ML20055J043
| ML20055J043 | |
| Person / Time | |
|---|---|
| Issue date: | 01/18/1989 |
| From: | Cunningham R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Morris B NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20055H979 | List: |
| References | |
| FRN-55FR843, FRN-55FR8460, RULE-PR-34 AC12-2-23, NUDOCS 9007310308 | |
| Download: ML20055J043 (4) | |
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[/ 0 "%,A UNITED STAT ES Roecklein 1
g NUCLEAR REGULATORY COMMISSION File Od 1l WASHING T ON, D. C. 20665 i
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January 18, 1989 JD
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MEMORANDUM FOR:
Bill M. Morris, Director Division of Regulatory Applications, RES FROM:
Richard E. Cunningham, Director Division of Industrial and Medical Nuclear Safety, NMSS
SUBJECT:
SAFETY REQUIREMENTS FOR INDUSTRIAL RAD 10GhAPHIC EXPOSURE DEVICES This refers to the request dated December 28, 1988, signed by Alan Roecklein, for review and comnents on the subject rulemaking for industrial radiographic equipment. While the transmittal slip does not make this clear, it is our understanding that Research is seeking division concurrence on the package. We are not prepared to concur at this time. We believe that the rule itself needs to be suastantially different from that proposed and that significant additional work is needed to the supplemental information in this package to address pertinent public comments, to better explain the requirements of the rule, and in evaluating the cost estimates for implementing the requirements.
Enclosed are our suggested changes to the rule. We are available to meet with you and your staff to discuss how our concerns on the supplementary information ortion of the package may be resolved.
Please contact me or Bruce Carrico p(X20634) to make arrangements for a mee, ting, l
bYY y
1 Richard E. Cunningham, Director Division of Industrial and Medical Nuclear Safety, NMSS
Enclosure:
As stated cc: FJCongel, NRR CCKammerer, GPA MCMalsch, OGC TNNovak, AEOD l
l g73g300900726 34 55FR843 PDR
i ENCLOSURE l
IMNS COMMENTS CHANGES TO FINAL RULE 1.
Paragraph 34.20(b)(1) of the proposed rule should be reinstated in the final rule.
We do not agree with RES's contention thic the labelling i
requirement is contained within the ANSI standard.
Instead, what the standard states is that a " provision shall be made for the attachment of a plate." We do not view this as clearly requiring the plate.
Note that this plate will have to be changed each time a source is replaced in a camera (as frequently as overy six months) and that this operation will i
normally be conducted by the user, not the manufacturer.
In current industry practice, the manufacturer provides a plate containing this information to the user with the source changer and new source.
We also note that Texas has similar requirements.
Lastly, one comment suggested l
that the device have a " notify if found" label; Texas' regulations contain such a provision; we believe this tuggestion has merit and should be i
considered.
2.
The last sentence in Paragraph 34.20(b)(2) of the proposed rule is unnecessary and should be deleted.
3.
As suggested by a commenter, we recommend that Paragraph 34.20(c)(1) be rewritten to be more similar to that used by Texas in its current rule.
For example, the paragraph could state:
"The coupling between the source assembly and the control cable Jiust be designed in such a manner that the source will not become disconnected if cranked outside the guide tube.
The coupling must also be such that it cannot be unintentionally t
disconnected under normal and reasonably forseeable abnormal conditions."
4.
Paragraph 34.20(c)(2) should be rewritten as given in the proposed rule
[34.20(c)(3)].
We do not agree with the use of an automatic securing device located on the control crank, r
5.
Paragraph 34.20(c)(3) should be rewritten as given in'the proposed rule
[34.20(c)(4)] a'id the last sentence should be deleted.
NRC's regulations I
are not an appropriate place for making recommendations.
It would be more appropriate to make these recommendations in.the. supplemental section of the rule package.
6.
Paragraph 34.20(c)(4) should be rewritten as given in t5e proposed rule l
[34.20(c)(5)).
Engraving methods other than laser etching would be acceptable.
Also,-the proposed rule allowed the source suppliers more flexibility for future improvements in label techniques.
7.
Paragraph 34.20(c)(5) shoulti be rewritten as given in the proposed rule
[34.20(c)(6)] and the last sentence should be deleted.
The opportunity for licensees to apply, under Section 34.51, for an exemption to this requirement should be discussed in the supplemental information portion of the rule package.
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1 e ' 8.
Paragraph 34.20(c)(6) should be rewritten as given in the proposed rule
[34.20(c)(7)].
(We are not quite surc what the change to this paragraph is meant to imply.) However, you may wish to consider combining this paragraph with 34.20(c)(5)-and make (c)(6) the first sentence of the paragraph.
Ti,;; combination may help make the requirement read better.
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9.
