ML20046D470
| ML20046D470 | |
| Person / Time | |
|---|---|
| Issue date: | 06/04/1993 |
| From: | Miller V NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Cool D NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20046D471 | List: |
| References | |
| NUDOCS 9308200172 | |
| Download: ML20046D470 (10) | |
Text
M -4 1993 A
MEMORANDUM FOR:
Donald A. Cool, Chief Radiation Health Effects Branch Office of Nuclear Regulatory Research FROM:
Vandy L. Miller, Assistant Director for State Agreements Program office of State Programs W%byM L h r
SUBJECT:
AGREEMENT STATE COMMENTS ON CONCEPTUAL MODEL RADIOGRAPHY STANDARD, 10 CFR PART 34 This memorandum officially transmits the comments we have received to date from the Agreement States on the conceptual model radiography standard, 10 CFR Part 34.
Twenty Agreement States provided comments on the proposed model.
Additionally, OSP received comments from the U. S. Navy.
The Navy is an NRC Master Materials licensee with extensive experience in industrial radiography and was a participant in the Irving, Texas radiography workshop held in November 1992.
The comments attached have been forwarded to Cheryl Trottier as they were received to provide as much time as possible for consideration in the development of the proposed rule.
If you have furthrr questions, please_ call Jim Myers at 504-2328.
Attachment:
As stated s
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To:
Assistant Director for State Agreements Program
SUBJECT:
RESPONSE TO ALL AGREEMENT STATES LETITR (SP-93-010)
PONCE?TUAL MODEL OF RADIOGRAPHY STANDARD, 10 CFR PART 38y Please check one of the following:
0 We acknowledge recei e referenced letter and have no comments. 4 O We acknowledge receipt of the referenced letter and providing comments which are attached.
{Short responses may be faxed to (301) 504-3502.}
O Other (please explain under comments).
Comments (use additional sheets as appropriate):
Please complete t following i ornation:
Signature:
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Name:
Title:
bp n, hijl.,/
Date:
}/h / /993
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State Programs
Contact:
Jim Myers State Agreements Letter Number:
Response Due:
MAY 7, 1993 PLEASE TYPE OR PRINT YOUR STATE ABREVIATION HERE:
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Assistant Director.for State Agreements Program
SUBJECT:
RESPONSE TO ALL AGREEMENT STATES' LETTER (SP-93-010)
FONCEPTUAL'MODEL OF RADIOGRAPHY JIA.NDARD. 10 CFR PART 3W Please check one of the following:
0 We acknowledge receipt of the referenced letter and have no comments.
O We acknowledge receipt of the-referenced letter and providing comments which as attached. ~
rt responses may be faxed (301) 504-3502.)
0 Other (please explain u
. corrasmt Coments (use additional sheets as appropriate):
YZ JM &
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Please complete the ollong information:
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Signature-name:
YM A.
h iti9 y M y n b i u /L /.
Titic:
Date:
M State Programs contact:
Jim Myers State Agreements Letter Number:
Response Due:
MAY 7, 1993 PLEASE TYPE OR PRTNT YoDR STATE ABREv7ATION HERE:
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1.
Do you currently have the two-person rule in your regulations? /
2.
If yes, what was the economic impact to implement the two-person rule by 4[dsyf Idd h F your licensees? -
s 3.
Do you currently have the requirement to designate a Radiation Safety Officer (RS0) in your regulations? -
5.
If yes, what was the economic impact to imple t this requirement by your 4/.vg 4ad & Vy licensees?
6.
Do you currently have the requirement to have visible and audible alarms on permanent radiographic installations? -
6 7.
If yes, what was the economic impact to implement this requirement by your licensees?
Mm' B.
What will be the economic impact on small versus large businesses to implement these requirements? - N Ist Mu"7#
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TO:
Assistant Director for State Agreements Program
SUBJECT:
RESPONSE TO ALL AGREEEENT STATEE LETTER (SP-93-010)
CONCEPTUAL MODEL OF RADICCRAPHY STANDARD, 10 CFR PART mr3q Please check one of the following:
O We acknowledge receipt of the referenced letter and have no comments.
X 0
We acknowledge receipt of the referenced letter and providing comments which are attached.
{Short responses may be faxed to (301) 504-3502.}
O Other (please explain under comments).
Comments (use additional sheets as appropriate):
See Att hents A and B.
