csure "C" (j I} ')
Some commenters thought more specific training requirements should be stated (30, 42, 44).
Staff Recommendation:
Altt'ough it can be argued that radiographers can get along without Parts 19, 20, and 34 of the regulations and can rely on the operating and emergency procedures, there is some value to their having copies of the actual wording of the regulations and the commitments the licensee has made to get his license.
In addition, posting of the regulations does not appear to be an adequate substitute for having the regulations on hand.
Understanding the regulations requires concentrated and prolonged thought and attention difficult to attain while standing at a bulletin board.
An oral examination with a record of the date snould be adequate for an assistant radiographer.
Retaining tests for 3 years would seem adequate since there is periodic retraining and presumably also retesting.
' hat someone knew more than 3 years ago has little relevance.
More specific guidance on training is appropriate for a guide and would be too inflexible for the regulations.
The Occupational Health Star.dards Branch plans to start a guide on this suoject witM n acout a year.
3 34.33(a)
"(a) The licensee snall not permit any ind:vidual to act as a radiographer or a radiographer's assistant unless, at all times during radiographic operations, each such individual mars a direct reading 15 Enclosure "C"
- ~,:
J' nO1 I'
pocket dosimeter and either a film badge or a thermoluminescent dosimeter (TLD).
Pocket dosimeters shall have a range from zero to at least 200 millircentgens and shall be recharged at the start of each shift.
Each film badge and TLD shall be assigned to and worn by only one individual."
Public Comments:
It was said that pocket dosimeters hold charge sufficiently well and can be recharged less frequently than at the start of each shift (24, 32).
Daily was recommended (24).
One comment suggested that two high range dosimeters (0-5R and 0-100R) should be required (33).
Another comment suggested restricting the range to 0-200 mR (32).
Staff Recommendation:
It is preferable for a radiographer's dosimeter to have available the full range for discharge and to have only his own expo'sure on the dosimeter.
Therefore, recharging should be dar.e at the start of shift.
There does not seem to be a real need for cdditional pocket dosimeters or restricting the range.
9 34.33(c)
"(c)
Pccket cosimeters shall be cnecked at periods not to exceed one year for cor ect response to radiation.
Acceptacle de imeters snail reac within plus or minus 30 percent of the true raciation ex::osure."
Public Comments:
Many commenters saw little pc. pose or need to check pocket cosimeters for accuracy (5, 8, 19, 25, 27, 46).
Because a film badge or TC 16 Enclosure "C" UOJ
report becomes available later on, discrepancies would show up.
- Also, the most common mode of failure is charge leakage which causes the dosimeter to read high.
This does not create a safety problem.
Dosimeters would be reported as " drifting" or " unable to hold a charge." Accuracy checks would not result in any exposure reduction.
Other commenters thought the tolerance of +30% was too wide (26, 35).
Another commenter thought sufficient notice would be required to establish an acceptable method of testing pocket dosimeters (49).
Staff Recommendation:
Commercially available pocket dosimeters are now manufactured to meet the specifications in American National Standard N13.5-1972. "Per-formance Specifications for Direct Reading and Indirect Reading Pocket Dosimeters for X-and Gamma Radiation." Manufacturers say they went to great effort to meet the standard.
This standard contains tough require-ments on ruggedness and accuracy.
The standard has been adopted by Regulatory Guide 8.4.
It would seem sufficient for radiographers to use dosimeters which meet the ANSI standard.
As acy checks are largely redundant and unlikely to result in any exposure reduction.
Ccmoarison with the regular film badge or TLD report already provides a cneck on accuracy.
The pecposed amendment should ce deleted.
! 24.33(d)
"(d)
If an individual's pocket cosimeter is discharged beyond its range, his film badge or TLD shall be immediately sent for processing.
17 Enclosure "C" r: n ?
r-i y
The individual shall be prohibited from performing radiographic operations until the magnitude of the exposure has been evaluated."
Public Comments:
Many comments opposed requiring that a radiogi ipher with a discharged dosimeter be prohibited from further work until his film badge or TLD was processed and his exposure known (1, 5, 12, 14, 16, 21, 25, 35, 38).
It was said to be costly and unnecessary to take a man off the job for 2-3 days while the badge is being processed.
Many comments though that an exception should be made when the dosimeter was just dropped.
Other commenters thought that the regulation should prohibit any further exposure to radiafion, not just exposure in radiography (2, 26).
Staff Recommendation:
To prohibit further work when a dosimeter goes off scale and there is no indication of a radiation exposure would be a costly requirement for licensees and one with little likelihood of being obeyed.