Although no changes to paragraph 34.20(c)(9) were proposed, we suggest this item be rewritten to state, " Source changers must provide a system for assuring that the source will not be accidently withdrawn from the changer when connecting or disconnecting the drive cable to a source assembly." This change should help to make it clearer that both the spent source and the. replacement source must be secure when making connections.
Also, while some comments suggested that this requirement seemed out of place, we do not necessarily agree and view changers as " associated equipment" for projection devices.
l 10.
We recommend that paragraph 34.20(c)(10) be rewritten as given in the l
proposed rule (34.20(d)], and be renumbered as 34.20(d).
However, we suggest that the word "new" be deleted from the paragraph.
The intent of-this provision was to have all devices obtained by licensees after a certain date meet the new requirements.
If the rule states "new devices" this will cause confusion.
Because the major complaint with this item appears to revolve around the external radiation levels, we do not support extending this compliance period beyond one year.
Our reasoning for this is:
(1) the ANSI standard was published almost eight years ago, (2) Texas implemented this.
requirement over a year ago, (3) there-does not appear.to be majority support to revise the ANSI standard changing the external radiation t
levels,-(4) ISO recommends the same levels, (6).I50'has held some discussion to lower the levels, (7) the' manufacturers can: limit the maximum source activity used in the devices ~ so that the ' levels can be met, l
(8) for most devices only a few additional pounds of; shielding will be.
required, and (9) devices used.as type B transport containers will already-meet the levels.
As an alternative, we suggest'a11o' wing an extended effective date, perhaps up to one year, to implement the rule.
This would allow the manufacturers two years to develop devices which meet the ANSI = standard and'the additional requirements of the rule, and would allow our Ilcensecione year to obtain personal alarm rate meters and develop procedures'for complying with.the other provisions of the rule.. This would also allow the instrument manufacturers sufficient time to market alarm rate meters which are more appropriate for use irt the industrial radiography industry than those that are currently.available.
11.
The numerous public comments ~ received indicat a a-signit: cant cost burden associated with the proposed 5 year period for cokpliance with paragraph 34.20(e).
However,' we believe-that the suggested.
extension to 10 years substantially weakens the safety significance of the rule.
We recommend that the Commission Paper present both
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options, with pros, cons, and costs, and request that the Commission make a decision in this matter.
12.
The first sentence of paragraph 34.21(b) should be revised to reflect a one year compliance period.
One commenter questioned if source changers where the same as storage containers as used in this section. We agree that they are and suggest that the term be addu to paragraph (b) for clarification.
s 13.
Paragraph 34.30(a)(3) of the proposed rule should be reinstated.in the-final rule.
The only portion of a radiography device that we can think of that may not be critical.to radiation safety is the carrying handle and..,
its attachment bolts._ IMNS staff believes that it-is_important that NRC be notified of equipment failures so that we can evaluate this rulemaking.
and to help identify potential generic problem areas with equipment.
However, we do think that this paragraph.could be modified to eliminate.
normal. maintenance or inconsequential problems.
For example, this paragraph might be revised to state, " Failure of any component, critical y
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to safe operation of the device, to perform its intended. function and which could potentially cause a radiation hazard, and is not-correctable-as a part of the-licensees routine maintenance. program or needs to be i
replaced." Also, paragraph (b) of this section should be. corrected to read, "... report submitted under paragraph (a) of this section."
14.
Section 34.33 of the proposed rule should be reinstated in the final rule.
However, " alarm dosimeter" shoold be replaced with " alarm rate meter.'"
IMNS does not support-the use of dosimeters or chirpers for_ reasons we have discussed at length with RES'in the past.
We particularly oppose a _
1 regulation which allows each licensee to pick the. type of instrument to use and which allows the licensee to establish the alarm set point... We-are concerned that such a_ system would be open-to abuse.and would be nearly 'non-inspectable.
I We feel that the comments concerning:the 500'mr/hr set point may have-misinterpreted the proposed requirement as implying that an individual.,.
I would receive a 500 arem accumulated dose before an alarm sounds, which,.
j of course, is not correct.
One comment questioned the need for such i
devices at fixed facilities where other warning devices are in.use;>we do l
not think they1would be necessary in these circumstances ~and suggest that the alarm rate meter is intended to alert a radiographer to an unexpected the requirement be rewritten to provide such an exemption.'. ' Also, since '.
,' 4 situation, the commenter who noted that the set point may be too low for his operations at a nuclear power reactor could be readily exempted from the' requirement because of all the.other safeguards one would imagine the-reactor is placing on personnel who have to work in 500 mr/hr fields.
The opportunity.for licensees to apply, under Section 34.51, for an exemption' to this requirement should be discussed in the supplemental'information portion of.the rule package.
15.
Appendix A, item II.C.3 should be changed to " Alarm rate meter."
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