ML20011B177
| ML20011B177 | |
| Person / Time | |
|---|---|
| Issue date: | 03/14/1975 |
| From: | Minogue R NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | |
| Shared Package | |
| ML20011B132 | List:
|
| References | |
| FOIA-81-303, TASK-CC, TASK-SE SECY-75-098, SECY-75-98, NUDOCS 8112040365 | |
| Download: ML20011B177 (16) | |
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C fi G-March 14, 1975 j
SECY 9 8 UNITED STATES NUCLEAR REGULATORY COMMISSION
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CO_NSENT CALENDAR ITEM l
For:
The Commissioners 1
Thru:
Acting Executive Director for Operations
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Subject:
PROPOSED AMENDMENT TO 10 CFR PART 20 ON PEMNEL_ MONITORING _ REPORTS Purpose :
To recommend publication for comment of proposed amendments to 10 CFR Part 20 to extend to all NRC specific licensees requirements for submission of annual personnel monitoring reports ($20.407).
Category:
')
This paper covers a minor policy question.
Issue:
Whether the Commission should extend to all NRC specific licensees requirements for submission of personnel monitoring reports.
Decision Criteria:
1.
To assure personnel monitoring data is available in order to provide for an ef fective regulatory program.
2.
To minimize cost and burden on licensees.
Alternatives:
1.
Retain existing reporting requirements applicable to only four categories of licensees.
2.
Pursue other means of obtaining exposure data.
3.
Extend the require.*ents for annual reports (520.407) to all NRC specific licensees, retaining the existing application of requirements for termination reports (620.408) to four categories of licensees.
Discussion:
Current practice in effect since February 17, 1969, provides for reporting of dosi:aetry data from industrial ty pe licensees which are considered to involve the greatest potential for o
significant occupational exposures. These comprise about
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9 450 of a total of about 7,000 licensees. As of January 4, 1974, reporting was chanced from a requirement to report (1) either the total number of individuals for whom personnel y
monitoring was required or the total number of individuals for whom such monitoring was provided, and (2) individually Z
identified monitoring data for each individual who exceeded C
in a year an applicabic quarterly limit,.ta, a requirement for a simple annual report on all individuals for whom monitoring was required.
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The Commissioners -
The proposed amendment to 10 CFR Part 20 (Fnclosure "A")
would require extension of the reporting requirements to all (approximately 7,000) licensees.
Further discussion is set forth in Enclosure "C",
and costing information in Enclosure "D".
Alternatives:
1.
Retain existing reporting requirements, applicable to only four categories of licensees.
Pro:
(a) The four categories of licensed industrial-type activities are considered to involve the greatest potential for significant Joses.
(b) This alternative would avoid potential repetition of opposition expressed toward the originally proposed system (See Discussion, Enclosure "C").
Con: Definitive data on radiation exposures in a large segment (6,550 of 7,000 licensees) of the nuclear industry would not be available.
2.
Pursue other means of obtaining exposure data.
Pro: This alternative would avoid imposition of additional reporting requirements on licensees.
Con:
(a) Attempts to obtain data by contract with several commercial dosimetry services proved unsatisfactory.
The services under contract included too few individuals in certain types of activities to be representative.
Similar contracts with all commercial services would be costly (unquantified) and would miss licensees who conduct their own dosimetry.
(b) Assembly of data by the Office of Inspection and Enforcement would be very time consuming for inspectors. Further, comparable data would not be available because of the time sequence of inspections and the f act that many licensees are never inspected.
3.
Extend the requirements for annual reports ($20.407) to all NRC specific licensees, retaining the
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T1..e Commissioners existing application of requirements for termination reports (520.408) to four categories of licensees.
Pro:
(a) This alternative would permit evaluation of exposure trends in all licensed activities and effectiveness of the regulatory program.
(b) It would permit comparison of current exposures among types of licensee and licensees within each type.
(c) Would assist in identification of situations to be studied further to assure that sources of in plant exposure are identified and kept as low as practicable.
(d) Five years of experience with reports from four categories of licensees has confirmed the feasibility of the system.
