ML20055J036

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Requests Review & Comments on Encl Final Amend to 10CFR34, Safety Requirements for Industrial Radiographic Equipment
ML20055J036
Person / Time
Issue date: 04/06/1989
From: Morris B
NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
To: Bernero R, Harold Denton, Murley T
NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS), Office of Nuclear Reactor Regulation
Shared Package
ML20055H979 List:
References
FRN-53FR8460, FRN-55FR843, RULE-PR-34 AC12-2-16, NUDOCS 9007310301
Download: ML20055J036 (2)


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-I MEMORAi.'OllM FOR: Thomas E. Murley, Director, Office of Nuclear Reactor i

Regulation l

Robert M. Bernero Director, Office of Nuclear Material Safety and Safeguards Harold R. Denton, Director, Office of Governmental and Public Affairs Edward L. Jordan, Director, Office of Analysis and Evaluation of Operational Data William C. Parler, General Counsel, Office of the General Counsel Patricia G. Norry, Director, Office of Administration FROM:

Bill M. Morris, Director, Division of Regulatory j

Applications, Office of Nuclear Regulatory Research SUBJEC'. :

FINAL AMENDMENT TO 10 CFR PART 34:

" SAFETY REQUIREMENTS FOR INDUSTRIAL RADIOGRAPHIC EQUIPMENT" 7

Picase review the enclosed final rule package and provide your connents and concurrence. The following is a sumery of this request.

1.

Title " Safety Requirements for Industrial Radiographic Equipment" 2.

RES Task Leader: Donald 0.Nellis,(492-3628) 3.

RES Task Number: OP 401-1 l

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Requested Action:

Provide cumments and concurrence on the enclosed

- rule package.

5.

Requested Completion Date:

g33 g 6.

Background:

The NRC and its agreement States have been concerned for several years about the nusber of radiation overexposures and potential overexposures involvin public. g radiographers, and in some instances, members of the general 9007310301 900726 55 843 PDR

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1 Thomas E. Murley 2

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The high radiation output from the radioactive sources used in the radiography industry are the basis for this concern. Many of the overexposures that have occurred have been the result of the radioactive i

source not being properly retracted into its shielded position at the end of each exposure as required, either as a result of equipment malfunction or improper operational procedures.

This amendment will adopt safety performance requirements for radiographic equipment in an effort to reduce equipment malfunctions, and will require radiographers to wear alarm ratemeters to provide reinforcement to survey meters in alerting radiographers to the presence of an unsuspected unshielded source.

We would also invite the Office of Nuclear Materials Safety (6) and t

and Safeguards to review the Staff responses to comments on sections 34.20(c)

Both of these have responses which include the suggestion that licensees who have difficulties in meeting these requirements may apply for an exemption under section 34.51.

We request that NMSS management consider the potential resource implications of processing a large nuder of exemption requests from the 1100 radiography licensees who may act on this suggestion.

Orlghal$lgnedbyBRIM0ffll l

Bill M. Morris, Director Division of Regulatory Application Office of Nuclear Regulatory Research

Enclosure:

Commission Paper with Enclosures DISTRIBUTION: [THOMASE.MURLEY, DIRECTOR]

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DATE:2/24/89

2/27/89 :

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