ML20055J041

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Offers Comments on Proposed Amends to 10CFR34,per 890111 Request
ML20055J041
Person / Time
Issue date: 01/25/1989
From: Cline W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To: Roecklein A
NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
Shared Package
ML20055H979 List:
References
FRN-55FR843, FRN-55FR8460, RULE-PR-34 AC12-2-21, NUDOCS 9007310306
Download: ML20055J041 (1)


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ATLANTA, GEOR3tA 30323 JAN 2 51989 MEMORANDUM FOR:

A. K. Roecklein, Acting Chief Radiation Protection anct Health Effects Branch FROM:

William E. Cline, Chief Nuclear Materials Safety and Safeguards Branch, DRSS

SUBJECT:

COMENTS ON PROPOSED AMENDMENTS TO 10 CFR 34 a:

(YOURNOTE.1/11/89) m In response to the subject request for review.*we offer connents as follows:

1.

10 CFR 34.20(b)(1):

We suggest that the positive force in one of the two mutually perpendicular (orthogonal) directions-be required to also test

> the completed connection.

A current design has this feature wherein the source control cable must be successfully moved.back before it will release the lock and allow the connected source 'to" move forward.

(See Enclosure.) This design' tests the completed connection and also prevents disconnection of the source assembly after use innless it is in the safe position in the shield.

i 2.

10 CFR 34.20(e):

We suggest that nonconforming equipment be allowed a grace period of five rather than ten years.

The latter interval implies that the rule change lacks safety significance, and most existing radiography source devices can be modified to conform for probably under

$1,000, i

l We appreciate the opportunity to comment.

i' William E. Cline

Enclosure:

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