Please complute the following information:
Signature:
Sk
,6 Q
V Name:
crn+n 3_
m c.,c Director
Title:
pennein-rn-e nl
,-a r-a Sancy Management, Ark Dept of Health Date:
vm. 7 1com State Programs
Contact:
Jim Myers State Agreements Letter Number:
Response Due:
MAY 7, 1993 PLEASE TYPE OR PRINT YOUR STATE ABRE7IATION HERE:
ATTACHMENT A RESPONSE TO ALL AGREEMENTS STATES LETTER (SP-93-010)
CONCEPTUAL MODEL OF RADIOGRAPHY. STANDARD 10 CFR PART 35
-ARKANSAS-Comments Re: 134.47(d) 1.
Delete the phrase.*and the possibility of radiation exposure cannot be rules out as the cause".
The regulation would have to state provided what constitutes ruling out an overexposure. Otherwise, a film badge or TLD might not be returned for processing simply because the radiographer believed he/she did everything right, but in fact missed a survey, et cetera.
2.
The determination of radiation exposure should not be left solely to the R.S.O.
In cases of uncertainty, the regulatory authority must also be involved.
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i RAD:145 jp pg 1 of 2 05/07/93
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ATTACHMENT B 1
j RESPONSE TO SPECIFIC QUESTIONS d
a 10 CFR PART 35 L
-ARKANSAS-i 0
i ll 1.
We currently do not have a two-person rule in our regulations.
i 2.
N/A i
3.
We do not have the requirement in our regulations, but it is addressed in licensing -
guidance and becomes a license condition.
.l;
(
4 Note:Tho was no Question 4.
5.
None, as designation of an R.S.O. is required by policy and becomes a license 4;
condition.
i 6.
Yes 7.
No economic impact study was required or done.
8.
Although we support it for health and safety reasons, very small businesses may-1 be driven out of business by the two-person rule. Other small businesses may see increased costs due to extra personnel needed but presumably, these costs 1
will be passed on to consumers. The other change should not have a significant.
impact on any size business.
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4 i
RAD:145 jp pg 2 of 2 05/07/93 1
I
+
i To:
Assistant Director for State Agreements Program
SUBJECT:
RESPONSE TO ALL AGREEMENT STATES LETTER I
CONCEPTUAL MODEL OF RADIOGRAPHY STANDARD, 10 CFR PART F g 4 i
i Please check one of the following:
O We acknowledge receipt of the referenced letter and i
have no comments.
i
/
O We acknowledge receipt of the referenced letter and providing comments which are attached.
{Short
{
responses may be faxed to (301) 504-3502.}~
o Otha,r (please explain under comments).
I comments (use additional sheets as appropriate):
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Please com the followin information-I Signature:
A d-kbm
-l Name:
k fRw
Title:
gv tv Date:
11 D q
State Programs
Contact:
Jim Myers State Agreements Letter Number:
Response Due:
MAY 7.
1993 Ch PLEASE TYPE OR PRINT YOUR STATE ABREVIATION HERE:
T f
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p j
l 1.
Do you currently have the two-person rule in your regulations?
No, so long as one person can adeouately control the area.
2.
If yes, what was the economic impact to implement the two-person rule by -
i your licensees? '
't 3.
Do you. currently have the requirement to designate a Radiation Safety Officer (RS0) in your regulations? Yes.
5.
If yes, what was the economic impact to implement this requirement by your
~
licensees? The economic' impact is unavailable at this time.
6.
Do you currently have the requirement to have visible and audible alams on permanent radiographic installations? Yes.
7.
If yes, what was the economic impact to implement this requirement by yo' r u
i licensees?
The economic impact is unavailable at this time.
8.
What will be the economic impact on small versus large businesses to implement these requirements? The economic impact -on snall versus large licensees is unavailable at this' time.'
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TO:
Assistant Director for-State Agreements Program f
SUBJECT:
RESPONSE TO ALL AGREEMENT E,TATES LETTER (SP-93-010)
CONCEPTUAL MODEL OF XADIOGRAPHY i
STANDARD, 10 CFR PART 35 i
i Please check one of the following:
O We acknowledge receipt of the referenced letter and have no comments.
i x
0 We acknowledge receipt of the referenced letter and l
i' providing comments which are attached.
{Short
)
responses may be faxed to (301) 504-3502.}
l 0
Other (please explain under comments).
Comments (use additional sheets as appropriate):
4 I
Please complete the f 1 wing information:
1 Signature:
(
0 V~
i Name:
Lyle Jerrett
Title:
Chief Date:
May 4, 1993 j
i I
State Programs
Contact:
Jim Myers State Agreements Letter Number:
Response Due:
MAY 7.
1993
)
-l PLEASE TYPE OR PRINT YOUR BTATE ABREVIATION RERE:
E I
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.