If a radiographer is in the middle of a job and his dosimeter is discharged -
perhaps after being dropped - it is very unlikely that he will stop the joo in the middle.
More likely he will ignore the off scale reading and comolete the work.
The requirement as proposed would encourage discbeying tne regulations and tnus fail to provide the licensee management with a timely notice of a possible problem.
As sucn the procosec regulation could cause more overexposures than it prevents.
Thus the procosal to prohibit further work should be witndrawn and the wording of this requirement left as is in the regulations presently.
However, the statement of considerations will explain that a licensee is 18 Enclosure "C" J
0B7 t
required under 5 20.201. " Surveys," to make an evaluation of the radiation hazards incident to the use of the radioactive source.
If an actual overexposure has occurred and the licensee has not evaluated and corrected the situation, the licensee would be subject to considerably more severe enforcement action than if the hazard had properly evaluated and corrected.
6 34.41 "During each radiographic operation not conducted in a permanent radiographic installation, the radiographer or radiographer's assistant shall maintain direct rurveillance of the operation to protect against unauthorized entry into a high radiation area, as defined in Part 20 of this chapter."
Public Comments:
A ccmm'nt suggested that locking should be an acceptable alternative e
to direct surveillance as presently allowed in the regulations (24).
In a telephone call made to emphasize their concern, the comenter said that in constructing submarines, for example, it is often possible to positively prevent access by locking doors.
If direct surveillance were substituted more personnel exposure wculd result in addition to extra cost.
Staff Recommendation:
Ucon reconsiceration of this point, there are gccc reasons to allow locking to serve as a suostitute for direct surveillance to orotect against unauthorized entry into a hign radiation area.
In general, it is more reliaole to decend on mechanical devices or engineered safeguards-than a human operator's actions.
An operator attempting to maintain surveillance 19 Encigs,u "C"
IJ o u g
over two or more entrances and simultaneously time the radiographic exposure, fill out his log, etc., can easily allow his attention to lapse for a moment.
Someone could enter the high radiation area unseen.
A lock has no such lapse of attention.
In general, such locking will be more reliable than the operator's surveillance.
The alternative of locking is consistent with the NRC's preference for relying on mechanical devices to assure safety instead of relying on proper operator action.
In addition, direct surveillance could be extremely expensive in situations where there are many entrances, which would not be guarded by one or two people.
For example, in a submarine the high radiation area could extend over several levels and many corridors.
Lacking passageways could accomplish as much as a dozen men in preventing unauthorized entry.
Similar.ituations could arise in radiography at nuclear power plants or similar industrial settings.
The staff also noted that the rule as proposed contained a major flaw.
Section 31.41 deals with the security necessary to prevent inadvertant entry into a high radiatinn area by unauthorized personnel.
This is quite separate from the question of alarms at permanent facilities; those alarms are aimed primarily at the radiographer himself.
The i 34.41 should tnerefore not ce amenced.
8 34.43(b)
"(b)
A survey with a radiation detection instrument shall be mace after each radiograchic exposure to determine that the sealed source has returned to its shielded position in the radiographic excesure device.
The 20 Enclosure "C" O: 0 -
q.
__f:
V,
entire circumference of the device srTil be surveyed.
If the radiograpnic exposure device has a source guide tube, the survey shall include the guide tube."
Public Comments:
Several commenters opposed the requirement to survey the entire length of the guide tube (3, 4, 19, 21, 23, 24, 49).
Surveying the entire length was said to be unnecessary (3, 4) needless (4), bothersome (4) and a waste of time (23).
It was said to be ineffectual and would direct attention away from getting the radiographer to survey at all (19).
One large company illustrated a survey technique which moved around the camera only, which they considered an excellent way to prove the source location (23).
A manufacturer of submarines, who telephoned to elaborate on his comments, said that the requirement caused great difficulties for them because they often run the guide tubes through conduits which were not accessible for surveys or up scaffolding where a survey of t. entire guide tube would be time consuming and dangerous (24).
Staff Recommendation:
There are adecuate survey tecnniques to detarmine that the source has returned to its shielded position wnich do not include a survey of tne entire length of the guide tuce.
However, a survey of the guice tuce can be cene cuickly and easily and can shcw the radiograoner in a very simole and unamciguous manner wnether the source is in the guide tuce.
