ML20127K706
| ML20127K706 | |
| Person / Time | |
|---|---|
| Issue date: | 12/02/1992 |
| From: | Rathbun D NRC OFFICE OF CONGRESSIONAL AFFAIRS (OCA) |
| To: | Graham B, Kostmayer P, Sharp P HOUSE OF REP., ENERGY & COMMERCE, HOUSE OF REP., INTERIOR & INSULAR AFFAIRS, SENATE, ENVIRONMENT & PUBLIC WORKS |
| References | |
| RULE-PRM-34-4 CCS, NUDOCS 9301260190 | |
| Download: ML20127K706 (5) | |
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UNITED STATES ri.
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Cecember 2, 1992 i
The Honorable Bob Graham, Chairman Subcommittee on Nuclear Regulation Committee on Environment and Public Works United States Senate Washington, DC 20510
Dear Mr. Chairman:
Enclosed for your information is a copy of a petition for rulemaking (PRM-34-4).
The petition was filed with the NRC by the International Union of Operating Engineers, Local No.
2.
The petitioner is requesting that the Nuclear Regulatory Comnission
(!!RC) amend its regulations governing radiographic operations to require that a two person team perfcrm industrial radiographic operations at temporary job sites.
The petitioner believes that for health and safety reasons the suggested change is necessary to maintain adequate surveillance, to more easily and safely handle required equipment, and to respond in the event of an accident or injury.
Also enclosed is a copy of the Federal Register notice of receipt of PRM-34-4.
This notice will request public comments during a 60-day period and will be published within the next few days.
Sincerely, p,
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Dennis K.
Rathbun, Director Office of Congressional Affairs Enclosurcs:
1, PRM-34-4 2.
Federal Register notice cc:
Senator Alan K. Simpson
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i December 2, 1992 The Honorable Philip R.
Sharp, Chairman Subcommittee on Energy and Power Committee on Energy and Commerce United States House of Representatives Washington, DC 20515
Dear Mr. Chairman:
Enclosed for your information is a copy of a petition for i
rulemaking (PRM-34-4).
The petition was filed with the 11RC by the International Union of Operating Engineers, Local flo.
2.
The petitioner is requesting that the Nuclear Regulatory Commission (NRC) amend its regulations governing radiographic operations to require that a two person team perform industrial radiographic operations at temporary job sites.
The petitioner believes that for health and safety reasons the suggested change is necessary to maintain adequate surveillance, to more easily and safely handle required equipment, and to respond in the event of an accident or injury.
Also enclosed is a copy of the Federal Register notice of rec eipt of PRM-34-4.
This notice will request public comments during a 60-day period and will be published within the next few days.
Sincerely, Original signed by/
Dennis K.
Rathbun, Director Office of Congressional Affairs
Enclosures:
1.
PRM-34-4 2.
Federal Register notice cc:
Representative Carlos J.
Moorhead-DISTRIBUTION RRDB READING PGNORRY RRDB SUBJECT HTHOMPSONJR MTLESAR DKRATHBUN DHGRIMSLEY EDO READ FILE
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Decerber 2, 1992 i
The Honorable Philip R.
Sharp, Chairman Subcommittee on Energy and power Committee on Energy and Commerce United States House of Representatives Washington, DC 20515
Dear Mr. Chairman:
l Enclosed for your information is a copy of a petition for
~
rulemaking (PRM-34-4).
The petition was filed with the NRC by the International Union of Operating Engineers, Local No.
2.
The petitioner is requesting that the Nuclear Regulatory Commission (NRC) amend its regulations governing radiographic operations to require that a two person team perform industrial radiographic operations at temporary job sites.
The petitioner believes that for health and safety reasons the suggested change is necessary to maintain adequate rurveillance, to more easily and safely handle required equipment, and to respond in the event of an accident or injury.
Also enclosed is a copy of the Federal Register notice of receipt of PRM-34-4.
This notice will request public comments during a 60-day period and will be published within the next few days, f
Sincerely,
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Dennis K. Rathbun Director e
Office of Congressional Affairs
Enclosures:
1.
PRM-34-4 2.
Federal Register notice cc:
Representative Carlos J. Moorhead
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NUCLEAR REGULATORY COMMISSION 1
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The Honorable Peter H. Kostmayer, Chairman Subcommittee on Energy and the Environment Committee on Interior and Insular Affairs United States House of Representatives Washington, DC 20515 D' ear Mr. Chairman:
Enclosed for your infor tion is a copy of a petition for rulemaking (PRM ,
a petition was filed with the NRC by the Internatior.
.f Operating Engineers, Local No.
2.
The petitioner is T
that the Nuclear Regulatory Commission (NRC) amend i
_ clons governing radiographic operatioris to require that a
.a person team perform industrial radiographic operations at temporery job sites.
