ML20011B198

Comments on Proposed Amends to 10CFR19 & 20 to Control Radiation Exposure to Transient Workers.Reduction of Risk to Workers Does Not Outweigh Extensive Record Collecting Demands on All Licensees

ML20011B198
Person / Time
Issue date:	10/25/1977
From:	Pedersen K NRC
To:	Gilinsky V, Hendrie J, Kennedy R NRC COMMISSION (OCM)
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References
FOIA-81-303 NUDOCS 8112040420
Download: ML20011B198 (1)

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October 25, 1977 MEMORANDUM FOR: Chairman Hendrie j

Commissioner Gilinsky j

Commissioner Kennedy Commissioner Bradford l

Ken Pedersen FROM:

SUBJECT:

PROPOSED AMENDMENTS TO 10 CFR PARTS 19 AND 20 TO CONTROL l

RADIATION EXPOSURE TO TRANSIENT WORKERS (SECY-77-538).

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Through amendments to 10 CFR Parts 19 and 20, the staff proposes to contrcl radiation exposure to transient workers by licensee control of the total occupational exposures to these workers.

I think that the proposed reduc-tion of risk to the relatively small nuAer of transient workers and moon-lighters does not outweigh the rather extensive record-collecting / keeping demands on all licensees, especially since the affected workers willingly and knowingly assume the risks: staff analysis, in my opinion, does not show the need for amendment of the regulations.

On the contrary, I believe that a good case can be made for continuation of the " status quo" as the better course, especially in the sbsence of data which would indicate whether transients and moonlighters experience on a relative basis signifi-cantly more of the higher occupational exposures.

Furthermore, exposure levels for transients and moonlighters who work at two or three facilities during any given quarter appear to be overly stringent since such levels are set to protect those working for four facilities.

I recommend, therefore, that you not approve publication of the proposed amendments. As an alternative to the present situation or the proposed amendments you might want to ask the staff to explore the feasibility of imposing additional controls on transients and moonlighters through changes to licenses in those areas where such workers are used and receive propor-tionately greater exposures than the rest of the worker population.

Such a study would require more precise data than used in SECY-77-538.

cc: Jerome Nelson Sam Chilk CONTACT:-

Pat Comella (OPE) 634-1541

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