(e) Amendments to the annual reporting requirements published January 4,1974, simplified the submission of reports and satisfied much of the opposition expressed toward the origi.nally proposed system.
Con: Some opposing comment may be anticipated claiming that the extended reporting requirements would constitute.an unwarranted burden on licensees.
This paper proposes publication of a notice of proposed amendments to 10 CFR Part 20 in the Federal Register, allowing 45 days for public comment.
Recommend at ion:
The Commission:
(a) Approve Alternative 3, i.e., extend the requirements for annual reports (520.407) to all NRC specific licensees, retaining the existing application of requirements for termination reports '($20.408) to four categories of licensees.
(3) Note 1.
The proposed amendment to 10 CFR Part 20 set out in Enclosure "A", will be published in the Federal Register, allowing 45 days for public comment;
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It..: Commissioners '
I 2.
If after expiration of the comment period no significant adverse comments or significant questions have been received and no substantial i
i changes in the text of the rule are indicated, the Executive Director for Operations will arrange for publication of the amendment in final form.
If significant adverse connects or significant changes in the text of the rule are indicated, the revised anendment will be submitted to the Commission for approval; 3.
The Joint Committee on Atomic Energy will be informed of this action; 4.
An appropriate public announcement, such as i
Enclosure "B",
will be issued upon filing of j
the notice of proposed rule making with the 1
Office of the Federal Register;
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5.
General Accounting Office review of the revised reporting requirements will be obtained prior
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to publication of the amendments in effective i
form; and l
, 6.
Pursuant to $51.5(d)(3) of Part 51 of the Commission's regulations, neither an environmental.
impact statement nor a negative declaration need be prepared in connection with these amendments since they impose only reporting requirements and thus are in~significant from the standpoint of environmental impact.
a l
Coordination:
The Offices of the Executive Legal Director, Nuclear Reactor i
Regulation, Nuclear Material Safety and Safeguards, and Inspection and Enforcement concur in the recommendation of this paper. The Office of Public Affairs prepared the draft'public announcement, Enclosure "A".
Scheduling:
(a) Approvals or comments by Farch 21, 1975.
(b) Affirmation at an early Policy Session.
h.
fl Robert B. Minogue, Acting Director Office of Standards Development ~
Contact:
Walter S. Cool, SD Extension: 443-6920 j
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NUCLEAR REGULXTORY COMMISSION 10 CFR Part 20 STANDARDS FOR PRCTfECTION AGAINST RADIATION
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Personnel Monitoring Reports The Nuclear Regulatory Commission has under consideration proposed amendments to 10 CFR Part 20. The proposed amendments would extend to all NRC specific licensees the requirements of 820.407 for the submission of an annual statistical summary report of estimated whole body radiation doses.
The snendments proposed in this notice do not involve any changes in requirements for the provision and use of personnel mon.toring equipment or the records of pe_rsonnel monitoring data that must be kept. The changes relate solely to the r. porting of the data.
On December 19, 1968 (33 F.R. 18926), amendments to 10 CFR Part 20 were published by the Atomic Energy Commission (licensing and related regulatory functions of the AEC were transferred to the NRC pursuant to section 201 of the Energy Reorganization Act of 1974) incorporating into the Commission's regulations requirements t ar the annual reporting of personnel monitoring information by four categories of licensed activities.
The four categories of licensees identified in 520.407(a) are those that were considered to involve the greatest potential for significant occupational radiation doses.
At the same time, reports by the four categories of licensees were required pursuant tc 920.408 on the exposure of individuals to radiation and radioactive material upon their termination of employment or work assignment in a licensee's facility. This requirenent was justified, Enclosure "A"
t 1
j primarily, as a means of evaluating the likelihood of significant multiple doses being received by a so called " transient worker".
On January 4, 1974 (39 F.R.
