ML19291A529
| ML19291A529 | |
| Person / Time | |
|---|---|
| Issue date: | 12/29/1977 |
| From: | Hanauer S NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Rich Smith NRC OFFICE OF STANDARDS DEVELOPMENT |
| References | |
| FOIA-79-109 NUDOCS 7905160446 | |
| Download: ML19291A529 (1) | |
Text
I J
y-24 977 r
i MEMORANDUM FOR: Ray G. Smith, Acting Director l
Division of Siting, Health and Safeguards Standards Office of Standards Develoment FROM:
Stephen H. Hanauer Technical Advisor to Executive Director for Operations l
SUBJECT:
PROPOSED AMENDMENT TO 10 CFR PART 34 h'
REF:
YOUR MEM0 DATED DECEMBER 9, 1977 h
While I have no particular quarrel with the referenced paper, I believe that the problem overall seems not to be adequately addressed.
I think the staff owes the Cormiission a discussion of the following points:
1.
Are the exposure rate and overexposure rate of radio-graphers satisfactory or is improvement needed?
If improvement is not needed, then these amendments are probably a waste of time and resources.
If improvement is needed, then these amendments are also a waste of time and resources in view of the statement (page 2 of Draft Cormiission Paper), "At best these amendments will cause a marginal improvement in radiographic safety.
2.
If improvement is not needed, then let's spend the r..
'.O resources somewhere else.
j-L*
3.
If improvements are needed, let us find out what it will take to effect an improvement, and not waste our k.
time on 30 pages of expensive paper yielding "at best w, -
a marginal improvement."
The long and short of it is that this paper reads like something E' ' '
written to crossoff a milestone in an M80 rather than something the agency needs. A higher goal should be striven for.
g' ~
DISTRIBUTION origi::bl ?! ; ed by Central Files stephen H. Ea auer SHHanauer RF Stephen H. Hanauer P
Technical Advisor to Executive Director for Operations cc:
R. Minogue C. Smith TA EDO
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12/ 29/77 730516 0$$b L'
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