ML19323D313
| ML19323D313 | |
| Person / Time | |
|---|---|
| Issue date: | 04/25/1980 |
| From: | Dennis N NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | Erlich G NATIONAL INSTITUTE OF STANDARDS & TECHNOLOGY (FORMERL |
| References | |
| FRN-45FR20493, RULE-PR-20 NUDOCS 8005210422 | |
| Download: ML19323D313 (2) | |
Text
.
e s
NOTE TO: Document Control Room 016
- hvCL, zy Qs
% b w p u h. h < b.
C 3 5 9 n o').
Please place'the attached document in the PDR using the following file.and file points:
PDR File Related Documents (SelectOne)
(Enter if appropriate)
Proposed Rule (PR)
ACRS Minutes No.
i Reg. Guide Proposed Rule (PR) l Draft Reg. Guide Draft Reg. Guide Petition (PRM)
Reg. Guide Effective Rule (RM)
Petition (PRM)
Effective Rule (RM)
Federal Register Notice l
SD Task No.
l NUREG Report Contract No.
l
Subject:
M,3 Mo%M bn,, p QS A?o b Sh DMn n 0, f(.
9 N.
um e
O w
I
['}
C' 8 005 210 Y2. 2 l
e
J 1
APR 2 519e0 Dr. Greta Ehrlich U.S. Department of Connerce Nations 1 Bureau of Standards Washington, D. C. 20234
Dear Dr. Ehrlich:
As you are aware, the NRC has recently published for coment ait advance notice of rulemaking on the subject of certification of personnel dosimetry processors. The advance notice clearly states the Government's cc=mittment to introduce regulatory changes to 10 CFR Part 20 intended.to.icarove the accuracy and consistency of dosimetry data used in making occupational dose assessments. The advance notice suggests the possibility that the proposed rule will require that dose estimates will cnly be acceptable to the NRC if performed by certified dosimetry processors. The revised Health Physics Society Standards Committee (HPSSC) standard will be recommended to the Commission, possibly in modified form, as the basis for the certification program.
An item of major concern to the NRC staff is the adoption of conversion factors which relato low-energy choton exposure (R) to dose equivalent index (rem). The conversion factors (Cx values) were recently measured at Battelle Pacific ?!orthwest Laboratories and reported in MUREG/CR-1057. As you are aware, significant differences exist between the Cx values modelled and accepted by your revised !!PSSC standard working groue and those measured at Battelle, particularly the 16, 78, and 100 key k-fluorescence measurements.
The values chosen will influence the magnitude of assigned occupational dose equivalents for some workers and thus could have considerable impact.
In the near future the staff will recocmend to the Commission proposed amendments to 10 CFR Part 20; in the develooment of the proposed acondments we will have to make a decision as to whether to recommend the Cx values in the revised stanocrd or the values determined at Battelle.
In making this decision we would like to take full advantage of your views as to why the values from the stancard should be used, rather than those measured at l
Battelle. Since you recently agreed to provide a justification of this l
nature, we are rcquesting it at this time.
Sincerely, ilwe Nancy Dennis Occupational licalth Standards Branch Office of Standards Development e
9
, - - - -