ML20033B769

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Ack Receipt of 810803 & 17 Ltrs Re Licensing of Persons Who Import Watches Containing Tritium Paint.Licensing Assures Protection of Public,But Annual Reporting Requirement Should Be Reviewed & Communications Made Clearer
ML20033B769
Person / Time
Issue date: 11/04/1981
From: Palladino N
NRC COMMISSION (OCM)
To: Coelho T
HOUSE OF REP.
Shared Package
ML20033B770 List:
References
NUDOCS 8112020092
Download: ML20033B769 (2)


Text

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November 4,1981 i

CHAIRMAN e:,

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The Honorable Tony Coelho g/4 United States House of Representatives Washington, D. C.

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Dear Congressman Coelho:

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This is in response to your letters dated' August' 3,1981 a'nd s

August 17, 1981 concerning the licensing of persons who import watches containing tritium paint.

The purpose of NRC regulations of tritium-contiining materials is to assure that their use and distribution do not create a public health hazard.

The general pattern of regulating, the distribution of radioactivity-containing consumer products is to license the initial distribution of the products

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instead of the ultimate consumer. The radiation exposure that could be attributed to a single tritium ^ watch dial manufactured in accordance with NRC safety rules is negli-gi bl e.

However, the total radiological impact resulting

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s from the distribution of millions of tritium dial watches as well as other radioactivity-containing consumer products, such as smoke detectors, bears evaluation from time to time.

The licensing of distributors appears to be a practical way to assure protection of the public and to limit the nupber of individuals and organization; subject to regulation.

However, the desirability of continuing to require annual l

reports from distributors -- particularly where the hazards of the distributed product are extremely small -- should 'be:

re-examined.

The reporting regulation was adopte over a decade ago in order to assure that the Atomic Ene(rgy Com-l mission had direct knowledge of the extent of distribution.

l of radioactive materials outside regulatory control.

As part of a published NRC staff study of radioactivit.y-containing consumer products, the staff has under review possible modifications in the Commission'_s policy statse mert concerning such products as well as changes to the corresponding rules.

I am, therefore, requesting the ssta ff to review the need for the annual report requirement and to recommend whatever changes appear justified in the li'ght of N

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PDR COMMS NRCC CORRESPONDENCE PDR,

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the more than a decade of experience with the regulation.

We should consider eliminating the reporting burden for those radioactive consumer products where the hazards are insignificant or where other means are available for assessing the potential radiological impact on a nationwide basis.

Finally, my reviewlof the past correspondence indicates that we should do better in communicating with licensees.

This should be especially true in cases involving small businesses that on occasion handle small amounts of radioactive material.

I, therefore, am directing the staff to ensure that NRC communications with licensees are clear.

We are also in receipt of y6ar October 19, 1981 letter which raises additional questions regarding our interactions with State Government Agencies.

We will be responding to these questions in the near future.

I appreciate your bringing these matters to my attention.

It is helpful to the Commission's efforts to improve the effectiveness and efficiency of our regulatory programs.

Sincerely,

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Nunzio P

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