ML20011B194
| ML20011B194 | |
| Person / Time | |
|---|---|
| Issue date: | 02/03/1976 |
| From: | Kenneke A NRC |
| To: | Huberman B NRC |
| Shared Package | |
| ML20011B132 | List:
|
| References | |
| FOIA-81-303 NUDOCS 8112040409 | |
| Download: ML20011B194 (4) | |
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UNITE] STATts NUCLEAR REGOLATORY CCMfAIS310F
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Tebruary 3, 1976 ICiORMiDUM FOR: Ben Huberman
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SUBJECT:
MEETING ON PROPOSED RUI.E FOR TRANSIENT WORKERS As a follow-up to your January 22 note to Tom Rahm. I met with 05D's Bob Alexander and Walt Cool at their request to discuss CPE co==ents.
They had written an additional half-paper or so to improve the i= pact-value assessaant. However, that and our discussion further indicated to me that there is not a favorable cost-benefit basis for requiring 8 20.401.b. (and, as a consequence, S 19.1.}. and 8 20.401.c.)
The gist of the cost problem,as I noted to them, is that 1.
The cost to licensees vill not be zero and could, in the aggregate, be tens of thousands of dollars just for the recordkeeping.
2.
The benefit may be zero i.e., there may be no, individuals actually being'affected.
In any event it is s=all, in that at most only 1 to 10 individuals out of a possible 20,000 may be of concern.
In respon.se to their concern about the aooearance of a loop hole in the regulations, I indicated that the other proposed changes (e.g., 4 201.01) should be sufficient to clarify the NRC's intent.
I also indicated they st be, concerned that the " appearance" of NRC requiring costs without cor=ensurate benefits was out of line with the Commission's policy of efficiency and effectiveness.
In response to their concern that' the proposal be inspectable and enforceni
- ,1 I indicated agreement with their objective, but disagreed that the S 20.401/5 19.13 changes were the only way to get there.
I suggested they put into the paper a discussion of other alternatives.
For example, if th
'j primary problem was with reactor licensees (a small fraction of the total licensses), then these could be covered by sppropriate technical spe d
fications in their licenses.
This would decrease the impact of the regulation without cuttins its probable benefit, if any.
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SD Note: The changes proposed in sto.401(b) in the previous drnft staff paper appear as proposed 500,102(a) in Enclosure "A" to this paper.
0112040409 810902 PDR FotA J-COTTINO81-303 PDR
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Alternatively, I suggested holding in abeyance the proposed changes to
$ 20.401 and 919.13 until further data show we have an actual problem j
and where it occurs, so that we could i= prove the impact /value basis for the action.
With the issue still unresolved, we closed by agreeing that one of the procedural options available was to proceed with the paper "as is", but with OPE views appropriately summarized.
Enclosure ec: Tom Rahm, EDO Rpbert Alexander, SD (yait Cool, SD l
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Enclosure "D" 9
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ENCLOSURE "E" ORAFT LETTER TO CONGRESSIONAL COMMITTEES Enclosed for the information of the is a notice of proposed amendments to 10 CFR Parts 19 and 20 of the Nuclear Regulatory Comission's regulations, The proposed amendments are designed to minimize'the possibility of overexposure of short-term workers, sometimes called " transient workers", and other individuals who may be employed by, or work in the restricted areas of more than one licensee within a single calendar quarter, and individuals who may work for more than one licensee at a time (moonlighter.).
In many cases, licensees operating within the Comission's basic radiation dose limits, set.forth in 10 CFR Part 20, pemit workers to receive up to 1.25 rems per calendar quarter without obtaining information on prior occupational dose.
It would be possible for more than one licensee to employ an individual in a calendar quarter. The individual could receive doses within the basic quarterly limit during each employment, and exceed the quarterly limit in total during multiple employments.
The proposed amendments would require licensees to control the total occupational radiation dose of individuals.
Implementing changes would require licensees:
(a) to obtain from more highly exposed individuals, infomation on dose during a current calendar quarter from sources Enclosure "E"
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outside of the licensee's control; (b) to furnish prompt estimates of dose, at the request of the individual, upon termination of work; and (c) to keep appropriate records.
The notice of proposed rule making is being filed with the Office of the Federal Register and will allow 60 days for public comment after publication in the Federal Register.
Also enclosed is a copy of a draft public announcement to be released by the Commission on this matter in the nex.t.few days.
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2 Enclosure "E" n-