The petitlener believes that for health and safety reasons the suggested change is necessary to maintain adequate surveillance, to more easily and safely handle required equipment, and to respond in the event of an accident or injury.
Also enclosed is a copy of the Federal Register notice of receipt of PRM-34-4.
This notice will request public comments during a 60-day period and will be published within the next few days.
Sincerely,
/
.)
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Dennis K.
Rathbun, Director Office of Congressional Affairs
Enclosures:
1.
PRM-34-4 2.
Federal Register notice cc:
Representative John J.
Rhodes
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May 6, 1992 Secretary, U.S.
tiuclear Regulatory Commission Washington, D.C.
20555
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Attention:
Chief Docketing and Service Branch
Subject:
Petiuon the tiRC to issue a regulation requiring as a
- minimum, two Radiographic Personnel when performing Industrial Radiography with Licensed Material at temporary jobsites.
Petitioner:
The International Union of Operating Engineers, Local No. 2 (hereafter referred to as IUOE) and i
its membership of Industrial Radiographers.
Current problems associated with one Radiographer using Licensed Material at temporary jobsites include but are not limited to the following:
1.
When working in a
congested
- adea, it is extremely difficult to keep the area under constant surveillance from all directions.
2.
When working in deep trenches, it is difficult to keep above ground areas under surveillance.
3.
Whenever possible, Radiographers often work after
,;her trades and crafts have left the area. In case of an accident involving Licensed Material, the Radiographer can not leave the area if a Radiation danger exists in order to notify the proper authorities.
4.
In the event of an accident involving physical injury at a retrote jobsite, the Radiographer could be placed in a life threatening situation.
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.D The IUOE and its entire membership feel that the ' gern.ral solution to the current problems associated with ene Radiographer at temporary jobsites could be resolved with an amendment requiring:a-minimum of two personnel when performing Industrial Radiography vith Licensed Material. The personnel could consist of but not be 4
ilmited to:
- 1. Two Radiographers
- 2. One Radiographer and One Radiographer Assistant-
- 3. One Radiographer and One Trainee
- a. The Trainee having successfully completed 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of approved Radiation Safety and passing an examination over the topics of instruction.
Grounds for and interest ~in the action requested:
The IUOE and its entire membership feel that with a minimum of two personnel at temporary jobsites, current problems associated with one person could be resolved in the following manner:
1.
In congested areas, the two personnel would be better suited to conduct and maintain proper surveillance.
L 2.
When working in deep trenches or high above ground, it would be much safer performing Radiography with two people.
- a. It is of ten dif ficult to get equipment into deep trenches or high above ground when working alone.
- b. Surveillance would be improved with two personnel in this type situat an, 3.
In case of an e.ccident involving Licensed Material, one individual could keep the area-under surveillance while the other could notify the proper authorities.
4.
In _the event of an accident involving -physical injury while performing Industrial Radiography with Licensed Material, the Uninjured individual could see that the Licensed Material is secured properly and administer or seek first aid for the. injured.
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Whereas, I believe the proposed amend:nent submitted by the IUOE to the fiRC to change pre'sent regulations on a temporary jobsite that would r eT-t r e two li Radiographera or a Radiographer and Assistant Radiographer is a responsible i
j act. Current laws and the recent increase in violations indicate tnat this I
change is necessary for a cafe working environntent.
l Therefore, I do hereby PETITIO!1 THE tiRC OF THE Uf4ITED STATES OF MiERICA to act i
inetediately to ensure responsible enforcement and fair regulation of the fiE E Industry in the United Stateu by paesir.g a Common Sense Arendment to Regulations which will make it a mandatory requirement to have two qualifted Radiographere or Radiographer ar.d Assistant Radioc;rapher en the temporary i
jotette when performing incustrial radiography.
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USNRC OFFICE ^r ".WN!S T R/.i' Y2 OCT 15 All'.47 Note:
An identical petition was filed by 443 members of the International U
Union of Operating Engineers, Locals 2.
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[7590-01; NUCLEAR REGULATORY COMMIGSION h
10 CFR PART 34 (Docket No. PRM-34-4)
International Union of Operating Engineers, Local No. 2; Filing of a Petition for Rulemaking AGENCY:
Nuclear Regulatory Commission.
ACTION:
Notice of receipt of petition for rulemaking.
SUMMARY
The International Union of Operating Engineers (IUOE),
Local No.
2, requests that the Nuclear Regulatory Commission (NRC) amend its regulations regarding licenses for radiography and radiation safety requirements for radiographic operations, as necessary, to require a minimum of two radiographic personnel when performing industrial radiograohy with licensed materials at temporary job sites.
The petitioner believes that the suggested change is necessary to ensure a safe working environment.
DATES:
Submit comments by (60 days following publication in the Federal Register).
