ML20055J034
| ML20055J034 | |
| Person / Time | |
|---|---|
| Issue date: | 04/21/1989 |
| From: | Norry P NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | Beckjord E NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20055H979 | List: |
| References | |
| FRN-53FR8460, FRN-55FR843, RULE-PR-34 AC12-2-12, NUDOCS 9007310299 | |
| Download: ML20055J034 (1) | |
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NUCLEAR REGULATORY COMMISSION 3
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f MEMORANDUM FOR:
Eric S. Beckjord, Director-Office of Nuclear Regulatory Research i
FROM:
Patricia G. Norry, Director Office of Administration 8
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SUBJECT:
FINAL AMENDMENT TO-10 CFR PART 34:
SAFETY REQUIREMENTS FOR INDUSTRIAL RADIOGRAPHIC EQUIPMENT The Office of Administration concurs on the final rule that arre'nds 10 CFR Part 34 on safety requirements for industrial r'adiographic that presents minor editorial corrections, copy of the finalp ule equipment.
We have enclosed a marked-up We have inserted language in 10 CFR 34.20(a) and under the EFFECTIVE DATE caption to comply with the regulations of the Office of the Federal Register pertaining to incorporation by l
reference (1 CFR 51.9(b)(5) and-(c)(1)).
We have forwarded a copy of the final rule to the Records nd Reports Management Branch, IRM, for their comment or conchrrence concerning the paperwork management aspects of this rulemaking action.
If you have any questions concerning this matter, please t'.ve a member of your staff contact Alice Katoski (extens).on -27926) or'
/o Michael T. Lesar, Regulatory Publications Branch, ADM (extension j
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hie.D,8 Patricia G. Norry, Direct 7
Office of Administration p'
Enclosure:
As stated i
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l p g i gn MEMORANDUM FOR: Bill M. Morris, Director Division of Regulatory Applications 1
Office of Research FROM:
Robert M. Bernero Office of Nuclear Director i
Material Safety and Safeguards l
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SUBJECT:
FINAL AMENDMENT TO 10 CFR PART 34:
" SAFETY REQUIREMENTS FOR INDUSTRIAL RADIOGRAPHIC EQUIPMENT" We have reviewed ti* final rule package as requested in your mencrandum dated April 6, 1989.
We concur with the rule subject to incorporation of the attached comments.
The attached connents and additional editorial comunents have been discussed previously with the RES task leader.
You have also requested consents on the staff's suggestion that licensees which have difficulties meeting certain requirements apply for an exemption.
In l
particular, you question how such requests may impact-resources. 'The first paragraph in question, 34.20(c)(6), addresses guide tube performance l
requirements.
We note that NRC received very few comments expressing potential t
problems concerning this requirement.
We recently spoke with a representative from the State of Texas, which has had a similar requirement in slace for several years, who informed us that they have encountered no pro>lems with this l
provision, nor have they received any exemption requests.
As such, we believe that the number of licensees who will need guide tubes that cannot meet the performance requirements will be small, the requests easily processed, and should not significantly impact resources.
The second paragraph, 34.33(f)(2), concerns the 500 mr/hr set reint for alarm rate meters.
NRC received one comment which indicated that at reactor sites, i
radiography sometimes needs to be conducted in higher radiation areas and that a 500 mr/hr alarm may be too low.
However, it is cur understanding that because of the potential exposure liability for the utility -in these situations th utility will provide substantial health physics oversight of the operation.e-The i
purpose of the alarm rate meter is to act as a redundant safety feature when other provisions are not available.
For this reason, the rule excludes fixed facilities where other warning systems described in Part 34 are in use. Because Part 34 specifies these additional fixed facility warning systems, it is an easy matter to provide this exclusion.
While operations in a high radiation area at a reactor site where there is substantial health physics oversight by the utility might also come under such exclusions, we do not see a straight forward y
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Bill Morris change to the regulations that would accomplish the exclusion.
It is our impression that relatively few radiography licensees conduct these types of operations at reactor sites. Therefore, we believe it would be easier to provide a case-by-case exemption. The requests will be easily processed and should not significantly impact resources.
If you have questions, please contact Bruce Carrico at Ext. 20634.
Robert R. Be@Mero Direc-r J'
Office of Nuclear Materi 1 Safety and Safeguards
Enclosure:
As stated i
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NMSS C0f9ENTS ON RADIOGRAPHY E0UIPENT RULE l
1.
On pa p 38 in 34.20(c)(3) of the rule, delete the words "or other suitable means and revise the paragraph to state that the safety plugs or covers wst be installed during storage and transport. These changes are needed.
in order to more clearly indicate that the licensee is required to use the i
plugs or covers supplied by the manufacturer. The responses to public j
comments should also be revised to reflect these changes.
i f..
On page 40 in paragraph 34.21(b), add "(source chenprs)" to the second sentence after "...to storage containers." This wi 1 help to clarify that changers are to be treated as storage containers for the purposes of this-paragraph.
3.
On page 42 in 34.33(f)(2), delete the words "or higher" frc3 this paragraph. As previously discussed, we would rather have a h w licensees who have a need to work in higher radiation fields apply for ar exemption than have this requirement open ended.
The res should also be revised to reflect this change. ponses to public omments 1
4.
You should restate the guide tube kinking resistance test criteria that NRC finds acceptable (outlined in the proposed rule) in your discussion of.
paragraph 34.20(c)(6) on page 22 so that this criteria is included in the final Statements of Consideration.
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