ML20055J040
| ML20055J040 | |
| Person / Time | |
|---|---|
| Issue date: | 01/25/1989 |
| From: | Pate R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Roeklein A NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20055H979 | List: |
| References | |
| FRN-55FR843, FRN-55FR8460, RULE-PR-34 AC12-2-20, NUDOCS 9007310305 | |
| Download: ML20055J040 (2) | |
Text
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n MEMORANDUM FOR:
A. K. Roecklein, Acting Chief Radiation Protection and Health Effects Branch, RES FROM:
Robert J. Pate, Chief.
Nuclear Materials Safety and Safeguards Branch
SUBJECT:
SAFETY REQUIREMENTS FOR INDUSTRIAL RADIOGRAPHIC DEVICES We have reviewed the final draft on the radiography rule and have the following comments:
1.
Page 9, remove Inc. from Conference of Radiation Control Program Directors, Inc.
2.
Page 10 Line 22, examines (typo) 3.
Page 12 Line 10, been (typo) 4.
Page 13. Line 12, remove out from sentence i
5.
Page 13 Line 21, increased from two tn ---.
6.
Page 21, Section C(6), the term " tube conduits" is misleading. Why not refer to them as guide tubes which it the standerd nomenclature?
7.
Page21,SectionC(5),needsclarification. Does the applicant have to request a license exemption for specia' form guide tubes, or will the exemption automatically be granted i S caset i
8.
Page 22. Section (10)(e), should sptc:/ that this requirement applies to old and new radiographic devices.
SamecommentforSection3(b).
9.
Page 23, Section 34.30(C), should 20.405 be amended to show this reporting requirement?
- 10. Page 26, Line 21 should 030 've 9307
- 11. AnalysisofCceents,Page26,Section34.33(a).
It would appear that 64% opposed would be quite significant from the commenters viewpoint.
Responw states that the staff does not agree with the assessment; however, it is not explained as to the rational for such a statement.
9007310305 900726 PDR PR 34 55FR843 PDR
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t A. Roecklein 12. Analysis <,f Connents Page 29. Section 34.33(f)(2), Staff position.
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Trigger le els should be established in the licensee's procedures at the time of application. Some sites or locations of use do not have Radiation Safety Officers available to establish the trigger levels.
We appreciate the opportunity to review the final draft on the radiography rule.
obert J. Pate, Chief uclear Paterials Safety and Safeguards Branch e
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