ML20128J081
| ML20128J081 | |
| Person / Time | |
|---|---|
| Issue date: | 10/04/1996 |
| From: | Paperiello C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Morrison D NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| References | |
| SSD, NUDOCS 9610100177 | |
| Download: ML20128J081 (1) | |
Text
october 4, 1996 MEMORANDUM TO: David L. Morrison, Director Office of Nuclear Regulatory Research FROM-Carl J. Paperiello, Director Office of Nuclear Material Safety and Safeguards
SUBJECT:
RULEMAKING PLAN - MINOR REVISION OF 10 CFR 32.14 TRITIUM LIGHT SOURCES - RESPONSE TO PRM-32-4 This is in response to your memorandum dated September 5,1996, regarding the rulemaking plan to revise 10 CFR 32.14. NMSS concurs with rulemaking plan, with the following comments:
- 1. A correction should be made to include in the package the table of calculated dose commitments as referred to in the mb-microtec ;etter dated July 29,1993.
- 2. Both the current version of $32.14, and the rulemaking plan, contain the statement "the method of containment or binding is such that the radioactive material will not be released or removed from
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the product under the most severe conditions which are likely to be encountered in normal use and handling." Staff feels that this requirement is excessively restrictive and not practicable. For example, one of the prototype tests often used for such products is the drop test. If this test is used as a required element of the prototype testing in the Regulatory Guide, licensees cannot be held to a "will not be released or removed from the product" restriction because these devices will sometimes break under these test conditions. In view of this and the fact that current guidance allows a threshold limit, we suggest that a more appropriate statement in the rulemaking might be
" the method of containment or binding is such that it is unlikelv that the radioactive material will be released or removed.. "
- 3. Summary item #6 in your memorandum states that this is a level 1 or 2 item of compatibility. It appears that this is not an item of compatibility, but is instead based on the fact that the Agreement States do not have the authority to regulate exempt products containing byproduct material. We suggest that the wording be revised to more accurately reflect this.
i In addition, please be aware that a number of user need memos have been submitted which concern related issues in consumer product areas. We suggest that the current rulemaking affords an opportunity to address these issues, and recommend that they be moved up in priority and be pursued in conjunction with the current rulemaking.
If you have any questions, please contact Michele Burgess of my staff at (301) 415-5868.
DISTRIBUTION: / enclosures NE02-SSD-7 NMSS SSSS r/f NMSS-9600329 FCombs, IMNS SBaggett, IMAB CPoland, NMSS CEstep, IMNS 3
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