21 Enclosure "C"
?^(
00
4 34.43(c)
"(c) When the use of a radiographic exposure device or storage con-tainer is to be terminated at the end of a work period, a survey with a radiation detection instrument shall be made of the locked radiography device or storage container to determine that the sealed source is in its shielded position.
A record of the surveys requireo by this paragraph (c) shall be kept for two years."
Public Comments:
One comment said "the end of a work period" is vague (24).
Another comment said records of this survey should not be required as the'9 is already excessive paperwork (22).
Staff Recommendation:
The term "end of a work period" is vague.
The wording should be changed to follow more closely the logic of the existing Part 34 by basing the requirement on the " direct surveillance" of the operation.
The survey at the end of work before the device is to be put in storage is important enough to require a record.
5 34.43(d)
"(d) An area survey of the perimeter of the restricted area with a radiation detection instrument shall be mace with the source excosed before or during the initial radiograchic exposure on eacn shift and wnen the source-target configuration for an exposure is suostantially different from that of the preceding exposure.
These surveys are not recuired for radiography performed in a permanent radiograpnic installation."
22 Enclosure "C"
/s ') 6 (j ') i
Public Comments:
The major objection to this change was that for many short exposures of a few minutes or less there would not be enough time for the radiog-rapher to survey the entire perimeter of the restricted area; therefore, the radiographer would have to ex:fose the source before the actual exposure (8, 13, 19, 23, 25, 32, 34, 39, 45, 46).
This was said to be an unnecessary exposure of the source which would cause more personnel exposure and result in more opportunity for accidents.
It was stated that before the exposure the radiographer will calculate the restricted area boundary.
Spot checks of the perimeter are then sufficient to verify the calculation (13).
Comments also said that "substantially different" is too vague and that radiographers are fully capable of determining when a resurvey of the perimeter is necessary (13, 23, 32, 40).
One cc= ment said records of these surveys should be required (43).
Staff Recommendation:
The staff recommends deletion of this paragraph.
As written, the regulation would cause unnecessary radiation exposure of the radiogracher, increase the opportunity for accidents, and be very time consuming anc costly with little resulting benefit.
The present Part 20 survey requirements are considered to be adequate.
Accendix A "V.
Case histories of Radiography Accicents" 23 Enclosure "C" 404
[) O ?
e.
,Public Comments:
No one opposed teaching case histories of radiography accidents that have occurred, but numerous ccmmenters thought the NRC should provide suitable study material.
Staff Recommendation:
No change in the proposed requirement.
IE has recently published suitable accident case histories in NUREG-0495.
24 Enclosure "C"
', 0,,
og, 3
U j j, m_
LIST OF COMMENTERS ON 10 CFR PART 34 AMENCMENTS PROPOSED MARCH 27, 1978 (43 FR 12715) 1.
Frank A. Malek, Jr., Training Department Manager, Gul f Nuclear, Inc., Houston, Texas.
2.
Aubrey V. Godwin, Director, Division of Radiological Health, Alabama Cepartment of Public Health.
3.
Rex E. Vincent, Radiation Protection Officer, Chicago Bridge and Iron Company, Houston, Texas.
4.
P. F. Lumbye, Manager, Product Assurance Department, Atlantic Research Corporation, Gainesville, Virginia.
5.
Carrell Pruitt, Radiation Safety Officer, Prjar Foundrf, Inc.,
Pryor, 0%1ahcma.
6.
Bruce J. Sylvester, J. G. Sylvester Associates, Inc., Rockland, Mass.
7.
Florentino F. Abrigo, Jr., Radiation Safety Officer, American X-Ray and Inspection, Inc., Farmington Hills, Michigan.
8.
Royce G. Burns, Radiation Safety Officer, Kooney X-Ray, Inc.,
Houston, Texas.
9.
William A. Mills, Director, Criteria and Standards Division, Office of Radiation Programs, U.S. Environmental Protection Agency, Wash. 0.C.
10.
James G. Stearns, Chief, Safety and Environmental Branch, Department of Energy Albuquerque Operations - Rocky Flats Area Office, Colo, 11.
Racert W. Mullins, Civilian Operations Officer, Decartment of the Army, Lane Star Army Ammunition Plant, Texarkana, Texas.
12.
Joe D. Hinton, Inscection Group Supervisor, Thicko3/ Louisiana Division, Shreveport, Louisiana.
13.
John W. Huffman, Radiation Protection Officer, The Hartford Steam Soiler Inspection and Insurance Comcany, Deep River, Connecticut.
14.
David M. Anderson, Manager, Environmental Quality Control, Bethlenem Steel Corp., Sethlehem, Pennsylvania.