Comments received after this date will be considered if it is practical to do so, but assurance of consideration cannot be given except as to comments received on or before this date.
ADDRESSEES:
Submit comments to: Secretary, U.S.
Nuclear Regulatory Commission, Washington, DC 20555.
Attention:
Docketing and Service Branch.
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5 l
For a copy of the petition, write:
Rules Review Section, Rules h
and Directives Review Branch, Division of Freedom c'
Information and Publications Services, Office of Administration, Washington, DC 20555.
FOR FURTHER INFORMATION CONTACT:
Michael T.
Lesar, Rules Review.
Section, Rules and Directives Review Branch, Division of Freedom of Information and Publications Services, Office of Administration, Washington, DC 20555, Telephone: (301) 492-7758 or Toll Free:
800-368-5642.
SUPPLEMENTARY INFORMATION:
Background-The NRC has received a petition for rulemaking submitted by the International Union of Operating Engineers, Local-No.
2.
The petition was assigned Docket No. PRM-34-4 on October 15, 1992.
The petitioner has requested that the NRC amend 10 CFR Part 34,
" Licenses for Radiography and Radiation Safety Requirements for Radiographic Operations," to require a minimum of two radiographic personnel when performing industrial radicgraphy with licensed material at temporary job sites.
The Petitioner The petitioner represents the entire membership of the International Union of Operating Engineers, Local No.
2.
Each of 1
l l
2 l
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e,
-I the-443 nembers of the union submitted an' identical petition in support of the requested action.
.sv Need for the Suggested Amendments The petitioner identified a number of current problems associated with the use of licensed material by one radiographer-at temporary job sites.
The petitioner believes that these problems could be alleviated by requiring that two radiographic personnel perform radiographic operations at temporary job sites.
The problems identified by the petitioner include, but are not limited to, the fellowing situations.
(1)
It is extremely difficult to keep the area under constant surveillance from all directions when working in a congested area.
The petitioner believes that a two person team would be better able to maintain proper surveillance.
(2)
It is difficultato keep above ground areas under surveillance when working in deep trenches.
Again, the L
petitioner believes that a two person team would be better able to maintain proper surveillance.
(?)
It is often difficult to get equipment into deep trenches or high above ground when working alone.
The petitioner
~
believes that a two person team could more. easily and safely handle the required equipment.
(4)
Whenever possible, radiographers work-after otner trade and craft-employees have left the area.
In case of an accident involving licensed material,- the radjographer cannot leave the l
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I area in order to notify the proper authorities if a radiation danger exists.
With a two person team one individual could keep the area under proper surveillance while the other notified the
~
proper authorities.
(5) In the event of an accident involving physical injury at a remote job site, the radiographer could be placed in a life threatening situation.
A two person team could see that the licensed material is secured properly and administer or seek first aid.
For health and safety reasons a two person team is necessary te maintain adequate surveillance and to respond in the event of an accident or injury.
The Solution The petitioner (IUOE and its entire membership of Local No.
- 2) requests that the NRC amend its regulations regarding licenses for radiography and radiation safety requirements for radiographic operations, as necessary, to require a minimum of two radiographic personnel when performing industrial radiograpny with licensed materials at temporary Job sites.
The petitioner states that the general solution to the current problems associated with one radiographer at temporary job sites consists of an amendment to the regulations regarding licenses for radiography and radiation safety requirements for radiographic operations to require that a two person team perform radiographic 4
1 i
I operations at temporary job sites.
The personnel comprising the two person team could include, but not be limited to --
(1)
Two radiographers; (2)
One radiographer and one radiographer assistant; (3)
One radiographer and one trainee.
The trainee must have successfully completed 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of approved radiation safety and passed an examination over the-topics of instruction.
Request for Comments Interested persons are invited to submit written data, viewa and arguments concerning the foregoing discussion.
Dated at Rockville, Maryland,-thisjd day of/'[vt4* b V 1992.
For the Nuclear Regulatory Commission.
(
[A Jahr/ C. Hoyle /
AcpngSecretaryoftheCommission, i
i 5
4 CONGRZ8SIONAL CORAE8PONDENCE SYSTEX DOCUMINT PREPARATICM CHECKLIST This checklist is be submitted with each document (or group of Q3/As) sent for.
ing into the CCS.gf g g
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BRIEF DEscaIPTIoM OF DOCUXEMT(5) 2.
TY7z or-DOccxxmTL-Correapendasse Eetringen(Qs/ Ash 3.
DoccxENT cowTscL 8ensitive (NRC only) -
Non-Seasitive 4.
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Congressional Committee Subcommittee s
5.
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(b)
(C) 5.
SOURCE OF DOCUMENTS 5820 (document name
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(c)
Atlachments
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?d)
Ratay (e) other 7.
8Y8 TEX LO4 D&TES (a) 4M Data oCA seat docuneat to cca (b)
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