.1000), AEC published an amendment to 820.407 to require the annual reporting of only a statistical summary of the estimated whole body exposures, rather than the actual estimated exposures to any body part of a named individual that exceeded in a year the applicable quarterly limit. This amendment provides additional data in that it requires submission of a statistical summary of all of the exposures estimated to haYe been received by individuals who are required to be monitored pursuant to 8820.202(a) or 34.33(a)
Further, some licensees choose to include data on ir.dividuals who were provided personnel monitoring equipment as part of good health physics practice even though it could have been shown that such monitoring was not required.
The Commission considers theinformation obtained pursuant to the required reports to be essential to the evaluation of the risk of radiation exposure associated with the related activities. The data permit a mean-ingful comparison of current exposure experience among types of licensees and among licensees within each type. The data are being used in the identification of situations to be studied further in order that guidance can be developed on actinn that should be taken to keep occupational radiation exposures "ss low as practicable".
However, it should be noted
.that the personnel monitoring data do not permit evaluation of what occupational exposures are "as low as practicable". Such evaluation requires study of the specific factors associated with a specific facility and activity.
2-Enclosure "A" l
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Therefore, in order to permit comparable evaluation of the occupational radiation exposure risks asscciated with all categories of Licensed activities, the proposed amendment to 520.407 that follows, would extend the reporting requirements of that section to all activities specifically licensed by the NRC.
Section 20.408 would be amended only to include specification of the four categories of Licensees that continue to be required to submit reports of individual exposure to radiation and radioactive material upon termi-nation of individual employment or work assignment in their facilities.
Those categories are currently set out in 520.407 and incorporated in 120.408 by reference.
Pursuant to the Atomic Energy Act of 1954, as amended, the Energy Reorganization Ac t of 1974, and section 553 of title 5 of the United States Code, notice is hereby given that adoption of the following amendments to 10 CFR Part 20 is contemplated. All interasted persons who desire to submit written comments or suggestions for consideration in connection with the proposed amendments should send them to the Secretary of the Commission, U. S. Nuclear Regulatory Connission, Washington, D. C.
20555, Attention: Docketing and Service Section by Copies of the ce.a =ats un the proposed amendments may be examined at the Commission's Public Document Room at 1717 H Street, N.W. Washington, D. C.
A date will be inserted allowing 45 days for public comment.
( Enclosure "A"
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Section 20.407 of 10 CFR Part 20 is revised to read as follows:
a20.407 Personnel monitoring reports.
Each person specifically licensed by the Comission shall, within
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the first quarter of each calendar year, submit to the Executive Director for Operations, U.S. Nuclear Regulatory Comission, Washington, D. C.
20555, the following reports covering the preceding calendar year:
(a) A report of either (1) the total number of individuals for whom personnel monitoring was required under IB20.202(a) or 34.33(a) of this chapter during the calendar year; or (2) the total number of individuals for whom personnel monitoring was provided during the calendar year:
Provided, that such total includes at least the number of individuals
' required to be reported under pars 6raph (a)(1) of this section. The report shall ind'este whether it is submitted in accordance with para 6raph (a)(1) or (a)(2) of this section. If personnel monitoring was not required to be provided to any individual by the licensee under EE20.202(a) or 34.33(a) of this chapter during the calendar year, the licensee shall submit a negative report indicating that such personnel monitoring was not required.
(b) A statistical summary report of the personnel monitoring information recorded by the licensee for individuals for whom personnel atonitoring was either required or provided, as described in paragraph (a) of this section, indicating the number of individuals whose total whole body exposure recorded during the previous calendar year was in each of the following estimated exposure ranges:
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Enclosure "A"
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ESTIMATED WHOLE BODY NUMBER OF INDIVIDUALS E'GOSURE RAhT,E IN EACH RANGE (Rems) //
No measurable exposure Measurable exposure less than 0.1 0.25 0.1 0.25 - 0.5 0.5 - 0.75 0.75 - 1 1
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The low exposure range data are required in order to obtain better information about the exposures actually recorded. This section does not require improved measurements.
2.
