ML20011B182
| ML20011B182 | |
| Person / Time | |
|---|---|
| Issue date: | 05/11/1976 |
| From: | Minogue R NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | |
| Shared Package | |
| ML20011B132 | List:
|
| References | |
| FOIA-81-303, TASK-IR, TASK-SE SECY-76-266, NUDOCS 8112040379 | |
| Download: ML20011B182 (5) | |
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UNITED STATES S'.t-76 266 May 11, 1976 NUCLEAR RE.GULNiGRY COV. MISSION INFORMATiON REPORT For:
The Comtissioners From:
Robert B. Minogue, Director, Office of Standards Development
'Ihru:
Executive Director for Operations
Subject:
AMENDLENT TO 10 CFR PARE 20 ON PERSCNNEL MONI'IORING REPORfS Purcose:
To inform the Comission of an NRC staff request for personnel monitoring data for 1975 from all IGC specific licensees.
Discussion:
During Policy Session 75-20 on April 24, 1975, the Nuclear Regulatory Cannission approved (Alternative 3 of SECY 75-98) publication of a notice of proposed amendment to S20.407, 10 CPR Part 20. The proposed amendment would exterx1 the requirement for an annual statistical summary report of personnel monitoring data so as to apply to all NRC specific licensees. The current requirement applies to only four categories of licensees, i.e., nuclear power reactors, industrial radiographers, fuel pro-cessing or reprocessing, and certain byproduct material processing or manufacturing operations. The notice of proposed rule making was published in the Feceral Recister on May 30,1975 (40 FR 23478).
j Copies of the notice were mallea to all licensees by letter dated
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June 2, 1975.
A total of only 36 letters of coment was received in response to the notice and letters to licensees. Of these,12 stated specific opposition to issuance of the proposed rule in effective form.
Nineteen of the letters either reflectea misunderstanoing of the proposed rule or suggested various minor changes. Five specifically favored the amendment, inclucing strong endorsements for proceeding with issuance of the propcsed amendment from the Environmental ProtectiomAgency and the Oil, Chemical, and Atomic ' Workers Inter-national Union.
Sane of the ccments raised questions regarding the value of the data to be obtained and the burden on the reporting licensees. In order to provide the Comission a better basis on which to evaluate the value and impact of tne proposed amendment, and to test the assumption that the four categories of licensees currently requirea to report involve the greatest potential for significant doses, we are requestino licensees to subnit a statistical sumary report. of whole body personnel monitoring results during 1975 as a voluntary, one-time action. It is recognizec that not all licensees will subnit the requested cata. Further, it will be necessary to
Contact:
exercise caution in the evaluation of the data, since those W. S. Cool 443-6920 8112040379 810902' 2h - -
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licensees with oetter raUiation control programs might be exWcted to be more willing to volunteer their oata. 'Ine results may thus be biased in the direction of unueresti-mating total occupational exposures. We are also inviting licensees to provice an estimate of the cost of their effort in preparing the report.
A oreft hotice to Licensees is set forth as Enclosure "A" to this paper. The Joint Conmittee on Atomic Energy will be informeo of this action. General Accounting Office approval of the request for the voluntary, one-time sutznission of a statistical suanary report will be obtained.
Cooraination:
The Ctfices of the Executive Legal Director, Inspection ana Enforcement, Nuclear Material Safety and Safeguaros, Nt: clear Reactor Regulation, Nuclear Regulatory Research, and Planning ano Analysis concur in the draft Notice to Licensees. The Office of Public Affairs concurs that the issuance of a puolic announcement is not warranted.
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R. 8. hinogue, Dir tor Office of Standards Developimnt Enclosure "A" tootice to Licensees DISTRIDUTION Conmissioners Commission Staff Offices Exocutive Director for Operations Secretariat
t Enclosure "A" NCTIICE 'IO ALL NRC LICDiSEES By letter dated June 2,1975, all NRC specific licensees were sent copies of a notice of proposed amendmen' to 10 CFR Part 20. The proposed t
amendment, if made effective, would extend the requirement for subnission of an annual statistical sunmary report of personnel monitoring results to all specific licensees.
The proposed amendment has not been made effective yet. The current NRC requirements apply to the four categories of licensees identified in 520.407(a), 10 CFR Part 20, only.
Coments on the proposed amendment raised questions regarding the value of the data to be obtained and the burden of reporting by licensees. The Comission (and its predecessor, the AEC) has found the personnel monitoring data received from the four categories of licensees to be valuable in several ways including the evaluation of exposure trends in the reported activities.
The cata also permit comparison of exposures between types of licensees and comparison of experience between licensees within types. For example, if monitoring data from licensees within a given type reveal that some licensees are able to conduct their operations with lower radiation doses than others, the NRC staff would consider actions that might be taken to develop generic guidance on how to keep occupational radiation exposures as low as is reasonably achievable. Data received under the existing regulation have been used in the developnent of Regulatory Guides 8.8 and 6.10, in the consideration of occupational exposure aspects of Appendix I,10 CFR Part 50, and in other actions regarding occupational exposure currently under consi-aeration.
Enclosure A
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- cuever, in creer to i rovice tne Cct.suiLcion witn a t.,ctter ear.ls to cvul z.te (1) the venellt to ce 00taineu tros.. extenuir.y tne perst.,utel
..cnitoring repcrting requirerient to all licenseet, arAl (1) tite ouruen that Lt.c propccou extensicn OL tna reycrting requirernelat wculu in. pose en licen-cees, area to test the assuaription tnat the tour categories or licensees currently rcqwircc to report inkt,1Ve tlie greatest potential lor significant coses, we are rcytesting y0u tu currait as a voluntary, one-tihae action, a utati tical sunkary repert et tne whole r.osy personnel Licnitoring results tur your 4.ctivities uuring 1:ie'.
v.e wculo appreciate receiving tne cata 1sio*
(11 ycu are cne or tne Icur categories ci licensees c) tpecitieu 11.p u..s u 'i t a ), aru nave alreauy sumitteu a report or l>b peti,c..t.el n.ur.itering uato, no Iurtner action is requesteu at tnis tir e.)
Is. r.ee;.ing with our policy ot assessirs tne value arma impact of all propcseo u.c.n9es la cur It.gulatory sistean, you alsc are inviteo to provice an estiit. ate et ycut ericct (a) in man-ncurs, ano (c) total cost in preparing an annual
=totirticci suonaty repcrt or enis type. acte tnat the action rec.uesteu invcives su a.. irs tne tour quarterly entries alreauy recuirea on 8cr:a Nic-a, cc equiva-lutt, tur ec.c....onitorcu inuivioual, ano enterin3 the apprcpriate numer at ira tvluuals in ectn Gt tiae estimatea wncle ocoy expcsure ranges specilleo in
.,2u. s v'i ( u ), Ib LJh Part 10.
A reproouction of tnat scriecule of exposure raryct. 1 cr.eicsea lor your convenience in sumittir g tne data for 1:rb.
ii.e tc,.crt sticulu ue niaileu cirectly to the Ottice or Management intort..aticn anc i-tuyran. ucateci, Perforn.ance Evaluatlun tsranch, b. b. huclear liegulatory Lei. ul:.sicn, wasnlia,tcn, L. L.
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.. uate will Le insertec allowing ob cays lor sumission ci tr.e data.
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. Your cooperation in voluntarily subnitting the requested dati is greatly appreciated.
Sincerely, Kenneth R. Chapman, Director Office of Nuclear Material Safety and Safeguards Attaciuttents :
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June 2, 1975, letter & enclosure 2.
Schedule of Exposure Ranges
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Enclosure "A" 1
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