15.
Thomas L. Junod, Associate Chief, Office of Eavironmental Health, NASA, Lewis Researen Center, Cleveland, Ohio.
25 Enclosure "C" bbb YlY
16.
Walter P. Peeples, Jr., President, Gulf Nuclear, Inc., Houston, Texas, 17.
J. A. Tipton, Radiation Safety Officer, Litton/Ingalls Shipbuilding, Pascagoula, Mississippi.
18.
Tcdd Wolmoth, Radiation Safety Officer, CAM Industries, Kent, Washington.
19.
Eric T. Clarke, Vice President, Technical Operations, Inc., Boston, Mass.
20.
H. Glasser, General Manager, Nuclear Associates, Carle Place, NY.
21.
William E. Morgan, Chief, Radiation Health Protection, The Boeing Company, Seattle, Washington.
22.
Clifford A. Asvitt, Director, Maintenance Inspection and Control, United Airlines, San Francisco, California, sucmitted by the Air Transport Association, Wasnington, D.C.
23.
George R. Henke, Radiation Safety Officer, Kaiser Steel, Napa, CA.
24.
J. F. Dallinger, Principal Engineer, General Dynamics Electric Boat Division, Groton, Connecticut.
25.
Otis C.
. amble, Radiation Safety Officer, Nuclear Energy Services, Inc., Conan Inspection Division, Houston, Texas.
26.
R. J. Tuttle, Manager, Radiation and Nuclear Safety, Atomics International Division of Rockwell International, Canoga Park, CA.
27.
William O. Parker, Jr., Vice President, Duke Power, Charlotte, NC.
28.
Gary R. Elder, Assistant Radiation Protection Officer, Townsend and Bottum, Inc., Ann Arbor, Michigan.
29.
Kenneth F. Sinclair, President, Xetex, Inc., Redwood City, California.
30.
Timothy C. Mather, Manager, Industrial Relations Decartment, Mcur Vehicle Manufacturers Association, Detroit, Micnigan.
31.
Bruca Kovacs, Senior Radiogracner and Corporate Radiation Safety Officer, Foster Wheeler Energy Corporation, Livingston, NJ.
32.
Michael H. Mcbley, Radiological Physicist and Joni.ny C. Graves, Radiological Physicist, Division of Radiological Health, Tennessee Department of Puclic Health.
33.
William J. Friecman, Certified Health Physicist, Healta Physics Consultants and Engineering, Sacramento, California.
/s ] I.
O') b 25 Enclosure "C"
34.
John J. Munro, III, Technical Director, Tech / Ops, Radiation Products Division, Surlington, Mass.
35.
Larry Buzan, Manager, Quality Assurance, Esco Corporation, Portland, Ore.
36.
Ronald P. DiPiazza, Manager, NES License Acministration, Water Reactor Divisions, Westinghouse Electric Corporation, Pittsburgh, Pennsylvania.
37.
A. A. Arcuni, Special Assistant for Nuclear Programs, Department of the Navy, Naval Facilities Engineering Command, Alexandria, VA.
38.
David D. Snellings, Jr., Director, Division of Radiological Health, Bureau of Environmental Health Services, Arkansas Dept. of Health.
39.
Albert J. Hazle, Director, Radiation and Hazardous Wastes Control Division, Colorado Department of Health.
40.
Johnny C. Graves, Radiological Physicist, Division of Radiological Health, Tennessee Department of Public Health.
41.
Marshall W. Parrott, Manager, Radiation Control Section, Health Division, Oregon Department of Human Resources.
42.
Aubrey V. Godwin, Director, Division of Radiological Health, Alabama Department of Public Health.
43.
Martin C. Wukasch, Director, Division of Occupational Health and Radiation Control, Texas Department of Health.
44.
Robert D. Funderburg, Supervisor, Radiation Control Section, Idaho Department of Health and Welfare.
45.
B. Jim Porter, Administrator, Nuclear Energy Division, State of Louisiana.
46.
John P. Lanham, Public Health Physicist, Radiological Health Program, Florida Department of Health and Rehacilitation Services.
47.
Nancy P. Kirner, Health Physicist, anc R. C. Will, Sucervisor, Radiation Control Program, Washington (State) Gecar: ment of Social and Health Services.
48.
J. C. McArthur, Commander, Pearl Harcar Naval Shipyard, Hawaii.
49.
R. D. Whita, Forman-Inspection and NOT, Frontier Airlines, Denver, Colo.
UYb L
27 Enclosure "C"