ML20024E260
| ML20024E260 | |
| Person / Time | |
|---|---|
| Issue date: | 01/24/2020 |
| From: | Anthony Mcmurtray NRC/NMSS/DMSST |
| To: | |
| MCMURTRAY A/415-2746 | |
| References | |
| Download: ML20024E260 (18) | |
Text
NRC Update on Federal Regulatory Activities Affecting Industrial Radiography Anthony McMurtray Office of Nuclear Material Safety and Safeguards Division of Material Safety, State, Tribal, and Rulemaking Programs February 13, 2020
Topics
- 10 CFR Part 34 Rulemaking
- 10 CFR Part 37 Activities
- Materials Inspection Program Changes
- Escalated Enforcement Actions 2
10 CFR Part 34 Rulemaking
Individual Monitoring Devices Direct Final Rule
- PRM 34-7: Rulemaking approved to go forward as a direct final rule by the NRC Commission on January 4, 2019
- Rule and Guidance Information should be issued as final in first half of 2020 4
Revised Radiation Safety Requirements Rule
- PRM 34-6: Clarification to Training, Surveillance, and the Two Man Rule
- Petition Proposed Changes to the following:
- 34.41(a): two qualified individuals present, but second person no longer required to observe the operations
- 34.43: revise training requirements for radiographers and radiographers assistants regarding number of training hours
- 34.47: combined dosimetry devices
- 34.51: eliminate that the other individual present maintain continuous direct visual surveillance
- NRC Evaluating Next Steps for Addressing Issues Raised in the PRM 5
10 CFR Part 37 Activities
Current Part 37 Activities
- Draft revisions to NUREG-2155 completed
- Public comment period ongoing and closes next week
- NRC provided responses to the 2018 GAO Audit in January 2019 Audit addressed implementation of Part 37 by NRC and Agreement State licensees
- Task Force on Radiation Source Protection and Security https://www.nrc.gov/security/byproduct.html 7
Information Notice (IN)
- IN 2019-04 issued August 14, 2019 Effective Cyber Security Practices to Protect Digital Assets of Byproduct Materials Licensees https://www.nrc.gov/reading-rm/doc-collections/gen-comm/info-notices/
8
Pending Commission Papers - Security
- SECY-17-0083: Category 3 initiative - rulemaking recommendations
- Amend 10 CFR Parts 30, 40, and 70 to require safety and security equipment to be in place before granting a license for an unknown entity.
- Amend 10 CFR Parts 30, 40, and 70 to clarify license verification methods for transfers involving quantities of radioactive material below Category 2.
- SECY-16-0115: Financial Assurance proposed rulemaking plan for Category 1 and 2 quantities of materials
- Rulemaking aspects of these initiatives part of integrated rulemaking plan (SECY-17-0025) 9
Materials Inspection Program Changes
11 11
- IMC 2800, Materials Inspection Program changed in 2017 to allow extension of the inspection interval for high performers
- IMC 2800 completely revised and reciprocity inspection information moved to this IMC (scheduled to be issued later this year)
- Future inspection program changes expected to further risk-inform the materials inspection program, including the Inspection Procedure for Industrial Radiography (IP 87121)
Current and Future Changes to the Inspection Program
Escalated Enforcement Actions
Industrial Radiography Escalated Enforcement
- IA-18-043 [30.10(a)(1)and 30.34(c)]
- Deliberately failed to use iridium-192 for the purpose of radiographic operations as authorized by the license 13
Industrial Radiography Escalated Enforcement
- EA-18-113 [30.34(c)]
- Failure to confine the use of byproduct material to the purposes authorized in the license 14
Industrial Radiography Escalated Enforcement
- EA-19-090 [34.13(g), 30.9(a), and 37.21]
- Submitted inaccurate information about the qualifications of the proposed Radiation Safety Officers (RSOs)
- Maintained a license without a qualified RSO
- Allowed unauthorized possession of and access to a radiography source without an access authorization program 15
Import of Non-U.S. Byproduct Material (Sealed Sources (Waste)) Without an Import License
- EA-18-170 [110.5, 110.9, 110.20(a) and 110.27(c)]
- Failure to obtain a specific license authorizing the import of non-U.S. origin radioactive waste (disused sealed sources) containing byproduct material (iridium-192, selenium-75, and ytterbium-169) into the U.S.
16
Industrial Radiography Security Enforcement Issues
- Several Severity Level III (10 CFR Part 37)
Violations during the Past Year https://www.nrc.gov/reading-rm/doc-collections/enforcement/actions/
17
Questions?
Tony McMurtray Senior Project Manager anthony.mcmurtray@nrc.gov 301-415-2746