Section 20.408, 10 CFR Part 20, is revised to read as follows:
820.408 Reports of personnel monitoring on termination of employment or work.
(a) This section applies to each person licensed by the Commission to:
(1) Operate a nuclear reactor designed to produce electrical or heat energy pursuant to 850.21(b) or e50.22 of this chapter or a testing facility as defined in 950.2(r) of this chapter; (2) Possess or use byproduct material for purposes of radiography pursuant to Parts 30 and 34 of this chapter; D Individual values exactly equal to the values separating Exposure Ranges shall be reported in the higher range. Enclosure "A"
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(3) Possess or use at any one time, for purposes of fuel processin6 fabrication, or reprocessing, special nuclear material in a quantity exceeding 5,000 grams of contained uranium-235, uranium-233, or 4
plutonium or any conbination thereof* pursuant to Part 70 of this chapter; or (4) Possess or use at any one time, for processing or manufacturing for distribution pursuant to Part 30, 32, or 33 of this chapter, byproduct material in quantities exceeding any one of the following quantities:
Radionuclide Quantity in curies 1
Cobalt-60 100 Gold-198 1
Iodine-131 10 Iridium-192 1,000 Krypton-85 10 Promethium-147 -
1,000 Technetium-99m --
2_/ The Commission may require, as a license condition, or by rule, regulation or order pursuant to $20.502, reports fron licensees who are licensed to use radionuclides not on this list, in quantities sufficient to cause comparable radiation levels. Enclosure "A" 6
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(b) When an individual terminates employment with a licensee described in paragraph (a) of this section, or an individual assigned to work in such a licensee's f acility but not employed by the licensee, completes his work assignment in the licensee's f acility, the licensee shall furnish to the Executive Director for Operations, U. S. Nuclear Regulatory Commission, Washington, D. C.
20555, a report of the individual's exposure to radiation and radioactive material, incurred during the period of employment or work assignment in the licensee's facility, containing infor-mation recorded by the licensee pursuant to 5520.401(a) and 20.108.
Such report shall be furnished within 30 days after4the exposure of the individual has been determined by the licensee or 90 days after the date of termination of employment or work assignment, whichever is earlier.
(Sec. 161, Pub. Law 8'-703, 68 Stat. 948 (42 U.S.C. 2201); Sec. 20l, Pub. Law 93-438, 88 Stat. 1242 (42 U.S.C. 5841))
Dated at this 1975.
day of For the Nuclear Regulatory Commission Secretary of the Commission 4 Enclosure "A"
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t Enclosure "B" DRAFT PUBL'IC ANNOUNCEMENT 1
bRC PROPOSES RULE CHANGE TO REQUIRE STATISTICAL
SUMMARY
REPORTS ON WORKER
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RADIATION EXPOSURES FROM ALL NEC LICENSEES The Nuclear Regulatory Commission is considering a rule change to extend to all NRC Licensees the requirement for annual statistical summary reports on worker radiation exposures. Currently, these summaries are required only from certain types of licensees.
Under a January 4, 1974 amendment to Part 20 of NRC Regulations, four categories of licensees are required to submit an annual statistical summary of monitored whole body exposures -- that is, the number of people in each of 18 prescribed ranges of radiation exposure. The data are being used to better evaluate the occupational exposures being experienced by employees of these licensees. The four categories are those which are considered to involve the greatest potential for significant occupational exposures.
The amendment to Part 20 now being proposed would extend this statistical I
summary reporting requirement to all NRC specific licensees.
The proposed amendments do not involve any changes in the requirements for the provision and use of personnel monitocing equipment or the records of personnel monitoring data that must be kept. The changes relate solely to reporting data already recorded.
Notice of the proposed amendments is being published in the Federal Interested persons who wish to submit written Register on comments for consideration in connection with the proposed amendments should send them to the Secretary of the Commission, U.S. Nacicar Regulatory Connission, Washington, D. C. 20555, Attention: Docketing and Service Section, by Enclosure "B
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ENCLOSURE "C" DISCUSSION Requirements for the reporting of occupational radiation dosimetev data were published in effective form on December 19, 1968. Original proposals would have applied to all AEC specific licensees. However, there were many 1
opposing comments. A summary of the comments most frequently mentioned, adapted from AEC 985/20, March 1,1968, is attached. The effective regulations were-limited to the four categories of licensed industrial-type activities which involve the handling of substantial quantities of radioactive material and which were considered to involve the greatest potential for significant doses. Pursuant to 320.407, these licensees (approximately 450 out of a total of approximately 7,000) were required to report (1) either the total number of individuals for whom personnel moniotirng was required or the total number of individuals for whom such monitoring was provided, and (2) individually identified monitoring data for each individual who exceeded in a year an applicable quarterly limit.
Further, pursuant to 820.408, the licensees were raquired to submit a report of an individual's total exposure to radiatinn and radioactive m terial upon his termination of employment or work assignment in the licensee's facility.
It was recoenized *har enca the feasibility of the program was established, it might subsequently be desirable to extend the provisions of 9520.407 and 20.408 to all NRC specific licensees.
By amendment published in effective form January 4,1974, 820.407 was changed to require the same four categories of licensees to submit an annual statistical summary report including all of the monitoring data on all individuals for vnom personnel monitoring was required. This amendment Enclosure "C"
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simplified the submission required, and should satisfy much of the opposition expressed toward the initial system. Five years of experience with reports from this limited group of licensees has confirmed the feasibility of the system.
There are a number of reasons why the staf f rej ects Alternative 1 and desires 4
to obtain annual statistical summary data upon monitored employees of all licensees. Data are available from only about 6% of NRC licensed accivities.
We do not,know how many individuals are being employed by the large majority of licensees in jobs that require the provision and use of personnel monitoring equipment, or the radiation doses such individuals are currently estimated to receive. We are particularly interested in the monitoring expe'rience of medical licensees uhere there are large numbers of young women employed as nurses and technicians.
The data will permit a heaningful comparison of current exposure experience among types of licensees and among licensees within types, and are essential to evaluate the over-all risk from radiation exposure in the nuclear industry. The data do not permit evaluation of what occupational exposures are "as low as practicable", since such evaluation requires study of the specific f actors associatr a with a specific f acility and activity. However, the data are being used in the identification of situations to be studied further in order that guidance can be developed on action that should be taken to keep occupational radiation exposures as low as practicable.
Efforts have been made to obtain the data by means other than requiring reports from licensees, Alternative 2, and have proven unsatisf actory. For several years, contracts vere let with a number of commercial suppliers of personnel monitoring devices, in an effort to obtain statistical information-Enclosure "C"
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on the personnel monitoring experience of their customers. These contracts have been terminated because, among other factors, it was'found that the number of individuals included in certain types of licensed activities were too anall to be representative.
Inspectors from NRC's Of fice of Inspection and Enforcement review the programs and records of many of these other licensees on a schedule which recognizes the degree of risk associated with each type of licensed activity.
However, it would be very time consuming for the inspectors to copy or duplicate the exposure data. Fu rther, the data would not be available at any one time because of the time sequence of inspection visits and the f act that many licensees are never inspected.
The propeeed amendment to 920.407 set forth in Enclosure "A", vosld extend the annual reporting requirements to all NRC specific licensees. Section 20.408 would be amended only to include specification of the four categories of licensees required to submit termination reports. Those categories are currently set out in 920.407 (a), and incorporated in 320.408-by reference.
The proposed amendments do not involve any changes in requirenents for the provision of personnel monitoring equipment or the records that licensees must keep.
The changes relate solely to ths reporting of the m nitoring data, and are not anticipated to have a significant tapact on licensees. The prpposed amendments have been f avorably reviewed by the Atomic Energy Labor Management Adviacry Committee. Enclosure "C"
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There is no advantage to be gained by the proposed reporting 293 15 5
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It would rer, ult in a financial burden on the public through increased 244 12 10 19 9
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4 45 351 ta>es and al.i :as.
3 The propose.l repor"ted data uould not be definitive for purposee of y
(a) vori:.n.*n's compensation decisions, and 156 6
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Filia badges do not provido an ac~ curate indication of tissue dose.
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The AEC is bypascing the will of Congress which has refused to support 122 2
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7.
The propo=ed aam:ndoents represent on undou extension of AEc authority.
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